Comarch on the Way to Becoming a PDP in France

France is about to switch from post-audit e-invoicing to a clearance model in 2024. That means e-Invoicing will become obligatory for businesses. Companies will have to choose either a certified private platform (PDP) or public invoicing portal PPF. Comarch is on its way to deliver the first one.

Comarch an official candidate

From the very beginning, Comarch has participated in PDP registration workshops. These meetings include legal and technical knowledge. Thanks to our specialists, information gained there has been analyzed and implemented in our solution. Comarch met the deadline for application launch and submitted it successfully before 21 October 2022. A dedicated department that can receive applications from operators to be registered as a PDP will be created next spring.

If you would like to know more about the e-invoicing obligation or our offer, let’s get in touch.

PDP responsibilities

A registered private platform (PDP) is a service provider that will be responsible for forwarding invoices in dematerialized format from the supplier to the customer, and will have to extract certain data from these invoices and forward the information to the tax authority.

There will be three acceptable invoice formats. These are UBL, CII and Factur-X (mixed format), but during a transitional phase, companies have the option to submit invoices in unstructured PDF format on their platform. The platform must carry out a transformation before forwarding the expected data to the recipient and the tax authority in a structured or mixed format.

PDP requirements

As intermediary between a supplier and a customer, a PDP must be able to transform the supplier’s invoice format into a format that suits its customer. This will be carried out under conditions that will ensure, in particular, the integrity, authenticity and completeness of the data.

PDP must be able to:

  • Forward electronic invoices, in a structured format, to their recipients’ platforms
  • Receive invoices and make them available to their recipients
  • Retrieve and forward mandatory invoice data to the tax authority
  • Receive and control e-reporting data (transaction and payment) and forward this information to the tax authority
  • Perform compliance controls on invoices and transaction data before forwarding
  • Manage the processing status of e-invoices
  • Provide the public invoicing portal with the information needed to update the directory

What’s next?

Comarch keeps in mind that obtaining a registration number in the central directory is required, and will take steps to obtain it. To do it, a candidate must provide the package information to demonstrate its ability to comply with defined security requirements. This also applies to the obligation to submit a compliance audit to the tax authority before the end of the first year after the registration number takes effect.

There’s more you should know about e-invoicing in Francelearn more about the new and upcoming regulations.


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