Latest Update: v2.2 of External Specifications

On March 31, 2023, the French Directorate General of Public Finance (DGFP) released an updated version (v2.2) of the technical specifications for the e-invoicing and e-reporting system which will be implemented in France for B2B & B2C transactions starting July 2024.

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Version 2.2 of the External Specifications expands upon previous versions and provides further details on how the new e-invoicing and e-reporting system will function in France.

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Background

Since 2017, suppliers issuing or receiving an invoice from a French public entity (business-to-government, B2G) have been mandated to do so electronically (e-invoicing) via the Chorus Pro platform.

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In 2021, the French government (Order no. 2021-1190) extended the requirement for issuing and receiving electronic invoices (e-invoicing) to all domestic B2B transactions (i.e., between two entities subject to VAT in France).

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For non-domestic B2B transactions and B2C transactions, the government will not require the exchange of e-invoices between the buyer and supplier. However, companies will be required to transmit specific invoice data and payment details electronically to the tax authority (e-reporting).

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Implementation Timeline

Both e-invoicing (domestic B2B) and e-reporting (non-domestic B2B and B2C) requirements will follow the same adoption timeline:

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• Large enterprise = more than 5,000 employees and more than €1.5B annual revenue or more than €2B balance sheet total
• Intermediate-size company (ISE) = more than 5,000 employees and less €1.5B annual revenue or less than €2B balance sheet total
• SME (including microenterprise) = more than 250 employees and more than €50m annual revenue or less than €43 balance sheet total

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How E-Invoicing Will Work in France

The French government is introducing a system called the "Y scheme," which effectively combines several e-invoicing models.

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In essence, the "Y scheme" allows sellers to issue their e-invoices either through an intermediary (a PDP or OD) or directly via a public portal (PPF). The system will then route the invoices to the buyer and report the relevant information to the tax authority.

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There are three stakeholders in the "Y scheme":

• The public invoicing portal (PPF): A public platform that collects invoices from sellers, stores them, and makes them accessible to buyers. The PPF also consolidates invoicing information for the tax authority.
• Registered private platforms (PDPs): Invoicing service providers approved by the tax authority to send e-invoices directly to recipients.
• Dematerialising operators (ODs): Operators offering invoicing services but not authorized by the tax authority to send e-invoices directly to recipients. ODs must connect either to the PPF or a registered PDP to send e-invoices to the buyer.

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As mentioned earlier, the difference between PDPs and ODs is that PDPs are authorized to forward e-invoices directly to the buyer without using the PPF as an intermediary. Buyers can choose any invoicing supplier (PDP, OD, or the PPF directly) as their preferred method, and the PDP issuing the invoice on behalf of the seller will comply with this.

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This implies that PDPs must be aware of the invoicing supplier chosen by each buyer to receive their e-invoices. To facilitate this, the French government will create a Directory where sellers and buyers can register their preferred service providers for receiving invoices.

• When the buyer chooses an OD as their provider, the PDP will send the e-invoice to the PPF, which will then forward it to the corresponding OD. The PPF will also report the transaction to the Tax Authority.
• When the buyer selects a PDP as their provider, the PDP will directly send the e-invoice to the buyer's PDP and only need to report specific fiscal data to the PPF, which will then report the information to the Tax Authority. This means that PDPs must be able to communicate with other PDPs and the PPF.

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Every PDP platform will support a set of standard formats to ensure seamless interaction with other PDPs. The buyer will specify their preferred e-invoice format for the supply of e-invoices. E-invoices can be generated as structured or hybrid formats, aligning with one of the three foundational formats compliant with the European Union's e-invoicing standard, EN16931. These formats include UBL, CII, and Factur-X.

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How can Invopop help?

Invopop helps global companies comply with local e-invoicing and e-reporting requirements. We offer an API that records every sale, converts it to the a locally-compliant invoice format, forwarding it to the buyer and reporting it to the appropriate tax authority, according to the local law.

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If you want to prepare to comply with new electronic invoicing requirements, contact us today.

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