19 June 2025

France publishes new standards for E-Invoicing Reform

  • The Association Francaise de Normalisation (ANFOR) published e-invoicing standard AFNOR Standard XP Z12-014 on 13 June 2025, introducing updated business-to-business use cases.
  • This standard includes significant changes to the 36 previously outlined use cases.
  • Multinational entities must familiarize themselves with these standards and stay informed about updates, as the XP Z12-014 standard will be revised again by the end of July 2025.
  • Affected entities should consult with tax advisors to ensure proper implementation of the new e-invoicing standards and to navigate the complexities of compliance effectively.
 

Executive summary

The Association Francaise de Normalisation (ANFOR) published a new voluntary electronic-invoicing (e-invoicing) standard in France on 13 June 2025. Specifically, AFNOR Standard XP Z12-014 and its annex provide new business-to-business use cases as instructed by the ANFOR commission, acknowledging the refocused role of the Portail Public de Facturation (PPF) and its impact on the overall e-invoicing system architecture. Although the new standard refers to the same 36 cases identified in the previous version of the V2.4 specifications published by the Direction Generale des Finances Publiques (DGFIP) in July 2024, these use cases have undergone significant changes compared to their initial description and instruction.

Standard XP Z12-014 and the first pages of Annex A summarize the nominal core of an electronic invoice (i.e., without specific use case). Annex A also includes the instructions for the 36 use cases identified in previous versions of the external specifications.

Three AFNOR standards

The XP Z12-014 standard aims to explain various use cases corresponding to business practices, generally organized by sector. The goal is both (1) to propose best implementation practices, whether to implement invoice data in the core minimum formats subject to a separate publication (XP Z12-012) or to use lifecycle statuses in exchanging and processing kinetics, and (2) to define a minimum functional core that partner dematerialization platforms (PDPs) are required to implement.

The ANFOR XP Z12-012 standard, published at the end of May 2025, describes Formats and Profiles of Invoice and Lifecycle Status messages, constituting the minimal core applicable to the E-Invoicing Reform in France issued in May 2024. This standard outlines all the data and management rules applicable to Flow 2 (e-invoicing invoice) as well as the management rules and expected format of Flow 6 (lifecycle), data that can also be used within the use cases identified in the AFNOR XP Z12-014 standard. These documents are therefore complementary.

Furthermore, the AFNOR XP Z12-013 standard, also published in May 2025, relates to the presentation of standardized APIs (i.e., IT interfaces) intended for stakeholders involved in electronic invoicing and e-reporting. This standard aims to (1) standardize data exchanges, messages or documents involved in invoice processing and e-reporting (e.g., invoices, lifecycle, directory, e-reporting) and (2) facilitate interoperability between enterprise information systems at large, including hosted management solutions either on-premises or in the cloud (including Operateur de Dematerialization (OD), the IT provider for e-invoicing solutions not being certified), as well as solutions of authorized third parties (e.g., accountants, factors, agents of buyers, third-party payers) and PDPs.

The XP Z12-012 standard is stable. The XP Z12-014 standard (use cases) will be updated again at the end of July 2025.

Implications

Multinational entities affected by these e-invoicing standards will want to become familiar with them, stay current on related developments and reach out to knowledgeable tax advisors for support in e-invoicing implementation.

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Contact Information

For additional information concerning this Alert, please contact:

Associée EY Société d'Avocats (France) Paris

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

Document ID: 2025-1306