France's E-Invoicing and E-Reporting Reform

France's reform is the one most often described inaccurately, because it is two obligations wearing one name. Getting the two apart is the first thing to do, and it changes the scope of the project substantially.

Two obligations

Electronic invoicing applies to supplies of goods and services between taxable persons established in France. Those invoices must be issued, transmitted and received in a structured format, through a registered platform.

Electronic reporting applies to the transactions the invoicing mandate does not reach: sales to consumers, and cross-border transactions with parties outside France. There is no invoice to intercept in those cases, so the data is reported separately. A payment reporting element attaches to services.

A business that sells only to French businesses is caught by the first. A business that also sells to consumers or exports is caught by both, and the second is usually the part that was not scoped. The general distinction is set out in e-invoicing and e-reporting are not the same obligation.

The platform model

France's structural choice was to license private operators rather than to route every document through a single state platform. A registered partner platform receives your invoice, validates it, transmits it to the recipient's platform, extracts the data the administration requires, and passes that on.

That produces a five-corner arrangement: the two businesses, their two platforms, and the administration. It differs from the Italian and Polish models in a way that matters operationally.

There is a commercial consequence and a compliance one. The commercial consequence is that you have a supplier with a contract and a service level, which is more than most countries' models give you. The compliance one is that you have chosen the party that carries out your validation, archiving and transmission, and choosing badly is your problem. Choosing an access point or service provider applies directly.

The timetable

The receiving obligation lands on everyone on the first date, including the smallest business. That is the same pattern seen in every staged mandate across Europe, and it is the part that is consistently under-planned because it requires no change at all to how you bill.

What has to be in the invoice

France requires data that the European core invoice does not make mandatory, which is why a document that passes European validation can still fail here. Four additions are worth knowing in advance:

• A transaction category distinguishing supplies of goods from supplies of services, because the tax point rules differ and the reporting depends on it.
• The buyer's and seller's French business identifiers, in the national scheme, not merely a VAT number.
• Delivery address where it differs from the buyer's address.
• Payment terms and payment status data feeding the payment reporting element for services.

None of these is exotic, and none of them is usually present in a customer master that was built for paper invoicing. That is the master data problem again, in French.

The life cycle statuses

The French model tracks an invoice through a set of defined statuses — deposited, rejected, accepted, and so on — and some of them must be returned by the buyer, not by a platform. This is the part of the reform with no equivalent elsewhere and the part most likely to be missed.

The implication is operational rather than technical. If a buyer is obliged to return a status, somebody in that buyer's organisation has to produce it, on time, for every invoice received. An accounts payable function that batches approvals weekly will not do that by accident. Plan it as part of exception handling, because a missing status is exactly the kind of quiet failure that accumulates.

The directory is the hard part

Of everything in the reform, the piece most likely to hurt on the first day is the least discussed, because it is not a format question and not a legal one.

For a document to reach a French counterparty, the sender has to know where that counterparty receives — which platform, under which identifier, for which of the counterparty's establishments. That information has to exist somewhere authoritative, be kept current as businesses change platforms, and be resolvable at the moment of sending.

Three things make it harder than it sounds.

Businesses move between platforms, and a directory entry that is stale routes documents to a provider that no longer serves that customer. Large organisations receive at more than one point — different subsidiaries, different sites, different business units — so an identifier at company level is not always precise enough to deliver. And the sender is the party that bears the consequence of getting it wrong, while the accuracy of the entry depends entirely on somebody at the other end having maintained it.

This is the French instance of a general problem rather than a French peculiarity: an address in any of these systems is a claim about capability that somebody else maintains, and the failure mode is silent. A well-formed identifier pointing at the wrong destination does not produce an error. It produces a delivery, to somewhere nobody is watching, and the first indication is a customer saying they never received the invoice — which is a master data problem wearing a routing problem's clothes.

Where to start

Establish which of your French entities is established for VAT purposes, then split your revenue into the three buckets the reform uses: domestic business-to-business, consumer, and cross-border. The first bucket is an invoicing project. The other two are a reporting project, and they usually belong to different people.