Recap of the B2B e-Invoicing and e-Reporting Mandate

France’s B2B e-invoicing mandate is a sweeping reform aimed at digitizing and standardizing invoicing processes for all businesses operating domestically. This initiative is designed to close the VAT gap, boost automation, reduce costs, and improve tax compliance across the French economy.

Legal Framework for the Electronic Invoice Reform in France

The legal foundation for French e-invoicing is rooted in Ordinance No. 2021-1190, published in September 2021, and reinforced by Article 26 of the 2022 Amending Finance Law. The legislation requires all businesses subject to French VAT to issue and receive invoices electronically for domestic B2B transactions, and to report certain transactional data to the public invoicing portal (PPF). The reform builds on the success of the Chorus Pro platform, which has been mandatory for B2G (business-to-government) invoicing since 2020. The mandate will eventually extend to all taxpayers established in France and cover all B2B and B2C transactions. Invoice data will be reported to the PPF in a structured format, either UBL or CIII, and transmitted to the buyer as a hybrid pdf file in the Factur-X electronic format.

Latest Updates to e-Invoicing in France Since January 2025

Originally scheduled to begin in July 2024, the rollout of mandatory B2B e-invoicing has been postponed. The revised timeline now sees a pilot phase commencing in 2025, with full mandatory e-invoicing for large and medium-sized businesses by September 2026, and for small and micro-businesses by September 2027. The legislative vehicle for finalizing these changes is the 2026 Finance Bill, which is under active development, including regulatory workshops with industry stakeholders. An Association Française de Normalisation (AFNOR) standardisation commission has also been established in relation to the electronic invoicing requirements.

The Role of the AFNOR Commission in the Electronic Invoice Mandate

A key player in the implementation is the AFNOR commission, established by the French General Directorate of Public Finance (DGFiP) to address technical and documentation challenges. The AFNOR commission brings together representatives from industry, software vendors, tax experts, and standardization bodies. It operates through five specialized working groups focused on:

• Defining technical specifications.
• Expanding e-invoicing use cases.
• Standardizing APIs for seamless interaction between businesses and service providers or Partner Dematerialization Platforms (PDP).

The DGFiP has revised its contract with AFNOR, now fully funding the commission’s work and allowing free participation for interested parties. The commission’s first plenary session was held in April 2025, with initial outputs from the working groups expected by summer 2025.

The B2B e-Invoicing Pilot Project

The pilot phase, launched in early 2025, is critical for testing the new e-invoicing model in real-world conditions. It involves the Portail Public de Facturation (PPF), service providers, and volunteer taxpayers, aiming to validate technical flows, data exchange, and incident resolution before full-scale rollout. The pilot is designed to ensure that all stakeholders, especially software providers and businesses, are prepared for the upcoming legal and technical requirements.

1.        Initial Testing Phase (Early 2025)

The first phase will begin real-world testing with a limited group of service providers and selected volunteer businesses. PDPs will test their ability to connect with the new centralized business directory (Annuaire), update client addressing information, and exchange invoices with the PPF. A small, representative sample of PDPs and companies will participate in this phase of the pilot, ensuring technical readiness and initial interoperability.

2.        Expanded B2B Interoperability Phase (Late 2025)

The second phase of the pilot will broaden the scope to include more service providers and businesses, focusing on interoperability and data exchange between different platforms. At this stage, participants will test the exchange of e-invoices and e-reporting data between multiple PDPs, and refine processes for addressing, error handling, and data validation. This interoperability testing, likely using the Peppol network, is scheduled for October 2025, ensuring all certified PDPs can communicate seamlessly.

3.        Full Electronic Invoice Functionality Phase (Early 2026)

The final pilot phase aims the complete technical and operational setup before the legal mandate begins. During this phase, participants will complete comprehensive end-to-end testing, including the transmission of e-invoices, e-reporting, and lifecycle data to the French tax authorities, as well as testing the “concentrator,” which processes and verifies directory and transaction data for VAT reporting. This full functionality testing is set for February 2026, and will be the final proof of concept and opportunity to perfect the system before homologation and transition to the full e-invoicing requirements.

4.        Transition to Mandatory Implementation of e-Invoicing in France

While not technically part of the pilot project, this important phase will ensure that all large and medium-sized businesses are ready for the 1 September 2026 deadline, with small and micro-businesses following in September 2027. The DGFiP will make final adjustments based on pilot feedback and provide broad communication and support for all businesses to ensure compliance. PDPs will also make any final adjustments to their systems and ensure that they have complied with all technical, legal and audit requirements before the start date of the mandate.

Looking Ahead to the e-Invoicing Mandate from 2026

France’s B2B e-invoicing mandate is progressing through a carefully staged approach, with continued collaboration between government, industry, and standardization bodies. The AFNOR commission’s work and the pilot project are pivotal in refining the technical and legal framework, ensuring a smooth transition to full e-invoicing by 2027.

eezi, Powered by VAT IT, is a certified PDP and will be joining the pilot program to ensure our readiness to assist our clients as well as to help the French government to develop the technical and regulatory specifications. Please contact us should you wish to join the pilot program as a volunteer and get ahead of the compliance curve!

To learn more about the French mandate, be sure to join our webinar with guest speaker, Lucien Gimenez, on 27 May 2025 at 12h00 GMT. Please register at the following link: https://lnkd.in/eNGrSNx2

You can also read our previous blog posts on France for a more comprehensive look at the mandate: https://blog.eezi.io/peppol-in-france-french-e-invoicing-mandate-and-pdps/ ; https://blog.eezi.io/whats-the-latest-about-french-e-invoicing/ and https://blog.eezi.io/e-invoicing-in-france-all-you-need-to-know/