Understand electronic invoice (e invoicing)

Electronic invoicing, or e-invoicing, refers to the issuance, transmission, and receipt of invoices in electronic format, with structured data allowing for automated processing. Unlike simple PDF invoices sent by email, electronic invoices comply with a strict regulatory framework and are often integrated with enterprise resource planning (ERP) systems or specific platforms. This practice is experiencing significant growth worldwide, driven by the desire of businesses and governments to modernize trade, reduce administrative costs, and combat VAT fraud.

In France, electronic invoicing has been mandatory for business-to-public (B2G) relations since 2020, and is gradually being extended to the private sector (B2B), with a timetable established by the tax authorities. This reform is part of a broader drive for digital transformation and the simplification of accounting and tax procedures. Companies must therefore adapt to new tools and new obligations, while reaping the benefits of this transition: time savings, reduced errors, increased traceability, and better management of financial flows.

In this context, understanding the challenges, procedures, and impacts of electronic invoicing has become essential for professionals, regardless of their sector of activity or the size of their organization.

I – Terms you need to know to understand e-invoicing:

1 – Electronic invoice:

It is an invoice issued, transmitted and received in a dematerialized form and which necessarily includes a minimum base of data in structured form, which differentiates it from “paper” invoices or ordinary PDF.

It will be sent to the customer via a dematerialization platform (PDP) accredited by the tax administration. The public invoicing portal was ultimately not implemented. The use of electronic invoices allows savings for all companies and constitutes a lever for modernizing the invoicing chain.

Invoices transmitted electronically are only valid if the authenticity of their origin (issuer identified), the integrity of their content (non-modifiable) and their readability are guaranteed. An electronic invoice is generated in UBL, CII or Factur X format. It can then be automatically read and integrated into the customer’s accounting system, without manual intervention.

2 – E-reporting:

E-reporting is the transmission to the administration of certain information (for example, the amount of the operation, the amount of VAT invoiced, etc.) relating to commercial operations that are not affected by electronic invoicing. These are sales and service provision transactions with individuals (or business to consumer transactions “B2C” such as retail) or transactions with operators established abroad (exports, intra-Community deliveries, etc.). E-reporting makes it possible to reconstruct the overall economic activity of a company complementary to electronic invoicing. Its aim is to allow, in the long term, to offer companies a pre-filling of their VAT declarations.

It should be noted that certain foreign companies not established in France may be subject to the e-reporting obligation, when the transaction they carry out is carried out with a person not subject to VAT or a taxable person not established in France and the transaction is located in France with regard to the rules of the General Tax Code.

3 – Dematerialization platforms:

A digital transformation platform is a service provider that will perform several roles:

• issuing, transmitting, and receiving electronic invoices from the supplier to the customer; it will be able to convert the invoice issued by the supplier into a format suitable for the customer;
• transmitting certain invoice data to the tax authorities (identification of the supplier and customer, amount excluding VAT, amount of VAT due, etc.);
• transmitting transaction data to the tax authorities that are not covered by an electronic invoice;
• transmitting payment data for all transactions.

This platform can be the same as the provider’s, or a separate platform.

Any company is free to choose the dematerialization platform(s) of its choice according to its needs. The platform must be able to offer a readable invoice if the user wishes.

Businesses must choose a partner digitalization platform (PDP). This is a platform that has undergone a registration procedure with the administration, for a renewable period of three years. By September 1^st 2026, all businesses, regardless of size, will need to have chosen a PDP in order to receive invoices electronically.

4 – Dematerialization platforms:

This is a directory managed by the tax administration, which constitutes a centralized database. It is accessible to all issuers of electronic invoices, and all companies that will receive invoices in electronic format are required to be listed there. It is mainly used to consult information or make an update request in order to be able to receive invoices at the requested location.

II – The implementation of the electronic invoice:

1 – Implementation schedule:

All transactions carried out between VAT taxable persons established in France must use the electronic invoicing process according to the following schedule:

• from September 1^st 2026 for large companies;
• from September 1^st 2027 for small and medium-sized enterprises (SMEs) and micro-enterprises.

Electronic invoicing applies to all transactions between companies established in France and subject to VAT. This applies to:

• deliveries of goods or services located in France that a taxable person makes to another taxable person and that are not exempt from VAT;
• down payments relating to these transactions;
• deliveries at public auction of second-hand goods, works of art, collectibles, or antiques.

Also affected by this obligation are taxable persons who are not liable for VAT (micro-entrepreneurs and legal persons with VAT exemptions) in order, particularly to control threshold overruns.

2 – The data to be transmitted:

• The new mandatory information to appear on invoices:

These mentions concern the transactions carried out between liable for VAT, they are:

• • • the SIREN number;
    • the delivery address of the goods, where different from the customer’s address;
    • information that the transactions giving rise to an invoice consist exclusively of deliveries of goods or services or consist of both categories of transactions;
    • the payment of the tax according to the debits, when the service provider has opted for this.

• The data to be transmitted to the tax authorities concerning transactions carried out with non-VAT subject persons:

Regarding these transactions, the data to be transmitted by the VAT taxable person are:

• • • SIREN number;
    • the period for which the transmission is made;
    • where applicable, the mention “option for the payment of the tax according to the debits”;
    • the category of transaction: delivery of goods, provision of services or mixed transactions;
    • the total amount excluding tax and the amount of the corresponding tax;
    • the total amount of tax due in France (in Euros);
    • currency;
    • the date of the transactions;
    • the number of daily transactions (for transactions not giving rise to an electronic invoice);
    • the invoice number (for operations giving rise to electronic invoicing).

• The data to be transmitted relating to the payment of service provision operations:

Regarding these payments, the data to be transmitted to the tax authorities are:

• • • SIREN number;
    • the period for which the transmission is made;
    • the effective collection date;
    • the amount collected, by VAT tax rate;
    • the invoice number (for operations giving rise to electronic invoicing).

3 – Format of electronic invoices:

Operators of partner dematerialization platforms and the public invoicing portal must transmit electronic invoices according to one of the three types of formats below:

• The Cross Industry Invoice (CII) format;
• The Universal Business Language (UBL) format;
• The mixed format (Factur-X) consisting of a structured data file in XML format and a PDF file.

4 – How the electronic invoicing system works:

The reform is based on a Y-shaped model, which organizes transactions around three main stakeholders:

• • Businesses: These are the issuers or receivers of invoices. They must use compatible tools to generate and process electronic invoices.
  • Partner Dematerialization Platforms (PDP): Private service providers registered by the government, offering advanced services (ERP integration, tracking, archiving, etc.)
  • The tax administration: This automatically receives certain invoicing data to ensure better tax control, particularly through the additional e-reporting requirement, which also applies to transactions not covered by e-invoicing (e.g., B2C or international).

5 – Frequency and timeframe for transmission of transaction and payment data (e-reporting):

The frequency of transmission of this data by the VAT payer varies according to the tax regime of his company:

6 – Penalty in the event of non-compliance with electronic invoicing and data transmission obligations:

Failure to comply with the billing and transmission of billing data obligations will result in a fine of:

• €15 per invoice in the event of non-issuance of an invoice in electronic format, capped at €15,000 per calendar year;
• €250 in the event of non-compliance with the e-reporting obligation, capped at €15,000 per calendar year.

In conclusion

Electronic invoicing is a legal requirement, but it also opens up new avenues for businesses in terms of productivity, security, and simplification.

Preparing today means:

• Anticipating regulatory deadlines;
• Getting a technological head start;
• Facilitating accounting and tax management.

We therefore advise you not to wait until September 2026 to take action. Start your transition to electronic invoicing now, choosing the right tools and partners for success. We can, of course, assist you throughout the process.

All the team of French Business Advice is at your disposal to clarify you on this subject, so do not hesitate to contact us!