France publishes updated specifications for e-invoicing and e-reporting

The French Government has released the latest version (2.1) of the “Dossier de spécifications externes de la facturation électronique”. The updated external technical specifications document was released on July 29, 2022 and the major update relates to vouchers and gift cards.

As a reminder, France will introduce mandatory e-invoicing and e-reporting in a phased approach starting July 1, 2024. All French businesses, regardless of size, will need to be able to receive e-invoices from their suppliers from this date. 

The External Technical Specifications document has several key chapters and sections setting out: 

• Background and objectives of the e-invoicing mandate 
  

• Regulatory and legislative framework 

• Overview of the public invoicing portal  

• Overview of partner dematerialization platforms 

• Formats for each trade flow 

• E-invoicing lifecycle 

• Directory 

• Invoicing/billing use cases 

• Connection protocols  

• Interoperability 

• Data elements  

• Invoice status management  

• Rejection and refusal of e-invoices 

Under the new e-invoicing regime, businesses will no longer send invoices directly to customers and instead these will need to be sent by an e-invoicing platform to the customer’s platform. French businesses issuing e-invoices to customers will be able to select an approved third-party commercial e-invoicing partner platform, known as partner dematerialisation platforms (PDP), or use the public invoicing portal, the “Portail Public de Facturation” (PPF). PDPs need to be authorised and accredited by the French Tax Authority and there is a formal approval and audit process. Where e-invoicing software/providers are not authorised, they are unable to act as PDPs and can only submit data to the PPF (merely acting as a bridge or connector). The French Government has suggested that the PPF will only have basic core functionality and therefore there is an expectation that this option will likely only be used by the very smallest companies in France. Which e-invoicing platform a business uses to receive e-invoices from suppliers is also a commercial choice and decision, and can be the same as the supplier, a different commercial platform or through the PPF.

France’s e-invoicing mandate will have multiple acceptable e-invoice formats and therefore there is some choice and flexibility for French businesses. All PDP partner platforms will offer a minimum number of common formats to guarantee interoperability. The customer will inform its supplier what format it wants to receive e-invoice in. E-invoices can be created in structured or mixed format in one of the three base formats compatible with the European Union’s e-invoicing standard, EN16931, namely:  

• UBL 

• CII 

• Factur-X 

Factur-X is a hybrid document that combines both a human readable PDF with machine readable XML language. Businesses won’t be able to simply scan paper invoices or create and send standard PDFs, and therefore Factur-X will likely be a preferred format amongst businesses as it is closer to today’s business as usual format and process and can be read easily by a person, including in shared service centres or accounts payable functions.

There are initially 24 mandatory items of data that will need to be included in the e-invoice and sent to the PPF platform. The data elements have mandatory taxonomies and formats, as set out in the technical specifications. The mandatory data includes: 

• Unique French business identification number (SIREN number - both supplier and customer) 

• Intra-community VAT number (both supplier, customer and tax representative if applicable) 

• Supplier’s and customer’s country 

• Category of supply (e.g. goods or services) 

• Invoice issue date 

• Unique invoice number 

• Number of rectified invoice in the event of the a corrective invoice being issued 

• Option for tax payment based on debits 

• Total amount exclusive of VAT, by VAT rate 

• VAT amount, by VAT rate 

• Applicable VAT rate 

• Total amount to be paid exclusive of VAT 

• Total Amount of VAT payable 

• In case of exemption - reference to legislation 

• Invoice currency code 

• Date of delivery of the goods or performance date of the service 

• Date of the deposit paid if it is different from the date of issue of the invoice.  

• Mention of self-billing, special scheme, or reverse charge (if applicable) 

Avalara has an e-invoicing solution that can help companies stay compliant in over 60 countries including the upcoming French -e-invoicing mandate starting 2024. Contact an expert at Avalara to discuss how we can assist with the upcoming e-invoicing mandate in France and watch our recent webinar on-demand.