Technical preparations in 2024 for B2B e-invoicing & B2C e-reporting launch in Sept 2026
The Direction Générale des Finances Publiques DGFiP has today unveiled 2024 technical preparations for the the Sept 2026 launch of B2B e-invoicing and B2C reporting. There will be a qualification phase in 2025, including full pilot.
The key 2024 dates include:
- Q1: Review by advisory bodies;
- Q2: Revised decree; external technical specifications
- Q2-3: (July) restart of registration of certified agents, ‘partner dematerialization platform (PDP)‘. These PDP’s will now require Peppol authority recognition to tackle the problem of interoperability which contributed to the delay in the mandate from July 2024.
- Q4: Publication of final technical specifications and swagger; mini-pilot for number of PDP’s and taxpayers;
- 2025: Interoperability testing; Full pilot
Jan 2024 Updated FAQs
On 5 January, the France issued an updated set of Frequently Asked Questions (FAQ’s) for its planned mandatory e-invoicing and e-reporting regime. These updated FAQ’s included:
- Confirmation of Sept 2026-27 launch dates;
- How to determine which phase of the launch a taxpayer was eligible for;
- Confirmation that all taxpayers must be able to receive e-invoicing from Sept 2026;
- Treatment of certain discounts and coupons; and
- Requirements for non-resident businesses within scope, in particular, foreign e-commerce merchants making distance sales to French consumers;
- Updates on Plateformes de dématérialisation partenaires;
- B2G e-invoicing requirements updates;
On 29 December 2023, the French 2024 Budget legislated for the launch of B2B e-invoicing and B2C e-reporting for large and medium-sized businesses from 1 September 2026. This will be followed by small businesses from 1 September 2027. In both cases, the government has the right to extend the deadlines by up to three months to December without recourse to Parliament.
The launch plan is now:
- 2025: large-scale pilot;
- Sept 2026 All businesses must be able to accept e-invoices. B2B e-invoicing and e-reporting for large and medium sized companies (more than 250 employees; and exceeding either of following: €50 million turnover; or €43 million balance sheet) There is an option to extend by further 3 months to Dec 2026; and
- Sept 2027 e-invoicing & e-reporting for small businesses below the above thresholds. There is an option to extend by further 3 months to Dec 2027.
On 26 December, version 2.3 of the French e-invoicing specifications in English were published. This version, available in French since July, separated out some use cases into separate documentation.
A word from the team at VATCalc – whatever the timing, remember our VAT e-invoicing service takes away the local obstacles to live reporting. All your transactions are fully audited against national tax legislation before submission to e-invoicing platforms and inclusion in your VAT returns. All in one application!
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.
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.
The launch of the PPF platform on time has also been cited as a reason for the delay. The test launch was going to miss the 2023 deadline, so undermining the pre-launch test in the first half of 2024. This could also likely mean the ongoing certification of PDP e-invoicing agents will drag, too.
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.
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 September 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
European Commission grants e-invoicing VAT Directive derogation for France
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 September 2026 (previously July 2024).
There are no plans to change the French VAT return or SAF-T FEC regimes.
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.
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.
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.