B2B Electronic Invoicing in France

France is moving forward with its new electronic taxation system for private companies. The Ministry of Economy, Finance, and Recovery has already established the legal and technical framework for the widespread implementation of mandatory electronic invoicing between private companies (B2B) and e-Reporting.

Currently, they are finalizing the details of the new B2B electronic invoicing and e-Reporting model. To achieve this, the French tax authority, Direction Générale des Finances Publiques (DGFiP), along with the state agency Agence pour l'Informatique Financière de l'Etat (AIFE), have organized a series of working groups with companies and technology providers, including EDICOM.

We analyze the characteristics of the new French electronic invoicing model with the latest updates announced by the government.

New Electronic Invoicing and e-Reporting System

The Direction Générale des Finances Publiques (DGFiP) has announced the framework guidelines for the new taxation model, based on the results obtained from the evaluation conducted with all stakeholders involved (companies, technology providers, and administration stakeholders).

The new tax scheme entails the mandatory use of electronic invoicing between private companies, as well as the transmission of transaction data to the administration and electronic reporting of VAT data.

Objectives of the New Tax System

Among the objectives sought by the government with the implementation of electronic invoicing, the DGFIP highlights:

• Strengthening the prevention and fight against tax fraud.
• Decreasing the costs associated with tax control.
• Simplify VAT declaration for taxpayers. Achieving greater competitiveness through cost reduction.
• Improving knowledge of the economic situation through immediate reporting of company activity information.

Advantages of Electronic Invoicing

With the widespread adoption of electronic invoicing, the French government aims to modernize the current tax system and benefit both the government and businesses.

Benefits of electronic invoicing for companies include:

• Cost reduction in invoice processing throughout the sales cycle.
• Reduction of administrative burden in tax management processes.
• Improved control over payment deadlines.
• Automation of invoicing processes.
• Improvement in commercial relationships.

Benefits of electronic invoicing for the state include:

• Improvement in combating tax fraud.
• Increase in VAT revenue.
• Greater understanding of business activity.

Proposed Model: Y Scheme

In the initial report, the government evaluated two possible schemes called "V" and "Y". The "V" scheme was based on a similar scheme to the one used in Italy, while the "Y" scheme resembled electronic invoicing systems developed in Latin America.

Ultimately, the French government has decided to opt for the "Y" scheme. In this model, electronic invoices are pre-validated and processed by the Partner Dematerialization Platform (Plateforme de Dématérialisation Partenaire) before being reported to the government. One of the reference countries for this model is Mexico's CFDI tax system, whose success has served as an example to be followed in many other countries, such as France.

The government will leverage the infrastructure of Chorus Pro, the current state portal for electronic invoicing with public administrations, and will adapt it to the new B2B electronic invoicing system.

The Ministry of Finance has argued that the choice of the "Y" scheme is based on reconciling the freedom to allow companies to choose the electronic invoicing technology provider they desire with the obligation to communicate invoicing, transaction, and payment data to the administration.

Which Companies Will Be Affected?

All companies subject to Value Added Tax (VAT).

Implementation Timeline

The government has established a gradual adherence timeline for the new invoice issuance and e-Reporting system based on a company's size:

• September 2026: Obligation for all companies to receive e-invoices and obligation to issue e-invoices in France for large and medium-sized enterprises.
• September 2027: Obligation for SMEs and micro-enterprises to issue e-invoices in France.

Electronic Invoice Format

Electronic invoices may be issued in UBL, CII, or Factur-X format.

Only Dematerialization Platforms (PDPs) will have the possibility to send other types of formats (EDIFACT, XML, etc.) as long as both, suppliers and clients, use Dematerialization Platforms.

Electronic Signature

Signing electronic invoices is not mandatory but highly recommended.

We always recommend signing invoices in all cases, whether they are EDI invoices or dematerialized invoices under any other standard (although this is not the only means accepted in France to preserve the integrity and authenticity of documents).

The type of electronic signature accepted in the transmission of electronic invoices is the qualified electronic signature. This type of signature provides the most guarantees, which is why this mechanism was naturally chosen within the framework of current French regulations on electronic signatures and invoices. This signature is carried out based on a qualified electronic certificate and through a secure signature creation device.

The PDPs must guarantee service provision that complies with DGFiP requirements. It is their responsibility to verify the validity, integrity, and authenticity of documents. Therefore, although the use of the signature is not mandatory, PDPs must be prepared to process and validate the electronic signature of electronic invoices they integrate.

Companies that send electronic invoices and do not want (or cannot) sign them may choose to use reliable audit trails or EDI interchange along with certain additional procedures.

Public Invoicing Platform (Plateforme Publique de Facturation - PPF)

Chorus Pro

Chorus Pro is the portal enabled in France to centralize the sending of electronic invoices to French public administrations. It is a centralized platform that facilitates the exchange of electronic invoices between companies and public bodies with the aim of simplifying and streamlining administrative processes.

The platform allows the reception of invoices in structured and standardized formats, such as UBL, CII, and Factur-X, thereby ensuring interoperability with other companies and organizations both nationally and in Europe. On the other hand, public bodies use Chorus Pro to receive, process, and electronically archive invoices.

Additionally, Chorus Pro complies with the security and confidentiality standards required for the exchange of sensitive information. The platform is regularly updated to ensure compliance with legal and tax regulations regarding electronic invoicing.

Chorus Pro is a consolidated infrastructure that enables the essential components for extending electronic invoicing to 100% of companies. The characteristics that have made it a comprehensive and efficient tool for managing electronic invoices directed to public bodies serve as the basis for the deployment of the electronic invoicing model between companies, which will convert the current portal into the PPF (Portail Public de Facturation):

• Invoice Centralization: Central point for the exchange and management of all electronic invoices in France. It allows companies to send and receive invoices securely through a single platform.
• Process Automation: It offers the possibility of automating processes related to electronic invoicing. This includes automatic generation and sending of invoices, as well as automated validation and tracking of tax documents.
• Direct Communication: Direct communication channel between invoice issuers and recipients.
• Validation and Verification: The portal carries out automatic validations of the electronic invoices to ensure their integrity and regulatory compliance. This helps to avoid errors and ensures that the documents meet current legal and tax requirements.
• Security and Confidentiality: The portal guarantees the security and confidentiality of the exchanged data and documents. It uses robust security measures and complies with established data protection standards.
• Integration with Internal Systems: PPF will inherit Chorus Pro's capabilities to integrate with companies' internal systems, thanks to the API methods enabled by the portal, and the communication systems defined to integrate future PDPs.

Chorus Pro will become a new B2B2G portal, renamed as the Public Invoicing Portal (PPF). The new portal will manage all e-invoicing flows directed to the public administration and any company, as well as e-Reporting, whether companies use a dematerialization platform (PDP) or transmit directly through the PPF.

Public Invoicing Platform (Plateforme Publique de Facturation - PPF)

The Public Invoicing Platform (PPF) will play a crucial role as the central hub of the General Directorate of Public Finance (DGFiP) in France, by centralizing all electronic invoices exchanged in the country. This platform is built upon the infrastructure previously established in France for managing electronic invoices sent to the public administration through the renowned Chorus Pro portal.

It is important to note that electronic invoicing in France now covers 100% of transactions between companies in the country, regardless of whether the recipient is a public body or not. To this end, the Chorus Pro portal has been enriched with new functionalities that expand its capacity, making this tool available for 100% of invoice issuers in France.

Methods for automatically transmitting invoices to the PPF, such as Electronic Data Interchange (EDI) and Application Programming Interface (API), only support the sending of invoices in one of three accepted formats: UBL, CII, and Factur-X.

Taxpayers wishing to send their invoices directly through the PPF will only be able to use one of the three authorized formats: Factur-X, UBL, or CII. Once invoices are manually submitted to the portal or through integration methods, the PPF will identify the recipient and perform minimal validations before sending the invoice.

Connectivity to the PPF will inherit the current methods to reach Chorus Pro.

It is necessary to follow a technical integration process using the standards established by the platform, which materialize in two possible methods to be implemented by those companies issuing and receiving invoices who decide to automate these processes:

• EDI: Electronic Data Interchange (EDI) allows companies to connect to Chorus Pro in an automated and standardized manner. Presumably, this will be the method favored by many PDPs for integrating with the PPF for those companies choosing to contract their services to manage the issuance and reception of electronic invoices.
• API: The Application Programming Interface (API) of Chorus Pro enables direct integration with the platform, applying defined calls to deliver invoices. This API will typically evolve to enable new methods to invoke all required calls according to the new mandatory electronic invoice model between companies. The use of APIs will remain valid for the future PPF as it is now for integration with Chorus Pro.

Dematerialization Platform (Plateforme de Dématérialisation Partenaire - PDP)

Companies will be able to manage their electronic invoices in France through PDPs (Partner Dematerialization Platforms).

These platforms will act as accredited third parties by the DGFiP for invoice validation, their submission to the hub that the French government has implemented to centralize invoice distribution in the country (we refer to the PPF or Public Invoicing Platform), as well as for delivering them to the recipient when they also use the services of another PDP.

Partners aspiring to become PDPs must be accredited by the French Directorate General of Public Finance (DGFiP). PDPs that successfully complete this process will have demonstrated that the service they provide complies with the requirements regarding information security. This process also confirms the PDP's ability to interoperate with other accredited partners.

The selection of one PDP over another will be conditioned by aspects such as their experience, the reliability of their solutions, service availability, or ability to keep their platform updated.

The added value they can offer in key areas such as system integration, processing of large invoice volumes, or deployment of complementary solutions to streamline the invoice lifecycle management will be crucial in choosing one PDP over another.

Functions of Invoice Dematerialization Platforms

A Partner Dematerialization Platform (PDP) is a technological provider that allows companies to manage their electronic invoicing in France without the needing to go through the country's public invoice portal (PPF).

After passing a certification process by the DGFiP called "immatriculation," PDPs demonstrate their ability to guarantee security and quality throughout the process of exchanging electronic invoices according to the standards required by the French state.

The PDP acts as an intermediary between the issuer and the recipient, ensuring the authenticity, integrity, and confidentiality of the documents.

Among the functions of the PDPs are:

1. Receipt and verification of invoices: The PDP receives invoices in electronic format and verifies their authenticity and legal validity. This includes verifying the electronic signature (for signed invoices) and compliance with the technical, fiscal, and regulatory requirements defined in current regulations.
2. Transformation and validation of invoices: The PDP transforms invoices into the required electronic format to comply with electronic data interchange (EDI) standards and fiscal and regulatory requirements. Additionally, it validates the integrity and consistency of the data in the invoice.
3. Archiving and preservation of invoices: The PDP archives electronic invoices and preserves them for the time required by tax and accounting legislation. This guarantees the integrity and authenticity of the documents and allows access in case of an audit or legal dispute.
4. Transmission of invoices: After verifying the recipient of the invoice, the PDP assumes its transmission to ensure it is delivered to the client correctly through the corresponding channel. In the case of invoices destined for clients using the services of another PDP, these can also be sent in an EDI structured format with more commercial and logistical information than can be transmitted through minimum base formats (Factur-X, UBL, CII).

Requirements to be a PDP (Partner Dematerialization Platform)

• Technical capabilities for processing electronic invoices: PDPs must be able to apply all processes required by the French electronic invoice system. This involves technically validating received data schemas, invoice signatures, issuing advanced electronic signatures, capabilities to preserve them with full guarantees for at least 10 years, etc.
• Flexibility in using formats among PDPs beyond the minimum base: PDP providers must be able to support a wide variety of electronic invoicing formats, beyond the minimum formats established by French law. This allows invoice issuers and recipients to exchange basic logistic and commercial information essential for their business, which cannot be exchanged in the formats of the so-called "minimum base."
• Extraction and transmission of data provided by the PPF in one of the specified formats: The PDP provider must allow the extraction and transmission of electronic invoicing data in one of the formats specified by the Public Invoicing Platform (PPF).
• Strong authentication of the invoicing platform: PDP providers must ensure that their electronic invoicing solutions are protected with strong authentication, such as two-factor authentication or electronic certificates, to ensure that only authorized users have access to the platform and information.

Benefits of using a PDP

Companies that choose to send and receive their electronic invoices through a Partner Dematerialization Platform will have greater capabilities and, presumably, value-added services depending on the electronic invoicing service provider.

Here are some of the benefits that PDPs are expected to offer to taxpayers who choose to use them:

• Security: Providers seeking accreditation as PDPs must demonstrate that they have significant security measures in place, hold ISO27001 accreditation, and have proprietary data centers.
• Periodic audits: PDPs will undergo periodic audits by independent entities to ensure that their operating conditions as platforms remain valid over time.
• Interconnection: PDPs will be interconnected to facilitate immediate invoice exchange between themselves and with the PPF.
• Multiple formats: While invoices sent directly to the PPF only accept one of the 3 minimum base fiscal formats, through a PDP, it is possible to use other formats such as EDIFACT, thus allowing the maintenance of current invoice flows between clients and suppliers.

In the specific case of the advantages offered by a PDP like EDICOM, in addition to the general ones listed above, it is worth noting:

• Technical capacity: EDICOM is an EDI and Electronic Invoicing provider with extensive experience and proprietary developments. Our capabilities simplify the processing of large volumes of information, integration with any management system, and the deployment of specific communication systems such as AS4, to offer the highest levels of security and traceability in integration with the PPF.
• Qualified eIDAS Signature Services: We are qualified providers of trust services for providing qualified signature services as established by the eIDAS regulation. We apply electronic signatures to the invoices we issue and automatically validate the signature of received invoices to offer maximum guarantees to our clients and users.
• Long-term eIDAS storage: We offer an Electronic Archiving System accredited by the eIDAS regulation to preserve issued and received invoices alongside the acknowledgments that make up their lifecycle.
• High availability: Our SLA guarantees a service availability of 99.9%.
• Human-attended user support service: A user support center with specialized technicians who handle incidents and queries, and 24x7 support for critical processes.

EDICOM Partner Dematerialization Platform

EDICOM, one of the leading international benchmarks in electronic invoicing solutions,is a candidate to become one of the first PDPs in France.

We hold significant international accreditations in information security, we are one of the largest EDI solution providers in the market, and we have extensive experience in electronic data interchange and international electronic invoicing since 1995.

Our data integration, invoice validation, electronic signature services, as well as our solutions for designing invoice approval workflows or long-term archiving, probably make us the PDP candidate with the most advanced platform in the market.

Electronic Invoicing Pilot Project

The system must adapt to the needs of the French business community and offer guarantees of robustness and security. Therefore, the deployment of electronic invoicing will be preceded by a pilot phase between 2024 and 2025. This pilot phase will allow testing the system's operation under real conditions and correcting any anomalies detected on the platform. Additionally, it will facilitate the French administration to establish a continuous improvement process with the participation of all stakeholders: the public invoicing portal (PPF), the associated dematerialization platforms, user companies, and software publishers.

DGFiP and AIFE, during the Communauté des Relais event, have confirmed that the start of the pilot project is scheduled for the end of 2024. Here, a technical preparation phase will begin, allowing PDPs to test the Annuaire (operation and update). It will be a small initial pilot ("Petit Pilote"), but with a sufficiently representative sample, in which PDP candidates will participate.

In 2025, the "Grand Pilote" pilot phase will begin. In this phase, production services will be opened to all companies participating in the pilot phase.

EDICOM has submitted its candidacy for the pilot project, inviting some of its main clients in France to join. In the end, a total of 12 companies, with diverse characteristics and from different sectors such as retail, logistics, and automotive, will join EDICOM's team. These companies, both national and international, will collaborate in testing classic flows and others more specific, such as corrective invoices, self-billing, and advances, addressing all formats accepted in the French electronic invoicing model. After submitting all the documentation to the French administration, EDICOM's candidacy has been evaluated as "Excellent" by the AIFE and DGFiP teams, positioning us as favorites to lead the execution of the project once dates and other details are established.

Electronic Invoicing Exchange Flow

In the Y scheme, companies generate electronic invoices and associated tax documents for transactions and send them to Dematerialization Platforms for validation. Dematerialization Platforms perform the relevant checks required by the DGFiP. After verifying electronic invoices, Dematerialization Platforms send the electronic invoice to recipients and, in turn, report the necessary tax information to the DGFiP through the Public Platform (Chorus Pro).

In case one of the parties does not have a Dematerialization Platform for reception or sending, they must manually report or consult electronic invoices through the government platform.

Thus, the Y scheme provides several exchange flows depending on whether companies have Dematerialization Platforms or not:

1. Circuit A: Invoice exchange between two partners using the PPF.
2. Circuits B1 and B2: Invoice exchange between a partner using a PDP and another using the PPF. When the invoice issuer has a PDP, it will normally generate its invoice. It will be the PDP that, based on the data issued by its management system, identifies the recipient, thus identifying that the channel to send the invoice should be the Public Invoicing Platform. The PDP must transform the invoice from its client into one of the three structured formats of the "minimum base" defined by the DGFiP to generate the minimum set of invoice data (UBL, CII, or Factur-X).
3. Circuit C: Exchange between two actors using Partner Dematerialization Platforms (PDP). In this flow, large companies usually have greater flexibility regarding electronic invoice exchange, thanks to the fact that Partner Dematerialization Platforms (PDPs) can continue to use both structured formats previously agreed upon between companies (such as EDIFACT or XML) and those defined by the DGFiP in the "minimum base" (such as UBL, CII, or Factur-X).

Additionally, the DGFiP has created the Annuaire, a centralized registry with company identification data to facilitate electronic invoice exchange between private companies and the government.

Annuaire - Centralized Directory of Companies

To determine whether the buyer uses the public invoicing portal (circuits A or B) or an associated dematerialization platform (circuits B or C), the “Y Scheme” requires the creation of a directory (ANNUAIRE) to identify the platform chosen by each invoice recipient.

The Annuaire is a centralized registry of companies managed by the L'Agence pour l'Informatique Financière de l'Etat (AIFE) containing company identification data, collecting at a minimum the French tax identity number called SIREN.

Companies will be identified in this directory through unique identifiers, with the aim of facilitating electronic invoice exchange between companies. This directory will allow interoperability between all stakeholders, specifying the platform used in the context of electronic invoicing, as well as the necessary information for routing and addressing invoices. Thus, it ensures more efficient and transparent communication in the electronic invoicing process between companies.

The Annuaire contains several categories of information:

• Identification of invoice-receiving companies, including details of the organizational structure for invoice management within each company (SIREN, SIRET, routing code).
• Identification and interoperability between dematerialization platforms for the receipt of electronic invoices and their validation period.
• Complementary data related to B2G exchange and correct routing of B2B invoices. All companies using electronic invoicing in France are required to register in the Annuaire. By registering, companies ensure that their electronic invoices are sent correctly and processed efficiently, helping to reduce errors and delays in the invoicing process, and to comply with tax and legal obligations regarding electronic invoicing in France.

Invoice Lifecycle Management

The electronic invoice exchange flow in France requires companies, in addition to issuing invoices, to generate notifications based on the transaction's status, covering the entire lifecycle of the electronic documents to be transmitted. This aims to provide complete traceability of the process to quickly detect any potential issues during the electronic invoice's lifecycle. This system is inherited from the current B2G electronic invoicing process, where administrative units regularly provide information on the processing status of an invoice.

The objectives pursued by the DGFiP with the transmission of invoice lifecycle statuses are:

• Providing a shared view of invoice processing for all stakeholders (issuer, recipient, administration),
• Determining a list and format for exchanging invoice processing statuses to ensure interoperability among actors (companies, PDPs, and PDFs).
• Detailing the process of invoice rejections and cancellations.
• Facilitating prefilling of the VAT declaration.

To achieve this, the French tax authority has defined a series of mandatory and recommended states to transmit during the invoicing flow. The mandatory states of the nominal lifecycle of electronic invoices are:

• Déposée (Deposited in your platform)
• Rejetée (Rejected by the platform)
• Refusée (Rejected by users)
• Encaissée (Payment received by the provider)

e-Reporting

In addition to electronic invoices, companies are also required to transmit a series of electronic tax reports, depending on the type of commercial transaction conducted. Currently, it has been determined that the following must be reported:

• Payment-related data.
• B2C transaction data.
• B2B International transaction data, depending on the type of data to be declared, the declaration system will vary.

You can find all the information about e-Reporting here.

Evolution of B2B Electronic Invoicing in France

• 1990: The same legal validity is granted to electronic invoices as to paper invoices through Article 27 of Law No. 90-1169.
• 2010: The European Union publishes Directive 2010/45/EU regulating the use of electronic invoicing in the private sector of member states.
• 2012: Transposition of the European Directive into Law No. 90-1169 De Finances Rectificatives.
• 2019: Finance Law No. 2019-1479 for 2020 announces its intention to make electronic invoicing between companies mandatory.
• 2020: A pilot project on electronic invoicing is conducted with 50 companies. 2020: The French tax authority Direction Générale des Finances Publiques (DGFiP) publishes a report with the general guidelines of the B2B electronic invoicing system.
• 2021: Ordinance No. 2021-1190 defines the legal framework associated with the mandatory use of electronic invoicing between private companies.
• 2022: Implementing Decision (EU) 2021/0388, adopted on January 25, 2022, validates derogations from European Directive 2006/112/EC. Thus, it is possible to mandate the format of invoices be electronic, and the recipient's acceptance principle no longer applies to electronic invoicing use.

Towards a B2B2G Electronic Invoicing Model

Electronic invoicing has been present in France since 1990. The culture of dematerializing documents is deeply rooted in French companies, as evidenced by their early adaptation to European Union directives in this matter, being among the first European countries to adapt public administrations to the use and management of electronic invoices.

Since 2020, both suppliers and public administrations must exchange electronic invoices through the Chorus Pro state platform.

As a result of the successful experience in implementing B2G electronic invoicing, the government has sought to extend its mandatory use to private companies. However, unlike the Italian model, France has decided to differentiate the taxation system for B2B invoices, delegating invoice validation to PDPs, which act as trusted third parties.

Global Electronic Invoicing Platform

EDICOM - Global electronic invoicing technology provider

EDICOM's global electronic invoicing platform facilitates international organizations' compliance with electronic invoicing in France, as well as the tax reporting required by the DGFiP.

From a centralized environment, it allows the management of all processes related to the sending and receiving of electronic invoices, as well as other fiscal documents, such as VAT reports, transport documents, or declarations that may be required by tax authorities in countries where a company operates.

EDICOM's global electronic invoicing platform acts as a bridge between the organization, French tax authorities, and key partners such as clients, suppliers, or logistics operators.

It offers a centralized and comprehensive solution for electronic invoicing and VAT compliance that will allow you to dematerialize not only your invoices and e-Reporting declaration in France but also anywhere in the world.

eIDAS Partner Dematerialization Platform

EDICOM is a qualified trust services provider in accordance with the European eIDAS regulation. This is a recognition that offers significant added value to the market. Once EDICOM is accredited as a Partner Dematerialization Platform, it will almost certainly become France's first eIDAS PDP.

The eIDAS regulation harmonizes mechanisms to be used by companies providing specific services for electronic signature and data encryption in the European Union.

EDICOM has various solutions accredited by the eIDAS regulation that can be key for the issuance and reception of electronic invoices:

• Advanced electronic signature services for ensuring the integrity and authenticity of documents as defined in current regulations in Europe for electronic invoicing. Through this service, EDICOM can sign invoices issued by its clients using recognized certificates and secure signature creation devices.
• Issuance of recognized certificates: Whenever necessary, EDICOM can issue recognized certificates on behalf of the issuer of electronic invoices.
• Electronic Archiving System: Audited long-term storage service in accordance with the eIDAS regulation, to preserve issued and received invoices with full integrity guarantees over time.