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In recent months, we have organized several webinars on the topic of "Electronic invoicing: Horizon 2024, challenges and benefits." During these webinars, Alban GIROUX, Product Director at Docoon and expert member of the FNFE (National Forum for Electronic Invoicing), and Victor DELANCRAY, Sales Director also at Docoon, explained the main points of the reform, the challenges, and best practices for implementing electronic invoicing systems.
If you were unable to participate in these online events, below are the most frequently asked questions during these webinars with answers from our experts. Find answers to questions you may have...
Please note: since this article was written, on October 15, 2024, the government announced a significant reduction in the scope of the PPF (Public Invoicing Portal). This public platform, initially designed to issue, receive, and manage electronic invoices for businesses, will now focus solely on two functions: the business directory and the tax data hub for e-reporting. As a result,all companies will now have to turn to a Partner Dematerialization Platform (PDP) to exchange their invoices and report VAT.
When will we know which companies are registered as PDPs?
As a candidate for PDP (Partner Dematerialization Platform) registration, Docoon was selected by the tax authorities to take part in a pilot phase. During this phase, the players involved in the electronic invoicing reform—PDP candidates, dematerialization operators (OD), and companies—are testing the various electronic invoicing circuits, use cases, and features of the Public Invoicing Portal (PPF), including e-reporting flows. The candidates selected to take part in this pilot phase, including Docoon, are serious contenders for PDP registration in the near future.
Is the electronic billing format already known?
Yes. Three formats will be accepted: FACTUR X (a mixed format consisting of a structured XML data file and a PDF file), C2I (Cross Industry Invoice), and UBL (Universal Business Language). It should be noted that these are "living" formats, i.e., they are scalable and capable of integrating extensions. For example, an extension of the CDII format already allows multiple orders to be managed in a single invoice, with the order reference appearing in the invoice line. Today, these three formats cover all use cases.
Docoon, as a future PDP, already knows how to generate these compliant formats and extensions. That is why some of our customers and partners already know how to generate these feeds.
Will small businesses be required to issue electronic invoices starting in 2024? *
No. According to the schedule set by the legislator, very small businesses must be able to issue electronic invoices that comply with the electronic invoicing reform as of January 1, 2020.January January 2026. However, they must be able to receive electronic invoices from large companies as of January 1July July 2024.
On that date, any small business that has not taken steps to comply with the electronic invoicing reform will receive its invoices on the Public Invoicing Portal (PPF). The company will then have to accept or reject the invoice and will be required to indicate its payment if applicable.
[(*) In a press release dated July 28, 2023, the DGFIP announced that the implementation date of the reform would be postponed indefinitely. This date will be set as part of the work to adopt the 2024 Finance Act. As part of the 2024 Finance Bill, amendment No. I-5395, tabled by the government on October 17, 2023, postpones the rollout, which will be implemented in two stages starting in 2026:
PHASE 1: from September 1, 2026 for all companies receiving goods and for large and medium-sized companies issuing goods
PHASE 2: from September 1, 2027 for small and medium-sized companies and micro-enterprises.]
What would be the advantage of working with a Partner Digitization Platform rather than a Digitization Operator?
Firstly, compliance. The very strict specifications that a Dematerialization Operator must comply with in order to become a Partner Dematerialization Platform are a guarantee of security.
Given the considerable number of companies and authorized representatives who will be registered on the Public Invoicing Portal within a very short period of time, we have little visibility on the timeframes and complexity of the registration process. Unlike an OD, a PDP will be able to register a company directly in the official directory without going through the public portal. PDPs will thus be able to delegate identity verification to third parties (accountants, banks, etc.) and facilitate the registration of millions of VAT-registered companies.
Finally, companies using the services of a PDP will in future be able to exchange other flows such as purchase orders.
Can a company register itself in the official directory?
It is important to note that all companies will be registered by default on the Public Invoicing Portal. If they do not respond, they will have one monthcreate one or more user accounts to retrieve invoices, which requires identity verification. Once identities have be create one or more user accounts to retrieve invoices, which requires identity verification. Once identities have been confirmed and accounts created, the company is free to determine which services it wishes to use.
If the company chooses to collaborate with a Partner Dematerialization Platform, it simplifies its procedures, as the PDP will register it directly in the directory. The DDP also creates and programs the services that the company will need in the directory, without going through the Public Invoicing Portal.
What is the difference between Chorus Pro (the Public Invoicing Portal) and a future PDP such as Docoon?
This question boils down to choosing between going directly through the PPF or working with a PDP. In addition to the essential aspect of compliance, using the services of a PDP avoids having to reconfigure the company's technical account with a new password every year. Once again, we have little visibility on the ergonomics that the PPF will offer its users.
If my ERP is able to issue and receive invoices in the formats required by the electronic invoicing reform, can I communicate directly with the PPF?
It's very difficult, and that's the whole challenge of the reform. As the volume of purchase/sales invoices increases, the process becomes very complicated. If you go through the PPF manually, you will lose a considerable amount of time. The reform provides an opportunity to automate all invoicing flows as much as possible.
Today, the leading publishers of billing tools are choosing to rely on a PDP, in addition to their ability to offer an OD service.
Based on your experience, what are the estimated times for each step in the Order To Cash (ODC) and Purchase To Pay (P2P) cycles?
It all depends on your information system and your publisher. Either you work with a proactive software publisher who will have anticipated the reform, in which case the time spent will be very little. Or you work with a publisher such as SAP, for example, which we know will manage a FACTUR X file at the last minute... Aim for full integration of the electronic invoicing reform into your ERP.
Will all invoices be accessible on the PPF from 2026 onwards, and how will the security of the environment be ensured?
Only B2B invoices from companies subject to VAT in France will be accessible, which excludes B2C and B2B invoices from companies not subject to French VAT. As a future PDP, we hope that the PPF will have the same security and resilience requirements.
How will the PDPs communicate with each other?
We are talking about interoperability between PDPs. To interact with each other, PDPs will rely on the international Peppol network. This is a highly secure network, as it uses standardized protocols and document formats, in case the PPF fails.
Is the expected format for e-reporting already known so that ERPs can interface with the future Docoon PDP?
Yes, we already know the data requirements, but the government has not yet made the e-reporting programming interfaces (APIs) available. Docoon is anticipating this and has already started designing API prototypes for its integration partners. They will then be able to start the development phase, and we will implement the interface as soon as the APIs are available from the DGFiP.
Does Docoon offer a service that allows VAT to be checked in connection with e-reporting?
The aim is to reconcile the VAT return with the pre-return. It should be understood that pre-filled returns will be complete from 2026, when all stakeholders will have started feeding data into the system. We already know that there will be discrepancies, for example regarding discounts, which will not be taken into account in the pre-filled returns. This is a real governance choice for the tax authorities. Docoon is already working on this issue with its clients...
Does Docoon already host data in a SecNumCloud data center? (one of the conditions for PDP registration)
Yes. Docoon has begun migrating part of its data center to a SecNumCloud host. We are among the first future PDP players to have started this project.
Are all companies affected by e-reporting?
Absolutely, with the obligation to follow the official schedule set by the legislator, which provides for several phases of deployment depending on the size and turnover of companies (2024/2025/2026).
In addition to its future PDP service, does Docoon offer upstream support such as project management assistance for the implementation of e-invoicing and e-reporting?
Yes. Today, around fifty distributors offer Docoon solutions on the French and European markets. These distributors manage the project management side of things for medium-sized accounts, while Docoon provides direct support to large accounts (large companies and mid-sized companies).
What will be the reception format on the future Docoon PDP?
As a future PDP, we will be required to manage the three authorized formats: FACTUR X, CD2I, and UBL. We strongly recommend that our customers use the FACTUR X format.
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