Electronic invoicing, transmission of transaction data and transmission of payment data.

Mainstreaming of electronic invoicing in transactions between parties liable to value added tax and the transmission of transaction data

The draft order that is the subject of this notification supplements the legislative provisions mainstreaming electronic invoicing between parties liable to VAT established in France and the transmission of transaction and payment data to the tax authority (e-reporting), as well as the corresponding draft decree, which is being notified simultaneously.

The draft order that is the subject of this notification amends the provisions codified in Annex IV to the General Tax Code (detailed below; Article 41 septies A to P), which were adopted in 2022. These provisions are part of the initial regulatory framework of method of electronic invoicing between parties liable to VAT and of transmitting the data to the tax authority.
Some of the regulatory amendments implement legislative amendments (as a result of the decommissioning of the public invoicing portal, as announced on 15 October 2024, and due to terminological replacements), while others are not directly related to legislative aspects (see details below).

The legislative provisions require taxable parties to fulfil their obligations to invoice electronically and to transmit transaction and payment data by means of an approved platform. To be an approved platform, operators must register with the French tax authority and meet the conditions laid down in the decree.
Article 41 septies A specifies the content and timing of the compliance audit report that the approved platform must submit to the tax authority within one year following registration and each time it applies to have its registration renewed.
Article 41 septies B specifies down the lists of platforms to be published and made available to businesses.
Article 41 septies C defines the conditions for platform interoperability.
Article 41 septies D and E define the particulars to be included on electronic invoices in a structured format.
Article 41 septies F and G lay down the checks to be carried out by approved platforms on invoices, and define the information to be completed on the status of the invoice in the transmission cycle.
Article 41 septies J to M lay down the conditions for transmitting transaction data.
Article 41 septies N to P lay down the conditions relating to payment data.
This new order introduces amendments (simplifications and new obligations) to the initial regulatory framework of the reform:
- a point on the compliance audit is added relating to the management of formal agreements (Article 41 septies A);
- a point on the audit is added relating to the requirement to connect to Chorus Pro (Article 41 septies A);
- amendments are made to the frequency of the compliance audit to make it clearer and to incorporate production data (Article 41 septies A);
- a point on the audit is added relating to compliance with AFNOR (French Association for Standardisation) standards (Article 41 septies A);
- a new platform surveillance audit is added: content and period (Article 41 septies A);
- compliance with the three standards published on the AFNOR website regarding the exchange of invoices (Article 41 septies C);
- the designation of Peppol as the network referred to in Article 242 nonies I of Annex II to the General Tax Code (Article 41 septies C);
- details on the formats and profiles that platforms must adhere to and manage (Article 41 septies C);
- rules governing conversion and legibility (Article 41 septies C);
- the tolerance for ‘PDF invoices’ is removed insofar as the public invoicing portal no longer allows it (platforms will still be able to offer OCR) (Article 41 septies C);
- ‘fees and charges’ are added to the invoicing data to be sent to the tax authority, and the list of invoicing data specific to T invoices is removed.