Gwenaëlle Bernier – Partner & Avocate Associée G56, Tax Technology & Transformation at EY

As France’s ambitious e-invoicing mandate approaches, Gwenaëlle Bernier – speaker at the Tax Compliance Summit Sovos Always On: Paris (19 Nov.) – shares expert insights on how digital transformation is reshaping tax compliance and operational performance. This interview dives into the real-world challenges and opportunities facing finance and tax leaders, revealing why the intersection of technology, regulation, and data is the hottest topic in French business today.

EY supports many companies as they prepare for France’s e-invoicing mandate — a reform that brings deep regulatory and technological change. In your view, what are the main challenges facing finance and tax departments, and how can they balance compliance with operational performance?

The first challenge is organizational: companies need a truly cross-functional framework that continuously involves the finance and accounting department, the tax department, and IT. Today these three pillars exist but often operate in silos, whereas the reform requires a unified view of accounting, tax, and IT issues, with dedicated time and clear governance. Implementation cannot be entirely “outsourced” to a service provider — some decisions and trade-offs must remain within the company, as they relate directly to its data and processes.

In practice, we first help companies establish this governance framework: clear executive sponsorship, shared accountability, and regular coordination points among teams. In large groups and mid-caps, this is crucial — the scale, diversity of flows, and ERP history make fragmented approaches ineffective. For small businesses, on the other hand, the challenge is simpler and the reform can fit into a broader simplification process supported by accountants or certified platforms.

Finally, companies must build new skills: tax teams need to understand data, while IT must understand tax logic. Anticipating business impacts — data quality, timing, upstream controls, reconciliations — has become essential. Successful projects are those where companies stop opposing “IT project,” “accounting project,” and “tax project,” and instead treat the reform as a single transformation, driven by a mixed, long-term team aligned around common goals.

Through your work, have you observed a shift in the digital maturity of French companies regarding taxation? What best practices distinguish those who are succeeding?

It’s important to remember that the e-invoicing reform is, first and foremost, a tax reform — it is written into the French General Tax Code under the VAT chapter. It is therefore part of a broader framework of compliance and tax control, which is often overlooked, though it is key to understanding why data quality is so central to its implementation.

The real shift today is that every tax department is becoming digital. It’s no longer just a few tech-curious tax professionals — it’s a broad transformation. Most tax departments are acquiring new skills, and tax professionals themselves are learning to understand systems, data flows, and formats, and to translate regulatory requirements into technical language. This allows them to apply the rules more intelligently and in closer alignment with business needs.

The best practice is to embrace this evolution toward a “tech-enabled” tax professional. Digital tools allow tax teams to collaborate with the rest of the company through a shared language: data. And this data — long used mainly for financial performance or marketing — has now become a core tool of tax compliance. That’s what makes this reform unique: though rooted in taxation, it impacts the entire company. It forces organizations to question the very nature of their ERP data — whether it’s structured, reliable, and truly usable.

The gradual shift toward prefilled VAT returns marks a new stage in digital tax administration. Are companies ready for this reversal — where the administration sends rather than receives declarations? How can they ensure data consistency and reliability in this new model?

The move to prefilled VAT returns will not affect all companies in the same way. For small and medium-sized enterprises, it’s primarily an administrative simplification. They will benefit from support through their accountants or simple tools, sometimes mobile applications offered by certified platforms. For them, prefilled returns will reduce administrative work without significantly changing their organization.

For large companies and mid-caps, however, the impact will be far more structural. Until now, VAT returns have been prepared mainly by accounting teams, with tax departments stepping in only later — during interactions with the tax authorities or audits. Prefilled returns will change that division of labor: tax teams will now need to monitor data continuously, as it will be transmitted to the authorities daily and may prompt immediate follow-up questions.

We are entering an era of reciprocal transparency: companies will reveal their VAT treatment of each transaction in real time, while the administration will send back a synthesized view in the form of a prefilled return. This will inevitably require companies to rethink their internal organization — particularly the split between accounting and tax functions — and to strengthen coordination with IT. It will also demand new skills and heightened vigilance on data quality. The goal will no longer be to produce an accurate return at month-end, but to ensure the reliability of information transmitted day by day. That means better mastering ERP configurations, which in France have often been defined without real tax input. The pace, granularity, and nature of the work will change: companies will need to anticipate, validate upstream, and reconcile accounting and tax data more precisely.

Artificial intelligence is increasingly used in compliance and tax management processes. How is this trend taking shape within the French tax administration?

The French tax administration is already equipped with artificial intelligence tools, the most well-known being Galaxie. This data-mining and analytics system, whose early versions date back to 2017, was formally established by decree a few years ago. It now forms the core of the administration’s intelligent data-processing capabilities.

As the reform rolls out and companies begin transmitting their e-invoices and e-reporting data, the administration will have not only the necessary technical infrastructure but also the software capabilities to analyze this information on a massive scale. By 2027, once all businesses are connected, the tax authority will have an almost complete view of France’s economic activity — what each company buys, sells, and trades domestically and abroad.

With Galaxie and this immense volume of data, the State will be able to conduct highly detailed economic and fiscal analyses. It will also transform the way audits are carried out: by the time a tax inspection begins, auditors will already have a detailed profile of the company, its operations, and any anomalies or unusual patterns compared to its sector. This is no longer theoretical — the public administration is ready to use these tools, and their effects will become tangible as the reform is fully implemented.

Do you believe AI is already transforming the role of finance and tax departments? Are they becoming, in a sense, key players in the company’s data strategy?

Today, finance and tax departments are still poorly equipped when it comes to AI. We’re at an early, experimental stage. Most companies are only beginning to explore the subject — often through general-purpose tools like office suite copilots — but very rarely with solutions designed specifically for tax or finance functions. True AI tools for compliance, anomaly detection, or tax data analytics are still being built.

There’s also a simple economic reason for this: finance and tax are not the company’s core business. Investment naturally flows to operational functions — those that produce and sell — while support functions come later, which explains the current gap.

However, the e-invoicing reform will accelerate this transition. Once companies are connected to certified platforms and able to exchange structured invoices, the next question will inevitably be: how can we use this data intelligently? That’s where AI will come in — to automate controls, enhance reliability, and anticipate discrepancies. Some platforms already offer advanced data-analysis features powered by AI, but adoption remains limited. Over the next few years, we’ll likely see rapid growth in these applications as tax departments realize the value of the data they now possess.

You stand at the intersection of tax and technology. How can we ensure that the growing use of AI in taxation remains ethical, transparent, and trustworthy?

AI is already legally regulated in the French tax sphere. The main framework stems from Article 154 of the 2020 Finance Law. When this law was adopted in December 2019, the Constitutional Council defined the conditions under which the administration could use AI tools, setting out eight criteria to ensure ethical, transparent, and compliant usage — particularly regarding personal data protection. These principles were further clarified by the French Data Protection Authority (CNIL) in its September 2019 report, which remains the reference for AI oversight today.

We therefore already have a clear legal framework: the State has set the guardrails. But risks still exist. With the generalization of e-invoicing, the tax administration will gain access to a vast amount of transactional data between companies. Over time, it could end up knowing an enterprise’s ecosystem better than the company itself — its suppliers, clients, and business relationships.

The challenge, therefore, extends beyond personal data protection to include trade secrecy. This is crucial: authorities must prevent even unintentional disclosure of sensitive business information that could weaken competition or expose strategic details. As long as our economic model is based on fair competition, protecting trade secrets must remain a fundamental safeguard.

France has adopted an ambitious, comprehensive model for its e-invoicing reform. How do you explain this leadership, and what does it reveal about France’s approach to digital taxation?

France made a decisive political choice in the summer of 2019: to make e-invoicing a cornerstone of economic modernization and efficiency. This commitment took shape in Article 153 of the 2020 Finance Law, which integrated e-invoicing and e-reporting into the General Tax Code. The decision reflects a longstanding conviction. Studies conducted at the European level as early as 2007 had already highlighted the potential benefits of such reforms in terms of simplification, productivity, and transparency. But France chose an ambitious path — to move forward on a fixed timeline, making the reform mandatory for all actors to accelerate digital transition.

Another reason for France’s leadership is the scope of its model. While most European countries separated the steps — first mandating structured e-invoicing, then, later, real-time reporting — France decided to do both at once. That makes the project more complex but also more complete.

At the same time, the 2020 Finance Law introduced a separate provision authorizing data mining, which led to the creation of the Galaxie system. In other words, France simultaneously launched digitalized exchanges, large-scale data collection, and AI-based analysis capabilities. This strategic decision explains why France now appears to be leading in both digital taxation and economic data governance.

As a member of the Global Exchange Network Association (GENA) and a former member of the European Commission’s VAT Expert Group, how do you see France’s position in the discussions around the VAT in the Digital Age (ViDA) project? Could it serve as a reference for other Member States?

France’s influence within the ViDA project will depend largely on how its representatives engage in European discussions. Within the Fiscalis group — which brings together finance ministry representatives from all Member States and the European Commission — much will hinge on France’s ability to defend its approach and share its experience.

In practice, France is already implementing, more than three years ahead of schedule, one of ViDA’s core pillars: the Digital Reporting Requirements. Starting in September 2026, France will effectively apply the same principles set to take effect across the EU in 2030. As a result, when ViDA comes into force, little will actually change for French businesses. Having already gone through this transition, they will likely serve as pilots and references for their European counterparts.

To make this advantage meaningful, France will need to promote both its model and its methodology at the EU level. The country has done extensive work on complex use cases — such as expense notes, multi-vendor invoices, and subcontracting — and on technical standards through AFNOR commissions. These efforts produced a pragmatic, collaborative approach that should be championed in Brussels. If each Member State designs its own rules, the goal of ViDA — harmonization — will be lost. The more aligned the standards, the smoother cross-border exchanges will become, improving both efficiency and competitiveness for European companies.

Beyond the current reform, what innovations do you foresee in digital taxation? Does the convergence of technology, compliance, and artificial intelligence signal a new model of tax governance?

We are witnessing a genuine paradigm shift in how the State conducts tax audits — and, consequently, in how companies behave as taxpayers. Until now, France has operated under a retrospective model: companies submitted highly aggregated VAT returns, and audits often took place two or three years later, with inspectors reviewing past decisions and requiring lengthy explanations.

With the combination of e-invoicing, e-reporting, and AI tools like Galaxie, we are entering an era of near real-time tax oversight. The administration will have an immediate view of economic activity and be able to target audits more precisely. This could be a positive evolution if it helps focus efforts on genuine non-compliance while easing the burden on companies acting in good faith.

However, this increased transparency also calls for a change in mindset. Instead of relying solely on ex-post enforcement, the goal could be to establish an ongoing, cooperative dialogue between companies and the tax administration — one in which businesses explain their choices and challenges as they arise. Tax law is rarely black-and-white; it often involves interpretation, especially when business innovation outpaces legislation. The challenge will be to build a relationship of trust, where the State supports companies in applying the rules rather than sanctioning them years later. In essence, this could mean moving from a “rear-view” audit model to a smarter, more collaborative approach that fosters both compliance and economic vitality.

Ahead of the Tax Compliance Summit Sovos Always On: Paris on 19th November, we asked Cyrille Sautereau, Chair of the AFNOR “Electronic Invoice” Commission and President of the National Forum for Electronic Invoicing and Public eProcurement (FNFE-MPE), to discuss the evolving landscape of e-invoicing reform in France, the challenges of interoperability, and the country’s role in shaping European standards.

The National Forum for Electronic Invoicing and Public eProcurement (FNFE-MPE) plays a key role in coordinating discussions around the reform. Could you remind us of the Forum’s mission and how it serves as a bridge between the administration and businesses?

The National Forum for Electronic Invoicing was created in 2012 following the establishment of the European Multi-Stakeholder Forum on Electronic Invoicing (EMSFEI), which led several Member States, including France and Germany, to create their own mirror forums. From the outset, its mission has been to support the development of e-invoicing in France, across both public and private sectors, in alignment with EU initiatives. We became an association in 2016 and now have more than 280 members divided into three colleges: users, service providers, and independent experts and consultants.

Our role is both normative and educational. Normative, because we actively contribute to the development of European and national e-invoicing standards, in close collaboration with the AFNOR “Electronic Invoice” Commission, which I also chair; and educational, because we provide best practices and help the ecosystem understand the regulations, enabling companies to transition smoothly to e-invoicing.

Finally, we fully play our role as a bridge between public authorities and the market. The FNFE is regularly consulted by the tax administration and lawmakers, particularly on regulatory developments related to the reform. We bring field expertise — our knowledge of invoicing practices, tools, and the operational constraints businesses face. This ongoing dialogue helps fine-tune regulations and ensures a harmonized, effective implementation of the reform.

The FNFE-MPE brings together public institutions, businesses, software providers, and technical experts. How do you manage to unite these actors, whose interests sometimes differ, around common standards?

The FNFE-MPE brings together a wide range of stakeholders: businesses, vendors, service providers, accountants, professional federations, and even representatives of the public administration. Our mission is to facilitate dialogue among these groups, which don’t always share the same priorities. The key is transparency and co-construction: everyone can take part in our working groups and contribute to developing the standards.

We hold several plenary sessions each year, along with about ten thematic working groups covering topics such as e-invoicing reform, interoperability, standards and norms, communication, best practices, invoicing and payment, B2G invoicing, and factoring. These forums allow members to share feedback, identify practical challenges, and bring them to standardization bodies.

This collaborative approach has fostered a genuine common language between public and private actors. That’s the strength of the FNFE — its ability to unite the entire ecosystem around a shared vision, ensuring that both technical and regulatory choices remain realistic, effective, and business-oriented.

One of the major challenges of the reform lies in ensuring interoperability between private platforms and public systems. In your view, what are the main hurdles to overcome to ensure a smooth and coherent ecosystem?

Interoperability is indeed one of the most sensitive aspects of the reform. Contrary to what people might think, the main challenge doesn’t lie in connecting private platforms to the Public Invoicing Portal — that interface is precisely defined by the DGFiP’s specifications — but rather in ensuring smooth communication among private players themselves.

The first challenge concerns certified platforms (formerly PDPs), which must be able to exchange data without multiplying bilateral integrations. That’s why we supported the rollout of the Peppol network in France — a model where one connection makes you interoperable with all other network participants. The second pillar is a shared addressing system based on the SIREN number and managed within a public directory. This ensures that every business is reachable through a stable e-invoicing address — one that remains unchanged when switching platforms.

Finally, there’s the “last mile”: connecting companies’ internal systems (so-called “compatible solutions”) to their certified platforms. Given the variety of software tools on the market, proprietary integrations must be avoided. That’s the goal of the AFNOR initiative to design a standardized API — a universal connector that ensures seamless transitions between platforms. Portability is essential for an open, sustainable ecosystem.

The French e-invoicing mandate — the progressive obligation for all companies to issue and receive invoices through certified platforms starting in 2026 — is part of a broader European movement driven by the ViDA (VAT in the Digital Age) initiative. How does France position itself in this EU-wide transformation?

The French reform is closely aligned with the European ViDA project, which aims to harmonize e-invoicing and reporting practices across the EU. ViDA calls on Member States to establish systems for e-reporting and e-invoicing based on structured data and standardized formats — exactly what France has already implemented.

Our national model, based on the exchange of structured electronic invoices between French taxpayers and the automatic transmission of data to the tax administration, already mirrors ViDA’s intended architecture. The key difference is that France chose from the outset to combine mandatory e-invoicing with e-reporting to the tax authorities — whereas other countries limited their first phase to B2B e-invoicing, postponing e-reporting to a later stage. We also introduced two unique features: invoice status tracking — ensuring lifecycle traceability and giving suppliers the visibility and value they’re entitled to — and B2C e-reporting, which isn’t covered by the European scope. In short, France won’t need to adapt its system to ViDA; it already embodies it.

Some believe that France could become a reference model in Europe, provided it successfully deploys the reform. Do you share that view? What lessons could other Member States draw from the French approach?

France can indeed become a European benchmark, provided the operational rollout succeeds. What sets us apart is the decision to tackle the issue holistically, integrating technical, regulatory, and business aspects from the beginning. While other countries proceeded step by step — first e-invoicing, then reporting — we decided to merge both dimensions right away.

Requiring VAT data to be transmitted to the tax administration from each invoice inherently assumes that, within each invoice, the seller is responsible for VAT collection and the buyer for deduction. This creates additional complexity in many cases where intermediaries — such as aggregators handling invoice consolidation or grouped payments — play a role without being the actual taxpayer.

Our approach builds on significant collaborative work within the AFNOR “Electronic Invoice” Commission, which I also chair. Over six months, more than 250 experts from all sectors took part in over sixty meetings. This work revealed the real complexity of use cases, often underestimated — for example, scenarios where several service providers appear on a single invoice for one buyer, such as in the water, leasing, insurance, or travel sectors. These configurations turned out to be far more common than expected. The AFNOR work also helped align French practices with the European semantic standard EN 16931 — ViDA’s foundation — while identifying its limitations and addressing them through data extensions or management rule updates.

Finally, this process confirmed the need for flexibility — allowing human-readable formats, like hybrid Factur-X invoices, which include operationally useful data that may not fit within the semantic standard or technical capabilities of some small businesses.

This ability to identify specific cases and address them within a shared normative framework is, in my view, France’s main strength. It helps anticipate complex situations, deliver standardized solutions (“the same problems, the same answers”), and maintain coherence between regulatory requirements and business realities. Many Member States will likely draw inspiration from this integrated approach when implementing ViDA.

Beyond compliance, the reform will generate an unprecedented volume of standardized economic data. Do you think this infrastructure could ultimately become a driver of competitiveness and innovation for French companies?

Beyond compliance, the reform will fundamentally change how companies manage their operations. By generalizing e-invoicing, we’re introducing structured, reliable, and continuously available data — replacing the paper and PDF-based exchanges that still dominate today. This is transformative: data becomes instantly usable by management systems, without re-entry or manual processing.

In practical terms, this will allow all companies — including SMEs — to reach levels of automation and visibility previously reserved for large groups. Cash-flow reporting or monthly closings will no longer take days of reconciliation: invoices will be integrated in real time, and discrepancies will appear immediately. This responsiveness will enhance business leaders’ ability to manage performance, detect weak signals, and anticipate payment delays — in short, to shift toward predictive management.

In the long run, value-added services could emerge from aggregated, anonymized data analysis. For example, a platform could offer buyers average market price benchmarks based on peer transactions, helping them better position themselves competitively. These uses will need to be regulated to preserve confidentiality, but they open promising perspectives. Competitiveness will thus depend not only on compliance, but on data quality and intelligent exploitation.

You’ll be speaking at Sovos’ Always-On event on November 19, which will bring together public authorities, businesses, and solution providers around e-invoicing and tax compliance. What do you expect from such a gathering at this pivotal stage of the reform?

We regularly take part in events like Always-On because they play an essential role in collective education around the reform. The more opportunities for dialogue, the better. For the FNFE-MPE, it’s a concrete way to fulfill our mission of supporting businesses. These meetings help clarify what the reform truly entails, demystify its implementation, and provide a neutral perspective that complements that of service providers.

That’s important, because many companies still have a fragmented understanding of the reform: some overestimate its complexity, while others haven’t yet grasped its full impact. In this context, direct exchanges among public authorities, experts, vendors, and users are key to building a shared culture and reliable reference points. Such events help reinforce a crucial message: the success of e-invoicing depends on adopting shared standards, ensuring consistency of practices, and rejecting unnecessary complexity.

For too long, everyone built their own processes, portals, and formats — often with limited success. One of the reform’s main goals, and one of the benefits of events like Always-On, is to move beyond this “each to their own” mindset and build a truly interoperable ecosystem.

Among the many topics that will be discussed during the event, artificial intelligence stands out as particularly important. AI is now increasingly present in both compliance and tax controls. How can we ensure that this technological evolution strengthens — rather than undermines — the relationship of trust between taxpayers and authorities?

The importance of AI will grow as data volumes increase. AI can first help companies better understand what the administration “sees” about them by comparing their internal data with prefilled information. This “mirror visibility” can help identify and explain discrepancies even before an audit is initiated.

That said, we must remain clear-eyed about technology’s limits. AI is an analytical support tool, not an arbiter of truth. Its effectiveness will always depend on the algorithms behind it and the quality of the data it processes. Used rigorously and transparently, AI can strengthen trust between companies and tax authorities by making processes more objective and efficient. Conversely, if poorly managed, it risks creating new areas of opacity or misunderstanding.

The challenge in the years ahead will be to strike the right balance: leveraging AI’s power to make compliance more reliable and streamlined while preserving human interpretation and dialogue. Only under these conditions can technology truly serve trust, rather than weaken it.

2025 will be a pivotal year for tax compliance, with governments accelerating e-invoicing mandates, SAF-T requirements and VAT reforms. In this Sovos webinar, Réka Hall, Senior VAT Consultant, will break down the latest updates — from Bulgaria’s SAF-T schema to new mandates across Europe, the Middle East and beyond. Gain clear, actionable guidance to stay compliant, avoid costly errors and future-proof your processes.

On 6th August, following multiple consultations throughout 2024 and 2025, the Polish government passed new legislation and updated schemas for its National e-Invoicing System (KSeF). The timeline and criteria for mandatory compliance have been clearly defined under the updated legislation of KSeF 2.0, meaning organisations may have as little as 6 months to prepare.

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SAP plans to discontinue support for ECC6 by 2025 and that deadline will loom closer and closer as the months pass by.

It is quite clear from market data that many companies will not be able to migrate to S/4 prior to the 2025 deadline – even 2025 will prove tight on time for many, and in some cases, companies will find this deadline near-impossible to make.

Furthermore, many SAP users are yet to automate procurement and customer interactions: a significantly large proportion of orders and invoices are still exchanged on paper, often using ample scanning and OCR software in accounts payable.

Tax digitization is a trend that continues to rise in importance, with tax authorities across the globe introducing e-invoicing and continuous transaction controls (CTCs) to close the VAT gap. Tax compliance requires processes to be updated to comply with these digital tax changes.

Legacy reporting processes, organizational structures and technologies that continue to directly interact with your ERP systems need to evolve. The transformation of indirect tax is becoming a reality: manual, decentralised or shared service centre-aided indirect tax reporting will become a peripheral activity while your organisation negotiates the transformation to ‘always-on’ compliance.

If these challenges sound familiar, our e-book is equipped to help you overcome them. Our expert team have distilled their knowledge into this easy-to-digest guide on a complex subject that is underpinned by an increasingly urgent deadline.

How Sovos can help

At Sovos our goal is to allow our SAP customers to switch to a single vendor they can entrust their data to. This seamless migration will simplify operations and ensure compliance with each country’s different periodic or continuous controls at any time.

In doing so, you decouple business and tax functionality so you can focus on the former to power your digital and finance transformation – important considerations in an increasingly digital world where widespread digitisation is the expected status quo rather than a purely innovative force.

Sovos provides certainty with a future-proof strategy for tackling compliance obligations across all markets as VAT regulations evolve toward continuous e-reporting and other continuous transaction controls requiring increasingly granular data.

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With the pilot phase of France’s e-invoicing reform fast approaching, we’re prepared to support businesses every step of the way. As a global provider of tax compliance solutions and a trusted technology partner, we’re ready to help companies navigate the upcoming transition with confidence.

Preparing for a Milestone Year

The French B2B e-invoicing reform is set to begin its pilot phase in February 2026, and we’re fully prepared to support companies during this critical stage.

With less than a year to go before the phased implementation of the mandate, we’re anticipating the needs of both French and international businesses operating in France. Our solution is complete, interoperable, and aligned with the latest specifications published by the French tax authority (DGFiP) and the AFNOR Commission.

A Pilot Phase Starting in February 2026

According to Article 91 of the 2024 Finance Law, the obligation to receive electronic invoices will apply to all VAT-registered businesses from 1 September 2026. The issuance of e-invoices and e-reporting data will be introduced progressively between 2026 and 2027.

To help companies prepare, the French tax authority has announced a pilot phase starting in February 2026. Participation will be voluntary and will involve testing all end-to-end flows, formats, and business scenarios set out in the reform. Companies and their Partner Dematerialisation Platforms (PDPs) will play a central role in ensuring everything is operational before the full mandate kicks in.

We’re Operational and Ready to Cover 100% of the Use Cases

We’re committed and ready to support our clients and partners in this next crucial step. Our solution enables participation in the pilot while covering all 36 use cases identified by the DGFiP, including:

Our platform is fully compliant with the latest technical specifications issued by the DGFiP, and we plan to support our first voluntary clients from the very beginning of the pilot in early 2026.

As of August 2024, we’re officially registered as a Partner Dematerialisation Platform (PDP no. 0004). Thanks to our deep regulatory expertise, strong local presence, and robust global infrastructure, we’re uniquely positioned to support clients not only during the pilot, but all the way through full implementation.

Guiding You Through the Transition with Confidence

This combination of technology, expertise, and trusted partnership makes Sovos a strategic ally in the transition to e-invoicing. We’re here to guide businesses of all sizes with confidence, ensuring full compliance with the evolving requirements in France, across Europe, and around the world.

Singapore is on the brink of a significant transformation in its tax reporting landscape. The Inland Revenue Authority of Singapore (IRAS) has announced a phased adoption of InvoiceNow, the national e-invoicing framework based on the PEPPOL network, set to commence voluntarily for GST-registered businesses in May 2025.

Germany – the largest economy in Europe, and the fourth largest globally – is moving towards mandatory e-invoicing. As a key exporter of industrial goods, automobiles, machinery and chemicals, many European countries depend on German supply chains. This demonstrates the importance of understanding your compliance requirements, and choosing the right solution provider is critical.

Greece has been in the process of implementing mandatory B2G e-invoicing over the past few years, with a B2B e-invoicing mandate expected to follow.

Following reports that Greece had requested a derogation to introduce mandatory B2B e-invoicing in 2024, the European Commission has published a proposal for a Council Implementing Decision to grant this authorisation.

This proposal confirms the Commission’s unanimous support for Greece’s intention to introduce a country-wide B2B e-invoicing mandate. It will be submitted to the European Council as a formal step before becoming an official decision.

Taxpayers and transactions in scope

In July 2024, Greece requested authorisation from the European Commission to introduce mandatory B2B e-invoicing.

According to the Commission’s proposed decision, the obligation will cover transactions between taxable persons established in Greece (B2B transactions). As a result, taxpayers who are VAT-registered in Greece but not established in the country will be excluded from the mandatory scope.

E-invoicing and existing tax obligations in Greece

According to the Greek government’s request, mandatory e-invoicing will strengthen the existing myDATA e-accounting system which has been in place since 2018. The system requires taxpayers to transmit transactional and accounting data to the tax administration in real-time or periodically, updating a set of online ledgers maintained on the government portal.

myDATA will continue to exist, but the Greek government foresees its improvement once e-invoicing becomes mandatory. E-invoice data will directly feed into myDATA, providing real-time information and ensuring higher data quality.

Additionally, such data will be used to pre-fill VAT returns – a measure already in place in Greece – but which should be facilitated and improved with the advent of mandatory e-invoicing.

E-invoice format

Greece should allow the issuance of e-invoices compliant with the European standard (EN 16931) in order to foster interoperability. The Commission does not mention any other specific formats.

While taxpayers will be able to exchange e-invoices in line with the EU standard, they will only report to myDATA the information necessary for tax purposes – rather than the full invoice.

Taxpayers are expected to be able to issue e-invoices via an Electronic Invoicing Service Provider, upgraded management programs (commercial/accounting, ERP) or the “timologio” free government application. However, more details will be revealed after the derogation is granted and the Greek government publishes its mandatory e-invoicing framework.

ViDA implications

The European Commission’s explanations also conclude that the e-invoicing system Greece aims to implement is aligned with the VAT in the Digital Age (ViDA) proposal, which was recently approved by ECOFIN (Economic and Financial Affairs Council configuration of the Council of the European Union) and is expected to be officially adopted during 2025.

Seeking EU approval has become a common approach in the EU, as the current VAT Directive allows taxpayers to exchange invoices in any format, paper or electronic. It also mandates that the use of an electronic invoice is subject to the buyer’s acceptance.

Countries such as Italy, Poland and Romania, and others have already obtained authorisation to implement mandatory e-invoicing systems. However, this will change once ViDA is enforced, as EU Member States will no longer need to request such authorisation if they wish to introduce mandatory e-invoicing systems for domestic transactions.

What’s next for Greece B2B e-invoicing?

The Commission proposes to grant Greece the authorisation from 1 July 2025 until 30 June 2026, as derogations are temporary and must be renewed over time. The Decision will apply until its final date or until ViDA requires Member States to apply any national provisions transposing the Directive once ViDA is officially approved.

This is a proposed decision by the European Commission to allow Greece to introduce mandatory e-invoicing measures. It must follow to by the Council before it becomes official and can produce legal effects. This is a procedural step and, based on the experience of other countries, is not expected to pose an obstacle to Greece’s receipt of the derogation.

This webinar will provide five key trends in Indirect Tax Digitization and provide valuable insights into how businesses can craft a long-term strategy to tackle these challenges. In the session, he will also detail how to maintain compliance in an increasingly complex regulatory environment.

The Middle East and Africa are facing a rapidly evolving landscape for E-Invoicing and VAT reporting. We follow this development and continue the successful first two editions of the E-Invoicing Exchange Summit and proudly announce the 3rd edition to be held in Dubai from February 10 to 12, 2025.

On the pre-conference day, Monday, February 10, you will have the opportunity to start the E-Invoicing Exchange Summit by attending the workshop “GENA Academy Essentials: Everything You Always Wanted to Know About E-Invoicing, but Were Afraid to Ask”. Furthermore, a great networking opportunity awaits you with the Icebreaker Reception in the early evening. The conference itself will take place on Tuesday and Wednesday, February 11 and 12, including the Networking Dinner on Tuesday evening.

Insightful presentations and interactive roundtable sessions on

In this webinar, we will revisit the foundational principles behind this mandate, covering its evolution up to the latest developments, so you have all you need to keep your business compliant.

Peppol E-invoicing explained: What it is and how it works

The global adoption of electronic invoicing is accelerating. Governments worldwide are pushing to adopt e-invoicing to digitally transform their national systems and, often, to close the VAT gap.

While many countries have introduced their own e-invoicing mandate to digitise fiscal controls, the requirements and systems implemented by each country often fail to align with one another. This makes it complex for multinational organisations to meet their electronic invoicing obligations.

To enhance interoperability, countries across Asia and Europe are embracing Peppol, a framework established to simplify interoperability for e-invoicing and other procurement documents. But what exactly is it? This blog has all the information you need.

What is Peppol?

Peppol began in 2008 as an effort to standardise public procurement in governments across the European Union. It is a framework made up of specifications that enable cross-border electronic procurement and a method of sending invoices to customers. Peppol integrates business processes by standardising the way information is structured and exchanged.

In recent years, Peppol has expanded its remit to include APAC. Singapore was the first Asian country to establish a Peppol authority. As well as being established in Europe, it also includes Australia, Japan, Malaysia and New Zealand.

What does it stand for?

Peppol is short for Pan-European Public Procurement On-Line, as it was initially a European initiative.

While receiving e-invoices has been mandated by law for all public sector entities in the EU since April 2020, being Peppol one of the options chosen by many countries to implement such obligation, and Peppol’s name derives from its European service, the standard is now being adopted outside of the union. Malaysia and Singapore are two non-European countries that have embraced Peppol in recent years, for example.

How does Peppol work?

While we have made it clear that Peppol is an EU-wide standard for exchanging electronic documents like e-invoices, that doesn’t explain how it actually works.

The European Union laid out standards for electronic invoices. These documents must meet the required specifications and, in most cases, be sent through its network. Most public sector entities in the EU are required to be able to receive such invoices, creating a uniform and universal method of invoicing B2G transactions across the region.

It’s worth noting that while the public sector is obligated to receive these invoices in some cases, they can also be sent to companies for B2B transactions. Peppol enables the efficient electronic exchange of e-invoices, purchase orders, and other business documents, whether you are a private business or a public organization.

Peppol invoices are sent to the recipient through a Peppol Access Point. This connects to the Peppol network and comes from an approved service provider, allowing businesses to electronically exchange documents with other organisations with an Access Point.

Peppol connects organisations through a network of Peppol-accredited Service Providers, removing barriers to electronic trading created by closed ‘three-corner’ networks.

What is a Peppol authority?

To ensure that the aforementioned Access Points follow the rules and regulations set out, it has official authorities. They are also in place to “set national requirements for the design and content of Peppol documents,” according to PEPPOL itself.

There are currently 17 Peppol Authorities in place, all of which are national bodies – bar one. OpenPeppol is the only authority which is not attached to a country as it serves as the official Peppol Authority in jurisdictions where no authority exists.

Why use it?

Its widespread implementation makes it an appealing option for many. Considering the variety of approaches to electronic invoicing across countries, the appeal to Peppol is the standardisation and interoperability of global electronic document exchange.

Having a collection of common standards for transferring electronic documents for every country an organisation conducts business in makes the process simpler – thus reducing the possibility of errors.

Standardising the way information is structured and exchanged makes it more secure. As well as invoices and purchase orders, Peppol has the potential to automate the exchange of any kind of business document, between any organisation, anywhere in the world.

Which countries use Peppol?

Peppol Corner Models

Corner models are frameworks for digital transactions. There are multiple approaches, though Peppol’s base framework is the 4-corner model

3-Corner model for e-invoicing

Now considered an old model, the 3-corner model for e-invoicing required senders and receivers to connect through a single service provider. Buyers would often decide on which service provider they use, meaning suppliers had to use multiple systems across their customers.

4-Corner model for e-invoicing

An upgrade to the previous approach, the 4-corner e-invoicing model connects four entities. The four corners are:

The introduction of Access Points secures transactions by ensuring that communication of documents is sent and received correctly, using document validation, Know Your Customer (KYC) procedures and more.

5-Corner model for CTC

As seen in Singapore, Peppol also has a 5-corner model. This approach adds another corner to the traditional model, being the Tax Authority/Government central platform. This framework is also known as Peppol CTC.

The 5-corner model allows tax authorities to receive almost real-time access to invoices, ensuring that tax information is transferred correctly.

At the discretion of the applicable government, the central platform can either validate documents before they are sent to the recipient or allow certified service providers to validate them instead, serving as a repository for the electronic invoices.

Peppol VIDA pilot project

This pilot project established by OpenPeppol demonstrates that the network and e-invoicing specifications can also be used to meet the digital reporting requirements of the EU’s VIDA proposal.

The project is open to EU Tax Authorities/Administrations, Service Providers and end users.

Sovos is participating in this pilot project. We are a respected member, serving as a provider in both Malaysia and Singapore.

Learn more about the adoption of electronic invoicing and its many rules and regulations in our E-invoicing Guide. For help complying with e-invoicing requirements and other tax considerations, consider our Compliance Cloud solution.

Every quarter, our VAT Snapshot webinar brings you the latest global e-invoicing updates to help your business meet the ever-changing demands of new and evolving mandates. In this session we’ll share updates for Estonia, Latvia, Lithuania, Poland, Slovenia, Greece, Malaysia and Saudi Arabia.

The Government of the Republic of Slovenia has released a draft proposal to implement mandatory e-invoicing and e-reporting for B2B and B2C transactions. This implementation would mark a significant shift in the country’s e-invoicing landscape.

Should the proposal be approved, taxpayers will be subject to a two-fold obligation: they must issue and exchange B2B invoices electronically and report B2B and B2C transactional data to the tax authority. Although clearance will not be required in the e-invoice issuance process, transactional data must be reported to the tax authority in near real-time, which shows that Slovenia is aligning with the global trend of governments implementing Continuous Transaction Controls (CTC).

Taxpayers under scope are all business entities registered in Slovenia’s Business Register (PRS), including companies, self-employed entities and associations. To register in the PRS, business entities must have a registered office or address in the territory of the Republic of Slovenia.

This new system also introduces a decentralised reporting and exchange model facilitated by registered service providers, called e-route providers. These are similar to the network exchange requirements in France and those planned for Spain.

The proposed mandatory e-invoicing and CTC e-reporting will be introduced from 1 June 2026.

E-invoicing requirements

The e-invoicing mandate would require taxpayers to issue, send and receive e-invoices and other e-documents for B2B domestic transactions.

Under the Slovenian proposal, e-invoices refer to an invoice or similar accounting document that records business transactions, regardless of what they are called. This includes credit notes, debit notes, advance invoices, payment requests, etc.

In cases where the issuer and recipient use e-invoice different standards, if using e-route providers, the recipient’s provider must convert the e-invoice to the syntax accepted by the recipient.

Regarding B2C transactions, consumers will have the option to receive either e-invoices or paper invoices. This must be agreed upon by the parties. If an e-invoice is issued, suppliers will be obliged to provide a visualised content version (e.g., PDF).

CTC e-reporting requirements

The proposal states that taxpayers must electronically report B2B and B2C transactional data, including cross-border transactions, to the Financial Administration of the Republic of Slovenia (FURS) within eight days of invoice issuance or receipt. Reporting must be done exclusively in the e-SLOG standard.

The reporting requirement extends to B2C and cross-border transactions, regardless of whether an invoice was issued electronically. This ensures that transactions such as these, for which e-invoicing is not mandatory, are reported to the FURS allowing it a comprehensive collection of taxpayers’ transactional data.

The selected method for e-invoice exchange will impact the e-reporting of transactional data. If the parties use e-route providers, both the issuer’s and recipient’s providers must send the e-invoice to FURS. For direct exchanges, both parties must separately report their transactions to FURS.

E-route provider requirements

The draft establishes obligations and certain technical requirements applicable to e-route providers. According to the Slovenian government, the requirements to become an e-route provider are comparable to those in France but without the need for certification

However, the public authorities will maintain a list of registered e-route service providers who must fulfil certain requirements, some of which are already listed in the draft law. The proposal does not state explicit local registration/establishment rules for e-route providers. The government will publish further regulations detailing the application process and other applicable requirements.

Next steps

The government must take certain crucial steps before enforcing the mandate. The Parliament must officially approve the draft law before the requirements are confirmed.

Moreover, publication of the technical specifications and further regulations are awaited, including details of the data reporting methods to the tax authority. Slovenia will need to apply for a derogation from the VAT Directive with the EU Commission to enforce mandatory B2B e-invoicing before the adoption of ViDA (VAT in the Digital Age).

For businesses operating in Slovenia, this will mean impactful changes to their outbound and inbound processes by 1 June 2026. This includes the acquisition of software or update of their systems to issue, send and receive e-invoices, adapting to the allowed e-invoicing formats and connecting to the FURS or availing the services of e-route providers to electronically report their data.

Have questions about how these changes could affect your operations? Ask our team of experts.

The Inland Revenue Authority of Singapore (IRAS) has announced the implementation of a phased adoption of InvoiceNow, the national e-invoicing framework based on the Peppol network, for GST registered businesses starting voluntarily in May 2025. The mandate will cover B2B transactions only, as the government is expected to make B2G mandatory in the coming years.

What is InvoiceNow?

InvoiceNow is a nationwide e-invoicing initiative by The Infocomm Media Development Authority (IMDA) for SMEs and large enterprises to streamline their invoicing for a faster and more sustainable way to transact, nationwide and worldwide.

What’s the timeline?

Singapore’s nationwide e-invoicing network was first announced in 2019 and has recently been referred to as InvoiceNow. The mandate will require GST registered businesses to use InvoiceNow solutions to transmit invoice data to IRAS. The transmission of invoice data to IRAS will be done through Peppol Access Point (AP) service providers, extending the traditional four corner e-delivery model to a fifth corner model.

Even though an implementation timeline for all businesses has not been shared yet, further updates are expected in the future.

Sovos is here to help

Saphety Level – Trusted Services, S.A is an IMDA-certified Peppol service provider in Singapore. Our regulatory experts can connect to the InvoiceNow network on your behalf.

In less than six months, Poland is going to introduce its long-awaited CTC clearance e-invoicing mandate – a tax reform that will impact a large amount of businesses.

It has been possible to issue and receive e-invoices voluntarily via Krajowy System E-Faktur (KSeF) since January 2022, but from 1 July 2024 it will become mandatory for suppliers and buyers that are in scope of mandatory e-invoicing to do this via KSeF.

A detailed understanding of the new regime, plus timely and proper preparation, is critical for compliance. Whilst there is a six-month grace period on financial penalties, non-compliance can negatively impact your business in many other, often unexpected, ways.

In this 45-minute deep-dive webinar, Marta Sowińska from our Regulatory Analysis and Design team will cover:

Join us on 8 February at 2pm GMT | 3pm CET for a thorough review of the Polish KSeF e-invoicing mandate and the opportunity to submit your questions.

As tax authorities continue to digitize processes in their mission to reduce fraud and close their VAT gaps, they are introducing requirements that provide greater visibility into a company’s financial operations in the form of Continuous Transaction Controls (CTC).

It would be a mistake to think that being prepared to meet obligations in one of the countries where you operate can simply be replicated in another – CTCs are far from a ‘one-size-fits-all’ solution.

Join us on 24 January 2024 in our latest quarterly VAT Snapshot webinar series where regulatory experts Dilara Inal and Marta Sowinska will examine how tax authorities in Poland, Romania, Israel, Greece and Spain – all simultaneously implementing CTC regimes – are doing so with different sets of requirements.

Don’t miss this opportunity to learn more about these unique regimes and what they mean for your business.

EY supports many companies as they prepare for France’s e-invoicing mandate — a reform that brings deep regulatory and technological change. In your view, what are the main challenges facing finance and tax departments, and how can they balance compliance with operational performance?

Through your work, have you observed a shift in the digital maturity of French companies regarding taxation? What best practices distinguish those who are succeeding?

The gradual shift toward prefilled VAT returns marks a new stage in digital tax administration. Are companies ready for this reversal — where the administration sends rather than receives declarations? How can they ensure data consistency and reliability in this new model?

Artificial intelligence is increasingly used in compliance and tax management processes. How is this trend taking shape within the French tax administration?

Do you believe AI is already transforming the role of finance and tax departments? Are they becoming, in a sense, key players in the company’s data strategy?

You stand at the intersection of tax and technology. How can we ensure that the growing use of AI in taxation remains ethical, transparent, and trustworthy?

France has adopted an ambitious, comprehensive model for its e-invoicing reform. How do you explain this leadership, and what does it reveal about France’s approach to digital taxation?