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Legal Framework for Electronic Invoicing in France
In France, the legal framework for electronic invoicing is based on a combination of national laws and EU regulations. France has taken significant steps to promote electronic invoicing, particularly in transactions between businesses and public authorities. The key legal provisions for electronic invoicing in France include:
1. EU VAT Directive (2006/112/EC)
As in all EU member states, the foundation for recognizing electronic invoices in France is the EU VAT Directive (2006/112/EC). This directive stipulates that:
- Electronic invoices have the same legal status as paper invoices, provided their authenticity (the sender’s identity) and integrity (the unaltered content) are ensured.
- These requirements can be met through methods such as electronic signatures or EDI (Electronic Data Interchange).
In France, these provisions are implemented through national regulations.
2. French VAT Act (Code général des impôts)
The French VAT Act includes specific provisions for electronic invoicing in the context of VAT compliance.
- Article 289-VI of the Code général des impôts recognizes electronic invoices as legally valid if they meet the requirements of authenticity and integrity. These can be ensured using methods such as:
- Electronic signatures
- EDI systems
- The electronic exchange of structured data (e.g., XML).
- Electronic invoices must be issued within the usual deadlines and comply with all legal requirements (e.g., the name and address of the issuer and recipient, VAT rate, invoice number, etc.).
3. Law Promoting Electronic Invoicing (Loi de Finances 2020)
A significant milestone in promoting electronic invoicing in France is the Loi de Finances 2020, which mandates electronic invoicing for businesses in France starting from July 1, 2024.
- From this date, all companies must issue electronic invoices for their B2B transactions. This expands the current requirements for B2G transactions (business-to-government) to include private sector transactions.
- The implementation of this law will occur in phases, starting with the largest companies. By the end of 2026, all businesses will be required to use electronic invoicing.
4. Electronic Invoicing Platform: PPF
- France has announced that its public invoicing portal (PPF) will no longer serve as a platform for electronic invoicing. Instead, businesses will be required to use approved partner dematerialization platforms (PDPs) to manage electronic invoices.
- All B2B and B2G invoices must be processed through the PDPs, both for the issuance and reception of invoices as well as the transmission of invoice data (eReporting).
- The first pilot phase (eInvoicing via PDP) will begin in September 2025.
5. Electronic Signatures and EDI (Electronic Data Interchange)
In France, electronic invoices can be validated using various methods to ensure their authenticity and integrity:
- Electronic signatures (compliant with EU Regulation 910/2014 on electronic identification and trust services) confirm the sender’s identity and ensure that the invoice has not been altered after issuance.
- Alternatively, EDI systems can be used to process transactions through secure communication channels that guarantee authenticity and integrity via technical solutions.
6. Archiving Requirements for Electronic Invoices
Like other EU countries, France requires electronic invoices to be archived for at least 6 years. Key requirements include:
- The invoices must remain readable and accessible at all times.
- Their integrity must be preserved, ensuring no alterations occur after issuance.
- Electronic invoices must be properly stored and easily retrievable for tax audits.
7. Technical and Legal Requirements for Electronic Invoices
The legal requirements for electronic invoices in France address not only the format and content of the invoices but also the transmission methods and security measures. These include:
- Mandatory content: Electronic invoices must include all information required for paper invoices, such as:
- Name and address of the issuer and recipient
- VAT identification number
- Invoice date and number
- Description of goods or services, quantity, VAT rate, and total amount.
- Structured format: Electronic invoices must be issued in a structured format, such as XML or UBL, particularly for invoices submitted to public authorities. Structured formats are also increasingly required for B2B transactions.
Conclusion
The legal framework for electronic invoicing in France is primarily based on the EU VAT Directive and national laws, including the Code général des impôts. Since 2020, the Loi de Finances 2020 has accelerated the transition to electronic invoicing, initially for B2G transactions and, increasingly, for B2B transactions. Companies must ensure their electronic invoices comply with all legal requirements, including authenticity, integrity, and archiving.
Mandatory receipt: From 01.09.2026 for all.
Mandatory sending: From 01.09.2027 for all large and medium-sized businesses. From 01.09.2027 for all small businesses.