BDO Indirect Tax News

French companies have been transitioning to e-invoicing for VAT purposes—particularly in the B2G sector—since 2021 and now they need to gear up for the implementation of mandatory e-invoicing for B2B transactions (i.e., transactions between VAT-registered companies established in France). The move to e-invoicing is part of a structural transformation of taxation, with clearly defined objectives:

• Strengthening the fight against VAT fraud by ensuring full traceability of invoicing flows;
• Simplifying reporting obligations, particularly through the use of pre-filled VAT returns based on data collected from e-reporting;
• Reducing payment times between companies by streamlining the processes for validation and transmission of invoices; and
• Reducing the administrative burden by automating tasks related to document management.

This transformation is based on three distinct pillars:

1. E-invoicing, which will require the issuance, transmission and receipt of invoices in a structured format.
2. Transmission of transaction data (e-reporting of transactions), which concerns transactions not covered by e-invoicing, such as transactions with operators established outside France and those conducted with individual consumers.
3. Transmission of payment data (e-reporting of payment), which will apply to the provision of services for which the chargeability of VAT is linked to collection, except in special cases.

The final timetable provides for a phased implementation of B2B e-invoicing:

• Taxpayers have voluntarily been issuing e-invoices via approved platforms and based on the central directory of recipients since July 2025.
• As from 1 September 2026, all companies must be able to receive e-invoices. Large and intermediate-sized companies will have to issue invoices in electronic format and transmit transaction data to the tax authorities.
• From 1 September 2027, e-invoicing and e-reporting will be extended to small and medium-size enterprises (SMEs), very small enterprises and micro enterprises, thus completing implementation of the regime.

Recent Developments in E-invoicing

Name changes

Partner Dematerialisation Platforms (PDPs) are private operators offering a technical interface for the issuance and receipt of e-invoices. PDPs will also be responsible for transmitting invoicing and transaction data to the Public Billing Portal (PPF) and for managing invoicing formats and securing flows. Use of these operators will be mandatory and will need to be approved by the General Directorate of Public Finances (DGFiP). Dematerialisation Operators (ODs), on the other hand, function as technical intermediaries between companies and PDPs. Their use will remain optional.

On 8 July 2025, the DGFiP announced a change in nomenclature: PDPs are now to be referred to as Approved Platforms (APs) and ODs are Compatible Solutions (SC). In addition to name changes, the administration wanted to strengthen the system by introducing two official labels:

• "Approved platform – Electronic invoicing," which will provide a guarantee of reliability for operators authorised to exchange invoices between companies; and
• "Compatible solution – Electronic invoicing," which will be used to distinguish tools that comply with the new e-invoicing rules and are interconnected with at least one approved platform.

These labels will secure company choices and establish a climate of trust in an ecosystem that continues to evolve.

Refocusing the role of the Public Billing Portal

The PPF—a platform created by the government—was initially designed as a free one-stop shop for companies that did not wish to use or could not use the services of an AP. In a press release issued near the end of 2024, the government announced that it will not offer billing services (sending and receiving), so all companies subject to the e-invoicing mandate will be required to use the services of an AP. However, the PPF will retain two essential functions:

• Management of the central business directory, which is essential for the proper routing of e-invoices between issuers and recipients; and
• Acting as a tax data hub for the transmission of information collected by the AP to the DGFiP.

The PPF will thus become a technical tool for interconnectivity, guaranteeing the fluidity and reliability of exchanges, but not a direct operational service for companies.

The deployment of PPF functionalities will be rolled out gradually between now and September 2026:

• The Business Directory service is now live
• Declaration Service (e-reporting):
  • Pilot phase: October 2025
  • Production: February 2026
• The lifting of technical reserves for APs is scheduled for the fourth quarter of 2025
• The due date of the first obligation: September 2026.

France becomes a Peppol authority

France took a decisive step in the implementation of e-invoicing on 8 July 2025 when joined more than 40 other countries as a Peppol national authority. This appointment gives the DGFiP a central role in the governance of the Peppol network in French territory. The Peppol (Pan-European Public Procurement Online) network is a technical and legal infrastructure for standardised, secure and interoperable e-invoice exchanges between various economic players at the national and European levels.

Before the adoption of Peppol, exchanges were made via separate channels, which were often incompatible with each other. Now, all operators will use a common language and harmonised traffic rules, facilitating cross-border flows and regulatory compliance. The creation of a Peppol authority facilitates the integration of international standards into national dematerialisation policies.

Mandatory information on invoices

E-invoices will have to include new information to enhance the traceability of transactions, facilitate the cross-referencing of data with the tax administration's databases and allow the automation of controls in the context of e-reporting. The following information will be required:

• The customer's nine-digit SIREN number, which will allow the precise identification of the recipient entity;
• The delivery address of the goods if that differs from the billing address;
• The nature of the transaction, i.e., whether it involves the delivery of goods, the provision of services or is a mixed transaction; and
• The payment of VAT on debits if the service provider has opted for that regime.

These additions, although technical, constitute a structural evolution of the invoice format, and will necessitate the adaptation of information systems, invoicing processes and accounting settings.

Penalties may apply for failure to provide mandatory information (e.g., EUR 15 per omission, capped at a quarter of the invoice, including VAT), failure to issue an e-invoice (e.g., 50% of the amount of the transaction and reduced to 5% if the transaction has been accounted for), failure to transmit an e-invoice (e.g., EUR 15 per invoice, capped at EUR 15,000 per tax year) and transmitting incorrect transaction or payment data (EUR 250 per error, capped at EUR 10,000 per fiscal year).

Standardisation efforts

AFNOR (the French Association for Standardisation) is a national body that plays a central role in the implementation of e-invoicing. As a standardisation body, AFNOR is responsible for developing technical standards that guarantee interoperability, regulatory compliance and the fluidity of exchanges between the various players in the system: companies, approved platforms, software publishers and the tax authorities.

Three core standards have been published in 2025:

• XP Z12-012: Repository on standardised formats and profiles of e-invoices and life cycle messages related to the regime;
• XP Z12-013: Standardised API specifications across platforms, allowing technical interfaces to be defined; and
• XP Z12-014: Formalisation of 36 B2B use cases (subcontracting, self-invoicing, factoring, etc.) to anticipate the different invoicing scenarios encountered by companies.

These standards now constitute the national technical basis for structuring, transmitting and processing e-invoices within the legal framework defined by the DGFiP. They allow companies to prepare for compliance, evaluate their flows and anticipate the connection phase between the APs and the PPF Data Concentrator.
 

Simplification and tolerance measures

Following work and consultations conducted earlier in 2025, the government announced a series of simplification and tolerance measures to facilitate the operational implementation of the e-invoicing measures and these have been communicated to the president of the FNFE-MPE and the AFNOR Electronic Invoicing Commission. There are 10 key measures divided into two categories: simplification measures (technical simplifications) and tolerance measures (regulatory tolerances).
 

Simplification measures

• Removal of invoice line data in e-reporting for international acquisitions, a change widely requested by field stakeholders;
• Elimination of the number of transactions to be transmitted in B2C e-reporting to reduce operational complexity;
• Elimination of blank e-reporting, i.e., taxpayers will not be required to transmit data if there is no data to be reported;
• Freezing the scope of the data to be transmitted, i.e., no additional data will be required, guaranteeing the stability of ongoing IT developments; and
• Exclusion of non-EU transactions between taxable persons established in France from the scope of e-reporting if they are subject to foreign VAT.

Tolerance measures

• Simplified calculation method for VAT on the profit margin in B2C e-reporting, via an average rate rather than a sale-by-sale calculation. Any discrepancies can be corrected in the VAT return;
• Exclusion from the penalty regime for entities without SIREN or whose SIREN is not yet in the central directory; and
• Postponement to 2027 of the obligation for non-established taxable persons to report on transactions in France and international acquisitions.

These measures must be included in government policy, integrated into a future decree or order or formalised in the 2026 finance law.
 

Formal agreement

It is proposed that a taxable person’s formal consent be required in two situations and, in both cases, the taxable person’s AP operator would be required to retain the consent: (i) when updating the address data in the central directory, and (ii) in the event of a change of AP for the receipt of invoices. The formal consent of the taxable person would have to be archived through 31 December of the second year following the expiration of the consent.

A decree would be issued to set out the information to be included in the formal consent, such as:

• Identity of the taxable person (name, address, SIREN/SIRET);
• Identity of the platforms concerned (old and new);
• Desired effective date of the change;
• Email addresses concerned (primary, secondary, functional);
• Signature of the legal representative or a duly authorised representative; and
• Numbering and archiving of the document according to a standardised format.

Mobility between Approved Platforms

A supervised mobility procedure is proposed that would allow a taxable person to change their AP at any time, unless explicitly requested otherwise. This procedure would outline the steps needed to change the AP and the relevant timeline.
 

Withdrawal of registration

A new ground would be available for an AP to withdraw its registration, so that if the tax administration identified noncompliance and the AP did fail to produce evidence of compliance within 15 working days after receiving a formal notice, the AP’s registration would be withdrawn. These provisions aim to guarantee the reliability of the system and provide a framework for relations between companies and platforms.
 

Chorus Pro

Since 1 January 2017, the government has been using Chorus Pro, operated by the Agence pour l'informatique financière de l'Etat, to receive and exchange invoices electronically. This mechanism, which is well integrated into public sector practices, constitutes the foundation on which the rules are based for public entities. Chorus Pro will retain its role as a platform to receive e-invoices but will also become the platform for issuing e-invoices for transactions subject to VAT, whether public or private and will ensure the transmission of transaction and payment data in accordance with the e-reporting requirements.

Starting in September 2026, public sector providers will have two options:

• Use an AP, except in specific cases (invoices for work contracts, statements of legal costs, requests for reimbursement, management of the legal commitments repository), which are the exclusive responsibility of Chorus Pro; or
• Continue to use Chorus Pro to send invoices (entry or deposit on the portal, deposit via EDI or API) to the state, local authorities or public establishments.

BDO Insight

With less than a year to go before e-invoicing becomes mandatory for large and intermediate-sized companies, the regulatory and technical framework for e-invoicing is becoming clearer. The standardisation efforts by AFNOR, the ramp-up of approved platforms, the creation of the Peppol France authority and the simplification measures bear witness to a collective mobilisation.

Although the new rules will introduce compliance and administrative obligations for taxable persons, they also create an opportunity for companies to modernise their processes and experience discernible gains in efficiency. The choice of an AP, the preparation of flows, the training of teams and the anticipation of specific use cases are levers to be activated now to secure a smooth and controlled transition to mandatory e-invoicing.

David Hirsch
BDO in France