Electronic invoicing: the DGFIP updates its information sheets!

Namely

The list of PDPs registered under reservation can be found here.

Update of the explanatory sheets on the reform

Other explanatory sheets for SMEs and micro-enterprises have also just been updated:

• Educational sheet – VSEs/SMEs – Preamble

The Four Key Objectives of the Reform

1. Enhance Business Competitiveness: By reducing the administrative burden of creating, sending, and processing paper invoices, as well as securing commercial relationships.
2. Facilitate VAT Declarations: Through pre-filling processes.
3. Combat Tax Fraud: By decreasing the VAT gap through automated cross-checking.
4. Enable Real-Time Business Activity Monitoring: To support precise government actions in economic policy.

Updated October 2024
Target Audience of These Documents: SMEs and Micro-Enterprises
Under Article 51 of Law No. 2008-776 of August 4, 2008, on the modernization of the economy (LME), businesses are classified into four categories: micro-enterprises, small and medium-sized enterprises (SMEs), intermediate-sized enterprises (ETIs), and large enterprises.
Decree No. 2008-1354 of December 18, 2008, specifies the criteria for determining the category of a business:

• A micro-enterprise (including auto-entrepreneurs) is a business with fewer than 10 employees and an annual turnover or total annual balance sheet not exceeding €2 million.
• An SME is a business with fewer than 250 employees and an annual turnover not exceeding €50 million or a total balance sheet not exceeding €43 million.

Overview of the System: 4 Components in the Reform
The term e-reporting can cover two obligations: on one hand, the transmission of transaction data (Sheet 7); on the other hand, the transmission of payment data (Sheet 8). The two systems are distinct, with payment e-reporting potentially complementing an electronic invoice or transaction e-reporting.
Electronic invoicing already in effect for the State, its public establishments, or local authorities and public local establishments (= B2G?) remains mandatory and applies to all legal entities governed by public law.
Taxable or non-taxable entities, including businesses benefiting from the exemption regime.

E-REPORTING OF PAYMENT DATA
= TRANSMISSION OF COLLECTION DATA
by the supplier/service provider,
only for SERVICE PROVISIONS, regardless of the invoiced amount,
excluding options on debits, excluding self-liquidated operations.

INTERNATIONAL B2B E-REPORTING
= TRANSMISSION OF INTERNATIONAL B2B TRANSACTION DATA
= Transmission of invoice data if your supplier or professional client is located inside or outside the EU.

B2C E-REPORTING
= TRANSMISSION OF B2C TRANSACTION DATA
= Transmission of daily revenue (regardless of amount) generated from individuals or non-VAT taxable legal entities (e.g., associations).

DOMESTIC B2B ELECTRONIC INVOICE
= Electronic invoice for all transactions (sales/service provisions) between professionals*
(operations within the scope of VAT) in France.

• Sheet 1 – What will happen to my company in terms of invoicing? 

Starting September 1, 2026, your business will need to be able to receive electronic invoices sent by large enterprises and intermediate-sized enterprises, which are required to issue all of their invoices in electronic format, as well as by voluntary businesses. This could include your electricity supplier, your phone/internet service provider, or suppliers of equipment.

Below is a timeline for the implementation of electronic invoicing based on the size of businesses.

Business Size

1. Large enterprise: More than 5,000 employees or turnover exceeding €1.5 billion and total balance sheet exceeding €2 billion.
2. Intermediate-sized enterprise: 250 < number of employees < 5,000 and turnover < €1.5 billion or total balance sheet < €2 billion.
3. Micro-enterprise: Fewer than 10 employees + turnover < €2 million or total balance sheet < €2 million.
4. Small and Medium-Sized Enterprises: 10 < number of employees < 250 + turnover < €50 million or total balance sheet < €43 million.

Updated October 2024

Important to Know
Auto-entrepreneurs or micro-enterprises benefiting from the VAT exemption (Article 293 B of the General Tax Code (CGI)) will also be required to receive and issue electronic invoices.

What is an Electronic Invoice Starting September 1, 2026?

The new requirement is that invoices issued between professionals in France must be electronic. This means the invoice must:

• Comply with a standardized electronic format;
• Include certain mandatory mentions in a specified format;
• Be transmitted via a dedicated platform.

Thus, electronic invoicing, as understood today, in the form of paper invoices, scanned invoices, ordinary PDFs, or documents generated by accounting software and then sent by email, will no longer comply with regulations.

Invoices will no longer be sent directly from the supplier to the client but will be transmitted through a state-approved dematerialization partner platform (PDP). Each business will need to choose a PDP, which is a private operator registered with the tax administration following a specific procedure.

The list of partner platforms is available and regularly updated on the impots.gouv.fr website in the Partner > Electronic Invoicing – Partner Dematerialization Platforms section (https://www.impots.gouv.fr/facturation-electronique-et-plateformes-partenaires).

Benefits of Electronic Invoicing

Electronic or dematerialized invoicing offers several advantages:

• Financial savings of 50% to 75% compared to paper processing;
• A reduction in processing costs of about 30%;
• Optimization of working time;
• A decrease in potential disputes;
• A reduction in payment delays.

In the long term, the information collected will facilitate the pre-filling of VAT declarations, simplifying the process as you will only need to correct your declarations.

By September 1, 2027, your business must also be able to issue invoices in electronic format. Therefore, you will no longer be able to send an invoice directly to your VAT-registered client (acting in a professional capacity) but will be required to use a private partner platform.

Don’t have software? The partner dematerialization platforms will offer various methods for creating invoices based on your needs. They will be responsible for issuing the electronic invoice to your client’s platform.

Examples

• If you are a baker-pastry chef with less than €91,900 in turnover (excluding tax), or a plumber with less than €36,800 in turnover (excluding tax), you must be able to issue invoices in electronic format via a partner dematerialization platform for sales/service provisions made to professionals with a SIREN in France by September 1, 2027. These invoices will continue to state “VAT not applicable, Article 293 B of the CGI.”
• If you have just started a consulting activity as an auto-entrepreneur, you must be able to issue electronic invoices by 2027 if you bill professionals in France.

• Sheet 2 – Will my company be obliged to invoice electronically? 

Will my business be required to invoice electronically?
Your business will need to issue electronic invoices for its operations with other taxable entities that have their registered office in France in the following cases:

1. You are a VAT-registered business
   A “VAT-registered business” refers to a natural or legal person that independently engages in an economic activity on a regular basis. All VAT-registered businesses must be able to receive electronic invoices by September 1, 2026, as from that date, all large enterprises will be required to issue all their invoices electronically. The transition to this requirement will be gradual and will depend on the size of your business (see Sheet No. 1).
2. You are a VAT-registered business but benefit from the exemption threshold (Article 293 B of the General Tax Code (CGI))
   Businesses that benefit from the VAT exemption threshold are not liable for VAT because their turnover is below the threshold at which VAT must be charged. However, they remain VAT-registered and are therefore subject to electronic invoicing, both in receiving and issuing invoices.

Updated October 2024
Thus, all micro-entrepreneurs (auto-entrepreneurs) are affected by the reform:
If you have a shop selling clothes and various jewelry and have a turnover of less than €85,800 (the threshold set in Article 293 B of the CGI in 2021), or if you are a plumber with a turnover of less than €34,400, you must be able to issue invoices in electronic format through a platform for sales/service provisions made to professionals with a SIREN in France by 2027 at the latest. These invoices will continue to state “VAT not applicable, Article 293 B of the CGI.”
If you have just started a consulting activity as an auto-entrepreneur, you must also be able to issue electronic invoices by 2027 if you bill professionals in France.

3. You are a VAT-registered business, but you carry out VAT-exempt operations that are not subject to invoicing (Articles 261 to 261 E of the General Tax Code (CGI))
   If your business performs operations for which there is an exemption from invoicing under Articles 261 to 261 E of the General Tax Code (CGI), you are not subject to electronic invoicing for these operations. However, in this case, your business:

• Is exempt from issuing electronic invoices only for the exempt operations that are not subject to invoicing;
• Must issue electronic invoices for other operations that are not VAT-exempt, including those conducted under the exemption threshold;
• Will still receive electronic invoices from its suppliers.

Consequences
Starting September 1, 2026, as invoices are transmitted electronically between the supplier and the customer via a partner dematerialization platform (PDP) (see Sheet No. 1), your business will need to have chosen an intermediary platform to be able to receive electronic invoices issued by large enterprises and any businesses that choose to participate in the reform early.

Important to Know

1. If you are part of a group of companies, whether fiscally integrated or not, the concept of the business considered is that of the legal unit; a legal unit is identified by its SIREN number.
2. If you are a non-profit organization and not subject to VAT, then you are not obligated to issue or receive electronic invoices.

• Sheet 3 – When should my company be ready to receive electronic invoices? And to issue them? 

From what date must my business be ready to receive electronic invoices? And to issue them?

1. Receiving Electronic Invoices
   ➢ By September 1, 2026 at the latest: You must have chosen a dematerialization platform for receiving electronic invoices from your suppliers.
   Starting from September 1, 2026, your business will need to be able to receive electronic invoices addressed by large enterprises, intermediate-sized enterprises, and voluntary businesses that choose to participate in the reform early.
   To do this, you will need to select a private partner dematerialization platform (PDP) registered with the tax administration.
   The intermediary platform you choose will be responsible for informing the administration through the central directory. This directory will list all businesses registered in France and will allow for the identification of the intermediary platform chosen by each business.
   The obligation to receive electronic invoices does not necessarily imply the obligation to issue electronic invoices. Thus, if your client is a large enterprise or an intermediate-sized enterprise that has already entered the reform, you, as a small or micro-enterprise, are not required to issue invoices to them electronically before September 1, 2027. However, you must be capable of receiving the issued invoices by choosing a platform.
   Therefore, before September 1, 2027, it is not your responsibility to ensure whether your supplier is obligated to issue an electronic invoice; it is up to them to know.

Updated October 2024

2. Issuing Electronic Invoices
   ➢ By September 1, 2027 at the latest: You must be able to send electronic invoices to your clients.
   By September 1, 2027, your business must be able to issue electronic invoices to professionals established in France via a partner dematerialization platform (PDP).
   You will also need to choose an intermediary platform for issuing your invoices. It can be the same platform used for receiving invoices or a different one.
   Moreover, if you wish, you can voluntarily participate in the reform early, before September 1, 2027.

• Sheet 4 – What are the first steps for my company in terms of electronic invoicing? 

What are the first steps for my business regarding electronic invoicing?

1. Form a Working Group within Your Business
   First and foremost, it is important to inform yourself about the invoicing reform using the documentation available on the impots.gouv.fr website.
   Next, it is relevant to identify the functions within your business that will participate in the transformation of invoicing: general management, legal department, accounting, IT department, etc.
   Then, map out the flow of incoming invoices from your suppliers and outgoing invoices from your business.
2. Choose an Intermediary Platform Before September 1, 2026
   Starting from September 1, 2026, your business must be able to receive electronic invoices sent by large enterprises and voluntary businesses. This could include your electricity supplier, your phone/internet service provider, or your equipment suppliers.

Updated October 2024

This is why you will need to choose a partner dematerialization platform (PDP) registered with the tax administration.
Not all dematerialization operators will be partners of the administration. To be able to transmit invoices between businesses, they must be registered with the tax administration following a procedure described in the General Tax Code. They will then be referred to as partner dematerialization platforms.
The list of partner dematerialization platforms is available on the impots.gouv.fr website on the Partner page: https://www.impots.gouv.fr/liste-des-plateformes-de-dematerialisation-partenaires-pdp-immatriculees-sous-reserve.

3. Assess Your Needs in the Context of the Reform, Particularly Regarding the Invoices You Issue
   It is advisable to inventory the available equipment in the business for invoicing: computers, tablets, smartphones, Wi-Fi connection, ADSL, etc.
   The decision to invest in specific equipment will depend on the tools you already have, the nature of the operations you carry out, and the number of operations you perform.
   Based on these criteria and to avoid over-equipping, it may not always be necessary to invest in new equipment. Simple and easily accessible solutions will be possible.

• Sheet 5 – What documentation is available? Where can I find more information? 

To inform yourself about the invoicing reform, you can visit the impots.gouv.fr page > Professional > How to… – Manage my business/association > I am transitioning to electronic invoicing and consult the documentation available.
This documentation is regularly updated and enriched.
You will find:
➢ A section “I discover electronic invoicing” that allows you to answer the initial questions about the reform (timeline, scope of the reform, operations concerned, application modalities of the reform, etc.)
➢ A section “I deepen my knowledge of the reform” that enables you to learn more about the system (for example, for international operations, specific sectors, etc.) and to access technical documentation (external specifications).

• Sheet 6 – From 1 September 2026, how will my company receive electronic invoices from my suppliers? 

• Electronic Invoicing Requirement: From September 1, 2026, suppliers, especially large companies (such as those in the energy, telecommunications, and internet service sectors) and intermediate-sized enterprises, will be required to issue electronic invoices. These invoices will be sent through a partner dematerialization platform (PDP) registered with the tax administration, which you must select in advance.
• Notification and Access: Upon receiving an invoice from a supplier, you will be notified by your PDP and will access the invoice according to the terms established with that platform. To view your invoices, you will need to log in to your chosen platform.
• Invoice Tracking and Management: Your platform will provide access to the status of invoices, indicating their stage in the transmission process. You will have the option to reject an invoice if it does not meet contract terms or contains errors, such as discrepancies with the order or delivery. The supplier will also be informed of any rejection. Improved payment timelines are expected, as both the supplier and client will have the same information regarding invoice issuance, sending, depositing, and receiving dates.

• Sheet 7 – Transmission of transaction data (or e-reporting of transaction data): is my company concerned? 

The electronic invoicing system, which targets transactions with your suppliers and professional clients established in France, is complemented by two other components: the transmission of transaction data (transaction e-reporting) and the transmission of payment data (payment e-reporting – Sheet 8).

Will my business be subject to the transmission of transaction data (transaction e-reporting)?
If you carry out the operations described in one or both of the following cases:

• Sales and/or service provisions to individuals or non-VAT taxable legal entities (such as associations) in France and abroad;
• Purchases or sales of goods or services to suppliers or clients established in the European Union or outside the European Union (excluding imports of goods).

Then you will be required to transmit data regarding these transactions to the administration.

Updated October 2024

When?
Starting September 1, 2027, you will need to send the administration information related to these operations, according to a frequency defined based on your VAT taxation regime (exemption threshold, simplified taxation regime, or normal quarterly or annual regime).

What data to transmit?
Only the data necessary for the administration, not the entirety of the transaction data, is expected.

• If you make sales and/or service provisions to non-taxable persons, you will be asked for your daily turnover (to be broken down by VAT rate if necessary).
• If you conduct purchases or sales of goods or services with VAT-registered suppliers or clients established in the European Union or outside the European Union (excluding imports of goods), a portion of the invoice data must be transmitted to the administration (the same data as for the electronic invoice).

For more information on the data to be transmitted, you can refer to the online documentation on impots.gouv.fr on the page “I am transitioning to electronic invoicing.”

How can I transmit this data?
As with sending and receiving electronic invoices, you will be able to transmit the data required by the administration via a partner dematerialization platform.
Transaction data can be entered directly on the platform or transmitted via a digital file.
When the operations are conducted with non-taxable persons, no personal data should be transmitted. Therefore, only aggregated daily data will be requested, not data on a transaction-by-transaction basis.

• Form 8 – Transmission of payment data (or payment e-reporting). Does my company have to transmit payment data for all transactions it carries out (purchase/sale, services/delivery of goods)? 

As part of the system, companies…

• providing services in France or abroad,
• whether they are subject to an electronic invoice or not,
• directed to professionals or non-taxable clients … will need to transmit payment data related to these operations to the administration, as they are the ones receiving the amounts due, an event that triggers the VAT liability.

They will not be required to do so if:

• you or the company has opted for VAT payment based on cash receipts.
  Note: This exception does not apply to the collection of a deposit on a service.
• the operation leads to VAT self-assessment.

Updated October 2024

What data to transmit?
The payment data includes:

• the date of receipt
• the amount received for the service.

Important to Know

• In the case of invoices or operations that include multiple VAT rates, the received amount must be allocated according to the applicable VAT rates.
• In the case of partial payment, that amount will be transmitted. When the balance is paid, new information will be sent to the administration.
  The client is not required to transmit information about the payment made to their supplier to the administration.

For more information on the data to be transmitted, you can refer to the online documentation on impots.gouv.fr on the page “I am transitioning to electronic invoicing.”