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17 October 2024

France | Latest information on electronic invoicing reform

  • A press release from the French Government provides an important development concerning the reform of electronic invoicing in France.
  • The government also announced its intention to restrict the scope of the Public Procurement Framework, governing public contracts.
 

In a press release issued on 15 October 2024, the French government reaffirmed the timetable for the electronic invoicing reform (1 September 2026 or 1 September 2027, depending on the size of the company) and announced a decision to restrict the scope of the Public Procurement Framework (PPF). The PPF will now focus solely on establishing a recipient directory, essential for exchanges between platforms, and a data hub for transmitting information to the tax authorities.

Reportedly, electronic invoicing reform will now involve, on the e-invoicing side, the transmission of invoices between professionals outside the PPF; only the "Flow 1" (e-reporting of invoicing data) will be transmitted to the PPF. This seems similar to German and Belgian models currently being developed.

The role of Certified Platforms known as "PDP" (for "plateformes de dématérialisation partenaire") appears to be critical, as their use becomes mandatory for sending and receiving an electronic invoice and pushing the e-reporting data to the Governmental Platform (i.e., the PPF).

The change restricting the scope of the PPF will disrupt several options or strategic decisions that companies had made as part of their e-invoicing project (i.e., for the implementation of the reform). Questions raised by the change include:

  • What strategies should companies pursue if they had previously favored a direct connection to the PPF?
  • What roles should Data Operators take in e-invoicing?
  • Will Lifecycle Data still needs to be transmitted to the PPF?
  • Are PDPs mandatory for all companies to transmit Flow 1 to the PPF?
  • How will the format/content of business-to-business e-reporting evolve, and how will it be transmitted to the PPF?
  • What invoice-archiving solution should a company choose (because the PPF would not provide this service)?
  • Will the objective of pre-filling value-added tax (VAT) returns change?
  • Is French legislation compatibile with the VAT in the Digital Age (ViDA) directive? Does this align with similar regimes (e.g., Belgium/Germany)?

A subsequent Tax Alert will provide further details on this new development, as reflected in the amended 2025 Finance Bill (PLF) and the forthcoming publication of a new version of the external specifications, expected by the end of the year.

For background on e-invoicing reform in France, see EY Global Tax Alert, France releases specifications for e-invoicing, dated 20 June 2024.

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Contact Information

For additional information concerning this Alert, please contact:

EY Société d'Avocats, Paris

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

Document ID: 2024-1916

 
 

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