France: Requirements for mandatory e-invoices beginning 2023

France: Requirements for mandatory e-invoices

A provision of the Finance Bill for 2020 (law n°2019-1479, article 153) provides for the phased-in introduction of mandatory e-invoicing (electronic invoicing) between taxable persons. Thus, companies will no longer be able to issue or receive paper invoices.


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The requirement to provide e-invoices to businesses is combined with a requirement to transmit the data of these e-invoices to the French tax authorities as part of an e-reporting mechanism.

These requirements are to be phased in during the period between 1 January 2023 and 1 January 2025.


A report was submitted to the French Parliament regarding the conditions for implementing the e-invoicing obligations, and identifying and evaluating technical, legal, and operational solutions as well as certain constraints for stakeholders. The government then in early November 2020 submitted a legislative amendment within the framework of the Draft Finance Bill for 2021 that aimed at specifying the terms and conditions for application of these e-invoicing obligations. The amendment was adopted by the National Assembly on first reading.

Phased-in between 2023 and 2025

Under the legislation, all businesses must be able to receive e-invoices beginning 1 January 2023. The schedule for phase-in of the e-invoicing requirements between 2023 and 2025 depends on the size of the company:

  • 1 January 2023 for large companies
  • 1 January 2024 for mid-sized companies
  • 1 January 2025 for small and medium-sized entities and others

Reporting to tax authorities

The legislation clarifies the scope of the French tax authorities’ e-reporting mechanism regarding:

  • The transmission of data concerning business-to-business transactions
  • The transmission of data concerning business-to-consumer transactions
  • The transmission of data concerning transactions with foreign operators
  • The payment status of invoices

Notably, the scope of the e-invoicing measure would allow information to be transmitted to the French tax authorities about transactions that are not subject to e-invoicing requirements (e.g., business-to-consumer transactions).

The requirement for a reliable audit trail documentation has been reiterated by the French tax authorities.

For more information, contact a tax professional with KPMG Avocats in France:

Laurent Chetcuti |

Armelle Courtois-Finaz | 

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