February 4th, 2021

From 2017 to 2020, electronic invoicing in France became fully mandatory for all business-to-government (B2G) exchanges. Now, France is continuing on its path to becoming 100% digital for intercompany transactions by gradually implementing e-invoicing mandates for business-to-business (B2B) exchanges. In fact, many measures have already been taken by the French government for this objective, which is now becoming a priority in their policy.

B2B E-Invoicing Obligation Schedule 

The Finance Bill 2020 was published in December 2019, proposing in article 153 that the goal is to start implementing B2B electronic invoicing mandates in France by 2024. Additionally, it determined the need for a government report for the implementation of such a project.

Almost one year later, in October 2020, the General Directorate of Public Finance (DGFiP) published its report “VAT in the Digital Age,” which it details the current situation in terms of electronic invoicing in France, as well as in other countries like Italy, Spain, and Portugal. The report sets out the objectives for the introduction of mandatory e-invoicing and recommends a solution based on the clearance model that integrates electronic invoicing and the transmission of tax data.

Finally, in December 2020, the French Finance Bill 2021 confirmed that there will certainly be a B2B electronic invoicing obligation in France. The implementation will follow the guidelines set out in the October 2020 report.

Objectives for the French Government

The four main objectives of the B2B e-invoicing obligation in France are as follows:

1. Strengthen the competitiveness of companies by reducing the cost of sending and processing paper invoices, as well as by securing commercial relations between companies

2. Fighting tax fraud and reducing the VAT gap

3. Enable a better understanding of business activity in order to promote better government action on economic policy

4. Facilitate, in the long run, VAT declarations by pre-filling

B2B E-Invoicing Obligation Calendar

The B2B electronic invoicing obligation in France will be enforced in accordance with two modalities:

1. All companies will be required to receive electronic invoices from 2023

2. According to company size, there will be an obligation to adopt the progressive issues (like the one that is set up for B2G operations)

  • 2024: Large Enterprises
  • 2025: Mid-Size Companies
  • 2026: Small Companies

The Preferred Clearance Model

The French government has studied two clearance models for B2B e-invoicing:

1. “V” Model: Similar to the B2G e-invoicing model, the V model mandates the transit of invoices through the public platform Chorus Pro, which is the only platform authorized to transmit invoices to the customer via, if necessary, the private platform of which it is affiliated

2. “Y” Model: In this model, certain private operators, previously certified as trusted third parties, are authorized to transmit invoices directly to the recipient companies (or, where applicable, to the private platform of which the customer is affiliated), without going through the public Chorus Pro platform

The implementation of the “Y” model is preferred insofar as it meets the expectations of companies and operators who, for the most part, have expressed their preference for this option.

In fact, all the companies that are already using third-party service providers see this as a way of limiting adaptation costs. On the other hand, those companies that do not already have electronic invoicing solutions believe that going directly through the public platform would limit cost of entry for this reform.

Moreover, the “Y” model appears to be more resilient; in the event of any individual platform failure, only part of the invoicing flow would be affected, with the possibility of redirecting exchanges to the remaining, fully functioning platforms.

Which Format(s) Will Be Required for B2B E-Invoicing in France?

In order to ensure maximum interoperability between the different platforms, it is envisaged to impose an electronic format that will be mandatory for exchanging invoices, as well as return flows. The UBL 2.1 format is given as an example in the DGFiP report and could potentially be chosen as the format, although it would need to be enriched to include all the necessary information.

However, taking SMEs and very small businesses into account, e-invoicing platforms (public and private) will also have to offer the following:

1. The ability to convert a native PDF document to an electronic format
2. The possibility to enter invoices manually (via a web portal)

In the long run, the French government wants to put an action plan into place to ensure that all businesses send either electronic invoices or mixed format invoices (Factor-X).

E-Reporting

E-reporting consists of the obligation for companies to transmit invoice data in electronic format to the tax authorities. It involves sending the tax authorities data that is similar to that which is requested in the case of electronic invoicing—but without personal data in the case of B2C.

And yes, we did say B2C, because the obligation of e-reporting will be imposed for transactions between professionals and private individuals (business-to-consumer, or B2C), transactions with foreign operators, and invoice payment status.

This e-reporting obligation will make it possible to carry out controls to detect discrepancies between declared VAT and recovered VAT, and thus fight tax evasion.

While nothing is set in stone just yet, the DGFiP report explains that the schedule for e-reporting should be the same as that for e-invoicing.

How Can You Prepare for the B2B E-Invoicing Obligation?

The simplest way to prepare is to scope out your options and choose a service provider that is able to help you fulfill your new obligations. That means choosing a service provider that is certified for electronic invoicing in France, is able to connect to all necessary platforms, can forward all invoices in compliance with the law, provides managed e-archiving services, and more. TIE Kinetix is often chosen to set up electronic invoicing projects in France, as well as Europe, and will therefore be able to manage your B2B electronic invoicing obligations as of 2023.

About Meidy Chazeau