To understand theELECTRONIC INVOICE
HOW TO IMPLEMENT
ELECTRONIC INVOICING?
Are you apprehensive about the move tomandatory electronic invoicing?That's normal, any change can be concerning! But rest assured, this transition is not insurmountable if approached correctly.
Don't wait to be compliant by 1st September 2026, the countdown is on!
NEED TOSEE MORE CLEARLY?WE GUIDE YOU,
ON VOUS GUIDE, STEPBYSTEP.
The5 stepsfor a successful transition:
Understand the reform and its opportunities for your business
Take stock of your equipment
Define your material and immaterial needs (training for your teams)
Select the approved platform suitable for your activity (PDP now PA)
Test, deploy and adjust the chosen solutions
Take the time tounderstand the reform, to anticipatethe deadlinesand to choose the righttoolsfor your business
The dates of the reform
2026
All businesses must be able to receiveelectronic invoices.
Large companies and SMEsmust issue their invoices in electronic format and declare their transactions.
2027
All businesses must issue their invoices in electronic format and declare their international B2B and B2C transactions.
What you need to know!
All your electronic invoices will go through acertified platform(CP), accredited by the tax administration.These private platforms, registered by the state,guarantee the security and compliance of exchanges.
Unlike traditional PDF invoices, electronic invoices contain structured data that systems can process automatically.
- The objectives of this reform:
- Reduce your administrative costs
- Speed up your payment times
- Simplify your VAT declarations
- Strengthen the fight against fraud
Who is concerned?
All businesses/entities subject to VAT are affected by this reform, regardless of their size:
- Large businesses and medium-sized enterprises
- Small and medium-sized enterprises
- Micro-enterprises and self-employed individuals
- Medical and liberal professions
- Associations
- Businesses exempt from VAT
Commerce, catering, real estate, agriculture, crafts... Each profession has its specifics! That is why we have created practical sheets that address the concrete questions of your sector.
Practical sheets by sector
WHAT IMPACTS FOR YOUR SECTOR?
What penalties do we face if we do not comply with the obligations?
In the event ofnon-compliance with the obligationsrelated to the electronic invoicing reform, various penalties may be applied. The major risk would obviously be toparalyse the activityof your business, which cannot issue orreceive invoices.Whether for you or the image of your business, it is better to avoid that!
- In the event ofdefault of electronic invoicing, a fine of €50 per invoice may be imposed.
- Thefailure to comply with the e-reporting obligationmay result in a fine of €500 per transmission failure, with a maximum annual cap of €15,000.
- If you do not designate aApproved Platform for receiving invoices, you risk a fine of €500, then €1,000 every quarter.
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Discover the Approved Platforms (PA)!
View the offers and specifics
Glossary
The directory lists all VAT-registered entities established in France with a SIREN. The PA platform chosen by the taxpayer to receive their invoices is indicated there. Registration in the directory is done by the PA following the signing of an opt-in form by the company or a person with a delegation mandate. The directory is managed by the AIFE and only the PPF and the PAs can update this directory.
It is structured into 3 categories of data:
1. Identification of the company for invoice addressing (SIREN, SIRET, routing code, suffix)
2. Identification of the platform chosen by the recipient company
3. The start and end dates of the subscription to the PA
An API is a software interface that allows an application to interact with another software to exchange data and functionalities.
Archiving is the process of collecting, classifying, preserving, and managing documents of an organisation. This can include the digitisation of paper documents, storage on secure digital media, the establishment of document management systems to ensure the longevity and easy retrieval of archived information, and the traceability of documents.
A taxable person is a natural or legal person who independently carries out a profit-making activity on a recurring basis, such as a professional activity. Micro-entrepreneurs, medical professionals, and liberal professions are also considered taxable persons and are subject to electronic invoicing. Certain operations may be exempt from VAT by law. See practical sheet "taxable persons".
From 1 January 2023, a new tax regime allows taxable persons established in France and linked to each other financially, economically, and organisationally to form a single taxable person (AU) for VAT purposes. The single taxable person referred to in Article 256-C of the CGI is subject to the large businesses' schedule for the implementation of electronic invoicing, that is, from the 1st, regardless of its size.
B2B or BtoB (Business to Business) refers to a commercial transaction between two businesses. This can include the sale of products or services from one business to another. A domestic BtoB transaction is a commercial transaction between two businesses established in France.
B2C or BtoC (Business to Consumer) refers to a commercial transaction in which a business sells products or services directly to end consumers (individuals).
B2G or BtoG (Business to Government) refers to a commercial transaction that takes place between a business and a government organisation.
BtoBtoC is a business model that involves a company selling products or services to another business, which in turn sells them to the end consumer.
The use cases were 36 specific situations described in the specifications of the DGFIP regarding electronic invoicing. Following the abandonment of the platform functionality of the PPF, it is the AFNOR commission that is responsible for standardising the processes between PA in these situations.
Chorus Pro is the shared invoicing solution that has been established for all suppliers (private or public) in the public sphere (State, local authorities...) to meet legal obligations regarding electronic invoicing. A supplier can submit their invoices directly on Chorus Pro or on their PA.
Digital preservation is the process of long-term preservation of documents, data, and other digital objects. It involves implementing techniques to ensure the durability, readability, and integrity of the preserved data.
The life cycle of an invoice is described by statuses. In the context of electronic invoicing, 4 statuses must be completed in the life cycle and submitted to the administration:
• Submitted: invoice accepted by the issuer's platform
• Rejected: invoice not accepted by the issuer's or recipient's platform (defined formats or non-compliant checks)
• Refused: invoice refused by the recipient (recipient error, on the invoice, etc.)
• Collected: which includes payment data (date and amount)
There are 10 other "recommended" or "free" statuses that will not be sent to the tax administration.
Dematerialisation refers to the process of replacing physical media with digital formats to store and share data. There are two types of dematerialisation:
• Duplicative dematerialisation: producing a digital copy of a physical medium (scanning a document)
• Native dematerialisation: medium created and generated directly in a digital format by computer software.
Payment data must be transmitted in the context of services that have not opted for VAT on cash receipts and that are not self-assessed. The concept of payment data encompasses collection data, as they are transmitted by the party receiving the payment. The invoice alone will not suffice to generate the VAT declaration and will require the addition of "payment data."
If a VAT-registered business established in France carries out transactions with non-VAT-registered or VAT-exempt clients, it must transmit the data of these transactions to the tax authorities.
In the case of an international B2B transaction, the data to be transmitted to the tax authorities will be identical to that transmitted in the context of e-invoicing, excluding the unique identification number (SIREN) of the non-established taxpayer in France. For B2C transactions, there are 10 types of data to be transmitted to the tax authorities.
EDI is a secure process for transmitting digital data between different computer systems to facilitate exchanges and commercial transactions. EDI allows for the replacement of paper document exchanges such as invoices, purchase orders, and delivery confirmations with real-time electronic transmissions, thereby improving the speed and efficiency of business processes. EDI is used by large companies in certain sectors (industry, retail, etc.).
In the context of Article 26 of the amending finance law for 2022 No. 2022-1157 of 16 August 2022, an electronic invoice is an invoice issued, transmitted, and received in a dematerialised form and which necessarily includes a minimum set of data in structured form, distinguishing it from 'paper' invoices or ordinary PDFs. It will be sent to the client via an Approved Platform (PA).
E-reporting is the transmission to the tax administration of transaction data that does not fall under e-invoicing. E-reporting encompasses the transmission of international B2B transaction data, B2C data, and payment data related to operations that fall under the category of services outside the option on debits. The operations subject to the e-reporting obligation are listed in articles 290 and 290 A of the CGI.
Factur-X is one of the three mandatory invoice formats for e-invoicing or foundational formats. It is referred to as hybrid or mixed because it contains structured billing data representing the basic information about the transaction and is in a PDF format that is readable and understandable by all. Additionally, mandatory data is stored in an attached XML file that will be processed and analysed by computer systems. This is the preferred format for micro and small enterprises.
A free invoice refers to an invoice that is not subject to a specific format or sending obligation related to the electronic invoicing reform.
The identification of a structure is based at a minimum on its SIREN. If the entity wishes, a more detailed reference based on the SIRET is also possible. In addition, a routing code and a suffix can be provided to identify, within the concerned entity, the service(s) responsible for handling the received invoices.
Registration refers to the process by which a PEPPOL Access Point (PA) is registered with a competent authority to ensure compliance with privacy and data security regulations. Thus, publishers wishing to become PAs must apply for registration. A list of registered PAs 'subject to' is published regularly, and the first definitive registrations will be published by the end of 2025.
Registration is valid for a period of 3 years.
Interoperability refers to the ability of different systems, products, or IT services to work together and share data from different programmes effectively and transparently, without the need for modification. This allows for greater flexibility and better use of resources to achieve improved efficiency and productivity. Interoperability often involves the use of APIs. PAs, being PEPPOL access points, are natively interoperable with each other.
Operators providing dematerialisation services but who are not registered by the administration as PAs. These operators cannot directly transmit electronic invoices to their recipients but must be connected to an Approved Platform (PA). The OD can access the directory to consult the address of a recipient but cannot know the PA of that recipient nor modify the directory as a PA does.
The reliable audit trail involves establishing "documented" and "permanent" internal controls specific to invoice management. It provides proof of the validity of invoices and convinces the tax auditor of the seriousness of the processes dedicated to invoicing.
According to Article 289-VII of the CGI, there is an obligation for PAF in the case of paper invoices and simple electronic invoices.
PAF is not mandatory in the case of EDI invoices (art. 289-VII-3) or signed or sealed invoices (art. 289-VII-2 and 4).
Any failure to transmit electronic invoicing or data transmission will be subject to a financial penalty.
For taxable persons, a fixed fine of €50 per non-transmitted invoice (e-invoicing), capped at €15,000 per calendar year, is provided for (art. 1737-III of the CGI) and a fixed fine of €500 per non-transmitted transmission (e-reporting), capped at €15,000 per calendar year (art. 1788 D I of the CGI). The first offence committed will not be penalised.
PA will also be penalised in case of failure: €50 per invoice up to a limit of €45,000 per year and €750 per transmission up to a limit of €100,000 per year.
An Approved Platform is a platform that has undergone a registration procedure by the administration, for a renewable period of three years, the conditions of which are specified by regulatory means. Only a partner platform is authorised to provide all the functionalities required by the reform regarding electronic invoicing and e-reporting. They meet a high level of security by being certified ISO 27001 and SecNumCloud. Only they can modify the directory for their clients.
To beregistered definitively, verification of technical compliance with the requirements of the specifications: exchange of invoices between approved platforms, data extraction... This step will take place by the end of 2025.
The list presents the approved platforms registered subject to conditions
Public portal created by the AIFE to meet legal obligations regarding electronic invoicing. It serves 2 roles:
- Administer the central directory of taxpayers
- Concentrator of mandatory data extracted from invoices, transaction and payment data to be transmitted to the tax administration.
Electronic sealing is a stamp linked to a legal entity: the firm. A sealed document guarantees the identity of the issuer and the integrity of the document. Sealing allows exemption from the PAF.
The electronic signature is a method of digital signing used to authenticate a person's identity and to validate the integrity of an electronic document. Its content is deemed approved by the signer. It allows for the replacement of handwritten signatures and can be used for commercial transactions such as signing contracts, quotes, and invoices. The electronic signature allows exemption from the PAF.
Publishers of Dematerialisation Operators (OD) who position themselves as SC independently. The DGFiP must publish details on the conditions to be met to use this designation.
The life cycle of an invoice is described by statuses. In the context of electronic invoicing, 4 statuses must be completed in the life cycle and submitted to the administration:
Submission: invoice accepted by the issuer's platform
Rejection: invoice not accepted by the issuer's or recipient's platform (defined formats or non-compliant checks)
Refusal: invoice refused by the recipient (recipient error, on the invoice, etc.)
Received: which includes payment data for services provided outside the VAT option on debits outside the self-assessment of VAT (date and amount)
There are 10 other "recommended" or "free" statuses that will not be sent to the tax administration.
