France's invoicing reform faces criticism

France's electronic invoicing reform has drawn criticism for potentially undermining the benefits of interoperability due to the multiplication of formats and exceptions. The first monitoring committee of the reform, convened on October 8, identified several challenges, including commercially difficult-to-compare offers, complex integration tools, and problems with exchanges between platforms.

Distributed system's intended goals

France's choice of a distributed system with multiple competing platforms was intended to promote innovation, avoid state control, and ensure companies' freedom of choice. While the goal of fostering competition is widely supported, concerns have been raised about the complexity this approach introduces across the entire system.

Belgium's simpler model

Belgium has implemented a simpler model by relying on Peppol, an international network used in public procurement, which allows the exchange of electronic documents through shared standards. Since January 1, 2026, Belgian companies involved in B2B electronic invoicing must use structured invoices with Peppol as the reference channel. This approach enables companies to work with different service providers without worrying about individual connections.

Peppol's design and French adaptations

Peppol's strength lies in its network based on shared rules, common mechanisms for discovering recipients, and infrastructure designed to allow participants to communicate without negotiating individual connections. France has also aimed to use this infrastructure but has introduced numerous specifics that risk diminishing the benefits of an international interoperable network.

Challenges for service providers

Formats are a concrete example, with receiving platforms needing to handle up to five different representations: UBL, CII, and three variations of Factur-X. While this diversity may be invisible to end users, it imposes significant challenges on service providers responsible for ensuring receipt, validation, and processing. The complexity increases with each new requirement and all possible combinations between them.

Future European requirements

This issue will become even more critical starting in 2030 with the European initiative ViDA, which will introduce new electronic invoicing and digital declaration obligations for certain intra-community operations. Europe needs its national systems to converge rather than introduce new specifics that other countries will then have to implement.