Requirements For Mandatory E-Invoicing In France

The French government announced in September 2019 that the requirements for mandatory e-invoicing would enforce the use of only electronic invoices for all taxable transactions in France.

Initially scheduled to take effect between 1 January 2024 and 1 January 2026, however, following a revision earlier this year (2023), French authorities have proposed new milestone dates for the mandatory B2B e-invoicing and B2B and B2C e-reporting programs.

The mandatory e-invoicing system is now planned to take effect from September 2026. As a result, all business owners must understand these regulations and how to prepare for compliance.

Companies and government institutions across the world today are fast adopting automation technology in all phases of their corporate operations. The e-invoicing mandate in France is one such advancement with many benefits, including the potential to tackle fraud.

Notably, introducing the e-invoicing system is part of the government’s effort to tackle tax fraud by seamlessly transmitting all transaction data to its tax authority.

In this article, we will focus on critical points and questions you may have about the requirements for mandatory e-invoices in France.

Is e-invoicing mandatory for all in France?

The mandatory electronic invoicing applies to all companies subject to VAT in France. Although the system kicks off fully in September 2026, it has been effective on all Business-to-government transactions (B2G) since January 2020.

At that time, the government set up a Chorus Pro automation solution to help public administrations easily comply with the mandate.

Technically, we can classify the recipients of this electronic solution according to their business model and company size.

In the first category, all transactions between business-to-business (B2B) and foreign operators must comply with electronic e-invoicing requirements in France.

Similarly, small and medium enterprises (SMEs), large companies, and medium-sized companies that process the types of transactions above are also required to start issuing electronic invoices in France.

Who is exempted from the mandatory e-invoice in France?

According to the tax authorities, mandatory e-invoicing in France will not apply to transactions during the importation of goods.

Enterprises are exempted from issuing e-invoices on transactions that cover medical activities, specific banking and financial operations, and training. This exemption is cited under articles 261 to 261 E of the general tax law.

Another special exemption covers foreign companies operating and registered in France.

Instead of issuing e-invoices, these companies will use the e-reporting system to report their transactions.

Lastly, all B2C transactions do not require e-invoicing. However, B2C companies are required to record and transmit these transactions through the e-reporting system.

Upcoming phases of implementation of electronic invoice in France

As mentioned, following an amendment to the French e-invoice regulation earlier this year, the implementation date of the mandatory digital invoice, initially planned for July 2024, is now as follows:

2024: Complete licensing of e-invoicing PDP agency and Public Invoicing portal
2025: Large pilot testing phase
Sept 2026: For large and mid-sized companies
Sept 2027: For small and medium-sized entities and others

Although the timeframe for implementing this reform is not uniform, businesses are to start preparing accordingly.

Manually getting set for this reform is precious time that could be spent on other productive actions.

To comply with this reform, connect with an e-invoicing service provider to ensure a fast and accurate business upgrade.

What is the scope of applying for digital invoices in France?

Although there are still ongoing developments concerning implementing this reform, we understand that the French government has adopted the “Y” model.

This model means that implementing e-invoicing reform in France is a shared responsibility between certified private e-invoicing corporations and public portals like Chorus Pro.

As a result, the “Y” model ensures maximum flexibility for the companies and tax authorities as they transition to e-invoicing.

In addition, the invoice can be processed in more than one format, unlike in a centralized model.

Note that companies that already have a digital invoice system in place would continue using them.

On the other hand, others will have to set up with a private electronic invoicing solution or Chorus Pro.

These existing e-invoicing providers will be considered suitable on the condition that:

Their invoicing is produced in a format that is easily read, extracted, and reported in an acceptable form.
The invoicing format can be easily transferred to authorized private corporations for a compliance check.

France e-invoicing requirements

In compliance with the mandatory electronic invoicing requirements, French companies are required to:

Extract and transfer the required invoice data to the tax authorities through Chorus Pro or their private e-invoicing enterprise for processing.
Compile and send tax reports on all B2C transactions (i.e., transactions with a non-taxable person), including payment data for services to the tax authority.
Be able to receive invoices in the specified structured format.

What is the acceptable format for the France e-invoice mandate?

There will be several formats acceptable for companies to process their e-invoice in France, and all associate platforms must offer a minimum number of standard formats to ensure interoperability.

Nevertheless, Frances’ official e-invoicing management solution, Chorus Pro, accepts invoices in UBL format (an advanced version of XML for invoices) or PDF.

More formats are expected to be allowed when all French companies have complied with this reform, including CII and Factur-X.

For instance, companies may consider using hybrid invoice management solutions like Factur-X if the invoices include visual elements.

Some vital information that would appear on the invoice include:

SIRET Number: Your company’s unique ID is recorded in France’s Business Directory Identification System or SIRET.
Transaction type: Your invoice should specify if the transaction is for goods, services, or a mixed service.
Detailed information: Complete detail of the address of where the service is to be delivered
Debits: Option for debits.

How to send e-invoices in France

French companies can successfully submit e-invoices on all taxable transactions to the Chorus Pro portal in three ways.

Through the PEPPOL eDelivery Network
Through electronic data interchange (EDI)
Through an application programming interface (API)

Most European governments use PEPPOL (Pan-European Public Procurement Online) to exchange electronic business documents.

Through PEPPOL, European organizations can securely transfer and send e-documents and messages or connect networks seamlessly.

France’s taxpayers must select private or public invoicing enterprises that support PEPPOL integration. For enterprises with a modest number of invoices, the portal allows them to create and upload invoices in PDF format.

Penalties for non-compliant with electronic invoices in France

To ensure compliance with the e-invoicing requirement in France, companies must make use of the E-Archiving System (EAS) or Electronic Vault, the only technical solution capable of safeguarding the integrity and authenticity of the archived file.

It is vital to note that failure to conform to these archiving requirements can lead to significant penalties from the French tax authorities.

Based on that, the French government chose a fixed fine per offence.

The mandate covers e-invoicing, e-reporting, and payment statuses, so the French government has placed different penalties for each category.

For every e-invoice that violates the requirements, the issuer will be fined €15, limited to €15,000 total per annum for taxpayers.

Surprisingly, fines for e-reporting and payment status infractions are far higher. A €250 fee capped at EUR 15,000 will be imposed for each missed data transmission obligation. In addition, there is no maximum penalty for a company.

In both circumstances, there is a waiver for the first offence, but only if the business corrects the infraction within 30 days of the government’s initial request. This waiver is currently in place until 2027.

Furthermore, there are legal penalties (€15 per invoice limited and €750 per transmission up to €45,000 sum per annum) for certified agents (PDP, Plateformes de dématérialisation partenaires) in the event of non-compliance by issuers using their services.

To avoid these penalties, businesses must ensure that their e-invoicing and archiving processes obey French regulations.

Need help with your French VAT compliance?

Storecove can prevent you from getting penalized by providing you with the right sending and receiving infrastructures for electronic invoicing. Schedule a demo with one of our e-invoicing specialists.

E-reporting requirements in France

In France, e-reporting is a system for transmitting specific information related to commercial transactions that do not fall within the scope of e-invoicing to tax authorities.

This is particularly relevant for transactions involving selling products and services to private individuals (B2C transactions) and dealings with operators established abroad, including exports, intra-community shipments, and more.

The e-reporting system will follow the same obligation schedule as the e-invoice schedule.

Inspired by countries like Spain, the French tax authority (DGFiP) has proposed reporting on B2C transactions, with different scenarios depending on a company’s IT infrastructure:

If the company uses point-of-sale (POS software)

It must declare a summary of all the tickets issued during the day, referred to as "ticket Z.”

If the company issues e-invoices

It can transmit the needed invoicing data to the tax administration through the same channel used in the B2B electronic invoicing circuit without sending it to the end client.

If the company does not have an IT system

It must send a summary of its operations conducted over a week or monthly.

For B2B transactions data at the international level, information on the following operations must be declared to the tax authority:

Intra-community deliveries of merchandise and services.
Exports made to businesses outside of the EU.
Operations destined for communities in overseas territories.
Intra-community acquisitions.

Are foreign companies affected by e-reporting regulations in France?

Foreign companies are subject to e-reporting regulations when they execute taxable transactions in France, for which they must charge French VAT.

Below is a summary of common circumstances involving transactions involving foreign entities registered for VAT in France:

Domestic sales B2B reverse-charge

These are domestic B2B sales made to a company based in France. In this circumstance, the client based in France, not the foreign company, is subject to the e-reporting obligation.

Domestic sales made to other foreign companies

In this instance, the supplier, which is non-established in France, is subject to the e-reporting obligation.

Domestic sales B2C

In this case, the supplier who is not based in France is subject to the e-reporting requirement.

What should businesses do to comply with the electronic invoice mandate in France?

If you’re doing business in France, you must proactively ensure compliance with the electronic invoice (e-invoicing) mandate. Here are the key actions that you need to consider:

Change management with suppliers

Recognize that your suppliers will be impacted by the mandate at different times, depending on their size and readiness. Communicate and collaborate with your suppliers to ensure a smooth transition.

Prepare contingency plans to address potential teething problems to minimize disruptions in your supply chain.

Learn how to receive and send invoices

Depending on your approach (connecting directly or using a Plateforme de Dématérialisation Partenaire or PDP), ensure that your business can provide and receive electronic invoices in acceptable formats, which may include UBL 2.1, UN/CEFACT CII, and Factur-X. Update your systems and processes as necessary.

Change management

Compliance with the new ordinance will require a shift in how your teams work and collaborate across departments. Break down silos and improve information capture and sharing, especially if your company operates globally.

Familiarize yourself with the e-reporting requirements

While e-invoicing is not mandatory for certain transactions (B2C and cross-border invoices), French companies are obligated to send e-reporting files for these transactions, adhering to specified data formats.

Ensure you have the capability to generate accurate reports for these transactions, which may differ from standard e-invoicing.

Ensure adequate performance and stability

If your business uses multiple ERP systems, ensure that they can process the mandated invoice formats in a timely manner. Verify that the connection between the Plateforme de Dématérialisation Partenaire (PDP) or Portail Public de Facturation (PPF) and your ERP systems remains stable.

Learn about the lifecycle requirements

You must be capable of transmitting chronological invoice status updates to the government platform, whether directly to PPF or through a PDP. These updates should include information about invoices submitted, refused, rejected, and received.

What are the benefits of e-invoicing in France?

As stated earlier, the French government introduced the digital invoice system to curb tax evasion fraud. But the system is even more beneficial to the government and French companies.

How?

Firstly, introducing electronic invoicing in France would reduce the cost of producing paper invoices. By doing that, the reform indirectly promotes a greener and sustainable work environment.
Secondly, using an electronic invoice solution eliminates the chances of human errors peculiar to manual data entry and the fear of losing invoice data. As a result, companies can quickly resolve invoice disputes with customers and the tax authority by reviewing data generated from stored electronic invoices. For the French government, the electronic invoice mandate sets it on the path to promoting and increasing global tax compliance.
Lastly, France’s tax authority can broaden its operation scope since the invoice reform is integrated into the e-reporting system. Therefore, they can compile information on B2C transactions that are not subject to tax.

E-invoicing solution in France

Looking for a global compliance solution to assist you as a company or government organization in sending your invoice to the French government?

Storecove has been helping B2B, B2G, and B2C enterprises in many countries with our comprehensive business compliance and invoicing solutions.

You could benefit from the following features:

Multiple invoice formats

The invoicing tool supports over 24 invoice formats. So, instead of processing your invoice in different formats, send your invoice to us. We will automatically convert it and send it in an acceptable format to the agency you want.

PEPPOL-certified

With Storecove’s invoicing tool, sending your invoice is as simple as sending a regular email. In addition, since we are an accredited PEPPOL access point, you can rest assured that we will always deliver your invoice.

Receive invoice responses

The integration with PEPPOL helps get feedback directly to you in your email box regarding the status of your invoice. The moment it is authorized and paid, a notification will be sent.

Set up your PEPPOL ID

Getting a PEPPOL ID is easy because Storecove will create one for you. The tool creates a verified PEPPOL ID from anywhere globally, including your VAT or Chamber of Commerce Number.

Takeaway: Understand France's e-invoicing requirements to stay compliant and save time

France’s e-invoicing requirements were initially scheduled to take effect between 1 January 2024 and 1 January 2026. However, following a revision earlier this year (2023), the mandatory e-invoicing system is now planned to take effect from September 2026.

This mandatory e-invoicing and e-reporting in France will stop tax fraud evasion and increase the country’s ranking among those promoting a green and sustainable environment.

For companies, electronic invoicing ensures efficient management of transaction information, dispute management, and easy retrieval. However, now is the time to prepare to implement electronic invoicing in order to be compliant and avoid penalties when the new regulation takes effect.

Ready for a more straightforward way to send your e-invoice? Join the thousands of businesses globally that have already embraced the future of invoicing. Contact us today to learn more.

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