Mandatory B2B E-invoicing in France [2025 Requirements]

Introduction

Since January 1, 2020, companies have been required to send their invoices to the public sector in electronic format.

In the near future, the mandatory handling of electronic invoices in B2B transactions will also become a reality. The aim is to simplify business operations and increase competitiveness by reducing administrative burdens, shortening payment times, and increasing efficiency through digitization, as well as simplifying VAT reporting obligations.

Once the reform enters into force, all taxpayers will be required to receive electronic invoices. The obligation to issue e-invoices will be implemented in stages, starting with large companies and eventually extending to all businesses. France presents an interesting case in terms of the model chosen for the implementation of e-invoices, which will be transmitted via Certified Platform (fr. Plateforme Agréée, previously known as PDP - Partner Dematerialization Platform).

E-invoicing Reform Components

The reform will concern:

Companies – both sellers and buyers
The Public Invoicing Portal (PPF) – the public operator that manages the central directory. It collects invoicing, transaction, and payment data, as well as information on invoice processing statuses (lifecycle), and transmits this data to the French tax administration.
Certified Platforms (formerly known as PDPs) – service providers registered with the tax authority that offer invoice dematerialization services. They exchange invoice data, e-reporting information, processing statuses, and directory data with other certified platforms, their customers (acting as sellers and/or buyers), and the Public Invoicing Portal (PPF).
Dematerialization Operators – providers of invoice dematerialization services who are not registered by the administration. These operators cannot directly transmit electronic invoices to their recipients or transmit data to the PPF. However, they can act on behalf of the company through Certified Platforms (fr. Plateformes Agréées, formerly PDPs), including Chorus Pro.

In addition, there are also plans to introduce e-reporting, which would require companies to provide tax authorities with additional data on international B2B transactions and B2C operations, including payment information.

E-Invoicing Implementation Timeline

The new timeline is as follows:

First Half of 2024 – Proposal for the licensing process of Certified Platform (fr. Plateforme Agréée, formerly - PDP).
2025 – Two UAT/Pilot phases:
○ Q1/Q2: Testing of the Directory
○ Q4: Testing of the “Declaration service”
September 2026 – Obligation to issue e-invoices for large and medium enterprises. All entities, regardless of their size, must be able to receive electronic invoices. (This phase may be postponed until December of the same year.)
September 2027 – Obligation to issue e-invoices for small enterprises. (This phase may be postponed until December of the same year.)
E-reporting requirements are expected to follow the same timeline.

Maintaining such a schedule means France will have to apply for an extension of the European Commission’s VAT derogation directive, as the current permission to introduce the planned system is valid only until the end of 2026.

As of March 2025, the French government reduced the VAT registration threshold for services from €37,500 to €25,000.

Comarch Approved as Certified Platform Provider

Comarch covers the B2G mandate through Chorus Pro Connectivity and is recognized as a Certified Platform (formerly PDP) for e-invoicing. Our e-invoicing solution is now fully prepared to support businesses in achieving compliance with the French reform, following scheduled deadlines set for 2026 and 2027.

Comarch transfers the invoice as a registered platform in a dematerialized format from the supplier directly to the customer. At the same time, it will extract specific data from these invoices and provide them to the tax authority (e.g., supplier and recipient identification, transaction amount excluding VAT, VAT amount due, etc.). Acting as an intermediary between the supplier and the customer, Comarch will be able to convert the supplier's invoice format into a format that suits his customer. This will be carried out under conditions that will ensure, in particular, the data's integrity, authenticity, and completeness.

E-invoicing process description

1. e-Invoicing (Facturation électronique)
- Mandatory for: All B2B domestic transactions between French VAT-registered businesses.
- Requirement: All invoices must be sent electronically via a Certified Platform (formerly PDP).
- Certified Platform Role: The issuing Certified Platform (formerly PDPE) processes and transmits the invoice to the recipient's Certified Platform (formerly PDPR), using the national directory (Annuaire) to ensure correct routing via secure platform-to-platform transmission.
- Format: Invoices must be in a structured format (Factur-X, UBL 2.1, or CII).
- Exception: Self-billing (autofacturation) is part of the e-invoicing requirement, with the buyer issuing the invoice on behalf of the supplier.
Process:
1. The supplier sends the invoice to its Certified Platform.
2. The platform queries the Annuaire to identify the recipient’s Certified Platform.
3. The invoice is transmitted securely from one Certified Platform to the other.
4. Flow 1: The issuing Certified Platform (formerly PDPE) extracts key invoice data and sends it to the PPF for VAT reporting.
2. e-Reporting
- Mandatory for: Non-e-invoiced transactions, such as:
  - B2C transactions*
  - Cross-border B2B transactions (international)*
- Requirement: Businesses must report transaction data to the Public Invoicing Portal (PPF) via their Certified Platform (formerly PDP).
Process:
1. The data is extracted either by the Certified Platform or by the supplier/buyer.
2. The extracted data is sent in Flow 10 to the Certified Platform (if extracted by the supplier).
3. The Certified Platform transmits the data to the PPF for VAT reporting purposes.
In addition to e-Invoicing and e-Reporting flows, there are also statuses and directory flows. Statuses enable real-time tracking of invoice and transaction lifecycles, including technical and business statuses. The Annuaire (directory) ensures proper invoice addressing by providing electronic addresses for all recipients and enabling correct routing through identification of each company’s designated Certified Platform.

What you can gain by using Comarch EDI:

Ready to exchange invoices in accordance with the legal framework for e-invoicing set out in Regulation no. 2021-1190 of September 15, 2021 on the extension of e-invoicing to all transactions between entities subject to VAT?
Thanks to Comarch EDI:
- Full compliance with e-invoicing regulations
Ready to be compliant with required UBL, CII, or Factur-X formats and monitor any interruptions in the availability of the platform?
Thanks to Comarch EDI:
- No change in the format used so far, thanks to the translation from any format to the required format
- Effective monitoring of the platform availability
Ready for full control over all documents exchanged with government platform?
Thanks to Comarch EDI Tracking and Archive:
- Easy and instant access to the status of all documents sent to the government platform
- Full insight into all incorrect documents with detailed information about the type of errors and the reason for their occurrence
- Presentation of archived invoices in a structured, readable form for the period required by law
Ready to provide technical support to ensure that all requirements are met?
Thanks to the cooperation with Comarch:
- Configuration of the API connection between the government platform and the Comarch EDI Service
- Support Services of a dedicated Comarch Project Manager during the implementation period of the project
- Comarch EDI Service Desk

1. Legal compliance
Full compliance with the latest data exchange regulations and modern data transfer standards
2. Digitization
Applying new technologies and IT solutions in order to streamline workflows and automate activities and procedures
3. Individual approach
Tailor-made solutions based on processes specific to each company – own road map and a suitable pace of changes
4.Security
Highest level of security for all sensitive and important company data

Frequently Asked Questions

1. What is Chorus Pro (Plataforme Publique de Facturation Electronic)?
Chorus Pro is a public invoicing portal (PPF) for sending structured invoices to the tax authorities in France. For now, it is being used for B2G transactions and soon will be also used for B2B ones.
2. Is e-invoicing mandatory in France?
For now, only B2G e-invoicing is valid in France. For B2B transactions, its implementation was planned for July 1, 2024, while on July 28, 2023, the French government announced a delay.
3. Who is liable to send e-invoices?
Generally, the obligation will affect all sized companies – large, medium and small (each year introducing the obligation for a specific size of companies). In 2024, all companies will be able to take part as volunteers in a pilot phase.
4. How to select best e-invoicing solution and provider?
The trusted partner must be certified as a Certified Platform (fr. Plateforme Agréée, formerly PDP). Their role will be to act as a trusted third party and transform, validate and send invoices to the French tax authority.
A good provider should also have experience in providing similar services in other countries, so you are sure they are exchanging your sensitive data securely, reliably and most of all in line with governments’ requirements.
The best solution needs to be in line with French requirements, so make sure the provider understands and is compliant with all requirements (for example, that they can technically serve the required format factur X).

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