Mandatory B2B e-invoicing & B2C e-reporting potential launch March 2026 to early 2027
France’s Direction Générale des Finances Publiques has floated a revised 2026-27 launch date for its mandatory B2B e-invoicing and B2C e-reporting regime. This follows it abandoning a July 2024 launch plan over this summer.
The potential new timetable, revealed at the French National Electronic Forum on 15 September, is:
- 2024 – in Spring the completion of the licensing of e-invoicing agents partner dematerialization platform (PDP)‘ During the remainder of the year, the completion of Public Invoicing Portal (Portail Public de Facturation or PPF).
- 2025 – Large pilot as a testing phase.
- 2026 March, Phase 1: large companies (more than: €1.5bn turnover or €2bn revenue; and 5,000 employees);
- 2026 October, Phase 2: companies below Phase 1 thresholds
- 2027, Phase 3 – potential later mandate start for small companies below: €2m turnover or balance sheet; and 10 employees.
This timetable will be confirmed in the 2024 budget Bill which should be presented in October 2023.
France will now have to apply to the European Commission for an extension of the VAT Directive derogation it was granted to impose e-invoicing. The permission received in 2022 only lasts until 31 December 2026.
The French postponement from July 2024 follows Germany’s delay to 2026-27 and possible delays to EU VAT in the Digital Age mandatory 2028 e-invoicing proposals.
27 July – France abandons July 2024 e-invoicing launch plan
France has responded to business, software provider and lobby group concerns around the short preparation time for the proposed July 2024 mandatory B2B e-invoicing and B2C e-reporting. The Direction Générale des Finances Publiques has announced today that both are delayed for at least 1 year.
The registration process for certified e-invoicing agents – partner dematerialisation platform (see below) – will continue.
The French proposals had been for a three-wave phased implementation (by company size) between July 2024 and January 2026 for:
- Structured e-invoices on domestic B2B transactions; and
- Digital reporting (e-reporting) of B2C and international B2B transactions
Read about our VAT e-invoicing product, which not only creates and submits e-invoices to global tax authorities, but is unique in providing full audit against local tax legislation. And since it is built on the same application as our VAT Filer, all of your sales or purchase e-invoices are fully reconciled to your VAT returns.
31 July 2023 – version 2.3 of e-invoicing specifications
The DGFIP has issued on 31 July 2023 the latest guidance on use cases for its mandatory e-invoicing regime – v2.3. In total, this includes 36 use cases of transactions, and how to treat them under the new regime.
May 2023 – PDP registrations now open
The certification process for approved French e-invoicing agents ‘partner dematerialization platform (PDP)‘ was opened on 2 May 2023. Businesses subject to the mandatory e-invoicing will be able to use PDP’s or submit directly to the French e-invoicing portal (PPF)
January 2024 pilot details
France has released a timetable for 3rd January to 30 June 2024 pilot prior to the 1st July 2024 launch of mandatory B2B e-invoicing for the first wave of large taxpayers. The pilot phase will be as follows:
Selection of pilot participants in 2023:
- 15 April 2023, publication of application forms on impots.gouv.fr site
- April – May, applications open to interested parties
- Mid-June, successful applicants notified. Partner Dematerialization Platform (‘PDP’) applicants will have to demonstrate they are able to efficiently collect registrations within an acceptable timeframe
- Sept, additional SME (‘PME’) and Very small (‘TPE’) enterprises added
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 March 2026 launch of B2B e-invoicing – following Mexican decentralised Continuous Transactions Controls model
The French tax authorities (Direction Générale des Finances Publiques) have clarified the revised proposed 2026 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.
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 March 2026 (previously July 2024).
There are no plans to change the French VAT return or SAF-T FEC regimes. Register for our FREE global VAT and GST news updates.
Small enterprises options to use e-invoicing prior to 2026
Small enterprises will be mandated to join the B2B electronic invoicing program from 2026 or 2027. However, they will be encouraged to join the regime on a voluntary basis from the revised March 2026 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 but it is not clear if this will be from the revised 1 March 2026.
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. Central platform exchange | Italy, Turkey | Platform responsible for invoice forwarding to customer |
| Customer or receiver may review and reject invoice | ||
| 2. 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 | ||
| 3. 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 | ||
| 4. Real time digital reporting | Spain, Hungary, South Korea | Invoice listing submitted immediately after invoice issued |
| No acceptance or regulation of invoice by tax authorities |
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.
