General information about the reform
What is e-invoicing?
E-invoicing —or electronic invoicing— refers to the issuance, sending and receipt of invoices in an electronic format that contains a minimum set of structured data items. This requirement affects all invoicing exchanges between companies subject to tax in France.
What is e-reporting?
E-reporting —also referred to as "data submission"— refers to sending certain transaction and payment data elements to the tax authorities for all B2C exchanges (with individuals) or international exchanges.
Are there standardized formats for electronic invoices?
Yes, the following three formats will be required: Factur-X, UBL and CII. They form what is referred to as the reform's "minimum set", and they also ensure that the data can be read in a structured way. These formats will be fully managed by the Lucca PDP.
What is the timeline for the rollout of the reform, according to company size?
- September 1st, 2026: Receipt requirement for all companies; issuance requirement for large companies and medium-sized companies.
- September 1st, 2027: Requirement for start-ups/SMEs to issue electronic invoices
What penalties may be applied in the event of failure to comply with the reform?
Failure to comply with e-invoicing requirements may result in financial penalties. The tax authorities have not yet provided details on the penalties that could be imposed. To give you an idea of how significant their impact could be, some initial penalties have been shared:
- In the event of failure to comply with the required invoice format, a fixed fine of €15 per invoice will be applied, capped at €15,000 per calendar year. The penalty will be applied from the second infraction onwards.
- In the event of failure to comply with the e-reporting requirement, a fixed fine of €250 per transmission will be applied, capped at €15,000 per calendar year. The number of transmissions required and their frequency will depend on your company's tax regime. The penalty will be applied from the second infraction onwards.
Companies and expense types affected by the reform
Which companies will be affected by the e-invoicing reform?
All companies subject to paying VAT in France will be affected by the e-invoicing reform.
Are associations formed under the French 1901 Law affected?
Associations formed under the 1901 Law will only be affected if they are subject to VAT. An association that does not conduct any commercial activities and which is not subject to VAT will not subject to this requirement. However, there are some specificities and it is therefore best to contact the tax authorities to get exact information on the matter.
Will the reform also affect international transactions?
No, transactions with foreign companies are not subject to the e-invoicing requirement. However, they are subject to e-reporting, which requires the regular transmission of certain elements of invoice data to the tax authorities. This reporting must be provided for each submission period.
Will expenses be affected?
Expenses are one of the use cases affected by the reform according to latest specific details shared by the tax authorities. To give a specific example, expenses where the supporting documents are invoices on behalf of the company, or expenses that are paid for by company payments methods, will be considered to be electronic invoices that must be transmitted via PDPs.
The State, via the AFNOR committee (French standardization association) is currently working on finalizing the specific details relating to these cases, which will allow us to provide more exact information on how these different use cases will be treated soon.
Partner Digitization Platforms (PDPs)
Do you have to select a PDP in order to ensure compliance?
Yes, all companies affected by the reform must select at least one PDP in order to comply. You do have the option of choosing one PDP for invoice receipt and another PDP for invoice issuance.
Does a PDP have to manage both the issuance and receipt of electronic invoices?
A PDP must have the capacity both to send and receive electronic invoices. However, PDPs are not required to provide a tool to their clients for the management of both the issuance and receipt of documents. Pre-registered actors are therefore going to focus on their current area of expertise.
How can I track which companies have been approved as PDPs by the French government?
The list of provisionally registered PDPs is available on the following website: impots.gouv.fr:List of provisionally registered PDPs. Lucca is officially a candidate for PDP registration and will soon appear on the list, once our file has been validated by the DGFIP (French General Directorate of Public Finances).
How much does a PDP cost?
Prices vary depending on the PDP selected. With its Invoices and Expenses solutions, Lucca is offering a guarantee of compliance at no additional cost.
How can I ensure that my PDP can be used over a long time period?
The process that PDPs have to go through for registration is a long one, requiring companies to produce several certifications. However, given the number of candidates, there is a risk that the market will shrink, and that some companies will no longer be in a position to provide this service. For major actors established in the market, this risk is limited.
Lucca Invoices rollout
How long does it take to implement this type of project?
The time it takes to implement this kind of project varies depending on the complexity of your invoice flows. In general, our timeframes for implementation range from 2 to 6 weeks.
Is the Lucca PDP compatible with ERPs and accounting software?
Yes, Lucca is integrated with the leading accounting software packages on the market, enabling automatic sending of invoices and direct entries into the accounting system.
Resources and contact
Where can I get a demo of Lucca Invoices?
You can request a demo via this link: Request a demo.