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e-Invoicing
November 22, 2024

Update on the E-Invoicing Reform Pilot: Where Do We Stand?

For several months now, uncertainty has surrounded the pilot phase of the e-invoicing reform. Initially planned for early 2024, it has been impacted by the reform’s postponement—now scheduled for September 1, 2026—and the abandonment of the Public Billing Portal (PPF) platform functions.

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A Planned Start… Then a Delay

In September 2023, 116 pilot projects involving over 1,300 companies, supported by their Partner Dematerialization Platforms (PDPs) or Dematerialization Operators (DOs), were selected to participate in a large-scale testing phase. Organized by the French Ministry of Finance, this pilot aimed to validate various exchange scenarios, including:

  • Flows 2, 1, 10.1, 10.3, 10.4
  • Use cases
  • A/B/C circuits

Initially scheduled from January to June 2024, the pilot has since been delayed, with recent communications from the General Directorate of Public Finances (DGFIP) indicating a potential rescheduling to the second half of 2025, contingent on the delivery of a qualification platform for the PPF.

A Mini-Pilot in 2025: Narrower Scope

Currently, a mini-pilot is being considered starting in February 2025, with the sole objective of testing the PPF directory service:

  1. Initially, only a few pioneering PDPs will participate.
  2. The pilot will gradually expand to include all PDPs.
  3. A directory service could go live in production by the end of Q1 2025.

The testing scope will be limited to e-invoicing, specifically focusing on Circuit C (PDP-to-PDP exchanges).

What Testing Is Necessary for the Reform’s Success?

While the mini-pilot represents progress, conducting functional interoperability tests before moving into production remains crucial. However, the question arises: who will organize these tests?

The most likely scenarios include:

  • FNFE or a future Peppol Authority taking the lead in coordinating tests in consultation with PDPs and the DGFIP.
  • Specific tests conducted by AIFE to assess the PPF’s role as a data concentrator, particularly for flows 1 and 10.

Preparing for 2025 and 2026

One thing remains clear: the deadlines of September 1, 2026, and 2027 are non-negotiable. To ensure a smooth deployment of the reform, it will be essential to:

  • Test the various invoicing chains in advance, ensuring their operational readiness in production.
  • Plan for a gradual deployment, allowing companies to begin production as early as 2025, on a voluntary basis.

 

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