The French reform on the transition to compulsory electronic invoicing raises many questions. We have grouped the ones that come up most often in these frequently asked questions. As a reminder, this reform only concern companies subject to VAT in France.
Report, formats, directory, mandatory information, e-reporting, PDP… Discover the answers to all the questions you ask yourself!
Calendar and directory
- How do I know when my company is affected by these obligations?
The implementation of electronic invoicing obligations will be done gradually depending on the size of the companies. The size of the company is assessed by the SIREN number. The new schedule under study is as follows:
- September 1, 2026: obligation for all companies to be able to receive electronic invoices
- September 1, 2026: obligation in issuance for large companies and mid-sized companies
- September 1, 2027: obligation in issuance for SMEs, VSEs and micro-enterprises
This calendar will only be official once the 2024 Finance Law has been adopted. These dates could still be postponed by another quarter.
- Will the self-employed also be affected by these obligations?
All companies subject to VAT in France are concerned.
- Is there a procedure to take to appear in the directory?
The directory will list the SIREN and SIRET of all economic players in the country. It will allow very precise routing of invoices. The initialization of the directory will be carried out by the Public Invoicing Portal (known as PPF in French) using data known by the administration. This directory can then be modified and supplemented by the Partner Dematerialization Platforms (PDP), on behalf of their clients. This is also one of the obligations of PDPs: to be able to update this directory reliably.
- Concerning companies going through a PDP, will this appear in the directory?
Yes, this is informed by the company’s PDP. This information is essential for routing invoices.
Formats
- Who chooses the invoice format?
It is the sender who chooses the format, unless your client imposes it on you.
- Will the EDI format be obsolete?
The EDI format will not become obsolete for several reasons:
- EDIFACT is a format that does not only cover invoices but a whole set of supply chain messages
- What exists must be maintained. The majority of Major Contractors use EDIFACT.
- It is preferable to choose an invoice format that allows maximum data to be stored. This increases your chances of being compatible with the obligations and specifications of your buyers.
- Where can we find the structure and specifications of the XML UBL, CII and Factur-X formats?
The specifications are available on the following website: https://www.impots.gouv.fr/specifications-externes-b2b
Partners Dematerialization Platforms and Dematerialization Operators
- Is a Partner Dematerialization Platform (PDP) only certified in France or at European level?
This certification is a DGFIP specification, so it is exclusively French.
- Can an EDM act a Dematerialization Operator?
Yes, an EDM can absolutely be a Dematerialization Operator. This is the choice made by our partner DocuWare.
- Is it possible to have two different PDPs for transmission and reception?
It is possible to have several PDPs or Dematerialization Operators. On the other hand, this is not necessarily the wisest choice because you are multiplying platforms and processes.
- All PDP solutions on the market offer the same functionalities, what are the subjects/functionalities that set you apart from other PDPs?
At first glance, a PDP must meet the specifications of the DGFIP, which means that they all look a bit similar… However, we stand out mainly by:
- Our expertise in all types of formats and interoperability thanks to more than 30 years of experience
- An open API architecture
- Our ability to integrate with third-party solutions, thus completing our functional offering.
- How will the PDPs interconnect? Will they use the PEPPOL network?
This is the path that seems to be taken. For our part, we are already interconnected with other PDPs in AS2 or SFTP.
Public Invoicing Portal – PPF
- Will electronic invoices intended for the public sector using the Chorus Pro platform be migrated to the PPF or will there be two separate platforms?
Ultimately, the Chorus platform will migrate to the PPF in order to keep only one platform.
- From what volume of invoices should we consider autonomy from the PPF?
This will depend on the mapping of your dematerialization flows, the profile of your buyers/suppliers and the number of invoices that you exchange with them. There is no universal answer to this question. This will depend on each company. The objective is also to see beyond this reform. This reform requires you to dematerialize your Franco-French invoicing flows but it is also an opportunity to dematerialize international invoicing flows. This is of major interest in terms of cost reduction and billing management in the company. If you send or receive 1000 invoices per month and you only dematerialize 100 following the obligation, it may be worth pushing the project to the point of dematerializing all of your supplier or customer invoices.
- Will the invoices that go through the PPF be pushed to clients or will clients have to collect them on the portal?
Clients will have to collect them from the PPF. The PPF acts as a server, it does not push invoices to clients’ systems. To do this, clients can be accompanied by a PDP or a Dematerialization Operator.
- Is it possible to enter invoices directly into the PPF
Yes, it will be possible to do so initially. This option is only realistic if you have a low volume of invoices to send.
Invoice flow
- When receiving an invoice, can we imagine receiving an email with the invoice in PDF?
This reform imposes a certain number of operations but it is not restrictive. There is always the possibility of duplicating feeds if you wish to receive a PDF by email. If you implement this solution, you still have the obligation to have in parallel an invoice dematerialization flow with a real electronic invoice, i.e. structured data. This is why it is important to master, through your service provider, the Factur-X format. In fact, the Factur-X format combines the best of both worlds: structured data and PDF, the readable version of the invoice. The PDF by email will not have legal value.
- What will be the mandatory fields to include in electronic invoices?
In the invoice, it will be necessary to provide at least the client’s SIREN, and potentially the SIRET and the routing code depending on the case. We advise you to work with the SIRET mesh, as is currently the case for Chorus PRO. To find out more about mandatory data, you can contact our project team who will provide you with the information.
- Will it still be possible to include specific data in your invoices?
Yes, it will be possible. This will allow you to continue to meet the requirements of your clients.
E-reporting flow
- What about invoices to individuals?
If these transactions are the subject of invoices, we can send them in PDF to customers in the same way as invoices sent abroad. In all cases, we will do the e-reporting, either from invoices or from data provided by your IS (for example, receipt statements).
- Will the PDPs be responsible for sending e-reporting to the PPF?
Yes, the PDPs will also be responsible for transmitting e-reporting. This can be generated in a more or less automated manner.
- What is the format of the e-reporting to be generated from the ERP?
If it is e-reporting on invoice, it is generally the same data as for an invoice. If it is a declaration e-reporting, like B2C receipt, these are summaries by period/VAT rate.
Life cycle flow
- Does TX2 Cloud manage the different non-mandatory lifecycle statuses?
Our status management system is open and allows you to manage several branches of status changes.
International invoicing
- Is a uniform electronic invoicing format planned at global and/or European level?
The European Commission is working on a project called VIDA, for VAT in the digital age. The aim would be to make electronic invoicing compulsory throughout the European Union. If this directive sees the light of day, new mandatory information could be added to invoices. As for the format, all we know is that it will be a structured format.
- What are the deadlines for other European countries which have chosen to switch to electronic invoicing?
To find out more on this specific point, we invite you to read our article Switching to electronic invoicing in Europe: Regulations and obligations in different countries.
Archiving of invoices
- Legal archiving is ensured by the PDP and/or by the PPF?
Archiving will be ensured by the public invoicing portal. However, TX2 CONCEPT archives and will continue to archive all of its customers’ electronic invoices over the legal period of 10 years. It is important to differentiate between archiving with probative value which must respect a certain number of constraints and archiving systems with added value which make it possible to restore the information. Archiving with probative value is not required of PDPs. At TX2 CONCEPT, for 15 years we have developed value-added archiving that complies with the requirements of the DGFIP and GS1 for the dematerialization of invoices. This is what is used in tax audits, for example.
Cost of an electronic invoicing project
- Is it possible to have an estimate of the invoice cost?
The subscription is based on a decreasing table depending on the volume of invoices processed in issue or receipt. Invoice costs can range from €0.40 to €0.05 depending on the volume (from 100 invoices per month to several thousand). Do not hesitate to contact our sales department who will send you a commercial proposal based on your needs so that you have a more precise overview of how much an invoice will cost you. The cost will also depend on the format of the invoice: EDI, OCR, etc. For example, with OCR processing, the cost is slightly higher.
- Is the 10 years archiving cost included in the cost per invoice?
At TX2 CONCEPT, yes. The cost of the invoice includes all invoice processing, the operation of our solution as well as 10-year archiving.
TX2 Cloud: PDP e-invoicing solution
- When can you contact us for an electronic invoicing compliance project?
You can do it now. You tell us your needs, the map of your suppliers and buyers and we guide you on the operations that will need to be carried out to set up a dematerialization flow that is functional now and compatible with future obligations.
- If you are already a user of our invoice dematerialization solution, what will be the changes with the new reform?
The major development consists of the transmission of data to the PPF, either for the invoices themselves, or for the e-reporting of invoices transmitted to a PDP. As you are already able to transmit invoices in electronic format, the step forward for you is quite small. Our consultants will be able to help you evaluate the work to be carried out, in conjunction with your ERP.
- Can we differentiate general expenses invoices from those for purchases and sales of goods in the TX2 Cloud interface?
Yes, it is planned.
- What formats are accepted for input and output to our PDP?
All formats are possible.
- Is it possible to query TX2 Cloud via API?
Yes, it was designed for that.
ERP compatibility and partners
- Which ERPs on the market are you already interfaced with?
We do not have an exhaustive list to give you. We have expertise in a large number of ERPs on the market. Here are some examples: SAP, Sage, Microsoft Dynamics as well as small ERPs. We can interface with all types of ERP as long as it provides us with a file structure format which we can then translate into a standardized format on our side. Therefore, regardless of the ERP you work with, we are able to adapt.
- Do you work with ERP partners to offer a joint solution?
We have had partnerships with certain ERPs for many years, notably VIF, for example. With VIF, we have developed a joint offer on electronic invoicing. This allows VIF to offer their customers and prospects a PDP offer. Everything will depend on the ERP. We can adapt to certain ERP files or we can work jointly on solutions. It depends on our level of partnership.
- Can document tracking be done directly via your ERP or will you have to connect to our TX2 Cloud platform?
Yes, provided that you, or your ERP, are able to either use our APIs to send the information back to your ERP, or to use tracking files transmitted periodically.
- What format is used to push invoices to your ERP?
It is your ERP which decides the format. It’s our job to convert the data to the correct format.
We hope we have answered the majority of your questions. If this is not the case, feel free to contact us directly. We will be happy to answer them!
