Listen Here to the Podcast version on Spotify
Executive Summary:
France is implementing a Continuous Transaction Controls (CTC) mandate for e-invoicing and e-reporting, significantly altering how businesses handle invoices. The implementation has seen timeline adjustments and a shift in technical approach. The mandate aims to improve data collection for the DGFiP (French tax authority) and enhance overall compliance. Key elements include the use of Partner Dematerialization Platforms (PDPs), the evolving role of the Portail Public de Facturation (PPF), and the importance of the Peppol network for interoperability.
Key Themes and Developments:
- Evolving Timeline: The mandate’s start date has been subject to change. Initially slated earlier, the current timeline is:
- 1 September 2026: All taxpayers must be able to receive e-invoices. Large and medium-sized companies must issue e-invoices and e-report. This date is subject to a potential one-quarter postponement without parliamentary approval.
- 1 September 2027: Small and medium-sized enterprises and microenterprises must issue e-invoices and e-report. This date is also subject to a potential one-quarter postponement without parliamentary approval.
- The original postponement was largely due to delays in the construction of the government’s central e-invoicing platform, the PPF.
- Shift to a 5-Corner Model: France is moving from a hybrid invoicing model (Y-Model) to a “pure 5-Corner model.” This means the Public Invoicing Platform (PPF) will no longer have a central role in the distribution of invoices between buyers and suppliers. Instead:
- “The PDPs will be responsible for facilitating transmission between buyers and suppliers and handling the e-reporting of the transactions to the PPF.“
- “Businesses who intended to connect directly to PPF to exchange invoices will no longer be able to do so. Instead, they will have to contract the services of a PDP platform.“
- This places significant responsibility on the PDPs.
- The Role of Partner Dematerialization Platforms (PDPs): PDPs are certified service providers crucial to the new system. They:
- Facilitate the exchange of e-invoices and e-reporting data between buyers and suppliers.
- Ensure the transmission of e-invoices and e-reporting of transactions to the PPF.
- “Offer the security and quality to bear the bulk of the functions with the upcoming mandate and help businesses comply.“
- The DGFiP published a list of candidate PDPs, indicating the application process is rigorous.
- The Evolving Role of the Public Invoicing Platform (PPF): The PPF (Portail Public de Facturation) was initially intended to play a central role in invoice distribution, but its function is now primarily:
- Data collection and aggregation.
- Receiving e-reporting data from PDPs.
- Delays in the PPF’s construction were a key reason for the mandate’s postponement.
- Peppol’s Importance: The Pan-European Public Procurement Online (Peppol) network is set to become the main interoperability framework:
- “Peppol is now expected to be the main framework and infrastructure used to ensure interoperability between the PDPs for the mandate.“
- “It is filling the gap for the PDPs on what protocols and communication channels should be used for sending and receiving e-documents between themselves.“
- The French Administration will become a Peppol Authority and will “oversee and manage the implementation and operation of the Peppol network within a designated country“.
- Mandatory E-Invoice Formats: From 1 September 2026, the mandatory e-invoice formats will be:
- UBL 2.1
- CII 3.0
- Factur-X
Key Players:
- DGFiP (Direction Générale des Finances Publiques): The French tax authority overseeing the mandate.
- AIFE (Agency of State Financial Information Technology): Agency working with the DGFiP.
- PDPs (Partner Dematerialization Platforms): Certified service providers facilitating e-invoice exchange.
- PPF (Portail Public de Facturation): The government’s public invoicing platform, now focused on data collection.
- OpenPeppol: An international non-profit organisation that develops and maintains the Peppol network, which facilitates cross-border e-procurement.
- FNFE & GENA: French organizations involved in promoting e-invoicing standards and interoperability.
Implications for Businesses:
- Selection of a PDP is critical: Businesses will need to contract with a certified PDP to issue e-invoices and ensure e-reporting compliance.
- Technical adjustments are necessary: Businesses must adapt their systems to support the mandatory e-invoice formats (UBL 2.1, CII 3.0, Factur-X).
- Stay informed: The mandate’s details and requirements continue to evolve, requiring businesses to stay updated on regulatory changes.
Action Items:
- Monitor official announcements from the DGFiP for updates on the mandate’s requirements.
- Evaluate and select a suitable PDP to ensure compliance.
- Assess current invoicing systems and implement necessary technical upgrades.
- Stay informed about Peppol standards and their implications for interoperability.
This briefing document is based on the information available as of December 17, 2024, and is subject to change based on further regulatory updates.
