Electronic invoicing: the scope of e-reporting of transaction data

The obligation to receive electronic invoices will apply to all VAT-registered businesses from July 1, 2024. Between 2024 and 2026, the issue of electronic invoices will become compulsory for these same players. The other forthcoming obligation for businesses concerns the e-reporting of transaction data. What you need to know about its scope and implementation.

E-invoicing and e-reporting

Article 26 of the amended Finance Act for 2022, which incorporates the provisions of the ordinance of September 15, 2021, sets the framework for the gradual generalization, from July 1, 2024, of electronic invoicing (e-invoicing) and the obligation to transmit transaction and payment data to the administration (e-reporting).

The requirement for electronic invoicing or e-invoicing applies to companies based in France that are subject to VAT and carry out transactions on French territory. This type of transaction is also known as "B2B". Transactions benefiting from VAT exemption under articles 261 to 261 E of the French General Tax Code are exempt from invoicing.

The obligation to transmit transaction and payment data, or e-reporting, applies to companies subject to VAT and trading with non-taxable persons (B2C transactions) or companies not established in France. VAT-exempt transactions do not fall within the scope of this obligation.

A decree and an order dated October 7, 2022 set out the application of these two obligations, and in particular :

  • the conditions for obtaining the status of partner dematerialization platform operator,
  • the tasks carried out by the public billing portal,
  • the compliance checks that operators will have to undergo,
  • billing, transaction and payment data to be transmitted by companies,
  • formats to remember.

To comply with these obligations and keep your accounting under control, it may be a good idea to call on a professional such as a chartered accountant.

Implementing the e-reporting obligation

If your company is subject to the e-reporting obligation, you will need to transmit the transaction data defined by decree to the administration via a partner dematerialization platform. Transmission methods and formats vary.

For example, cash register software facilitates the transmission of data in dematerialized, structured format. If you send electronic invoices to your private customers, you can submit them directly to your partner dematerialization platform (PDP) or to the public invoicing portal, which will extract the data needed for e-reporting to the tax authorities.

On the other hand, if you don't have cash register software, or if you don't file invoices, you'll need to transmit or enter a summary statement of the transactions carried out over the period. The data transmitted for e-reporting purposes will then be limited to the amounts of the transactions and the related VAT.