Electronic invoicing and e-Reporting in France

New Taxation Model and Requirements

The Direction Générale des Finances Publiques (DGFiP) has announced a new taxation framework based on extensive evaluations involving all stakeholders. This new scheme introduces:

• Mandatory electronic invoicing between private companies.
• Transmission of transaction data to the tax authorities.
• Electronic VAT reporting, ensuring transparency and compliance with fiscal obligations.

This modernized system is designed to enhance efficiency, reduce tax fraud, and provide the French administration with real-time insights into economic activity.

Companies affected

The e-Invoicing and e-Reporting mandate applies to all companies subject to Value Added Tax (VAT) in France. This includes businesses of all sizes and industries, ensuring compliance with national and European fiscal regulations.

Invoice Format

The Direction Générale des Finances Publiques (DGFiP) has mandated that all electronic invoices—whether Business-to-Government (B2G) or Business-to-Business (B2B)—must be issued in one of the following formats:

• UBL (Universal Business Language)
• CII (Cross-Industry Invoice)
• Factur-X (a hybrid PDF format combining visual representation and structured data)

This flexibility ensures interoperability while adhering to the technical requirements of France’s e-invoicing system.

Implementation timeline

The French government has outlined a phased timeline for the adoption of the new e-Invoicing and e-Reporting system, tailored to company size:

September 2026:

• Mandatory reception of e-invoices for all companies.
• Large and medium-sized enterprises required to issue e-invoices in France.

September 2027:

• Small and micro-enterprises required to issue e-invoices in France.

This progressive approach ensures a smooth transition while allowing businesses of different sizes to adapt to the new requirements effectively.

e-Invoicing Pilot Project

The rollout of electronic invoicing in France will begin with a pilot phase scheduled for 2026. This phase aims to test the system under real operating conditions, identify and resolve potential platform anomalies, and refine the process before full implementation.

In addition to technical adjustments, the pilot phase will foster collaboration between key stakeholders, including the Public Invoicing Portal (PPF), certified dematerialization platforms, user companies, and software providers. This collaborative approach will enable the French administration to establish a robust framework for continuous improvement, ensuring the system's long-term success.

e-Invoicing Workflow in France

In the revised Y scheme, companies generate electronic invoices and associated tax documents for their transactions and send them to Partner Dematerialization Platforms (PA/PDPs) for validation. These platforms perform the necessary checks mandated by the Direction Générale des Finances Publiques (DGFiP). Once verified, the invoices are sent to the recipients, while the PAs also report the required tax information directly to the DGFiP.

The Public Invoicing Platform (PPF) has undergone significant changes. Its scope has been reduced to serve two primary purposes:

• Directory Maintenance: Identifying companies using their SIREN/SIRET numbers and ensuring interoperability between companies connected through a PA/PDP.
• Consolidation of Information for Public Administration: Managing data flows (Flow 1) and e-Reporting.

As a result, only Circuit C remains in effect, with circuits A and B1/B2 excluded from the framework, at least during the initial stages of implementation.

Invoice lifecycle management

In France, the electronic invoice exchange flow requires companies to not only issue invoices but also generate notifications throughout the transaction's lifecycle. These notifications provide complete traceability of the process, enabling the quick detection of potential issues.

This system is an evolution of the current B2G electronic invoicing process, where administrative units regularly update the invoice's status.

Mandatory Invoice Lifecycle Statuses

To ensure consistency and transparency, the DGFiP has outlined mandatory statuses for the nominal lifecycle of electronic invoices:

• Déposée (Deposited): Invoice is submitted to the platform.
• Rejetée (Rejected by the platform): Invoice does not meet platform requirements.
• Refusée (Rejected by users): Invoice is declined by the recipient.
• Encaissée (Payment received): Payment is confirmed by the provider.

These lifecycle statuses form the backbone of the traceability system, ensuring seamless processing and compliance with France’s e-invoicing regulations.