Electronic Invoicing in France
France started its journey to 100% eInvoicing for public sector bodies in 2017. At first, only large corporations sending invoices to public sector bodies were mandated to send invoices electronically via the Chorus Pro Portal (CPP). In 2020, the dictate was expanded so that any supplier invoicing a public sector body or regional authority in France is required to submit invoices electronically. The government’s preference is for invoices to be sent machine-to-machine in a specific XML format using EDI, however, there are two more manual options for smaller businesses and lower volume suppliers.
Wider rollout of eInvoicing using CPP
While the rollout of eInvoicing is progressing well for all invoices to public sector bodies, the requirement for all B2B invoices in France to be sent electronically is at an earlier stage, with compliance for all being mandatory by 2023. Non-EU businesses selling in France need to appoint a fiscal representative alongside completing VAT registration and returns. Fiscal Representatives take responsibility for ensuring that VAT submissions in France are compliant for their non-EU clients.
The change will also affect sales invoices to consumers (B2C) so that by 2023 suppliers will need to send invoices to their appointed e-invoice agent (Plateforme Privée Certifiée), who will forward in on to the tax authorities, who then issue the invoice to the customer. In addition to sales invoices, taxpayers must provide other VAT transaction data, including:
- Payment status of an invoice
- B2C transaction data
- Cross-border transaction data (EU intra-community supplies and exports/imports).
Two manual options on CPP
Smaller businesses can opt to enter invoice data manually on the Chorus Pro Portal (CPP), either by typing the data into a form. This laborious option is said to be for businesses sending up to 1,000 invoices per year to government bodies. The second alternative to EDI is for businesses issuing between 100 and 10,000 invoices per year and involves logging into CPP and importing invoices as PDFs. Each invoice must be a separate, digitally signed PDF and these must be imported one by one.
Two EDI Options in XML format
Invoices sent by EDI must be in one of two XML formats: INVOICE UBL V2 format. allows the generation of invoices in INVOICE UBL V2 format and in UN/CEFACT CII 16B, which includes the option to send invoices in the FACTUR-X format, which is a hybrid format used in Franco-German invoicing and involves a structured data file and a PDF being sent together so that the machine to machine version is supported by a human-readable document.
To comply businesses must choose between in house EDI management, outsourcing their EDI connections to an eInvoicing specialist or hopping onto the CPP via the PEPPOL network. (See diagram) The latter involves having a connection to an official Peppol Access Point, usually through a third party. The PAP intermediary maintains the connection with the PEPPOL network providing a single pipeline for any invoices into Europe, instead of the supplier’s IT team or EDI supplier setting up individual web services or SFTP connections with each receiving party. Any small scale and inefficient solution introduced for the short term runs the risk of becoming unscalable and highly problematic as requirements change and the adoption of eInvoicing reaches critical mass. To avoid the risks of becoming unwittingly non-compliant, especially if eInvoicing standards change again, many businesses are using the EU compliance as a spur to overhaul of their invoicing across their global operations, implementing one system that has the flexibility to accommodate further changes to the eInvoicing standards in any country around the world.
Taxpayers will be required to send invoices to their appointed e-invoice agent (Plateforme Privée Certifiée). They will then forward to the tax authorities who will in turn issue to the customer. In addition to sales invoices, taxpayers must provide other VAT transaction data, including:
- Payment status of an invoice
- B2C transaction data
- Cross-border transaction data (EU intra-community supplies and exports/imports)
Five Key facts about B2G eInvoicing in France
- EU Directive 2014/55/EU was developed into EN 16931-1:2017. This mandated that all invoices to public sector bodies in the EU should be sent electronically. Each member state, while forced to comply, has some margin for variation.
- The legal framework in France is contained in Ordinance No. 2014-697. This sets out the three main ways for submitting invoices to public sector bodies through the Chorus Pro Portal (CPP) – EDI, PDF or manual entry.
- The CPP is overseen by the State Financial IT Agency, AIEFE (Agence pour l’Informatique Financière de l’Etat).
- In November 2020 the finance bill was amended by the French government and a timeline was introduced by which all invoicing in France must be electronic as follows: Large businesses January 1st 2023, Medium-sized businesses by 1st January 2024 and small businesses by 1st January 2025.
- The recent amendments expand the coverage so that all invoices in France to businesses and from businesses to individuals are affected.