B2B e-invoicing mandate in France
B2B stands for business-to-business, so a B2B invoice is one that is exchanged between two legal entities.
B2G stands for business-to-government. In 2017, France had started introducing mandatory B2G e-invoicing for suppliers to the public sector. As of January 2020, all suppliers to public entities have been required to issue invoices electronically via the official and obligatory platform Chorus Pro. The B2B e-invoicing mandate we discuss in this checklist is separate to the existing mandate for B2G invoices, we just mention it for clarification purposes.
B2C stands for business-to-consumers, so a B2C invoice is one that is sent from a company to a natural person (as opposed to another business).
Domestic invoices means both the sender and receiver of an invoice are VAT-registered in the same country. In the context of the e-invoicing mandate in France, it means both companies are subject to VAT in France.
“Electronic invoice” according to the French mandate
Only structured formats will be considered valid e-invoices for fiscal purposes under the French B2B mandate. This means that by latest 2026, paper and simple PDF invoices will no longer be valid in France for domestic B2B e-invoicing. The DGFIP (Direction générale des Finances publiques; translates as General Directorate of Public Finance) is planning to regulate the use of a number of formats, as long as they are compatible with the European Norm. The initially permitted three formats are UBL 2.1, UN/CEFACT CII and Factur-X. Other formats, such as Peppol BIS, may be allowed in the future.
E-invoicing will not be mandatory for B2C and cross-border invoices. However, to get a complete overview of all invoice transactions, the government will require companies to send e-reporting files. E-reporting requires a specific set of data-points in a specific form and will have to be sent on a recurring basis. Companies will have to be able to produce e-reporting and send them to the government platform, either directly or through a partner platform (PDP) which can produce these files and deliver them to the government platform.
These transactions are affected by e-reporting:
- The transmission of data concerning B2B transactions for non-French customers.
- The transmission of data concerning B2C transactions for taxable transactions in France.
- The transmission of data concerning purchases from foreign operators (excluding imports).
- The payment status of invoices for services (for services declared on e-invoices as e-reporting).
FNFE, or Forum National Français Officiel de la Facturation Électronique, translates to the National French Official Forum for Electronic Invoicing. It serves as a recognized platform in France dedicated to discussions, insights, and collaboration on electronic invoicing practices. The FNFE plays a crucial role in promoting industry standards and best practices of electronic invoicing processes.
FNFE-MPE, or Forum National Français Officiel de la Facturation Électronique et des Marchés Publics Électroniques, is an association with the mission of fostering extensive consultation among French public and private entities in the deployment of electronic invoicing and electronic public procurement in France. It serves as a driving force in defining regulations, industry standards, public policies, and incentive measures contributing to this objective.
The French Tax Authority (Direction générale des Finances publiques - DGFIP)
The DGFiP (Direction Générale des Finances Publiques, or the Treasury Department of the French state) is one of the main branches of the French public administration, falling under the aegis of the Ministry of Finance. The DGFiP is responsible for managing the finances of France.
Invoice Lifecycle Management
In addition to invoice data, companies will have to transmit the invoice processing statuses to the government platform - directly or via a partner platform. The invoice lifecycle will guarantee more transparency on the status of operations to the government. Some statuses will be mandatory (invoice submitted, refused, rejected, received) and other will be optional (disputed, approved, etc.).
PDP stands for Plateformes de Dématérialisation Partenaires, which translates to Partner Digitalization/Dematerialization Platform. Vendor registration to become a PDP is now open – no platform can claim to be registered or accredited before completing the registration process. PDPs will need to undergo a compliance audit to demonstrate to the administration their capacity to fulfill the requirements.
PPF stands for Portail public de facturation, which translates as public billing portal. The publicly trusted third party offers free services and concentrates on invoicing and billing data for the tax authorities.
When a company is registered in France, the INSEE (Institut national de la statistique et des enquêtes économiques; translates as French Institute of Statistics and Economic Studies) assigns a unique identifier called SIREN number (Système d'identification du répertoire des entreprises; translates as “Business Directory Identification System”). The SIREN number consists of a 9-digit number that identifies the company according to the order of registration in the Sirene directory. This unique identifier is used by all public bodies and administrative organisms in their relations with the company and it remains the same throughout the lifecycle of the company and cannot be changed. In the context of the e-invoicing mandate, the SIREN number defines the legal unit, i.e. the company/business, to whom the mandate will apply to.