e-invoicing Reform

Concerned companies:
All businesses subject to VAT

Regulatory Framework:

• e-invoicing: The obligation to issue electronic invoices (e-invoicing) and transmit invoicing data to the tax administration.
• e-reporting: The obligation to transmit transaction and payment data to the tax administration, referred to as e-reporting.

e-invoicing: Y-Scheme
Four key stakeholders:

• Companies
• Their Dematerialization Operator (OD)
• The Public Invoicing Portal (PPF)
• Partner Dematerialization Platforms (PDP)

Process Flow - 5-corner model:

• The supplier's invoice, formatted by the OD, must be transmitted via the issuing partner platform (PDP-E).
• The PDP-E extracts the data required by the tax administration and transmits it via the data concentrator (PPF).
• The OD retrieves the invoice from the receiving PDP (PDP-R) and integrates it into the buyer’s information system.
• The buyer takes charge of the invoice and issues a status (Life cycle). This status is transmitted through the PDPs and ODs to the supplier, who is thus informed about the status of the invoice.

Implementation Timeline:
The exchange of B2B electronic invoices will become mandatory starting in September 2026, depending on the company's size:

• Large Enterprises (GE)
• Intermediate-Sized Enterprises (ETI)
• Small and Medium-Sized Enterprises (TPE/PME)

Exchange Formats:
Electronic invoices must include a minimum structured data set, complying with the European semantic standard EN16931.

• Core Formats: XML/UBL, XML/CII, Factur-X
• Other Formats: EDIFACT, etc.

Archiving period:

• The minimum requirement is 6 years under tax law and 10 years under commercial law.

Reference links:

• AIFE: Agency for State Financial Information Technology
• DGFiP: General Directorate of Public Finance
• Tax Authority: External Specifications
• FNFE: National Forum of Electronic Invoice