Senate backs early e-invoicing & e-reporting amendment proposals for an early July 2025 launch for large enterprises; Bill now in National Assembly review
The French Senate (upper house of Parliament) approved on 27 November a 2024 Budget amendment  for an early start of 1 July 2025 for mandatory e-invoicing & e-reporting for large businesses. This is instead of the planned Sept 2026. The Budget now returns to the lower house National Assembly for review of the amendment.
A second amendment was proposing changing the start date for mid-sized businesses to Sept 2027 instead of Sept 2026. But keeping the large enterprises at Sept 2026.
It is not clear if either amendment will be accepted by the Assembly since there is much opposition from the business community. But the final dates should be resolved by parliament by the end of December 2023. If (big if!) the first amendment did pass, then the new timetable would be shifted from starting in Sept 2026 to:
- July 2025 for large companies (more 5,000 employees; and either of following: €1.5 billion turnover; or €2 billion balance sheet);
- Sept 2026 for medium sized companies; and
- Sept 2027 for small businesses (less than 250 employees; and not exceeding either of following: €50 million turnover; or €43 million balance sheet)
La Commission des Finances is a standing committee of the French National Assembly.
Mandatory B2B e-invoicing & B2C e-reporting potential launch Sept 2026 to Sept 2027
France’s lower house of Parliament, Assemblée Nationale, has proposed on 17 October 2023 an amendment to the recent Finance Bill for a revised 2026-27 launch date for its mandatory B2B e-invoicing and B2C e-reporting regime. This follows France abandoning a July 2024 launch plan over this summer.
The potential new timetable, revealed in the amendment:
- 2024 – in Spring the completion of the licensing of e-invoicing agents ‘partner dematerialization platform (PDP)‘. During the remainder of the year, the completion of Public Invoicing Portal (Portail Public de Facturation or PPF).
- 2025 – Large pilot as a testing phase.
- September 2026, Phase 1: large and medium sized-companies issue e-invoices and submit e-reporting. All taxpayers must be able to receive e-invoices from this time. NOTE: option to extend further to 1st December 2026.
- September 2027, Phase 2: small enterprises (les PME and TPE) must be able to issue e-invoices and comply with and e-reporting. NOTE: option to extend further to 1st December 2027.
France will now have to apply to the European Commission for an extension of the VAT Directive derogation it was granted to impose e-invoicing. The permission received in 2022 only lasts until 31 December 2026.
The French postponement from July 2024 follows Germany’s delay to 2026-27 and possible delays to EU VAT in the Digital Age mandatory 2028 e-invoicing proposals.
27 July – France abandons July 2024 e-invoicing launch plan
France has responded to business, software provider and lobby group concerns around the short preparation time for the proposed July 2024 mandatory B2B e-invoicing and B2C e-reporting. The Direction Générale des Finances Publiques has announced today that both are delayed.
The launch of the PPF platform on time has also been cited as a reason for the delay. The test launch was going to miss the 2023 deadline, so undermining the pre-launch test in the first half of 2024. This could also likely mean the ongoing certification of PDP e-invoicing agents will drag, too.
The registration process for certified e-invoicing agents – partner dematerialisation platform (see below) – will continue.
The French proposals had been for a three-wave phased implementation (by company size) between July 2024 and January 2026 for:
- Structured e-invoices on domestic B2B transactions; and
- Digital reporting (e-reporting) of B2C and international B2B transactions
31 July 2023 – version 2.3 of e-invoicing specifications
The DGFIP has issued on 31 July 2023 the latest guidance on use cases for its mandatory e-invoicing regime – v2.3. In total, this includes 36 use cases of transactions, and how to treat them under the new regime.
May 2023 – PDP registrations now open
The certification process for approved French e-invoicing agents ‘partner dematerialization platform (PDP)‘ was opened on 2 May 2023.  Businesses subject to the mandatory e-invoicing will be able to use PDP’s or submit directly to the French e-invoicing portal (PPF)
Selection of pilot participants in 2023:
- 15 April 2023, publication of application forms on impots.gouv.fr site
- April – May, applications open to interested parties
- Mid-June, successful applicants notified. Partner Dematerialization Platform (‘PDP’) applicants will have to demonstrate they are able to efficiently collect registrations within an acceptable timeframe
- Sept, additional SME (‘PME’) and Very small (‘TPE’) enterprises added
7th Oct 2022: Technical details published for e-invoicing any payment data published; includes requirements for agent ‘dematerialisation platforms’
Decree No. 2022-1299 of 7 October 2022 cover the rules for electronic invoicing in transactions between persons subject to value added tax and the transmission of transaction data. This covers the 3-phase rollout of B2B e-invoicing, starting 1 July 2024. This report covers:
- E-invoices: issuing, transmission and receipt
- Invoice and payment details: transmission
The decree brings forward six months the opening of the registration process to April 2023.
Taxpayers will submit e-invoices directly via State Financial IT Agency (Agence pour l’informatique financière de l’État, AIFE), or use ‘dematerialisation platforms’, which are approved agents.
Registrations start April 2023 for September 2026 launch of B2B e-invoicing – following Mexican decentralised Continuous Transactions Controls model
The French tax authorities (Direction Générale des Finances Publiques) have clarified the revised proposed 2026 launch plans for B2B e-invoicing and B2C invoice reporting:
- April 2023: The registrations process will start April 2023 with the launch of the Chorus Pro-based  portal, portail public de facturation (‘PPF’) – for companies  registering directly and potential certified agents (PDP).
- Jan 2024: A pilot will be launched for a six-month period for businesses and PDP’s on a voluntary basis
- Feb 2024: The first list of confirmed PDP agents will be published at the start of 2024.
France has opted for a Decentralised clearance model of Continuous Transaction Controls model (used in Mexico and Chile). This comes with the option to use certified agents (PDP, Plateformes de dématérialisation partenaires) able to clear invoices instead of direct reporting by the business via PPF. This is rather than the Italian-style Centralised clearance (see below for more details).
French mandatory e-invoicing fines regime
The French Parliament has adopted the provisions of the Finance Law 2022, which includes the phased introduction of e-invoicing. A late addition to the rules is the penalty regime for missed e-invoices. This will be:
- For taxpayers: €15 per invoice limited to €15,000 total per annum
- For e-invoice certified agents certified agents (PDP, Plateformes de dématérialisation partenaires): €15 per invoice limited to €45,000 total per annum
European Commission grants e-invoicing VAT Directive derogation for France
On 21 January 2022, the European Commission granted France a temporary departure from Articles 218 and 232 of the VAT Directive to be able to impose mandatory electronic invoicing on certain B2B transactions. This clears the way for France to introduce electronic invoicing from September 2026 (previously July 2024).
There are no plans to change the French VAT return or SAF-T FEC regimes.
Derogation from EU VAT Directive on e-invoicing
France now has it’s derogation from the European Commission and EU Council from the requirements from Articles 218 and 232 of the EU VAT Directive. This prevents member states from imposing e-invoices (and withdrawing paper-based invoices).
This is a temporary derogation between 1 January 2024 and 31 December 2026. After this time, France would need to apply for an extension based on evidence of the cost effectiveness in combating VAT fraud of the measure. Â The Directive requires sellers of goods or services to provide paper-based invoices unless both the customer and seller agree to use electronic invoices.
The ongoing EU VAT in the Digital Age proposals includes a strand around harmonised Digital Reporting Requirements (DDR) across the member states. This originated from the 2020 Tax Action Plan measures for a fairer and more efficient EU tax regime.
Scope of French e-invoicing
The following transactions will be included in the new regime:
- Business-to-businesses transactions
- Business-to-consumer transactions
- Exports and imports transactions
- Payment status of VAT invoices
- Imports of services
- Exports excluded
Information on B2C and intra-community, export and imports will have to be provided by other means to be determined.
How to create French e-invoice
French invoices may by created in the following formats:
- Structured format: UBL invoice / CII D16B / XCBL
- Hybrid format: Minimum UBL invoice / CPP hybrid / FACTUR-X (PDF-A3) / Minimum CII
There will be three options to create a French e-invoice:
- Direct to PPF via:
- Enabled accounting or ERP EDI route
- In-house or external software with controls over digital signature
- Use of outsourced approved providers, PPF, to file to PPF on your behalf
Note: Taxpayers can submit their invoices in PDF format instead of one of the structured format sand PDPs until the start of 2028. The PPF must be able to convert PDF invoices to one of the structured formats (CII, UBL or FACTUR-X) set by the mandate.
