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.
