Who says electronic invoice, says new regulations and therefore obligation. So what will be the new information to be included in your dematerialized invoices?
Summary
How will the electronic invoice change the form of invoices?How will the electronic invoice be sent to customers?What will be the mandatory data on an electronic invoice?Electronic invoice and PDF format: the problematic case
In 2023 you will start receiving electronic invoices from major national operators, then increasingly until January 2025, when all your invoices will be received and issued in a very different way from today.
How will the electronic invoice change the form of invoices?
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Paper invoices will be prohibited for invoices subject to French VAT
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Invoices in simple PDF files such as you send or receive a lot will also probably be prohibited in 2025. A transitional phase is being studied for the period 2023-2024.
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You will therefore have the obligation to organize yourself so that your invoices are dematerialized and transmitted in a standardized electronic format among the formats authorized by the tax authorities (Factur-X, UBL, etc.)
How will the electronic invoice be sent to customers?
The mode of transmission will require the use of a Certified Electronic Invoice Platform (PFEC) for the issuance and receipt of any invoice between VAT taxpayers (example of PFEC: Chorus Pro). Sending an email attachment or sending a direct download link to the customer will therefore be prohibited.
What will be the mandatory data on an electronic invoice?
Currently, the information that must be included in an invoice are specified in tax doctrine and some derive from commercial law. They apply to all formats (paper or electronic).
From 2023, the obligation of an electronic format will also expand the amount of data to be mentioned in invoices.
- Certain data will be mandatory to ensure the transfer of invoices to the correct recipient, as well as the return of information to the sender on the payments.
- SIREN or SIRET number of the transmitter
- Client’s SIREN or SIRET number
- The unique number of the invoice
- Part of the data will be extracted by the PFECs and transmitted to the tax administration. The objective being to fight against fraud, then to pre-fill VAT returns (eventually), new information will be required:
- Total or partial payments already cashed
- References to a previous invoice (e.g. for credit notes)
- The references of delivery notes related to the invoice
- The effective date of end of delivery or end of service
- The delivery address for the goods / the delivery address for the services
- The detail of the lines with the articles, the unit prices, the discounts …
You must therefore prepare to integrate these new constraints, and for example start collecting the SIREN numbers of your “business” customers, because these identifiers will condition the entire operation of the system.
Electronic invoice and PDF format: the problematic case
Simple PDF invoices are also called “image invoices” as opposed to “mixed” (like Factur-X) or “structured” (like UBL) invoices. These contain the data in a computer format in addition to the visual display of the invoice.
In a simple “image” PDF, it is impossible to read data reliably, that is, without a character recognition process, supplemented by human verification of reliable recognition of the content.
The cost of verifying the recognition of the content is very high, and would be prohibitive if we had to extract from these PDFs all the information that will be required: many systems can recognize the headers and footers of invoices fairly reliably, but the detail lines is much more complex. In a transitional period, it will probably still be possible to file PDF invoices on the national platform Chorus Pro or certain PFECs, but it will necessarily be necessary to verify or re-enter a large amount of data. It is therefore acceptable from time to time but unrealistic for significant volumes of invoices. It is for this reason that this format will be phased out, most likely in 2025, although it will still be accepted during the phased roll-out of 2023-2024.
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