The Mandatory Electronic Invoice

What is an "Electronic Invoice"?

Pursuant to paragraph VI of article 289 of the CGI, "an electronic invoice is an invoice or a flow of invoices created, transmitted, received and archived in electronic form, whatever it is". Thus, for an invoice to be an electronic invoice, the entire invoicing process must be electronic. This implies that:

• A simple PDF invoice sent by email is not necessarily an electronic invoice
• An electronic invoice is not a scanned invoice

The law provides for several obligations for an electronic invoice to be valid

• Authenticity of its origin: the electronic invoice must guarantee the identity of its issuer 
• Integrity of its content: it must not be modifiable
• Legibility: the invoice must be easily readable

Mandatory electronic invoicing:
Keep up with the legal environment

The 3 accepted formats

The General Directorate of Public Finance has defined 3 electronic invoice formats to be respected for receipt and transmission:

• CII (Cross Industry Invoice):Open standard developed by the United Nations Center. This XML data format of the EN16931 standard has already been adopted as the data format of Factur-X,
• UBL (Universal Business Language): XML-based open standard for electronic data exchange between different business partners and organizations,
• Factur-X: This standard, developed jointly by the French Tax Authorities (DGFiP), theInterdepartmental Union for Electronic Billing (UIEE ) and experts from various industries in France, is a so-called 'hybrid' format that consists of the readable part of the invoice (PDF) and the structured data (XML) of the invoice.

Mandatory electronic invoicing

In September 2021,Ordinance no. 2021-1190 led to the generalization of electronic invoicing between companies subject to VAT. This measure aims to improve the competitiveness of companies in the marketplace. This new legislation puts forward 4 objectives:

1. Strengthen the competitiveness of companies,
2. Simplify, in the long run, the VAT declaration obligations,
3. Improve fraud detection,
4. Improve real-time knowledge of business activity.

   Mandatory electronic invoicing deployment schedule

After several twists and turns, the French government has just approved the definitive dates for the roll-out of electronic invoicing in France on 22.12.2023.

Here are the dates for the implementation of the new regulations:

▶️ Obligation de réception: Pour toutes les entreprises au 1er septembre 2026 (au plus tard le 1er decembre 2026)
▶️ Obligation d'émission: Grandes entreprises et ETI le 1er septembre 2026 (au plus tard le 1er decembre 2026). VSEs/SMEs: September 1, 2027 (by December 1, 2027 at the latest).