B2B electronic invoicing: what are the obligations for 2023?

B2B electronic invoicing to become mandatory from 2023

Since January 1, 2020, all French companies have been under the obligation to send their invoices to public entities in electronic format, via the platform Chorus Pro. Initially confined to B2G (business to government) B2B electronic invoicing: what are the obligations for 2023?exchanges only, this provision is now in the process of being imposed on B2B (business-to-business) exchanges as well.

3 billion This is the number of B2B invoices published each year in France, as an indication of the enormously high stakes concerning the successful dematerialization of invoices.1

Through its Article 153, the 2020 Finance Law indeed introduces this new obligation for electronic invoicing for all B2B exchanges subject to VAT. This will also be accompanied by the obligation of e-reporting, requiring the additional transmission of data in order to allow the administration to monitor the transactions carried out. Although the outlines of this reform may still be changed, particularly within the framework of the ongoing consultations, the roll-out of this obligation will probably be carried out in 3 stages:

• 2023: all companies, regardless of their size, will need to be able to receive invoices in electronic format, while large companies will also have an obligation to issue their invoices electronically;
• 2024: mid-size companies (referred to in France with the initials ETI) must have implemented the issuing of electronic invoices;
• 2025: the obligation to send invoices in electronic format will be extended to very small businesses and SMEs.

After Italy and Portugal, France alsoplans to become the third country in the European Union to generalize B2B electronic invoicing. This change also echoes the expected future changes to harmonize VAT practices across the continent, such as the eIDAS Regulation which will be applied to data filing and electronic identification.

Lessons from the DGFiP report

Faced with the high stakes represented by the transition to electronic invoicing, the General Directorate of Public Finances (DGFiP) issued a report on the subject last October, entitled VAT in the digital age in France. Based in particular on the results of a first experiment carried out in 2020, via a B2B portal similar to Chorus Pro, the document first details the 4 main objectives of the reform:

• To fight against tax fraud: by allowing in particular the automated cross-checking between invoices issued and invoices received, the measure aims above all to reduce the observed gap in VAT revenues. This should also facilitate the detection of hidden activities (undeclared work for example), make it possible to subject marketplace sellers to VAT or even ensure automatic monitoring of companies. The French Court of Auditors (Cour des Comptes) estimates that this measure could increase VAT revenues by around 15 billion euros each year.2
• To strengthen the competitiveness of businesses: the digitization of invoicing also aims to reduce the administrative burden on companies and the corresponding cost that this represents (processing, verification, monitoring, dispute management, etc.). The French Ministry of the Economy also estimates that electronic invoicing will make it possible to achieve 50 to 75% savings compared to paper processing.3
• To monitor business activity in real time: the measure should also provide a more accurate and real-time view of the country’s economic activity, sector by sector. This phenomenon was already observed in Italy during the Covid-19 lockdown periods, for example. What is the interest of this change? This will make it possible to adapt national economic policy more quickly and in line with the actual economic situation.
• To automate VAT declarations: in the long term, the government intends to propose prior completion of VAT declarations, based on information obtained from invoices transmitted electronically. Companies would thus only need to check the elements already completed and, if necessary, to make corrections, allowing them to reduce the human and economic cost of declarations.

In this report, the DGFiP also highlights a major problem: the obligation of electronic invoicing will not be sufficient to achieve the 4 objectives mentioned above. Why is this the case? Quite simply because the information included in invoices does not in itself make it possible to have a global view of the situation of a company in terms of VAT payments. This is why electronic invoicing will potentially need to be supplemented by a mandatory transmission of additional data, also called e-reporting. It is envisaged that this will focus on the following elements:

• data relating to non-domestic sales;
• B2C transactions;
• payment data.

Two consequences for companies that can already be anticipated now

For companies subject to VAT, the switch to electronic invoicing is a major challenge, especially since most do not have the resources to introduce it and the framework for the reform is still unclear. Be that as it may, for professionals, it is important to focus now on two facets that will be essential for updating the invoicing function: architecture and format.

1 million This is the number of French companies which, according to their own estimates, will not be ready on January 1, 2023.4

The architecture chosen for the implementation of electronic invoicing will probably be based on the model currently in place in Mexico, providing for an extension of Chorus Pro in order to collect data from e-reporting. In this configuration, companies would have three possible options for transmitting their invoices:

• manual entry or the submission of invoices directly on Chorus Pro, which would only be possible for companies with a limited billing volume;
• the automated sending of invoices, via a connection between a certified software program (ERP, checkout software, etc.) and Chorus Pro;
• the use of a certified third-party platform, authorized to send invoices to companies without having to go through the Chorus Pro platform.

The format of invoices also deserves all the attention of companies, especially since they will all be required to receive them in electronic format from 2023 onward. Although many questions are still pending (conversion issues, the qualities required of the original invoice, the conditions for the obligation of readability, etc.), the DGFiP report suggests that professionals will have the choice between three different formats:

• a standardized and structured format based on the use of an EDI (electronic data interchange), through which the company would publish its invoice;
• an unstructured format, based on free invoice creation, in PDF format for example;
• or a hybrid format, associating images and structured data.

Becoming progressively compulsory between 2023 and 2025, B2B electronic invoicing will be an obligation for all companies, especially since it seems clear that it will also be extended to B2C in the medium term. Although the procedures are still subject to further modification in the months to come, it is vital to tackle the issue immediately, as the deadlines are short and the changes required are enormous.

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1 According to the Direction Générale des Finances Publiques Report La TVA à l’ère du digital en France, October 2020. (link in french) 2 La fraude aux prélèvements obligatoires, Cour des comptes, 2019 (link in french) 3 Dematerialization of invoices and accounting and financial management, Ministry of the Economy, Finance and Recovery, 2020 (link in french) 4 2020 Finance Law: impact of the generalization of BtoB electronic invoicing on VSEs & SMEs, OpinionWay for Quadient, 2020 (link in french)