Recent years have seen a surge in the number of countries pushing for the introduction of modern e-invoicing and e-reporting solutions. Obvious advantages flowing of rapid document dematerialization and digitization outweigh the initial burden of system development and adoption.
Even though many e-invoicing systems tend to be similar, all have their own regional flavors tailored for the intricacies of the local tax landscape. The same applies to the upcoming French e-invoicing and reporting system. While sharing a general concept with other established solutions, it features an array of unique features to facilitate efficient document and information exchange.
What are the major differences between France’s e-invoicing mechanism and similar systems introduced in other European countries? Might the French model have an edge over other systems? Read our article and find out.
State of E-invoicing in Hungary
Since July 2018, entities issuing invoices in Hungary have been obliged to report data regarding each issued invoice to a government-run platform operating in a real-time invoice reporting (RTIR) model. Even though invoicing is not strictly regulated, there is still a duty to furnish the tax authority with relevant invoice data in the correct file format (namely NAV XML V3.0) for it to be accepted.
The Hungarian system does not facilitate any kind of document exchange for B2B, B2G or B2C traffic.
State of E-invoicing in Germany
In 2020, Germany introduced mandatory e-invoicing for B2G transactions at the federal level, with numerous federal states voluntarily adopting it.
Due to the lack of a single publicly sanctioned e-invoice processing model, the approach is highly decentralized. Entities may decide whether to process invoices in a structured or more traditional manner. Enterprises can also process documents via the PEPPOL network, using the PEPPOL BIS 3 and XRechnung formats (known in France as Factur-X).
Germany’s central government offers its own e-invoice processing platform (Zentrales Rechnungseingangsportal OZG-RE), but a number of federal states created their own invoicing portals.
To facilitate document exchange in such a fragmented landscape, the federal authorities set up a unified invoice routing system (Leitweg ID) for governmental entity recipients. The German authorities are also preparing to introduce a countrywide B2B e-invoicing obligation. The federal government has obtained EU permission to implement the invoicing system at the start of 2025. In July 2023, the federal Ministry of Finance proposed that the mandate be postponed until the 1st of January 2026.
No official propositions regarding the model of a future e-invoicing system have yet been made.
State of E-invoicing in Poland
The country is right on the cusp of introducing mandatory B2B invoicing based around a central invoice clearance platform (KSeF). Isuing e-invoices via the platform will become obligatory from the 1st of July 2024.
Poland’s KSeF platform is designed to become a hub for issuing, receiving and storing e-invoices. It is set to be used solely for the purpose of processing B2B invoices, as B2G invoicing is already handled by a separate platform (PeF), and B2C invoicing will remain as it is.
There will be two options for accessing the KSeF platform’s functionalities: through the official website or using an API via an authorized partner’s platform.
State of E-invoicing in France
France’s proposed e-invoicing and e-reporting system aims to combine and enhance many other systems’ features to maximize functionality and streamline operations.
The French model will be based on dual modes of invoice exchange, either via a public platform (PPF) or directly between authorized private platforms (PDPs). Invoicing entities will have a choice of solutions best suited for their type and scale of operations.
PPF (unlike other countries’ solutions) will accept three different document formats – UBL, CII and Factur-X. In addition, authorized private platforms (PDPs) mean that invoice issuers and receivers will be able to keep using their current reporting and invoicing software, as all conversion and data extraction tasks will be handled by the PDP.
Similarly to the German approach, the French system will feature a central directory for invoice routing. However, it will have a much broader scope – covering B2B invoices as well.
Apart from facilitating e-invoice issuing, the French solution will include an array of e-reporting for international B2B and B2C transactions. This means that PPF, together with services offered by PDPs, will offer a complete package for e-invoicing and reporting.
Comarch as a registered private platform (PDP)
Comarch has been a participant in the process of introducing the new e-invoicing system from the outset. We have been taking part in a series of PDP registration workshops, gaining the legal and technical knowledge necessary for authorization as a registered platform. Thanks to participation in the processes leading up to establishing the system, we intend to gain invaluable experience to provide the best level of service as a PDP right at the start of the mandate.