Regulatory updates - France

On 15 October, the General Directorate of Public Finances (DGFiP) announced that there would be a major change in the upcoming French e-invoicing and e-reporting mandate. According to the announcement from the DGFiP, the role of the public invoicing platform (PPF) is being shifted towards data collection and aggregator, and will no longer have a central role in the distribution of invoices between buyers and suppliers.

In short, France is moving from a hybrid invoicing model with a central platform and decentralized certified service providers (PDPs) towards a pure 5-Corner model only using the PDPs for invoice distribution and data extraction. The PDPs will be responsible for facilitating transmission between buyers and suppliers and handling the e-reporting of the transactions to the PPF.

This means that software providers and businesses who intended to connect directly to PPF to exchange invoices will no longer be able to do so. Instead, they will have to contract the services of a PDP platform.

At this point, there are over 70 registered PDPs, with more coming. The DGFiP has expressed their full confidence that these certified service providers will offer the security and quality to bear the bulk of the functions with the upcoming mandate and help businesses comply.

Although it has yet to be officially confirmed by the administration, Peppol is now expected to be the main framework and infrastructure used to ensure interoperability between the PDPs for the mandate. It is filling the gap for the PDPs on what protocols and communication channels should be used for sending and receiving e-documents between themselves.

The current timeline for the introduction of the French mandate remains the same.

• 1 September 2026 - obligation for all companies to be able to receive e-invoices and for large companies and mid-sized companies to issue e-invoices;
• 1 September 2027 - obligation for small and medium-sized enterprises and microenterprises to issue e-invoices.

There are many more ramifications with this new change in policy and more to come. Stay tuned with Pagero for the latest updates on the French mandate.

On 27 March 2024, a Decree was published in the Official Journal of the French Republic, making alterations to the current legislation regarding the upcoming CTC mandate and the registration process for prospective PDPs.

There will be a transitional regime where the General Directorate of Public Finances (DGFiP) will grant PDPs conditional registration and access to the public platform’s (PPF) test environment. Subsequently, the PDPs must submit technical test reports to demonstrate a compliant solution, or the authorities will revoke the registration.

The start date will be announced on the tax administration’s website and directly to the parties concerned.

Moreover, the decree cements the mandate timetable. The mandate will enter into force on 1 September 2026 for large and intermediate-sized taxpayers and 1 September 2027 for micro-, small- and medium-sized taxpayers.

The French CTC mandate is set to start on 1 September 2026. From its start, all businesses will have to be able to receive e-invoices, while large- and medium-sized businesses will have to start issuing e-invoices and e-report a defined scope of transactions and payment data.

During the meeting, the DGFiP re-affirmed their commitment to upholding the new deadline and offered the following guidance on the timetable:

• Q2 2024: Publication of new technical specifications and new decree that will allow service providers to obtain Partner Dematerialization Platform (PDP) status without having to prove connectivity with the Public Billing Portal (PPF);
• Q3 2024: First PDP certifications are expected to be issued;
• Q4 2024: A restricted pilot on a smaller scale with a limited amount of participants that includes testing of the PPF directory and core functionalities;
• 2025: Pilot on a larger scale with many participants.

Additional topics discussed in the community relay meeting were, amongst others, the re-opening of the pilot application (more information expected in the next meeting in spring), interoperability between PDPs and the training of chartered accountants in the context of the CTC mandate.

Pagero has been included together with other aspirants on the DGFiP’s initial PDP candidate list. The list contains all service providers that have applied to become PDPs ahead of the French CTC mandate.

The list is published for informative purposes and does not guarantee that any service provider on the list will be approved as PDP. No candidate has yet been approved and registered as a PDP. Approval will only be granted after a rigorous examination process of the application.

Follow Pagero and stay up to date with the latest information about the French mandate.

There has been a lot of back and forth regarding the timeline of the French CTC mandate. After many debates and with the rejection of the Senate's proposed amendment to start the mandate on 1 July 2025, the following timeline has now been decided:

Timeline

• 1 September 2026: All taxpayers must be able to receive e-invoices. Mandatory for large and medium-sized companies to issue e-invoices and do e-reporting.
  • This timeline may be postponed by one quarter without Parliament's approval.

• 1 September 2027: Mandatory for small enterprises to issue e-invoices and do e-reporting.
  • This timeline may be postponed by one quarter without Parliament's approval.

As previously reported by Pagero the application to join the pilot phase is to be reopened. Expected start of pilot phase is in 2025.

As it currently stands the timeline for the French CTC mandate is being actively debated and scrutinized in the French parliament, as well as by other stakeholders.

Last month the Direction Générale des Finances Publiques (DGFiP) introduced an amendment to the bill suggesting the starting point of the mandate to be 1 September 2026 (large and medium enterprises) and 1 September 2027 (remaining businesses), this timeline has also been announced on the DGFiP’s website.

The most recent development is that a Senate amendment to the proposed timeline has been introduced that if adopted would set the following implementation timeline:

• 1 July 2025: Mandatory for large enterprises to issue e-invoicesand do e-reporting. All other businesses must be able to receive e-invoices starting from the same date.
  • This timeline may not be postponed without Parliament's approval.
• 1 September 2026: Mandatory for medium enterprises to issue e-invoicesand do e-reporting.
  • This timeline may be postponed by one quarter without Parliament's approval.  
• 1 September 2027: Mandatory e-invoice issuance and e-reporting become applicable to the remaining businesses.
  • This timeline may be postponed by one quarter without Parliament's approval.

The final version of the timeline is expected to become official by the end of December this year with the adoption of the 2024 Finance Bill.

Since the French e-invoicing and e-reporting mandate was postponed back in July this year there has been lots of speculation on what the new timeline will look like. As we reported in a previous update, there had been indications from the DGFiP that the mandate was expected to be postponed until 2026. This indications has now been confirmed with additional details on dates and roll-out.

On the 17 October 2023 an amendment was introduced by the French Authorities to the Finance Bill of 2024. This amendment proposes the introduction of the mandate in 2026 with the following timeline:

Proposed timeline

• 2024: Finalizing the construction of the PPF
• 2025: Pilot phase
• 1 September 2026: Mandatory for large and medium-sized companies to issue e-invoices and do e-reporting. All taxpayers must be able to receive e-invoices.
• 1 September 2027: Mandatory for small enterprises to issue e-invoices and do e-reporting.

The membership of a company to the different size-categories is assessed at the level of each legal entity on 1 January 2025 based on the last financial year. 

The Finance bill of 2024 is expected to be adopted in Q4 of this year.

Additionally, The French Government will have to apply to the European Commission for an extension of the VAT Directive derogation to impose B2B e-invoicing. The current derogation received in 2022 lasts until 31 December 2026.

As previously reported by Pagero, the much-anticipated French e-invoicing and e-reporting mandate was postponed at the end of July. Since then, the biggest follow-up question on everyone’s mind has been “How long is the delay?”.

During an invite-only meeting held for service providers and other business representatives on 14 September 2023, AIFE and DGFiP offered some guidance on the topic.

The main reason stated for the postponement of the mandate is the delays in the construction of the PPF (Portail Public de Facturation), the government’s central e-invoicing platform. Next year will be dedicated to finalizing the construction of the PPF.

The following timeline is subject to change and the definitive version will be published at the end of the year with the 2024 Finance Act:

Preliminary timeline

• 2024: Finalizing the construction of the PPF
• 2025: Pilot phase
• 2026: Roll-out in 2 or 3 phases with full deployment by the end of 2026 or 2027 (similar roll-out as before by size of the taxpayer)

Additionally, AIFE and DGFiP also mentioned the re-opening of applications for the pilot phase and that the BoFiP (Fiscal texts) are in progress but will not be published before the main texts (2024 Finance Act).

Follow Pagero for the latest updates on e-invoicing in France.  

As previously reported by Pagero on 28 July 2023, the commencement of the French electronic invoice mandate was postponed. Amid these delays, the work on the obligation, the platform, the work with stakeholders, and the acknowledgement of PDP applications continues.

On 31 July 2023, the French Ministry of Economy and Finance (Le ministère de l'Économie et des Finances) announced the updated electronic invoicing external specifications document.

The External Specifications file combines all the documents describing the exchange formats with the public invoicing portal as part of the e-invoicing generalization.

This new version 2.3 is available in French and can be accessed here.

The entry into force for France’s long-awaited electronic invoicing mandate has been delayed. The project, which has been a large topic of discussion between stakeholders since 2021, has now been further stalled for the French economy to have more time to adapt to the upcoming changes.

The postponement date will be announced as part of the French 2024 finance law. The intent is to provide 4 million companies the ability to transition into electronic invoicing under France’s proposed requirements seamlessly and with greater efficiency.

Amid these delays, work continues regarding the mandate, the platform, work with stakeholders, and the acknowledgment of PDP applications.

The announcement made by the French Ministry can be found here.