Invoice signature/stamping

* The 'tax value' notion relates to French standards and can only be applied to French organizations. The European Union, via the article 233 subparagraph 1.a of the directive 2006/112/CE, only requires an advanced signature or stamp.

There are numerous solutions that can be used to sign/stamp and/or timestamp invoices and it can be difficult to choose the one that will meet your needs and procedures. Client certificate? Server certificate? RGS? eIDAS? Hosted?

Some definitions

** Please note the we are only referring to sales invoices in this article.

Paper invoice: it is the original invoice with tax value the most often used in the invoicing processes.

Digitized invoice: it is a digital version of the paper invoice. A digitized invoice must be re-materialized (printed) at the end of the invoicing process, usually by the customer. In this case the paper invoice is document with the tax value.

Original invoice: it can be the paper invoice or the digitized invoice under certain conditions. An invoice must be an original if it is intended to be sent by electronic means.

Electronic invoice: it is an original invoice with tax value. It replaces the paper invoice. To be considered as such, the e-invoice must be created, sent and archived in electronic format. The whole process has to be digital.

Make the distinction between an e-invoice and a digitally-sent invoice
Only an original invoice can be sent by digital means (eIDAS advanced or qualified signature or stamp). A signed invoice can then replace a paper one if the recipient allows it. But a digital transmission does not exempt you from needing a paper format of your invoices. The recipient will mostly have to re-materialize it (print it) except if its organization accounting department abide by the digital invoicing standards (one needs to check the certificate and the PDF signature/stamp).

E-invoicing: sending and/or receiving invoices by electronic means. Between 2024 and 2026 the transition to e-invoicing between all French organizations subject to VAT will take place (see the calendar below).

Identifying the needs

It is essential to know what the needs are: what is the signature/stamping for? What will become of the documents you want to sign?

• 1 . You simply need to send your invoices by e-mail
  In that case your invoices don't need to have a tax value. However they need to be original and will have to be re-materialized (printed) by your customers to be integrated in their accounting.
  To be considered as original an invoice must be signed/stamped by a certificate providing a advanced level of signature.
  
  
• 2 . You want to archive supplier invoices / store them digitally
  Then they must be signed/stamped and timestamped by RGS* or eIDAS advanced certificate.
  
  Livre des procédures fiscales Article A102 B-2 (FR)
  
  
• 3 . You want to create e-invoices with a real tax value
  Those invoices will have to be signed/stamped and timestamped by RGS** / eIDAS certificates providing qualified signatures. The won't have to be re-materialized (printed) to be transferred to the tax administration for instance.
  
  Décret pour transposer les dispositions relatives aux règles de facturation par voie électronique de la directive 2010/45/UE du Conseil du 13 juillet 2010 (FR):
  Link to legifrance

 Decree No. 2023-377 of May 16, 2023 also specifies that it is possible to sign (with an ID certificate) but also to stamp (with a stamp) your invoices to provide them with the desired legal value.

Legal obligations

The Order 2021-1190 of September 15, 2021 defines the legal framework requires for the generalisation of electronic invoicing.

It includes a schedule for all organizations subject to VAT. At some point, they will all have to accept and issue their invoices in electronic format.

The deployment will be progressive and is going to take account of the organizations size:

• as of July 1^st 2024: all organizations must accept electronic invoices
• as of July 1^st 2024: big organizations must issue their invoices in electronic format
• as of January 1^st 2025: intermediate size organizations must issue their invoices in electronic format
• as of January 1^st 2026: small organizations must issue their invoices in electronic format

In a nutshell

Here is a guide about invoices signature:

Experience feedback regarding e-invoicing

A few month ago we dematerialised the customer accounting. Discover why and how a SME switched to e-invoicing by reading our case study (FR).

Useful links

• Create an invoice with tax value with Adobe Acrobat DC
• Batch signature/stamping of invoices
• Certificates to sign/stamp invoices
• Online wizard: Select a certificate to sign/stamp invoices
• What are the risks incurred by a non-compliant invoicing?
• E-invoicing and e-reporting : new regulation

• Invoices dematerialization with regard to tax regulations (FR)
• "Digitized" paper invoice: what to do after the disappearance of the "original duplicate"? (FR)
• LegiFrance: Invoices storage (FR)
• The e-invoice (FR)
• Generalization of electronic invoicing for organizations
• October 7, 2022 decree 2022-1299 pertaining to the e-invoicing generalization in transactions between organizations subject to VAT and to the transmission the transaction data