The French authorities published new legal documentation that provides details on the overall French Mandate requirements. Some of them, especially with regard to the obligations of the Partner Dematerialization Platform (PDP) operators and e-reporting deadlines, were long-awaited.
- Decree No. 2022-1299 provides requirements and obligations of the Partner Dematerialization Platform (PDP) operators and the Invoicing Public Portal (PPF), the process of obtaining the status of PDP operator, interoperability of platforms, content of the transaction and payment data to be transmitted to the TA.
- The Order of 7 October 2022 regulates formats and the content of e-invoices (new mandatory fields), methods of transmission to the PPF (“flow”, “portal”, “service” modes), frequencies and dates of data transmission. It also provides further details in relation to the compliance audit the PDP operators will have to communicate to validate/renew their initial registration.
The Decree and the Order envisages rules concerning the application process and qualification requirements. Obligations of the PPF are also set forth. The PDP operator candidates shall apply for registration as of Spring 2023 (precise date still to be confirmed), instead of September 2023 as previously set.
Transmission frequencies and deadlines concerning e-reporting obligations (cross border transactions) are also mentioned in the Order. Depending on the VAT regime that the taxpayer is subject to, different timings apply.
Furthermore, until January 2028, taxpayers can submit their invoices in PDF format instead of one of the structured format sand PDPs and the PPF must be able to convert PDF invoices to one of the structured formats (CII, UBL or FACTUR-X) set by the mandate.