On 19 June 2024, the French Tax Administration (FTA) released the latest version (V.2.4) of the "external specifications" for electronic invoicing (e-invoicing) reform. The FTA and the Agency for Financial Information Technology (AIFE) have reaffirmed their commitment to the implementation schedule for the reform, set for 1 September 2026.

The release of these new specifications was previously announced in March 2024, as part of the timeline for the reform. Additionally, in late May, it was confirmed that the Directory containing the addresses of all French companies subject to the e-invoicing requirement will be made available to the certified platforms (PDPs) by the end of 2024.

This new version of the specifications is divided into several documents:

• An introductory sheet that explains the purpose of this new version and summarizes the main changes
• A general folder containing detailed specifications
• A document related to use cases
• Numerous appendices detailing the technical content of the data to be transmitted, including semantic formats of the main flows and examples of technical formats, particularly regarding the consultation and updating of the Directory

The new specifications contain many more changes (exceeding 100) than previous versions had. Without being exhaustive, the main new features include:

• A description and diagramming of directory flows
• An overhaul of the lifecycle management, including for business objects (e.g., invoices, transmission, directory and flows)
• Specifics on the management of invoice readability
• Clarifications on value-added tax (VAT) rounding rules

Furthermore, the semantic formats have undergone numerous changes (especially Flow 2 for e-invoicing and Flow 10 for e-reporting) as well as structural and content modifications (e.g., new data, changes in cardinality, modification of management rules, addition or removal of management rules, and changes in logical type or length).

In addition, although the number and names of the generic use cases documented in the external specifications have not changed, the associated management rules have been extensively rewritten for a significant portion of the cases listed.

The official English version of the specifications should be publicly available later during the summer of 2024.

For additional background on e-invoicing reform in France, see EY Global Tax Alert, France revises schedule for adopting e-invoicing reform, dated 23 January 2024.