Extension of the implementation dates of the B2B e-invoicing Mandate.
Update: 9 December 2024
On September 15th, 2024, the French Tax Authorities published a Press Release announcing a profound change in the upcoming French Mandate for electronic e-invoicing & e-reporting.
Indeed, the Public Portal (aka PPF) will no longer provide e-Invoicing Services, making it compulsory for every FR-established and VAT-Registered Taxpayer to send and receive e-Invoices via a 3rd Party Dematerialization Platform (aka PDP) of its choice.
After this initial announcement, the FR TA has communicated additional details, whether on the rationale behind that pivotal decision or on the next milestones until the Mandate enters into force:
- The FR TA very much insisted on that the start dates are confirmed – September 1st, 2026 and September 1st, 2027 are the dates on which companies will need to comply – at the latest.
- The decision to remove the e-Invoicing Services from the PPF, was made after the DGFiP realized that the PDPs offerings will be broad enough (in terms of functionalities and positioning) to cover the needs of all the Taxpayers – whatever their profile.
- With the PPF focused on Data Gathering (CTC & e-Reporting Services) and Central Directory Management, its development is easier, and its delivery is secured.
- Main next Milestones are:
- Mid-November 24’: Release of a note focusing on the Directory Pilot (for PDPs only).
- Mid-December: Release of the next version of the External Specifications (Data Gathering & Directory Services).
- March 2025: Directory Pilot for all PDPs to test interoperability with the PPF (Directory Services).
- Q4 2025: Data Gathering Services are delivered in a UAT Env. so that PDPs can complete end-2-end tests at the end of which – if successful – their Official Registration will be confirmed.
- Jan 2026: Ahead of the September 2026 ‘Go-Live’, a Global Pilot Phase will be organized (precise modalities not available yet) so that Taxpayers can test the whole processes with their PDPs.
Update: 2 January 2024
The Finance Law for 2024 has been officially adopted and published in the Official Gazette on 30 December 2023. With the finalization of the law, the new implementation dates are as follows:
Receipt of e-invoices: Starting from 1 September 2026, ALL taxpayers, regardless of their size, will be required to be capable of receiving e-invoices. This date may be extended to December 1, 2026, at the latest, but only by decree.
Issuing e-invoices:
- For Large Corp. & Mid Caps.: Obligation to issue electronic invoices on September 1, 2026. This date may be extended to December 1, 2026, at the latest, but only by decree.
- For SMEs (other than Large Corp. & Mid Caps): Obligation to issue electronic invoices on September 1, 2027. This date may be extended to December 1, 2027, at the latest, but only by decree.
International B2B, B2C transaction and payment data transmission:
The e-reporting obligation for international B2B (sales and purchases) and B2C transactions and Payment data follows the same timetable as that for issuing electronic invoices (September 1, 2026 or September 1, 2027 depending on the size of the company).
The implementing decree that will formally ratify this new schedule is expected during the first quarter of 2024.
Looking for more information about how to comply with the French Mandate? Contact our expert team.
Update: 19 October 2023
The long-awaited new implementation timeline regarding the e-invoicing and e-reporting within the draft Finance Law for 2024 has been unveiled on 17 October 2023.
According to the draft amending General Tax Code and Law No. 2022-1157, the new dates are as follows:
Implementation phases: The roll out of the mandate will now occur in two phases, as opposed to the previously planned three phases.
Issuing e-invoices:
- The first phase, targeting large and medium-sized companies, is scheduled for 1 September 2026.
- The second phase, which covers small and micro-enterprises, is scheduled for 1 September 2027.
Receipt of e-invoices: Starting from 1 September 2026, all taxpayers will be required to be capable of receiving e-invoices.
E-reporting obligations: The enforcement of e-reporting obligations will follow the same revised dates.
It is important to note that the above-mentioned dates, September 2026 and September 2027, may be subject to readjustment with the possibility of rescheduling to the 1st of December as the latest date, in the respective years.
After the adoption of Finance Law for 2024, a Decree complementing the law is expected to be issued in the first quarter of the upcoming year for full enforcement of aforementioned obligations.
Companies need to take advantage of the additional time through active participation in the pilot phase during which all relevant use cases should be tested so that changes to applications, processes and systems can be taken care of and fine-tuned in good time to ensure compliance.
Looking for more information about how to comply with the French Mandate? Contact our expert team.
Update: 15 September 2023
In a recent meeting of the Communauté des Relais, the tax authority released additional details surrounding the previously communicated postponement of the B2B e-invoicing mandate in France.
This delay is a result of the tax authority listening to feedback from French businesses who have struggled to meet the original timeline. It’s further evidence, as previously iterated by the ICC of just how much time and effort is required for most businesses to compare for the complexities of a new mandate.
While the formal dates are still to be defined, the revised main timeline was presented as part of a roll-out in 3 stages:
2024: The authorities will publish the first list of officially registered service providers (PDPs – Plateformes de Dématérialisation Partenaires) by the spring of 2024. During the course of 2024, the development of the public portal (PPF – Portail Public de Facturation) will be completed.
2025: During this year, a large-scale pilot project, involving companies of all sizes will be conducted. The tax authority views this pilot as an opportunity for taxpayers to fine-tune their e-invoicing and e-reporting processes and systems to comply with what has grown to be, a complex and sophisticated CTC framework.
2026: The roll-out of the obligation for the entire economy will largely take place during 2026. However, at what pace remains to be seen once the Finance Law is adopted by Parliament at the end of 2023.
Businesses impacted by the French mandate, headquartered in France and elsewhere, will now be in a better position to successfully comply with the new reform, assuming they make use of the added time provided by the French authorities. In particular, by proactively using the pilot program to build confidence and knowledge on the critical path to readiness. For the largest taxpayers facing these obligations, it would be prudent to regard these changes as a mere 6-month postponement, with the beginning of the pilot program acting as the de facto starting date. To understand the full impact on their business processes and data flows, companies will need to thoroughly test up to 36 use-cases. The many software vendors helping companies to streamline their purchase-to-pay and order-to-cash processes will certainly be eager to test the compliance of their solutions as early as possible in what has become a completely new ecosystem.
Participation in the extended pilot, with professional support from Sovos, provides a risk-free environment to assess and then conduct the essential finetuning.
Sovos is one of the first 20 candidates for service provider (PDP) accreditation in France, and as such will be ready to sustain our customers as they take the numerous steps needed to fully comply with the new CTC framework, drawing on its rich experience of keeping customers compliant with complicated e-invoicing obligations around the world.
Looking for more information about how to comply with the French Mandate? Contact our expert team.
10 August 2023
The French Directorate General of Public Finances (DGFiP) officially postponed the implementation of the country’s electronic invoicing mandate on 28 July. The postponement is in order to provide necessary time for taxpayers to comply with the mandate.
The latest official word states that the revised timeline for the mandate will be provided within the framework of the Finance Law for 2024. We expect this law to be adopted in late 2023.
In addition, on 31 July the DGFiP published updated ‘External specifications file for electronic invoicing’(version 2.3). Despite deferral of the initial go-live, these updates demonstrate the authorities’ commitment to developing the mandate and set the expectation that preparations by taxpayers, vendors, PDP candidates and professional organizations must continue.
The French Mandate is one of the most complex tax digitization initiatives seen in EMEA to date. It’s essential that companies continue their preparations. Compliance with this mandate requires readying applications, processes and systems to a complex set of requirements. According to the ICC, businesses need at least 12-18 months to prepare for the shift to e-invoicing and e-reporting.
Please note that this information is subject to any further updates or changes from the French authorities and no further details are available at present. We will communicate any additional information once it is made available.
Sovos is experienced in helping our customers navigate digitization regulations around the world, including the French Mandate.
Looking for more information about how to comply with the French Mandate? Contact our expert team.
