Mandatory B2B E-Invoicing in France: What it means for your business
August 2022
The French Tax Authority (DGFIP) has announced its intention to make e-invoicing and e-reporting compulsory from 1 July 2024*.
Read on to understand what this means and who will be affected by the changes. We also consider the wider global trend of mandatory e-invoicing and the steps businesses should take to prepare for what is ahead.
*Important update: The French government announced on 28th July 2023 that it was decided to postpone the implementation of the system, scheduled for 1st July 2024, to allow sufficient time for this reform to be a success. The date of the postponement will be defined as part of the work to adopt the Finance Act for 2024. Therefore, all dates mentioned on this page are subject to further change.
This page will continuously be updated (originally published August 2022, last updated November 2023)
The what and why of e-invoicing
E-invoicing is different from merely generating an invoice in a digital format. Rather, it refers to specific frameworks for the issuing, delivery, and receipt of invoices in a standardised way.
The data contained in e-invoices follows a structured form, enabling it to be automatically logged on companies’ accounts systems. In most – but not all – jurisdictions where it is mandated, e-invoicing is accompanied by an ‘e-reporting’ requirement, i.e. submission of data to the relevant country’s tax office.
Why is e-invoicing on the rise?
In short it is because governments are losing tax revenue receipts. Across the EU in 2021, the annual tax gap – i.e., the amount of tax revenue lost to fraud or inaccurate reporting – was estimated to be in excess of EUR 130 bn. Tax authorities see it as a way to reduce inaccuracies (not least, e-invoicing theoretically eliminates the possibility of revenue somehow becoming lost on its way to an AP system). E-invoicing is also favoured by treasury ministries because it can help reduce the gap between tax liabilities and tax being actually paid.
When governments go down the mandatory e-invoicing path, they usually apply it to government procurement first, before rolling it out to B2B transactions. The UK is currently at the stage of mandatory e-invoicing for public bodies following the introduction of The Public Procurement (Electronic Invoices, etc) Regulations 2019. This means that virtually all public sector organisations are required to use e-invoicing.
What is changing in France?
France has had mandatory e-invoicing for business-to-government (B2G) transactions in place since 2020. This means that any B2G sales invoice must be an invoice and must be compatible with the country’s designated platform for this, Chorus Pro.
France has now announced that from July 2024, all companies subject to VAT will be required to accept e-invoices. Furthermore, the use of e-invoices along with e-reporting will start becoming mandatory for B2B transactions from July 2024 through to January 2026 (depending on company size).
To whom does this apply?
The rules apply to French VAT registered and established companies. Such companies will need to have the capacity to receive e-invoices. If they issue invoices to business customers, they will also need to move to e-invoicing in respect of those contracts within the relevant timeframe.
Also, the new e-invoicing requirements are accompanied by additional e-reporting rules. Be aware that despite there being no requirement for French companies to issue e-invoices for B2C transactions or in respect of customers based outside of France, certain data in respect of such transactions will need to be submitted to the French tax authority.
Companies with a multinational presence will need to check carefully whether, and to what extent they are caught by the new rules.
Timeframes at a glance
- All companies subject to VAT in France must be able to receive e-invoices starting 1 July 2024.
- Mandatory issuance of e-invoices and e-reporting for enterprises: 1 July 2024.
• Small and medium-sized enterprises (a workforce of less than 5000, and annual sales of less than 1.5 bn or a balance sheet total of less than 2bn)
• SMEs and small enterprises (fewer than 250 employees and annual sales of less than 50m or a balance sheet total of less than 43m)
E-reporting data requirements
E-invoices can be issued through the Portail Public de Facturation (PPF) via the Chorus Pro platform, which is the system currently used for B2G e-invoicing. Alternatively, businesses can opt to send invoices via an approved third-party commercial platform (known as a PDP). Under each system, businesses issue the e-invoice to the platform and the platform does the rest: i.e. delivery of the e-invoice to the buyer and reporting to the French tax authority (DGFIP).
The invoice can be created in one of three base formats compatible with the EU’s e-invoicing standard: UBL, CII, Factur-X.
The following information needs to be captured and transmitted to DGFIP:
Companies with a multinational presence will need to check carefully whether, and to what extent they are caught by the new rules.
• Date of payment collection
• Amount collected, including VAT
• Unique identification number (SIREN) for both supplier and customer
• Intra-community VAT number for supplier and customer
• Intra-community VAT number of supplier’s tax representative
• Supplier’s and customer’s country
• Category of supply
• Invoice issue date
• Unique invoice number
• Number of the rectified invoice if a corrective invoice is issued
• Option for tax payment based on debits
• Total payable exclusive of VAT
• Amount of corresponding VAT by rate
• Applicable VAT rate
• Details of any exemption
• Invoice currency code/designation
• Mention of self-billing (where applicable)
• Reference to any special scheme
• Mention of reverse charge (where applicable)
• Date of delivery or performance
• Date and amount of any deposit paid
Preparing for the changes
Organisations with a corporate presence in France should act now to determine the extent to which the new regime will impact their invoicing and accounting processes. Even if you do not have a French presence but you regularly provide goods or services to companies over there, it is good practice to find out the requirements of your business partners. In other words, if regular customers intend to start using e-invoices, do you have the technical capabilities to accommodate this?
France is currently ahead of the UK in rolling out the mandatory use of e-invoices and e-reporting beyond B2G transactions. However, given the direction of travel in this country (particularly with the government’s Making Tax Digital initiative), it is likely to be only a matter of time until similar requirements are put in place here.
This is the ideal time to consider your readiness for e-invoicing, particularly with regards to AP and AR automation. Also, despite mandatory e-invoicing being a government-driven policy, it can also bring material benefits to businesses. Not least, the fact that data is sent directly to a buyer’s AP system means that invoices can be logged, processed and approved in a fraction of the time it would take with traditional invoicing processes.
More generally, if you can demonstrate to business partners that you are equipped with e-invoicing capabilities at an early stage, it helps demonstrate your commitment to hassle-free billing and invoice management: a potentially valuable selling point in the current climate.
Looking to futureproof your accounting processes to accommodate new ways of invoicing?
Millennium is highly experienced in working with European companies, helping them manage the diverse accounting regulations.
Focussing on digital invoicing, our software has been used to successfully process hundreds of thousands of outgoing and incoming XML invoices for Unit4 Financials (previously known as Coda) since January 2019, when it became obligatory in Italy.