France B2B E-Invoicing: Senate Supports Early Launch in July 2025 for Large Enterprises
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 B2B e-invoicing & e-reporting. This is instead of the planned September 2026. The Budget now returns to the lower house National Assembly for review of the amendment.
A second amendment proposed changing the start date for mid-sized businesses to September 2027 instead of September 2026 while keeping the large enterprises at September 2026.
It is not clear if either amendment will be accepted by the Assembly since there is significant opposition from the business community. However, the final dates should be resolved by Parliament by the end of December 2023. If the first amendment passes, the new timetable would be:
- July 2025 for large companies (more than 5,000 employees and either: €1.5 billion turnover or €2 billion balance sheet).
- September 2026 for medium-sized companies.
- September 2027 for small businesses (less than 250 employees and not exceeding €50 million turnover or €43 million balance sheet).
France B2B E-Invoicing & B2C E-Reporting: New Potential Launch Timeline (2026-2027)
France’s lower house of Parliament, Assemblée Nationale, 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 earlier this year.
Proposed Timeline:
- Spring 2024: Completion of licensing for e-invoicing agents (Partner Dematerialization Platform – PDP) and the Public Invoicing Portal (Portail Public de Facturation – PPF).
- 2025: Large-scale pilot testing phase.
- September 2026 (Phase 1): Large and medium-sized companies must issue e-invoices and submit e-reporting. All taxpayers must be able to receive e-invoices. (Option to extend further to December 2026.)
- September 2027 (Phase 2): Small enterprises (PME and TPE) must issue e-invoices and comply with e-reporting. (Option to extend further to December 2027.)
France will now have to apply to the European Commission for an extension of the VAT Directive derogation granted in 2022, which expires on 31 December 2026.
Why the 2024 Launch Was Abandoned
On 27 July 2023, France officially abandoned its July 2024 e-invoicing launch plan due to concerns from businesses, software providers, and lobby groups about insufficient preparation time. The delay was also influenced by issues with launching the PPF platform on time.
The phased implementation originally planned between July 2024 and January 2026 included:
- Structured e-invoices for domestic B2B transactions.
- Digital reporting (e-reporting) for B2C and international B2B transactions.
France B2B E-Invoicing: Key Regulatory Updates and Technical Specifications
Latest Developments:
- 31 July 2023: Version 2.3 of France’s e-invoicing specifications released, covering 36 transaction use cases.
- May 2023: Certification process for Partner Dematerialization Platforms (PDPs) opened for businesses subject to e-invoicing.
- April 2023: Selection of pilot participants began, with applications open to interested parties.
Regulatory Framework & Compliance Details
On 7 October 2022, France published Decree No. 2022-1299 covering the regulations for electronic invoicing between VAT-registered businesses. The decree outlines the three-phase rollout of B2B e-invoicing, originally planned for 1 July 2024.
Key Compliance Measures:
- E-invoicing submission: Businesses will submit e-invoices via the State Financial IT Agency (AIFE) or through certified dematerialization platforms (PDPs).
- Mandatory e-invoicing fines:
- Taxpayers: €15 per invoice, capped at €15,000 per year.
- Certified e-invoice agents (PDPs): €15 per invoice, capped at €45,000 per year.
European Commission VAT Directive Derogation
On 21 January 2022, the European Commission granted France a temporary departure from Articles 218 and 232 of the VAT Directive, allowing mandatory B2B e-invoicing. This derogation is valid from 1 January 2024 to 31 December 2026, after which France must apply for an extension based on its effectiveness in reducing VAT fraud.
This move aligns with the broader EU VAT in the Digital Age (ViDA) proposal, which seeks to standardize Digital Reporting Requirements (DRR) across member states.
Scope of France B2B E-Invoicing: What Transactions Are Included?
Covered Transactions:
- Business-to-Business (B2B) transactions.
- Business-to-Consumer (B2C) transactions.
- Exports and imports transactions.
- VAT invoice payment status tracking.
- Imports of services.
Excluded Transactions:
- Certain B2C transactions.
- Some intra-community transactions.
- Specific export/import transactions (to be determined).
How to Issue a B2B E-Invoice in France: Accepted Formats & Submission Methods
Accepted E-Invoice Formats:
- Structured format: UBL Invoice / CII D16B / XCBL.
- Hybrid format: Minimum UBL invoice / CPP Hybrid / FACTUR-X (PDF-A3) / Minimum CII.
Submission Methods:
- Direct to PPF via:
- Enabled accounting or ERP EDI route.
- In-house or external software with controls over digital signature.
- Outsourced approved providers (PDPs) filing to PPF on behalf of businesses.
Note: Taxpayers can submit PDF invoices until 2028. The PPF must convert these to structured formats (CII, UBL, or FACTUR-X) for compliance.
The new proposal for July 2025 may seem daunting to business owners around the world. But, with our team of VAT experts, you will never be left in confusion.
Get in touch with our team today so that you can stay on top of all your e-invoicing compliance.
