July 2024 French B2B e-invoicing and B2C e-reporting – new technical guidelines
The French General Directorate of Public Finance has issued new technical guidelines for the first-stage launch of its mandatory electronic invoicing and reporting regime which start on 1 July 2024. This latest round includes:
- new example templates, including factoring and intermediaries
- updated supporting annexes
- how to make corrections and updates for e-reporting flows
- mandatory invoice formats for VAT Groups
- details of mappings and file formats
- further details of API spec’s
18 Oct 2022: new FAQ’s for France’s July 2024 rollout of e-invoicing
A new set of e-invoicing Frequently Asked Questions (FAQs) was issued by the French General Directorate of Public Finance. These help businesses and PDP agents (Plateformes de dématérialisation partenaires) to prepare for the launch of B2B electronic invoicing from mid-2024.
These latest FAQs and the below Technical Details include updates on:
- Frequency for transmitting invoice and payment data via 3 submissions per month:
- 10th (1st to 10th of the month)
- 20th (11th to 20th of the month)
- last day (21st to last day of month)
- 3 new mandatory data fields required:
- Delivery of goods or supply of services
- Advance payment of VAT
- Customer SIREN number
- Intra-community supplies
- Confirmation of rollout between 1 July 2024 and 1 January 2026
- Guidance on PDP’s applications
- Platform interoperability
7th Oct 2022: Technical details published for e-invoicing any payment data published; includes requirements for agent ‘dematerialisation platforms’
Decree No. 2022-1299 of 7 October 2022 cover the rules for electronic invoicing in transactions between persons subject to value added tax and the transmission of transaction data. This covers the 3-phase rollout of B2B e-invoicing, starting 1 July 2024. This report covers:
- E-invoices: issuing, transmission and receipt
- Invoice and payment details: transmission
The decree brings forward six months the opening of the registration process to April 2023.
Taxpayers will submit e-invoices directly via State Financial IT Agency (Agence pour l’informatique financière de l’État, AIFE), or use ‘dematerialisation platforms’, which are approved agents.
Registrations start April 2023 for July 2024 launch of B2B e-invoicing – following Mexican decentralised Continuous Transactions Controls model
The French tax authorities (Direction Générale des Finances Publiques) have clarified the July 2024 launch plans for B2B e-invoicing and B2C invoice reporting:
- April 2023: The registrations process will start April 2023 with the launch of the Chorus Pro-based portal, portail public de facturation (‘PPF’) – for companies registering directly and potential certified agents (PDP).
- Jan 2024: A pilot will be launched for a six-month period for businesses and PDP’s on a voluntary basis
- Feb 2024: The first list of confirmed PDP agents will be published at the start of 2024.
- Jul 2024: launch:
- 1 Jul 2024 for large companies (more 5,000 employees; and either of following: €1.5 billion turnover; or €2 billion balance sheet)
- 1 Jan 2025 for medium sized companies
- 1 Jan 2026 for small businesses (less than 250 employees; and not exceeding either of following: €50 million turnover; or €43 million balance sheet)
France has opted for a Decentralised clearance model of Continuous Transaction Controls model (used in Mexico and Chile). This comes with the option to use certified agents (PDP, Plateformes de dématérialisation partenaires) able to clear invoices instead of direct reporting by the business via PPF. This is rather than the Italian-style Centralised clearance (see below for more details). See our global e-invoicing tracker.
Learn more about French VAT in our country guide.
French mandatory e-invoicing fines regime
The French Parliament has adopted the provisions of the Finance Law 2022, which includes the phased introduction of e-invoicing. A late addition to the rules is the penalty regime for missed e-invoices. This will be:
- For taxpayers: €15 per invoice limited to €15,000 total per annum
- For e-invoice certified agents certified agents (PDP, Plateformes de dématérialisation partenaires): €15 per invoice limited to €45,000 total per annum
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European Commission grants e-invoicing VAT Directive derogation for France to launch in July 2024
On 21 January 2022, the European Commission granted France a temporary departure from Articles 218 and 232 of the VAT Directive to be able to impose mandatory electronic invoicing on certain B2B transactions. This clears the way for France to introduce electronic invoicing from July 2024.
Small enterprises options to use e-invoicing prior to 2026
Small enterprises will be mandated to join the B2B electronic invoicing program from 2026. However, they will be encouraged to join the regime on a voluntary basis from the July 2024 launch date. The same is the case for the new e-reporting requirement, although it wouldn’t be necessary to join e-reporting at the same time – they may join just the e-invoicing.
The tax authorities also confirmed that if the small enterprise does voluntarily register before 2026, they do not have to issue all invoices through the e-invoicing system. They may continue to issue paper invoices in some cases.
Lastly, it is confirmed that irrespective of whether the small company is mandates yet, its customers are still obliged to accept e-invoices from 1 July 2024.
Derogation from EU VAT Directive on e-invoicing
France now has it’s derogation from the European Commission and EU Council from the requirements from Articles 218 and 232 of the EU VAT Directive. This prevents member states from imposing e-invoices (and withdrawing paper-based invoices).
This is a temporary derogation between 1 January 2024 and 31 December 2016. After this time, France would need to apply for an extension based on evidence of the cost effectiveness in combating VAT fraud of the measure. The Directive requires sellers of goods or services to provide paper-based invoices unless both the customer and seller agree to use electronic invoices.
Italy SdI rollout of its e-invoice regime required this application. Italy – and France likely to replicate – did not include non-resident businesses with a local VAT registration. However, the Direction Générale des Finances Publiques (DGFIP) has said it is looking at including foreign taxpayers.
You can check the right VAT calculations on e-invoices with our Advisor and Auditor services. Check VAT Calc’s global live VAT invoice transaction and e-invoice reporting tracker to see where else real-time submissions of invoices is being implemented. The ongoing EU VAT in the Digital Age proposals includes a strand around harmonised Digital Reporting Requirements (DDR) across the member states. This originated from the 2020 Tax Action Plan measures for a fairer and more efficient EU tax regime.
Mexican certified e-invoicing agent model
The Mexican e-invoice system of having certified third parties acting as the e-invoicing intermediary has been adopted. So all taxpayers will need an outsourced Plateforme de Dématérialisation Partenaire (PSP) e-invoicing agent. It is their role to create, validate and send the e-invoices to Chorus Pro. This includes the use of digital signatures on invoices.
This differs from the Italian SdI model which requires invoice submission and approval directly to the tax office prior to it forwarding to the customer.
CTC e-invoicing and real-time models
|Invoice reporting model||Examples||Features|
|1. Real time invoice reporting||Spain, Hungary, South Korea||Invoice listing submitted immediately after invoice issued|
|No acceptance or regulation of invoice by tax authorities|
|2. Central platform exchange||Italy, Turkey||Platform responsible for invoice forwarding to customer|
|Customer or receiver may review and reject invoice|
|3. Central clearance||Govt platform accepts invoices, validates, and buyer acknowledges invoice|
|Brazil, Colombia||Pre-clearance variation - clearance before invoice exchange|
|Chile, Costa Rica||Post-clearance - clearance short time after exchange|
|Document types not regulated and therefore inconsistent and may resort to email and similar|
|4. Decentralised clearance||Mexico, Guatemala, Peru, France||Certified e-invoice agent (PAC) submitts inoices|
|Document types not regulated and therefore inconsistent and may resort to email and similar|
Scope of French e-invoicing
The following transactions will be included in the new regime:
- Business-to-businesses transactions
- Business-to-consumer transactions
- Exports and imports transactions
- Payment status of VAT invoices
- Imports of services
- Exports excluded
Information on B2C and intra-community, export and imports will have to be provided by other means to be determined.
How to create French e-invoice
French invoices may by created in the following formats:
- Structured format: UBL invoice / CII D16B / XCBL
- Hybrid format: Minimum UBL invoice / CPP hybrid / FACTUR-X (PDF-A3) / Minimum CII
There will be three options to create a French e-invoice:
- Direct to PPF via:
- Enabled accounting or ERP EDI route
- In-house or external software with controls over digital signature
- Use of outsourced approved providers, PPF, to file to PPF on your behalf
Note: Taxpayers can submit their invoices in PDF format instead of one of the structured format sand PDPs until the start of 2028. The PPF must be able to convert PDF invoices to one of the structured formats (CII, UBL or FACTUR-X) set by the mandate.