Reminder of the reform timetable
The objective of the reform is to dematerialise invoices so that they contain structured data.
The compulsory issue of invoices in electronic format (e-invoicing) and the obligation to transmit information and payment data (e-reporting) will be introduced gradually, depending on the size of the companies:
- from 1 July 2024 for large companies ;
- from 1 January 2025 for medium-sized companies;
- from 1 January 2026 for small and medium-sized enterprises (SMEs).
However, the obligation to receive invoices in electronic format will be mandatory on 1 July 2024 for all companies, regardless of their size.
Advance notice possible for SMEs
Very Small Entities that wish to do so may anticipate the implementation of the electronic invoicing obligation before the 2026 deadline.
The administration specifies that early entry into electronic invoicing (e-invoicing) has no effect on the obligation to transmit e-reporting data. A company may therefore enter into e-reporting separately, as long as it does so at the latest on the date of entry into force of the system applicable to it.
Furthermore, as long as the company is not subject to the obligation to issue invoices, but wishes to issue electronic invoices before 1 January 2026, it may choose to transmit all or part of its invoices in paper format. If it wishes to join the system before the date of entry into force, it must however comply with the applicable terms and conditions, i.e. in particular use a partner platform or the public invoicing portal (Chorus Pro). It should be noted that a simple PDF sent electronically is not considered an electronic invoice within the meaning of the system.
E-invoicing and extraction of invoice data
The tax authorities do not retrieve all the information on an invoice. To facilitate the implementation of electronic invoicing, the number of data to be included in a precise structured format is limited to data useful for the preparation of VAT returns and for combating fraud. This data will be acquired in two stages, with a smaller number in 2024 than that targeted for 2026.
The taxable person must be able to present a “legal” copy of invoices issued and received at the request of the administration (CGI art. 289, V). A copy of the invoice must be kept by the supplier and by the customer for 6 years. In the event of an audit, the administration must be able to ascertain the absence of fraud and compare the invoice issued and retained by the supplier with the one received by the customer from its platform. (That’s why the Piste d’Audit Fiable is important to confirm).
E-reporting and data transmission
If a company that has already joined the e-invoicing and e-reporting system receives invoices that are not electronic, because the sender is not yet subject to it, the recipient company must not transmit the data from these invoices to the administration.
Intra-EU acquisitions of goods are included in the transmission of transaction data of the taxable person established in France, which is not the case for imports. Data relating to imports should therefore not be transmitted to the administration in the context of e-reporting.
It is specified that, in the case where the company has neither cash register nor invoicing software, manual data entry will be possible on the public invoicing portal and should also be possible on the partner dematerialisation platforms.