Earlier this year we reported about the legal status and trends regarding scanning of inbound paper invoices in Europe. One of the topics raised in that post was that France was in the midst of legal reform in this area: for some time the French framework entirely prohibited the concept of conversion of form for inbound purchase invoices, limiting the possibility to scan and archive an electronic copy only to outbound invoices. This, however, is no longer the case after recent changes to Livre des Procédures Fiscale. This law, together with a subsequent Ministerial Arrêté published in late March, sets out conditions and processes that must be followed for digitalization of invoices originally created in paper form. If the process fulfills the requirements set out in the Arrêté, the paper original can be discarded and the taxpayer may rely on the digitalized copy as the original invoice for tax purposes.
So what does the process look like? The scanning must, of course, be performed under stringent and well documented internal processes and controls. The graphical digitalization of the paper original must truly be an exact representation of the original (colors included). But the process can be outsourced to a third party, and there are no accreditation/certification requirements. The resulting file must be PDF or PDF/A-3 and digitally signed with one of the alternatives listed in the new law (RGS* -a local French security standard- minimum and Qualified Certificates issued by a provider included in the French TSL are two of the four alternatives). Every file must also be individually time-stamped.
All in all, the regulated process is quite balanced in our opinion, without laying down too detailed requirements but still managing to maintain high assurances of integrity and consistency with the original.
