E-Invoicing in France: Complete guide

Latest Updates on French E-Invoicing

Based on the official  annoucement dated 15 October 2024, The Public Procurement Framework (PPF) will now focus on maintaining a recipient directory and a tax data hub, rather than serving as a free platform for issuing and receiving e-invoices. This shift emphasizes the role of Certified Platforms (PDPs), which will be mandatory for sending, receiving, and reporting invoices electronically. These updates reflect a streamlined approach to digital invoicing, with the government supporting businesses through this transition.

For more details, visit the official announcement.   

Mandatory B2B E-invoicing in France

Electronic VAT invoices for B2B transactions and e-reporting of all supplies not falling in the e-invoicing obligation will be progressively introduced in France, following a three-years calendar plan.

Electronic invoices are already mandatory since January 2020 in France concerning transactions with the public administration (B2G).

What is E-invoicing in France?

E-invoicing entails issuing, sending, and receiving your invoices in a structured electronic format, which allows for the automatic and electronic processing of the invoice data. The French government has approved the implementation of an e-invoicing mandate for B2B domestic transactions in France, requiring all businesses to issue their invoices in a specific structured format and according to specific transmission requirements.

The French e-invoices may be issued in one of the three syntax formats allowed: 

• Cross Industry invoice (CII)
• Universal Business Language (UBL)
• Factur-X, which is hybrid format composed of a structured XML and a PDF.

A Continuos Tax Control (CTC) measure is introduced, as the e-invoice data must be transmitted to the tax authorities in real time, either through the remittance of the e-invoice, or by reporting the invoice data in the e-reporting scenarios. 

When Will E-invoices in France Become Mandatory?

Initially planned for July 2024, the requirement has now been postponed. The obligation will be  rolled out in phases based on the size of the company and the business activity carried out. Find below the new implementation schedule: 

• 1 September 2026: Required by large and intermediate size taxpayers. Also, all companies must be able to receive electronic invoices by that date. 
• 1 September 2027: Small and medium size businesses.

It is important to note that, despite the progressive implementation calendar, all companies must be able to receive electronic invoices by 1 September 2026. More information.

Benefits of E-invoicing for Companies

Various benefits are expected to be seen by implementing e-invoicing, including but not limited to the following:

• Reduced administrative burden on invoice management.
• Lower invoicing costs.
• More precise monitoring of invoices.
• Reduced risk of VAT fraud.
• Easy preparation of VAT returns due to pre-filling.

In average, businesses pay a cost of 12€ for each paper invoice processed. E-invoices cost 3€ per invoice, hence improving productivity and reducing administrative burdens.

Public Billing Platform or PPF

The Chorus Pro platform is the electronic platform currently available for uploading  e-invoices issued in transactions made with the French public administration (B2G). You can access the portal here. This platform will now serve also for the B2B e-invoicing and e-reporting purposes, and it is renamed for this mission as Public Procurement Framework (PPF). 

Despite the initial plans, the Public Procurement Framework (PPF) will no longer act as a free alternative for issuing and receiving e-invoices. The PPF will focus on maintaining a recipient directory and a tax data hub, rather than serving as a free platform for invoice exchanges as initially planned. This role remains now entirely on the Certified Platforms (PDPs), which will be mandatory for sending, receiving, and reporting invoices electronically. Also, upon issuance of the invoice, the PDP performs a pre-validation check on the e-invoice before reporting it to the PPF, or public platform.  

How to Submit French E-invoices?

Electronic invoices will be sent to clients via a dematerialization platform, also known as PDP or private electronic platform. The public portal will no longer be available for the exchange of e-invoices. In their role as an intermediary between the supplier and recipient, PDPs will have the ability to transform the format of the e-invoice issued by the supplier into a format suitable for the client, allowing the interoperability between different service providers.

Upon issuance of the e-invoice, the certified PDPs will transmit the e-invoice to the customer's platform, and report it to the public platform. 

PDP operators must also provide their users with information relating to the e-invoice status:

• "Deposit" in the event of acceptance of the invoice by the issuer's platform;
• "Rejection" by the issuer's or recipient's platform if the invoice is not compliant;
• "Refusal" by the recipient of the invoice;
• "Collected", this status also includes payment data.

Which Companies Will be Impacted by French E-invoicing?

Companies established in France and involved in domestic sales and purchases transactions.

E-invoicing will be mandatory for all domestic transactions (sales and purchases and supplies of services) between companies established in France and VAT taxpayers. Non-taxable transactions for VAT purposes are not under mandatory e-invoicing or e-reporting implementation. You can find here the official information published by the French tax authorities.

What is E-reporting in France?

E-reporting is the obligation to declare those sales not falling within the scope of French e-invoicing. This is for exports, imports, sales to private individuals (B2C), intra-Community supplies and acquisitions.

The implementation calendar is the same as for the B2B e-invoicing obligation. You can refer to the previous section.

In general, transactions are listed in Article 290 of French VAT Law. This includes sales and supplies of services transactions made with French private customers, e.g., domestic retail sales or customers established abroad – both private customers or companies, e.g., intra-Community supplies and exports.

Also, foreign businesses will have to comply with the e-reporting obligation when they perform the taxable transactions from the above list in France.

Are Foreign Businesses Impacted by E-reporting in France?

Foreign businesses are subject to e-reporting obligations when they perform taxable transactions in France, for which they must charge French VAT. You will find below a list of common scenarios on transactions made by foreign companies registered for VAT in France:

• Domestic sales B2B reverse-charge: these correspond to domestic sales B2B made to a company established in France. In this case, the client based in France is subject to the e-reporting obligation and not the foreign company.
• Domestic sales made to other foreign companies: in this case, the supplier non-established in France is subject to the e-reporting obligation.
• Domestic sales B2C: in this case, the supplier non-established in France is subject to the e-reporting obligation.

More Information about French E-invoicing & E-reporting

From a legal perspective, the Ordinance No. 2021-1190 sets the grounds for general implementation of a B2B e-invoicing mandate in France (Ordonnance n° 2021-1190 du 15 septembre 2021 relative à la généralisation de la facturation électronique dans les transactions entre assujettis à la taxe sur la valeur ajoutée et à la transmission des données de transaction). The ordinance also clarifies the definition of an electronic invoice, clarifying it refers to an invoice issued, transmitted, and received in a dematerialized form and which necessarily includes a minimum base of data in a structured format, differentiating it from "paper" invoices or ordinary PDF.

The French tax authorities published a FAQ article about this new obligation, updated when necessary.

Finally, the technical specifications for B2B e-invoicing and e-reporting are published on the authority’s website. A new version of the technical specifications was released in June 2024. These are the result of consultations with several stakeholders, like companies and technical experts. These exchanges highlithed the need to clarify certain aspects of the e-invoicing solution, to include some additional elements and adjustments, as well as to implement help elements for the future users. The June 2024 technical specifications include some changes:

• Directory flows simplified. The volume of data exchanged was simplified: one consultation flow and one modification flow.
• Historic function.
• Invoice status management.
• Rounding possibility. Particularly, when the VAT is calculated in the invoice line.