French Interoperability Charter sets an example for global e-invoicing

Blog Compliance, Peppol March 14, 2019

Evelina Eriksson explores the importance of e-invoicing standardisation and why initiatives like the French Interoperability Charter best practice guidelines are the way towards global alignment.

Aligning the standards for global interoperability

The electronic landscape is growing rapidly, and the need to align the standards for interoperability models between e-invoice service providers has never been more present. 2019 saw the implementation of the European standard for e-invoicing, but finding common ground for standardised processes in electronic data exchange between taxpayers and their technological service providers remains an ongoing challenge.

With mounting pressure to comply with increasing regulations, many organisations are creating and managing their own e-invoicing standards, based on varying legal and technical requirements. The lack of unanimity results in difficulties for businesses to understand how to become compliant, remain compliant, and the general do’s and don’ts of e-invoicing interoperability within Europe and beyond.

At Pagero we actively work towards the standardisation and harmonisation of global e-invoicing. For that reason, we support and adhere to the French Interoperability Charter for the Transmission of Electronic Invoices. The Charter was released in November 2019 by the Forum National de la Facture Electronique et des Marchés Publics Electroniques/National Forum on E-Invoicing and Marketplace & Public E-procurement (FNFE-MPE). Documents like these are the foundation for creating a global e-invoicing model that is fair, transparent and efficient across all borders.

Setting best practices for e-invoice exchange

The FNFE-MPE is a French association established in 2012 by the Direction Générale des Entreprises, Ministère de l’Economie, de l’Industrie et du Numérique (DGE) which works to simplify and further the deployment of e-invoicing in France.

As a result of issues presented in the October 2018 report on the European Multi-Stakeholder Forum on E-Invoicing (EMSFEI), the FNFE-MPE compiled a working group to produce the Charter.

The Charter defines best practices for how e-invoice exchange in France should be done in a legally compliant manner, especially when using e-invoice service providers.

Pagero has provided feedback on some aspects outlined in the Charter and is listed as one of the first conformant service providers on the FNFE-MPE site.

Outlined below are some of the aspects which FNFE-MPE is aiming to align in France and the importance best practices hold in your daily operations and future business growth.

“Finding common ground for standardised processes between taxpayers and their technological service providers remains an ongoing challenge.”

A standardised e-invoice format

The French Interoperability Charter recommends that e-invoice service providers first and foremost agree on and use one single technical format for invoice exchange between each other. This should be a standard invoice format which is published and easily accessible, following the European standard EN16931 syntaxes. Examples of these standardised formats include the Peppol BIS Billing 3.0, a Core Invoice Usage Specification (CIUS) of the EN Standard, UBL 2.1 and INVOIC D96A.

Such uniformity will help service providers uphold basic formats which will undoubtedly provide for easier connectivity and streamline the standards and processes of interoperability—ultimately lowering the cost of e-invoicing for businesses.

The Pagero platform is designed for the exchange of a pre-approved e-invoice format between service providers regardless of sender/receiver, resulting in smoother onboarding processes and faster connectivity.

Defining what makes an original tax e-invoice

A tax invoice is an invoice allowed for tax purposes, as opposed to copies or duplicates of the document which are not permitted. It may also be referred to as an “original invoice.” For legal and fiscal compliance, it is essential that trading partners and their e-invoice service providers share a mutual understanding of what constitutes the original tax invoice.

The Charter states that the original invoice issued should be identical to the invoice received. In scenarios where doubts may arise—for example when trading partners exchange an invoice data file and a readable presentation which can both be considered the original invoice—the Charter attempts to align this by stating the following:

“Sender and receiver should share the same vision of what constitutes the original invoice…The original invoice is created under the mandate of the sender (the supplier) in accordance with tax regulations…And that for the duration of the required archiving period, each party is able to provide evidence that the information entered into its accounts is indeed the same information on the original invoice.”

Providing guidelines such as these, the Charter outlines where gaps or ambiguities may arise, how to address them, and how best to align between supplier and buyer.

“The French Interoperability Charter outlines where gaps or ambiguities may arise, how to address them, and how best to align between supplier and buyer.”

Acknowledgement of receipt

Another noteworthy specification of the Charter is that of the sending of receipt. In an interoperability context, receipts or “acknowledgements” are used to indicate the receipt of a message, in this case, an e-invoice. The FNFE-MPE states that “Electronic invoices should be transmitted via means ensuring secure transmission and with integrated technical acknowledgement of receipt.”

The French Interoperability Charter goes as far as saying that the moment the receipt is received by the sending party, the e-invoice is considered transmitted to the receiving party. A statement this clear advocates for implementation and use of receipts in an interoperability context, which is key to determining responsibility in the document exchange between service providers.

Additionally, having these receipts in place can help Pagero Support provide an accurate status of transmission and ascertain liability in e-document exchange.

A template for written interoperability agreements

The Charter highlights the importance that e-invoice service providers “define the conditions of their collaboration” in a written agreement. The Charter recommends the Model Interoperability Agreement (MIA) provided by the European E-invoice Service Providers Association (EESPA) for this purpose. Having such an agreement in place provides transparency, predictability and reduced costs for both service providers and businesses.

Pagero, as a member of the EESPA, has been using MIA for many years to document the details of compliant interoperability exchange with other service providers, and we aim to continue doing so.

Benefitting service providers and businesses

Pagero embraces the initiative taken by the FNFE-MPE and we are confident that the Charter, with its best practice recommendations, will help fill in gaps and move towards necessary harmonisation in the market. The Charter will bring benefits to service providers as well as businesses. From an e-invoice service provider’s perspective, we look forward to being an active participant in similar initiatives as it will help standardise processes and unify the market.

Take a look at the final version of the FNFE-MPE’s Interoperability Charter for the Transmission of Electronic Invoices

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