New timetable for the French e-invoicing mandate

On December 29, 2023, after months of uncertainty over the schedule for France’s e-invoicing mandate coming into force, Article 91 of the French Finance Act no. 2023-1322 for 2024 set out the long-awaited new timetable.

In this post, we examine the various dates that apply to both companies and Partner Dematerialisation Platforms (PDP) for the registration procedure.

Before the mandate comes into force, you will need to define the size of your company (each legal entity) by assessing it from January 1, 2025, based on the last financial year closed before that date. For example, you would use the financial year ending on September 30, 2024, to evaluate the size of your enterprise in 2025.

The new timeline, like the previous ones, isn’t final. The French tax authority (DGFiP) may delay it again, possibly until December 1, 2026 or 2027, depending on company size. 

This new schedule could also be affected by the outcome of the new request for authorisation provided for in Article 395(1) of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax or by the VAT in the Digital Age (VIDA) initiative. 

The obligation to transmit transaction, payment, and lifecycle data (e-reporting) will adhere to the same timeline as that for e-invoicing as outlined in the table above. 

Another aspect that has been overlooked in the discussions is the timeline that applies to future PDPs. Avalara believes the DGFiP will make the necessary adjustments during the first quarter of 2024. The initial schedule was divided into two stages: 

• Accreditation number: Operators wishing to position themselves as PDPs were required to have the accreditation number by July 1, 2024. We believe this date will be rescheduled to September 1, 2026, provided the DGFiP keeps this obligation aligned with the timeline for the mandate starting. 

• Compliance audit report: Although the DGFiP had granted operators who want to be PDPs one year after the reform comes into force to complete the accreditation process (July 1, 2025 instead of July 1, 2024), we assume this additional time will no longer be granted. Instead, PDPs will have to complete the entire accreditation process (submission of application and compliance audit) by September 1, 2026. 

Despite this new, hypothetical timeline, companies are likely to have their say by imposing stricter commitment dates on their future PDPs, to ensure they are fully aware of the facts before embarking on the selection and contracting processes.

E-invoicing mandates and requirements are evolving all the time. Avalara E-Invoicing and Live Reporting can help you comply with current rules and futureproof your business against changing legislation. Speak with Avalara to find out more.