La Minute Tax

Every week, the Tax Minute with our partner Aurélie Maudhuy !

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• Reform on electronic invoicing in France: an essential step before coming into force in 2026

The electronic exchange of invoices is made mandatory from 1^Er September 2026 for domestic transactions between VAT taxable persons established, domiciled or having their usual residence in France. This electronic invoicing obligation consists of the issuance, transmission and reception of invoices, accompanied by the communication of certain invoice data to the tax authorities.

In addition to the electronic invoicing obligation (e-invoicing), the tax authorities provide for e-reporting obligations, i.e. the transmission of data relating to non-domestic inter-company transactions (B2B International) and between businesses and an end consumer in France (B2C), as well as certain payment data.

As part of this reform, the State Financial Information Agency (AIFE) has been publishing, since the end of 2021 and in various versions, the “external specifications” document bringing together all the elements that make it possible to describe the formats of exchange with the public billing portal (PPF).

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The most recent version “3.0” of December 18, 2024 is aimed directly at partner dematerialization platforms (PDP) insofar as it describes, from a functional and application point of view, the services offered by the PPF (for example, the directory) and the methods of exchanges with the PDPs.

For its part, the French Association for Standardization (AFNOR) has set up an Electronic Invoice Commission which is responsible for describing the formats and profiles of invoices and life cycle statuses constituting the minimum basis for the reform. Last May, it published two documents detailing the components of the common core of businesses, PDPs and dematerialization operators. A publication on use cases is coming soon.

At a time when the choice of PDP is becoming crucial for companies, it is just as necessary to carry out a detailed mapping of sales and purchase flows internally, in order to qualify these flows in the field (e-invoicing or e-reporting) or outside the scope of the reform, accompanied by an audit of information systems (IS).

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It is quite traditional to prioritize the company's main flows. However, companies are advised not to wait to analyze minority or exceptional flows (e.g. expense reports relating to employee business travel, management of vouchers or gift cards, processing of discounts, transactions with the company's CSE, real estate transactions, self-billing, etc.).

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The same applies to the cleaning of the company's customer/supplier databases (including up-to-date and valid information on VAT and Siret/Siren numbers) in order to comply with the requirements on mandatory information on invoices defined in article 242 nonies A of Annex II to the General Tax Code.

The detailed flow mapping set up by the company constitutes an essential information base for continuing the work of controlling and updating the settings in the IS and mapping with the PDP. This will require the company to transmit invoice data in a format adapted to the reform that may contain a significant number of invoice lines in line with the European Semantic Standard EN16931.

I will be speaking at a conference on the theme “Electronic invoicing reform: where are we?” ” on Thursday June 19 as part of the A3F (French Association of Women Tax Specialists).