Electronic invoicing between persons subject to VAT (“e-invoicing”) and the transmission of transaction data (“e-reporting”) come into force gradually from 01.07.2024 depending on the size of the companies.
Article 26 of the amending finance law for 2022 legalized the content of ordinance 2021-1190 of 15.09.2021 relating to the generalization of electronic invoicing in domestic transactions between persons subject to VAT. The reform, already known to companies, could not be ratified during the finance law for 2022 given the censorship of the Constitutional Council (Cons. const. 28.12.2021 n° 2021-833 DC) (Law 2022-1157
you 16.08.2022 art. 26, OJ of 17.08).
The reform has two main axes:
- the first axis corresponds to the obligation to issue and receive invoices in electronic format (“e-invoicing”). The objective is to dematerialize the invoices so that they can include structured data, that is to say data which constitutes a basis of mentions and which follows a standard agreed between the parties to meet the requirements of EDI. (electronic data interchange);
- the second axis corresponds to the obligation to transmit information and payment data (“e-reporting”). This is for a company to transmit to the tax authorities all information that does not fit into the field of invoicing.
Persons subject to VAT in France will eventually have to issue, transmit and receive invoices in electronic form in their transactions with other persons subject to VAT and transmit the invoicing data to the tax authorities, as well as data relating to transactions not domestic or with a non-taxable person. The confidentiality of this data will be protected by the administration. To fulfill these obligations, companies may freely choose to use either a dematerialization platform known as a “partner” of the administration, or directly to the public invoicing portal Chorus Pro (category&category_id=860d0fdf1bfee41088bb6280604bcbe2).
The amending finance law for 2022 confirms the timetable for the reform, announced by the administration in its “Frequently Asked Questions” devoted to electronic invoicing (available on the website The deployment of the electronic invoicing obligation will be put in place from gradually, taking into account the size of the companies:
- on 01.07.2024 for large companies;
- on 01.01.2025 for intermediate-sized establishments (ETI): workforce of less than 5,000 people whose annual turnover does not exceed €1,500 million or whose balance sheet total does not exceed €2,000 million; and
- on 01.01.2026 for VSEs-SMEs: workforce of less than 250 people whose annual turnover does not exceed €50 million or whose balance sheet total does not exceed €43 million.
Novelty. The law brings a new precision compared to the ordinance concerning the date on which the belonging to a category of companies (large companies, ETI, SME and small companies) is assessed. Thus, it is decided at the level of each legal person on 30.06.2023, on the basis of the last financial year closed before this date or, in the absence of such a financial year, on that of the first financial year closed from this date. date.
Recall. The obligation to receive invoices in electronic format will be mandatory on 01.07.2024 for all companies, regardless of their size.
› As indicated by the Ministry of the Economy, Finance and Industrial and Digital Sovereignty in a press release dated 17.08.2022, construction work on the public invoicing portal has begun to enable the deployment of an experiment from the 03.01.2024, i.e. before the entry into force of the system.
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