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e-Invoicing, Regulations
January 8, 2025

E-Invoicing and Its Geopolitical Stakes

France’s electronic invoicing reform relies on a Y-architecture, where Partner Dematerialization Providers (PDPs) play a central role in issuing and receiving invoices. This model, also recommended in the European directive ViDA (VAT in Digital Age), is a major step toward tax digitalization and harmonization across Europe.

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Inspired by initiatives in South America, the reform is not limited to electronic invoicing. Tax authorities may eventually regulate other types of digital transactions, including:

  • Stock levels,
  • Shipments and transportation,
  • Salaries,
  • Bank records.

The ultimate goal is to strengthen the fight against tax fraud using advanced tools such as fiscal datamining and artificial intelligence.

Partner Dematerialization Providers (PDPs): The Core of the System

To gain PDP status, candidates must meet stringent requirements:

  1. Data Localization and Supervision in the EU:
    • Ensure data is hosted in Europe.
    • Prohibit data transfers outside the EU.
  2. SecNumCloud Certification Compliance:
    • Protect against extraterritorial laws (FISA, Cloud Act, etc.).
    • Secure data against cybersecurity risks.
  3. GDPR Compliance:
    • Anonymize and pseudonymize personal data, even if minimal on invoices.

These requirements aim to foster the development of European cloud sovereignty and artificial intelligence alternatives.

The Impact of Geopolitical Ambitions

This is not just a French initiative. Across Europe, similar movements are taking shape:

  • ENISA is working on a European cybersecurity certification scheme for cloud services.
  • Local standards such as C5 in Germany and ENS in Spain further bolster this effort.

However, implementing these regulations remains complex:

  • No jurisprudence yet to clarify specific points.
  • Additional requirements are imposed by sensitive sectors such as Banking, Defense, Nuclear, and Aerospace.

For instance, some companies demand:

  • Data storage exclusively in France.
  • A ban on using public American cloud services.

A Challenging Context for Non-European Players

This reform highlights a strategic shift: reducing dependency on American software vendors and hyperscalers. Electronic invoicing serves as a pretext to strengthen French and European digital sovereignty.

Is this just the beginning of a broader independence movement? Only time will tell.

 

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