E-invoicing Reform in France: Clarifications from the DGFiP

At a recent meeting organized by the FNFE, several questions were submitted to the DGFiP concerning the new electronic invoicing obligations. This article presents the answers provided by the French tax authorities.

New mandatory information on invoices

The application date for the new mandatory statements has been postponed to September 1, 2026. As a reminder, invoices will need to include:

• The customer's identification number (SIREN)
• The delivery address, if different from the customer's address
• An indication of whether the invoice relates to a sale of goods, services, or whether it is a mixed invoice
• The option for businesses to pay VAT on a cash basis for service invoices, if they have opted for this method

Transfer of data outside the EU

A strict reading of the decree prohibits a Partner Dematerialization Platform (PDP) from transferring data it manages for its customers to systems not hosted in the EU. However, this issue can be circumvented by using a dematerialization operator (OD) whose system is hosted within the EU.

Regarding data transfer, two questions remain to be answered by the DGFiP:

• Is it possible to specify that companies can ask for their data to be sent to them wherever they wish?
• Is a consultation on a portal or a call via an API made by the company considered to be a data transfer within the meaning of this article? The same applies if the data is transmitted by e-mail (the last mile for an SME, for example).

This issue has significant implications for businesses, many of which manage their invoices from shared service centers located outside the EU (such as in India). Additionally, some organizations have their information systems hosted in single locations outside the EU (like the USA). The clarification of these points is crucial and ongoing.

Electronic invoicing : What is the scope of SecNumCloud certification?

Several questions about the SecNumCloud certification remain unanswered by the DGFiP. The certification requirement applies to cloud hosting, but what about processing components carried out in environments hosted within the EU that are not SecNumCloud certified? For example:

• Services for converting, transforming, and creating readable invoices
• Electronic signature or stamping services
• Peppol access point for transmission (sending/receiving invoices)

Clarifications on these points are essential for businesses preparing to comply with the new French e-invoicing requirements. The DGFiP continues to work on providing solutions that meet the needs of businesses.

Next Steps

Basware has applied to be an accredited Partner Dematerialization Platform (PDP) by the French government. We are collaborating closely with the Relay Community to ensure compliance with the forthcoming reform. Discover more about our e-invoicing solutions or contact us for a personalized consultation.