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E-invoicing and e-reporting : new regulation

On July 1st, 2024 the transition to e-invoicing will be launched in France leading to no paper invoicing policy.

What are the new rules?

As of July 2024 all organizations will have to be able to receive electronic invoices. By July 2026 all organizations will have to issue their invoices in electronic format. This progressive deployment will also take into account the organization size.

An accounting software compatible with the new standard will be required as well as an access to an online invoicing platform (free or chargeable). The mandatory elements to display on your accounting documents stay the same.

The calendar:

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

Who's concerned?

All invoices regarding transactions between organizations subject to VAT will have to be created in electronic format, meaning the B2B transactions between French organizations collecting and redistributing VAT to government. A declaration system (e-reporting) is also planned for international B2B transactions and B2C ones.

Note: B2G (Business to Government) exchanges are concerned as well but already require e-invoicing via Chorus Pro platform since 2017.

Why such an evolution?

The e-invoicing deployment has several objectives:

  • Simplify the organizations workflow and reinforce their competitiveness by lightening administrative load, diminishing the payments delay and increasing their productivity ;
  • Eventually simplify obligations regarding VAT declaration (with pre-filled declarations) ;
  • Enhance fraud detection ;
  • Get a real time knowledge of the organizations activities.

How are going to be transferred the invoices?

Dispatching and receiving invoices will be done by means of dematerialization platforms (Partner Dematerialization Platform or PDP).

Each organization will have to select a platform to receive its invoices (supplier invoices) and a platform send its invoices (customer invoices). In most cases the organizations will choose a single platform for both purposes. The government will provide the free platform Chorus Pro (the Public invoicing portal or PPF) and private platforms (PDP) will be available.

This will result in a "Y-shaped diagram":

Those diagram present the different sending and receiving options. In all cases the PPF will concentrate the data intended for the tax administration and will transfer it. It is the PDP that extract the invoicing data to give it to the PPF.

The directory

The link between all the actors involved in the e-invoicing process will be assured by a shared directory (managed by the PPF) that will list all concerned French organizations and designate their receiving platform (the dispatching platforms are not to be displayed there, only the receiving ones will be).

The identifier will be the organization number (SIREN) but it will be possible to indicate invoicing entities by their SIRET.

The registration procedure to the directory are not known yet.

The Partner Dematerialization Platform (PDP)

The PDP will be audited to obtain a 3-year valid renewable accreditation. There is no list yet.

Note that you'll be able to switch platform at any time.

The invoices format

Several formats will be accepted for the invoices transmission:

  • UBL format: XML document compliant with the OASIS U.B.L. 2.1 specifications
  • CII format: XML document compliant with the CIII specifications regarding naming rules, cardinality and format (datatype).
  • Factur-X format: the mixed Factur-X invoice is a PDF/A-3 formatted file. The invoice original document is the PDF/A-3 file as a whole and therefore including embedded files such as the structured data file (XML file) and attached additional documents.

E-reporting

The e-reporting is the procedure consisting in sending to the tax administration the data pertaining invoices payment and transaction data (payment without invoice). It targets international B2B transactions, B2C ones and transactions between organizations not subject to VAT.

The invoice is sent to the customer directly by the supplier. At the same time the supplier sends the e-reporting data to its PDP.

This will result in a slightly different "Y-shaped diagram":

Such an invoice must keep respecting the current dematerialization regulation if it is sent to the customer by e-mail or if it has to be archived in digital format.

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