invoice compulsory by 2024: decree published

Nov 14, 2022 | Digitalization invoices

On October 7, Decree 2022-1299 and its accompanying order, concerning the generalization of the invoice were published in the Journal Officiel.

It sets out the procedures for implementing the obligations to issue and receive electronic invoices, transmit invoicing data to the DGFIP and make payments.

Even though the numerous workshops organized by the DGFIP and the various technical specification documents they produced had already largely described the conditions of application of the reform, the publication of the decree sets them in stone.

It also provides a number of clarifications and adjustments to bear in mind:

1 - Mandatory information :

The decree announces 4 new compulsory indications that must accompany the invoice :

  • Customer Siren no.
  • sales category (goods, services or mixed)
  • VAT debit option
  • the delivery address if different from the purchaser's address.

These changes will apply according to the same timetable as the introduction of the reform, and will affect all invoices.

2 - The very broad scope of PDP actions

The Digitalization Partner Platforms(PDP) will have a broad and comprehensive scope of action. They will be able to intervene in :

  • Sending, transmitting and receiving the invoice in electronic form from supplier to customer
  • Extract useful data from electronic invoices and transmit them to the tax authorities via the Public Billing Portal(PPF)
  • Receive the transaction data requested by the e-reporting and transmit them to the PPF
  • Collect service payment data.
  • Check the quality of billing, transaction and payment data
  • Ensure correct addressing of invoices using directory information
  • Ensure that invoices comply with tax regulations
  • Manage and transmit invoice processing statuses
  • Keep track of their actions and processed flows

2.1 stringent safety requirements

At the same time, PDPs will have to meet strict specifications, particularly in terms of security. In particular, they will have to be ISO27001 certified as soon as they apply for registration, and guarantee that no data can be transferred outside the EU. PDP user access will also have to meet stringent security requirements (two-factor identification, professional digital identity, etc.).

2.2 interoperability requirements

PDPs will be required to interoperate with the Public Billing Portal and at least one other PDP, as well as with all customer recipients.

In reality, this means expecting future PDPs to offer a totally interoperable solution, except in a few very special cases.(PDPs targeting a restricted community of suppliers and customers).

2.3 the role of feeding and maintaining the directory.

PDPs will also be responsible for registering declared entities and their representatives, and will guarantee the accuracy of this information.

3 - Invoice formats are confirmed

The decree confirms that the UBL, XML CII and mixed PDF A/3 formats + minimum data requirements or more under XML CII are the formats that will have to be used from July 1, 2024. This confirms Factur-x, even if some details are still missing on the format of the readable version of the invoice which must accompany the structured format.

The publication of this decree confirms many of the modalities and parameters for the widespread implementation of the invoice electronics.

Obviously, there are still a few details to be fine-tuned, which should be covered in the next technical specifications and Bofip, due to be published by the end of the year.

However, the reform and its implementation are now sufficiently precise for the work of bringing financial and accounting processes into line and optimizing them to begin.

To support you in this project, which involves far-reaching changes to your company's financial, accounting and tax practices, we have designed a specific consultancy service to help you define your project and embark on your transition with peace of mind, making the most of it.

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