E-Invoicing 2026 unexpected bounce !

The “e-invoicing” saga continues!

The French Ministry of Budget and Public Finance has just published a new press release, n°010, dated 15 October 2024, setting out the practical details of the reform of e-invoicing (link to French version). In essence, while the timetable for rolling out the reform has been confirmed, the scope of the Public Invoicing Portal (PIP) will be reduced.

A much smaller role for the Public Invoicing Portal than originally envisaged

Although the press release is intended to be reassuring, in reality it highlights two points:

1. The latest phasing-in timetable amended by Article 91 of the Finance Act for 2024 has been maintained, although some businesses were waiting for some latitude on the “e-reporting” aspect in particular:

• On 1^st September 2026, with the obligation for all companies to be able to receive dematerialized invoices and for large and medium-sized companies to be able to issue dematerialized invoices;
• On 1^st September 2027, with the obligation for SMEs and micro-businesses to issue dematerialized invoices.

2. The scope of the PIP would be limited to a central business directory service and a concentrator for transactional data, payment data and lifecycle status (as a minimum).

Observations

To date, the provisions of Article 289 bis of the French Tax Code, which allow operators to choose whether to use the Public Invoicing Portal (PIP) or a Partner Dematerialization Platform (PDP), in accordance with the Y scheme acclaimed by the administration from the outset, have not been amended. The press release alone cannot bring about legislative or regulatory change. As the Budget for 2025 is currently under discussion, potential amendments will have to be monitored very closely.

The use of a PDP would become unavoidable and should force all taxpayers who had made the initial choice to use the PIP via a direct connection or a Dematerialization Operator (OD) and those who had not yet defined the target scenario to start thinking now:

• On choosing the right PDP for them,
• On the possibility of becoming a PDP (this is the case for various companies on the official published list).

Although the official list already includes more than 70 PDPs, the compliance audits have not yet been definitively carried out and their registration has only been carried out “subject to conditions”. This uncertainty necessarily creates a degree of uncertainty that is detrimental to taxpayers who choose a PDP that is not definitively registered or that is unable to ensure the required interoperability. If this is not clearly stated, PDPs will probably have to rely on Peppol (Pan-European Public Procurement Online – a European network created in 2008 by the European Commission, which aims to enable the secure sending and receiving of electronic documents in a standardized format), which already ensures this interoperability.

On a wider scale, the draft of the VAT Directive for the digital age (ViDA), under discussion since December 2022, provides for the exchange of data and the use of cross-border electronic invoicing to become the norm within the European Union, and confirms PEPPOL’s role in compliance with the European e-invoicing standard (EN 16931).

Feedback

Our observation is that, while electronic invoicing (domestic B2B) is one of the stages best managed by companies, e-reporting, which is less well known, requires more work given its broader scope (incoming/outgoing intra-EU and extra-EU flows, B2C flows, with some exceptions), requires data to be digitized and, at the same time, invoices to be maintained by any means (a format not covered by the reform).

In practice, as part of our support for certain large CAC 40 and ETI companies, the first to be affected by the reform from September 2026, we have deployed a dynamic and efficient approach aimed at :

1. Carrying out an assessment of the existing situation, to anticipate the need for compliance and the scope of the project

=>Review of the quality of repository data, in particular :

• The composition of invoices
• Review of P2P and O2C workflow
• ERP integration capability
• Archiving

=>Securing the VAT component, in particular :

• VAT audit of flows
• VAT flow mapping
• ERP VAT settings
• E-reporting
• Reliable audit trail documentation (for the record, this will be maintained)

2. Defining an efficient roadmap for co-construction of the target (partial PDP, possibility of becoming a PDP);
3. Carrying out the necessary work to ensure compliance;
4. Training teams and partners in implementation.

This work is carried out in an agile and complementary manner with leading players in the transformation of the Finance function (in particular AXYS). Our Arsene Innovation subsidiary is also deploying innovative customer and financial tools to improve operational performance (ResolveFEC, ResolveTVA).

We’ll be getting back to you shortly with the date of our specific Webinar for France, to explain how the reform is being implemented as a fully-fledged corporate project and to share current best practice.

We remain at your disposal for any assistance and/or questions you may have.

The Arsene VAT Team