E-invoicing in France & Digital Reporting Requirements

What is electronic invoicing in France?

France is implementing new laws that include mandatory e-invoicing and continuous transaction controls (CTC) for all businesses operating within the country. According to Article 289 bis of the General Tax Code, an electronic invoice is one that is issued, transmitted and received in paperless form and should include a minimum core set of data in a structured format, distinguishing it from a “paper” invoice or a standard PDF.

Not only are electronic invoices highly regulated digital documents, they must also comply with specific technology that is provided by the government and by private vendors. In France, that technology program is called Chorus Pro.

Some of the goals of e-invoicing in France are to:

• Streamline and automate financial reporting
• Make payments more punctual and efficient
• Increase the government recoup of VAT revenue

These goals and the plan for electronic invoicing in France stem from the European Unions’ VAT in the Digital Age (ViDA) plan, which wants to see e-invoicing and digital reporting spread across Europe.

In fact, electronic invoicing is rolling out in most countries around the world, including other EU member states. For example, Spain e-invoicing rules and Portugal e-invoicing rules are in the works.

Timeline for the French e-invoicing and CTC mandate

E-invoicing in France will start to roll out to B2B businesses in 2025 as a pilot phase, and the rest will be staged over a few years. The stages of the e-invoicing rollout are based on business turnover, with higher earning companies first. The exact timeline is still pending some revisions and clarifications, but here is the plan for now.

B2B e-invoicing will become mandatory for large and medium businesses operating within France first, starting in 2026. Then the rest of businesses will follow in 2027.

• Sometime in 2025: B2B e-invoicing pilot phase begins!
• September 2026: All France-based taxpayers will be required to have the ability to receive e-invoices. Large and medium-sized businesses will be required to both receive and send e-invoices.
• September 2027: Small and micro businesses based in France will be required to receive and send e-invoices.

How are business sizes defined in France’s e-invoicing law?

• Large companies: Larger than 5.000 employees AND larger than €1.5B revenue or €2B annual balance sheet total.
• Medium companies: Between 5.000 and 250 employees AND below €1.5B revenue or €2B annual balance sheet total AND above €50M revenue or €43M balance sheet total.
• Small companies: Below 250 employees AND below €50M revenue or €43M balance sheet total.
• Micro businesses: Below 10 employees AND below €2M revenue/balance sheet total.

Background: Mandatory B2G e-invoicing in France

In 2017, France began implementing mandatory B2G e-invoicing, selecting Chorus Pro as the official platform for businesses to send e-invoices to the public sector. As of January 2020, all B2G suppliers must issue electronic invoices to any governmental bodies or public organizations.

The e-invoicing rules were drafted in several decrees throughout 2014-2022, and iterated on even more after that. You can check out the latest official law regarding VAT electronic invoicing in France here.

Which transactions require electronic invoices in France?

Eventually, all businesses that are based in France will be required to issue and receive electronic invoices. But which transactions must comply?

The e-invoicing rules apply to all taxable B2B transactions that take place within France. Transactions that are exempt from VAT are also exempt from e-invoicing rules. If you’d like to learn more about which transactions are taxable, check out this guide to France VAT.

Businesses are already required to issue electronic invoices for B2G transactions.

How does French e-invoicing work?

There are a few different actors involved in the French e-invoicing process, and each one has a specific role:

1. The French tax authority, Direction Générale des Finances Publiques or DGFIP, is the governmental body responsible for overseeing the e-invoicing project.
2. Chorus Pro is the government’s chosen technology for
3. Private platforms for electronic invoicing, also referred to as “registered private online platforms” or PDP, which must comply with the technology criteria and be registered with France’s tax authorities.
4. The businesses that send the electronic invoices.
5. The customers and businesses that receive the electronic invoices.

How will I issue and receive my invoices?

You must choose an online platform, or multiple platforms, to serve you in the creating and receiving electronic invoices.

So, business owners can use either Chorus Pro or a registered private online platform (PDP) that is designed to automatically handle electronic invoices on their behalf and report transaction data to the French tax authorities. These systems, the public and the private, are compatible and can “communicate” with each other, so to speak. This compatibility means that you can use a platform that is actually different from your supplier or customer, but the e-invoicing process is not interrupted!

But which one do you choose? Here is a bit more information about the two options, Chorus Pro and the private service providers or PDPs.

What is Chorus Pro?

Chorus Pro is the French centralized portal for public sector e-invoicing administration.

The taxpayer will most likely be able to utilize existing connectivity with Chorus Pro, either directly or via a service provider, to exchange full invoices with trading partners connected to the governmental platform. In this case, both e-invoicing and e-reporting will be fulfilled simultaneously.

What is a PDP?

A registered private online platform is a third-party software that provides e-invoicing and e-reporting services to help you comply with France’s laws. So these online platforms serve several purposes:

• Issue, send and receive the electronic invoice from the supplier to the customer. If you and the other business use different invoice formats, then the platform will convert the other’s invoice into a format that suits you, and vice versa. The technology must ensure the integrity, authenticity, readability and completeness of the data.
• Extract certain invoice data and send it to the tax authorities via Chorus Pro. This relates to digital reporting requirements for VAT (more on that later!), and the extracted data could include the identification of the supplier and customer, transaction amount excluding VAT, amount of VAT due, VAT rate applied, etc.
• Forward other transaction data that isn’t subject to an electronic invoice to the tax authorities.
• Transmit payment data for all transactions.

So, in this scenario, you would contract the services of a PDP that would handle not only issuance, exchange (interoperability) and receipt of e-invoices but also handle the real-time reporting obligation. In this scenario, only the VAT-related subset of the e-invoice will be reported to Chorus Pro.

Aside from the basic steps of the process, there are a number of obligations on both the companies that send and receive invoices and the providers that offer electronic invoicing services.

Rules for complying with French e-invoicing

The law outlines numerous obligations, and we can’t list them all here. But this list contains many of the rules that are important for onlines businesses:

• Businesses and public entities are obliged to issue, send, and receive electronic invoices through private platforms or the public solution called Chorus Pro, offered by DGFIP.
• Private e-invoicing providers will have to ensure free interconnection and interoperability between technology solutions or platforms.
• The sender and recipient need to provide information on the status of invoices via digital reporting.
• Taxpayers must report on e-invoices in real time! More on that below.
• E-invoices must be stored in a secure archive by both the issuer and recipient for 10 years.

Penalties for not complying with electronic invoicing in France

Based on the law published in the French Official Gazette, companies that fail to issue e-invoices or fulfill e-reporting obligations may face financial penalties.

Here’s what noncompliance looks like, when it comes to electronic invoicing in France.

• Failure to issue an invoice in the proper electronic format carries a fine of €15 per invoice, with a maximum cap of €15,000 per calendar year per company.
• Failure to report the file online may result in a fine of €250 per transmission, also capped at €15,000 per calendar year.
• PDPs that don’t provide the required information to the tax authorities may be penalized with fines of €15 per invoice and €750 per transmission, with both penalties capped at €45,000 per calendar year.

So, make sure you are tracking deadlines, using a compliant invoicing software, and following the appropriate accounting practices! If you’re located in France, you should probably be following the accounting rules of the International Financial Reporting Standards (IFRS).

How to create an electronic invoice in France

The France e-invoicing decree lays out several technical specifications that all businesses must adhere to, in order for an e-invoice to function, travel through the system, and be registered as legitimate.

First, electronic invoices in France must be formatted in ways that are compatible with the Chorus Pro portal used by government as well as private providers. Only approved formats will be considered valid e-invoices for fiscal purposes. The DGFIP plans to regulate the use of a number of formats via the PPF and PDPs, as long as they are compatible with the European Norm.

For now, the e-invoices must be generated using one of the following formats:

• UBL (Universal Business Language). An XML format for invoices and credit notes. The law specifies it should be UBL 2.1.
• CEFACT (Cross Industry Invoice). An XML format that contains a maximum data-set for specific use cases. The law specifies it should be UN/CEFACT II.
• Factur-X. A Franco-German standard for hybrid e-invoice (PDF for users and XML data for process automation).

Only these three formats will be allowed initially, but other formats such as Peppol BIS may be permitted in the future.

Note: By 2026, paper and simple PDF invoices will no longer be valid in France.

What are the digital reporting requirements for e-invoices in France?

Digital reporting is an important part of the French e-invoicing requirements. All taxpayers in France will have to report these electronic invoices in real time. Taxable persons must use invoicing software certified by the French tax authority to send invoice data to the Chorus Pro platform.

Report e-invoices in real time

In France the method for e-reporting is known as continuous transaction controls, or CTC. This can be done in one of two ways:

• Option 1: Issue an e-invoice to Chorus Pro and they will do the rest (delivery to buyer and reporting to DGFIP).
• Option 2: Issue an invoice through a PDP, and the PDP will do the rest: distribute the e-invoice to the buyer through the PPF (Portail public de facturation) or the buyer’s PDP, then report it to Chorus Pro.

Report the lifecycle status of e-invoices in France

Buyers must also report the status of electronic invoices that they send or receive. The DGFIP’s goal is to have complete traceability over the document and detect any possible issue during its lifecycle.

The statuses include:

• Déposée (Deposited on your platform)
• Rejetée (Rejected by the platform)
• Refusée (Rejected by the users)
• Encaissée (Collection made by the supplier)

Types of transaction documents required in France digital reporting

Several different types of invoices and other transaction documents could be required when reporting tax and sales data to the French government. These include:

• Invoices
• Simplified invoices
• Receipt
• Invoice-Receipt
• Credit notes (full and partial)

Note: Some types of transactions, such as import invoices and B2C receipts, will be possible to report separately from the transaction and not in real time. The DGFIP will provide more clarifications about this before the law goes into effect.

At Quaderno we are already working to support the future law in France, so we can serve our customers with French e-invoices as soon as it’s required. For now, our automatic invoices and VAT compliance help business owners save time and have peace of mind. See the benefits with Quaderno’s free trial.