Electronic invoicing: What does the reform entail?

This page presents you the main aspects of the reform This information is updated periodically (last update on XX/01/2025 

The legislative framework is defined by the amending finance law No n ° 2022-1157 du 16 août 2022 (art.26) and modified by article 91 of the finance law for 2024.  

Decree no. 2022-1299 and an order of October 7, 2022 set out the technical and practical aspects of the reform's implementation  

A new decree n°2024-266 of March 25, 2024 draws the consequences of the postponement of the reform's application (a new order is also expected). 

Following the changes to this project announced in a press release issued by French Minister for the Budget and Public Accounts on 15 October 2024, these texts will be subject to new amendments that, according to the latest information available, will not take place until the end of 2025.  

The reform will become mandatory for all companies on 1 September 2026, with the smallest companies (SMEs and VSEs) only required to issue invoices electronically from 1 September 2027. 

Obligation to issue and transmit invoices electronically (e-invoicing)

The obligation to issue and transmit invoices electronically (e-invoicing) will apply, according to article 289 bis of the French Tax Code – FTC, to transactions between taxable persons (see our infographic here) or between a taxable person and a non-taxable legal entity established in France, when involving  : 

• supplies of goods and services (excluding those exempt from VAT pursuant to Articles 261 to 261 E of the FTC and transactions related to top-secret defence matters) as well as the related payments made on account before the goods or services are supplied; 
• supplies of second-hand goods, works of art, collector's items or antiques via public auction. 

All businesses must be able to receive electronic invoices as from the reform’s initial entry into effect,1 September 2026 (see our infographic here); 

• Companies will be obliged to issue their invoices in one of the accepted minimum electronic formats. In practice, it will still be possible to use other formats to issue or receive invoices, provided that an appropriate partner dematerialization platform (DPP) is chosen.
• The obligation to issue invoices in such electronic formats will apply to large companies and ETIs from 1 September 2026, and to SMEs and VSEs from 1 September 2027; 
• A centralized directory, administered by the public invoicing portal (PPF) and listing all businesses by SIREN number, will be used to identify issuers and recipients of invoices. This directory will be enriched, for each company, with the identification of its chosen PDP (and, when applicable, the invoicing addressing level as soon as it is notified by its designated PDP).  For public-sector organisations, the directory will be initialised with the addressing level of the establishment (SIRET) and the routing code level with Chorus pro as a reception platform.
• When invoices are sent electronically, certain data will be extracted and sent to the tax authorities via the PPF (under its role of “data concentrator”). The invoice data that will be exchanged with the tax authorities is described here (in French).
• So far, businesses were supposed to have the choice between a direct transfer of its used and/or received invoice either directly through the public portal or via one or several PDPs. According to the announcement of the French Minister for the Budget confirmed by the updated external specification file, the transfer will only be possible via one or more PDPs, which will be responsible for carrying out certain checks on invoices and extract the requested data for reporting to the authorities through the PPF.
• Dematerialization operators may obtain PDP status for three years, renewable, following a two-stage procedure. First, applicants must submit a complete application and, if approved, be granted PDP status and added to the public list of PDPs. Then, they have twelve months to  provide a compliance report, written in accordance with the regulatory conditions and specifications, to make their registration official for the full three-year term (renewable). Until this confirmation, the PDP is designated as “immatriculée sous reserve” (registration subject to confirmation).  The list of  PDPs that are registered but waiting for confirmation is available here.
• An additional compliance audit must be carried out for each triennial identification renewal. The authorities will be able to remove from the list of PDPs any operators that breach their obligations (see, in particular, Art. 242 nonies B–D, FTC Annex II and Art. 41 septies A, FTC Annex IV) These rules apply subject to possible amendments based on the announcement issued on 15 October 2024 by the Minister for the Budget and Public Accounts; 
• As already envisaged in the initial timetable for the reform, the transmission of invoicing data will concern only part of the mandatory information at the start of the reform (1st September 2026). This base will be supplemented by other data when the obligations under the reform are extended to all companies.
• However, a new decree is expected to  confirm the principle of a progressive increase of data to provide.
• What is certain, however, is that the list of mandatory information for invoices will be extended to include (from 1 September 2026 and, for SMEs and VSEs, from 1 September 2027): the client’s SIREN number, the full address of delivery or performance of the service, classification of the invoice as being for goods, services or both and, whether the company has opted to pay VAT on debits.  
• All invoice data must be submitted and received through a PDP in one of the approved syntactic formats from which data can be extracted for reporting to the tax authorities.

Under the initial version, the reform’s regulatory texts (Art. 41 septies C, FTC Annex IV) provided for the possibility of using the following solutions:

• an A-3 PDF file associated to a structured XML file (such as Factur-X);
• an invoice sent under the EDI format and through a structured message under an XML format or according to the UBL, CII or Edifact syntaxes (but, in the latter case, only between two PDP);
• or an invoice in PDF native format (i.e. a PDF file without an associated XML and directly issued by the company’s information system). This possibility was intended to be offered temporarily. 

Initially, it should have been possible to enter manually the invoicing data via the public platform (PPF). If the obligation to use a PDP is confirmed by law, a question will be whether special simplified measures will be planned for very small businesses. 

According to the new version of the external specification file, invoice files should be sent:

• Either in a semantic and syntactic format that complies with European standard EN16931, integrated into files in UBL, CII and Factur-X formats, with PDPs responsible for converting both outgoing and incoming files for their customers, if necessary.
• or in other formats (e.g. Edifact) subject to the agreement of both parties.

The transmission of data to the tax authorities will be done through the PPF based on the data transmitted by the PDPs in UBL or CII format.

Obligation to transmit transaction data (e-reporting) 

This obligation will apply to : 

• all French taxable persons, for all transactions listed under the new Art. 290 I, FTC, unless the transaction in question is exempt under Art. 261–261 E, FTC;
• all non-French taxable persons, for transactions performed in France and requiring them to pay French VAT. 

In practice, these are the concerned transactions: 

• transactions between two non-French taxable persons, when the operation would be covered by the e-invoicing obligation; 
• supplies of goods or services to any non-taxable person, whether established or resident in France or elsewhere; 
• intra-Community acquisitions of goods, as well as acquisitions of goods or services on which a French taxable person is liable for VAT under the reverse charge mechanism; 
• transactions involving persons established in Monaco, in accordance with the applicable rules. 

In addition to VAT exempt transactions and those which are not subject to mandatory invoicing (such as training services, medical activities or certain banking and financial transactions) and those related to top-secret defence matters, the following operations will not be subject to the e-reporting obligation: imports, transactions carried out by non-taxable legal entities or those carried out between non-taxable persons. 

The transaction type will determine what data need to be reported (Art. 242 nonies M, FTC Annex II). A table describing such data is available here (in French).

For B2B transactions, the data to be reported will mirror the mandatory information for e-invoicing (except for the number used to identify the client – see Art. 41 septies K, FTC Annex IV). 

For other transactions (BtoC such as retail sales, distance sales, etc.), the data must be aggregated by day and must include, in addition to the identity of the taxable person, the period concerned, the existence of an option to pay VAT on debit, the category of transaction and, for each tax rate, the amount exclusive of tax and the corresponding tax, the total amount of VAT due in France, the date and the number of transactions. The data should be transmitted in a structured format. 

If an invoice is issued (even if it is not compulsory under the tax regulations) its number will have to be reported. 

The frequency of transmission depends on the reporting regime to which the company belongs, i.e. at least three transmissions per month for those subject to the normal regime, one per month for those subject to a simplified regime and only one every two months for other companies (FTC, ann. II, art. 242 nonies O and ann. IV, art. 41 septies M). A table describing such data is available here (in French).

Transaction data is routed to the PPF by the PDP(s) chosen by the company.

Obligation to report payment data 

Except in situations where the reverse charge mechanism applies or when the service provider has opted for the payment of VAT debit, the tax authorities must also receive (according to the Y scheme similar to the one for the other obligations) information relating to the payment of services falling within the e-invoicing or e-reporting obligations (FTC, new Article 290 A) as well as information relating to public sector contracts, but with the exception of information linked to top-secret defence matters. 

The scope of this obligation deserves particular attention, especially as the administration intends to require payment reporting for advance payments received by service providers who have opted for payment of VAT on debits. 

The party responsible for providing this information will generally be the service provider based on its cash receipts. 

The data to be transmitted are, in addition to the identity number of the declarant and the period covered, the date of collection, the amount collected split by tax rate, and for transactions giving rise to an invoice, the invoice numbers (collections of BtoC transactions are aggregated by day). The tax authorities have published guidelines on this matter, which are available here (in French).

The data will ultimately allow (not defined to date) the pre-filling of VAT returns, considering the chargeability rules applicable to the transaction. 

Compliance with this obligation requires a systematic matching between invoicing data and payment data compatible with the reporting frequency set at once a month for companies subject to the normal or simplified regime (to be transmitted before the 10th of the following month for the former and between the 25th and 30th of the following month for the latter) and once every two months for the other companies (to be transmitted between the 25th and 30th of the month following the end of the period) 

Invoice life cycle 

The monitoring of the invoices' life cycle will be carried out on the public portal through various statuses. Only 4 statuses are currently considered mandatory for all transactions concerned by the reform: submission and rejection (i.e. by the platform), which are automatically entered, and refusal and receipt of payment (only for companies bound by this obligation) that require manual processing by the recipient for refusal and by the seller or service provider for collection (FTC, ann. IV, art. 41 septies G). 

Involvement of partner dematerialization platforms  

It is from the PPF (or henceforth from the “data concentrator”) that the tax authorities should receive the invoice, transaction and collection data that companies will be required to communicate to them, and only this data. 

Under the new framework of the reform, all taxable persons will have to choose a partner dematerialization platform (PDP), which will be responsible for receiving, sending and monitoring invoices, both outgoing and incoming, and for transmitting to the PPF the data intended for the tax authorities.

Each PDP will have to be able to enable its users to use electronic invoicing under conditions that comply with regulations, to carry out certain formal checks and identify invoice recipients, and to update the central directory of data concerning their users. They must, of course, be able to extract and transmit the data they receive from their users, and which must be forwarded to the French tax administration (CGI, ann. II, art. 242 nonies E)

Click here for the list of PDPs registered “sous reserve” (registration subject to confirmation). 

Sanctions 

As the project currently stands, there are specific penalties for non-compliance with the new obligations. 

Therefore :

• Regarding the electronic invoicing obligation: 
  • non-compliance with the obligation to issue an electronic invoice will be punishable by a fine of 15 euros per invoice, with a ceiling of 15,000 euros per calendar year;
  • each omission or failure by a dematerialization platform operator to comply with transmission obligations will give rise to a fine of 15 euros per invoice, up to a maximum of 45,000 euros per calendar year. 
• Regarding the obligation to transmit transaction and payment data: 
  • the fine applicable to the taxable person is 250 euros per transmission, up to a maximum of 15,000 euros per calendar year for each of these two obligations.
  • non-compliance with these obligations by a dematerialization platform operator gives rise to a fine of 750 euros per transmission, capped at 45,000 euros per calendar year for each of the two obligations. 

The operator is exempt from each of these penalties in the event of a first offence during a calendar year or the three preceding years, and on condition that the offence is remedied spontaneously or within 30 days of a first request from the administration. 

What are the next steps in the reform? 

The opening of the directory, announced for the end of the first quarter of 2025, should then rapidly allow PDPs registered “sous réserve” (subject to confirmation) and companies that have already chosen a platform to begin a test phase.

Our infographics

• French companies: here are your new obligations!
• Timetable of the reform
• Glossary of electronic invocing
• E-reporting of payment data
• E-reporting for transaction data
• Central directory: Who does what?
• Central directory: Essentials

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