France (2023 eInvoicing Country Sheet)

Legislation

Article 193 of the Law n°2019-486 of 22 May 2019 codified in the Public Procurement Code [1]  stipulates that holders and subcontractors entitled to direct payment of contracts involved in public procurement shall send their invoices in electronic form, which have to be accepted by all public administrations[2].

The submission of eInvoices to the public sector has been implemented, on a gradual basis, from January 2017 to January 2020 considering the size of companies as described in the Ordinance No. 2014-697 of 26 June 2014 on the development of electronic invoicing repealed by the law n°2019-486.

Article 26 of the amending finance law n°2022-1157 for 2022 states an obligation for taxable persons to send eInvoices with mandatory fields in a structured form to be forwarded to the Tax Administration and to transmit data to the tax administration on Business to Consumers and cross-border transactions by means of a platform (see 9. Reporting requirements).

In December 2023, the French National Assembly indicated the following initial dates for the implementation by an adopted amendment to the 2024 Budget. The proposals are as follows:

• September 2026: All businesses must be able to accept eInvoices. B2B eInvoicing and eReporting for large and medium sized companies. There is an option to extend by further three months to December 2026; and
• September 2027: eInvoicing and eReporting for small businesses. There is an option to extend by further three months to December 2027.

eInvoicing platform and eInvoicing management solutions

In France, due to compulsory legislation concerning eInvoicing, a national unique invoicing portal called Chorus Pro has been developed by the Agence pour l'Informatique Financière de l’État (AIFE), the French national public agency for IT, attached to the Ministry for the Economy, Finance and Industrial and Digital Sovereignty [4].

Except for some contracting authorities (i.e., SNCF, SNCF Réseau, SNCF Mobilités, Caisse des dépôts et consignations), Chorus Pro allows all suppliers of the public sector to submit their invoices, to check their invoice current status and the associated payments. Usage of Chorus Pro is free of charge for suppliers and contracting authorities.

The portal accepts three ways for invoices submission: the manual entry of invoices on the platform, download of PDF or XML invoices (signed or not), and Electronic Data Interchange (EDI) in direct connection or via a service operator.

Chorus Pro allows the use of the UBL Invoice 2.1 standard for different types of formats (including structured OASIS UBL 2.1 and minimal OASIS UBL 2.1). Since April 2018, the platform also allows the use of standard UNCEFACT XML CII 16B, stand alone and through Factur-x hybrid format (with 5 profiles of data for Factur-x).

In 2020, Chorus Pro also implemented an auto-completion mechanism based on the companies’ identification (SIRET) to ease invoices completion. A "My Messages" space has been developed as well to allow suppliers and public structures to communicate about exchanged invoices.

No electronic signature is required for eInvoices, but it is commonly used. The archiving period is10 years[5].

eInvoicing implementation in sub-central level contracting authorities 

Chorus Pro, the central hub for eInvoicing in France, allows suppliers to submit eInvoices to central and sub-central level contracting authorities. The approach for receiving and processing eInvoices is the same for central and sub-central level contracting authorities. Both for public authorities and SMEs, the uptake of eInvoicing is mandatory by law. 

The foreseen eInvoicing benefits are the cost and operational savings, the reduction of administrative burden, the reduced time of payments and the contribution to process automation[6]. At the sub-central level, eInvoicing treatment is undergoing changes directed towards automatizing processes within the system.

Status on the implementation of the European Standard on eInvoicing (EN)

The usage of Chorus Pro (processing compliant documents against the EN) is free of charge for any business partners. Consequently, the implementation of the EN had no direct financial impact on public administrations and suppliers.

The national centralized eInvoicing infrastructure Chorus Pro, already supports UN/CEFACT CII and OASIS UBL 2.1. In order to maximize the benefits of a common standard, France lets suppliers decide which electronic format and channel they will use.

Moreover, access to Peppol, which is enabled through Chorus Pro facilitates the cross-border exchange of eInvoices. Chorus Pro uses CII with Factur-X, the Franco-German standard for hybrid electronic invoicing (named ZUGFeRD in Germany)[7].

Since January 1^st 2020, it’s mandatory for all companies in France to send eInvoices to public contracting entities on ChorusPro portal.

France provided specific support to onboard SMEs and support them in their adoption of eInvoicing. For example, Chorus Pro proposes many ways to accept invoices such as downloading PDF/XML eInvoices and indirect data exchanges with EDI through a service provider, among others.

Monitoring eInvoicing implementation

The Agency for State Financial Information (AIFE) operates the central eInvoicing platform Chorus Pro that monitors the uptake of eInvoicing at both central and sub-central levels, including the number of suppliers using eInvoicing and the number of eInvoices submitted electronically. 

The platform in place, Chorus Pro, is used by all contracting authorities and their suppliers. Chorus Pro took in charge 11 million eInvoices in 2017. 27 million in 2018 and 45.6 million in 2019, 54 million in 2020 and 68 million in 2021 for more than 160,000 public entities and from around 730,000 suppliers.

Approach for receiving and processing eInvoices

The Agency for State Financial Information (AIFE) is responsible for operating the (single hub) eInvoicing platform (Chorus Pro).

Economic operators submitting eInvoices and public entities receiving and processing eInvoices are connected to Chorus Pro, a three-corner operating model. As part of the connection to Chorus Pro in Application Programming Interface (API), the AIFE has set up a “Service Intermediation Platform” for the Transformation of the State in January 2020[8]. This platform pools the API services of both the State and the public sector.

With this platform, the authentication mode for API calls on Chorus Pro (Oauth2 open protocol) has been set up to replace authentication by digital certificate aiming at simplifying the authentication process.

Chorus Pro also allows receiving and processing of eInvoices from non-domestic suppliers (thanks to its connection to Peppol) and allows archiving of the eInvoices processed via the platform.

Use of Core Invoicing Usage Specifications (CIUS) at national level

France has established a national CIUS and implementation guidelines for the EN in order to make the following optional fields of the core semantic model mandatory in the national CIUS[9].

• The code of the administration which receives the invoice (i.e. the identifier of the contracting authority); and
• A sub-code of the Purchase Order number, which is an extra code used by very large organizations like the State

Additional information

Chorus Pro   users can access three different places to get support and enhance their onboarding experience:

• The Chorus Pro portal itself, allowing entities to send invoices to public customers, either directly through this portal or through another means (management software, dematerialization operator, EDI, etc.);
• The Chorus Pro community website, where all the documentation to use Chorus Pro can be found ,i.e. numerous tutorials, as well as access to the support offer proposed by the AIFE;
• The Chorus Pro users' club, where users share their feedback and experience about Chorus Pro.

The French National EInvoicing Forum (Forum national de la facture électronique et des marches publics électroniques – FNFE-MPE)[10] and the German Forum (Forum elektronische Rechnung Deutschland – FeRD)[11] have developed Factur-X, a hybrid invoice based on the EN16931. Factur-X is now implemented in Chorus Pro. Any supplier can send its invoices in Factur-X format to all contracting authorities, even on MINIMUM profile.

Digital reporting requirements

As part of article 26 of the amending finance law  stands the obligation to send e-reporting information on Business to Consumer (B2C) sales, international B2B sales, Intra-EU supply information and payment information for service supplies where the tax point date (VAT eligibility) is on payment. 

Based on the measures deployed between 2024 and 2026, the use of e-invoicing will be mandatory for B2B transactions (established businesses only). The system will be built on the existing platform used for B2G e-invoicing (Chorus Pro). A e-reporting system covering B2C transactions, as well as non-domestic transactions (both intra- and extra-EU) will be built as well. The taxpayer will be able either to use the public platform to deliver the invoice to the counterpart, or to send the invoice to the counterpart through private intermediaries registered by the French tax administration, which will then send the e-invoice to the public administration via Chorus Pro. The platform will extract the data from the e-invoice, and only store those that are necessary for tax control activities (i.e. excluding commercially sensitive information such as the description of the goods or services exchanged). Data on B to C transactions, non-domestic transactions and payment data will also have to be provided by the seller . The platform will accept different formats, CII, UBL and Factur-X, while making sure that companies are making the work to use native structured formats. There will be as well several modes of connection, via an online portal, Electronic Data Interchange, or an API.

The entry into effect of the new obligations will be made in steps. The issuance of einvoices will be made mandatory in July 2024 for large companies, in 2025 for intermediate-size enterprises, and from 2026 for small and medium enterprises. From July 2024, receiving e-invoices will be mandatory for everybody [12][13].

[1] (République Française, 2023),[2] (Edicom, 2021), [3] (République française, 2023)  [4] (Communauté Chorus-pro, 2021), [5] (Compliance updates – France, 2023), [6] (CEF Digital, 2020), [7] (Forum National de la Facture Electronique, 2021), [8] (PISTE, 2021), [9] (Ciciriello, 2021), [10] (Forum National de la Facture Electronique, 2021), [11] (Forum elektronische Rechnung Deutschland, 2021), [12] (VAT in the Digital Age Report, 2022), [13] (République française, 2023)

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Last updated:  Feb 19, 2024 16:30