Summary:

After the official announcement by the French Government to postpone the mandatory B2B e-invoicing and B2C e-reporting mandates, take note of the updated tentative dates you need to be aware of:

• Obligation to receive electronic invoices
  • From September 1, 2026 for all companies, whatever their size.
• Obligation to send electronic invoices
  • Large companies: from September 1, 2026
  • Medium-sized companies (ETI): from September 1, 2026
  • SMEs and micro-enterprises: from September 1, 2027
• Obligation to transmit e-reporting information:
  • Large companies: from September 1, 2026
  • Medium-sized companies (ETI): from September 1, 2026
  • SMEs and micro-enterprises: from September 1, 2027

What we do know is that the core requirements that make up the mandate and the associated invoicing framework are unlikely to change significantly and will regulate the following:

• The submission, reception, and transmission of e-invoices.
• The exchange of the invoice life cycle information.
• The transmission of e-reporting data to the tax authority in the context of international business-to-business transactions and transactions between businesses (B2B) and the end consumer (B2C) in France.

It will be important that customers include all the data requirements in their invoice data to ensure compliance.

Instructions:

Invoice Data Content

The minimum data content for domestic B2B invoices is defined according to a starting phase and a target state. 

Data content for the starting phase is the following:

• Identity number specified in the first subparagraph of Article R 123-221 of the Commercial Code (SIREN) – taxable person
• Individual identification number provided for in Article 286 ter of the General Tax Code (intra-community VAT number) – taxable person
• Individual identification number provided for in Article 286 ter of the General Tax Code (intra-community VAT number) – tax representative of the taxable person
• Country – taxable person
• Identity number specified in the first subparagraph of Article R 123-221 of the Commercial Code (SIREN) – customer
• Individual identification number provided for in Article 286 ter of the General Tax Code (intra-community VAT number) – customer
• Country – customer
• Category of the transaction: delivery of goods (LB) / supply of services (PS) / dual (LBPS)
• Date of issue of the invoice
• Unique invoice number
• Corrected invoice number if a corrective invoice is issued
• Option to pay VAT on debits (the due date is not the date of receipt)
• Total excluding VAT broken down by tax rate
• Corresponding tax amount broken down by tax rate
• Applicable VAT rate (to be broken down if multiple)
• Total amount payable excluding VAT
• Tax amount payable
• In case of exemption, reference to the legal provision
• Invoice currency code/description
• “Self-billing” indication
• Reference to a special scheme referred to in Article 242 nonies A (15 and 16 of I)
• “Reverse charge” indication
• Date of delivery of the goods or completion of the service
• Date of advance payment if different from date of issue of the invoice

French authorities are planning to extend the data content with the following fields and reach the target state (schedule not confirmed):

• Price reduction (price discounts, discounts, rebates)
• Precise description of the goods delivered or services rendered
• Quantity of goods delivered or services rendered
• Price excluding VAT for each item of goods delivered or services rendered
• Delivery/service address, if different from the customer address
• Date of issue of the corrected invoice in the case of correcting invoice
• Discount information
• Eco-contribution (Art. L.541-10 of the Environmental Code)