France e-invoicing mandate: new decree outlines PDP accreditation process

The French tax administration has issued a new decree (no. 2024-266 of March 25, 2024) clarifying the process for e-invoicing solution providers seeking Platform Dematerialisation Partner (PDP) accreditation as part of France’s e-invoicing mandate. The decree provides more details to assumptions we made in a previous article in January about the timetable for the forthcoming mandate.

Since June 2023, e-invoicing solution providers that wish to become a PDP have had to submit an online application without including the results of their e-invoicing solution’s interoperability tests with the public invoicing portal (Portail Public de Facturation or PPF), as the PPF is not yet ready for testing. Under the new decree, the French tax authorities have implemented a provisional procedure to allow the 58 service providers that have already applied without interoperability tests to obtain accreditation.

Based on our understanding of the new regulation, the PDP accreditation process will have at least 4 steps:

• Eligibility: E-invoicing solution providers that wish to become a PDP have to apply online, providing required documents such as ISO 27001, the SecNumCloud qualification of their hosting provider, and technical documentation describing their e-invoicing solution. The French tax administration then reviews the completeness and consistency of the submitted documents and adds the PDP candidate to the official list available here. 

• Capability: The French tax administration then reviews the content of the technical description of the proposed e-invoicing solution to ensure that the PDP candidate understands the requirements and their practical implementation. Compliant applications will receive a temporary accreditation number. 

• Interoperability: PDP candidates with a temporary accreditation number will have to prove the interoperability of their e-invoicing solution with the PPF. Once the PPF has been made available, the PDP candidate will have three months to carry out the interoperability tests and submit the results. However, the French tax administration has not confirmed exactly when the PPF will be ready for testing. PDP candidates that fail the interoperability test will have their provisional accreditation number withdrawn. 

• Compliance: Within 12 months of having their interoperability test results validated, each PDP candidate will have to go through a compliance audit carried out by an independent auditor. They must then provide the French tax authorities with a compliance report outlining the results of the audit and the SecNumCloud qualification of their hosting provider if this wasn’t provided previously.

Avalara is proud to announce that it has applied to become a PDP and is now formally listed as a candidate.

This is a significant milestone and has involved a huge cross-functional international team working hard to obtain a new ISO27001 certificate for our next-generation E-Invoicing and Live Reporting solution, as well as months of detailed requirements, architectural, and design workshops to ensure and document that our solution meets the French requirements.

Based on communications from the French tax authorities, we understand that the first PDPs will be announced this summer.