Upcoming B2B e-invoicing mandate in France: Official Decree published

The Journal Officiel de la République Française (the French Gazette) has officially published Decree No. 2022-1299 and an associated order on e-invoicing. This confirms the implementation of the e-invoicing technical requirements and specifications that had already been announced and published, as well as confirming the following specific invoice changes:  

  • Inclusion of the delivery address for goods where different from the customer’s address on the invoice 

  • Inclusion of the customer’s SIREN number on the invoice  

  • Narrative “Option for payment of tax on basis of debits” (“Option pour le paiement de la taxe d’après les débits”) on the invoice where supplier has opted to account for VAT on an accrual basis under the régime des debits. 

Requirements to be met by accredited Partner Dematerialisation Partners (PDPs) include:  

  • SecNumCloud cybersecurity certification is mandatory  

  • ISO 27001 certification required  

  • Ensure no data is transferred outside the EU  

  • Mandatory audit report from agreed third-party to be provided to the tax authority   

  • Use of the central directory (Annuaire) to send e-invoices to customer’s PDPs. 

The legislation also confirms the main basic functionality to be provided by the main Public Invoicing Portal (PPF) as well as the mandatory services to be provided by accredited PDPs:

Mandatory Partner Dematerialisation Partners (PDP) services and functionality

  1. Ensure PDP users can enter, store, issue and transmit e-invoices under conditions that guarantee the authenticity of their origin, the integrity of their content and their legibility
  2. Identify and verify recipients of e-invoices via use of the central directory (Annuaire)
  3. Update PDP user’s information on the central directory

  4. Ensure transmission of e-invoices to the main Public Invoicing Portal (PPF) or other PDP under interoperability agreements

  5. Receiving e-invoices sent by other PDPs or by the PPF and making them available for the PDP’s users

  6. Manage the status of e-invoices (providing status to users, allowing users to update, transmitting processing status to the PPF and to other PDPs)

  7. Extract mandatory e-invoice data elements required by the tax authority and submit to the PPF

  8. Extract mandatory e-reporting data and submit to the PPF (with a minimum of 1 transmission and maximum of 3 transmissions per month).

Main Public Invoicing Portal (PPF) services and functionality 

  1. Archiving of e-invoices for up to 10 years 
  2. Collection of invoicing, transaction and payment data on behalf of the Tax Authority 
  3. Daily updates to the central directory 
  4. Interoperability agreement to be signed between the PPF and all PDPs. 

Timeline for mandatory e-invoicing in France

As a reminder, and as confirmed by this published legislation, France will introduce mandatory B2B e-invoicing and e-reporting from July 1, 2024 on a phased approach based on the following timeline:  

Business size Date Requirement
All companies and businesses July 1, 2024 Receive e-invoices
Large Companies July 1, 2024 Issue e-invoices and e-reporting
Small and Medium-sized Enterprises (SMEs) with workforce of less than 5,000 people and annual sales of less than €1.5 billion or a balance sheet total of less than €2 billion January 1, 2025 Issue e-invoices and e-reporting
SMEs and Very Small Enterprises (VSEs) with fewer than 250 employees and annual sales of less than €50 million or a balance sheet total of less than €43 million January 1, 2026 Issue e-invoices and e-reporting

France also recently confirmed penalties for failing to issue compliant e-invoicing under the upcoming B2B e-invoicing mandate. 

Avalara has an e-invoicing solution that can help companies stay compliant in over 60 countries including the upcoming French -e-invoicing mandate starting in July 2024. Contact an expert at Avalara to discuss how we can assist with the upcoming e-invoicing mandate in France and watch our recent webinar on-demand.

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