Invoices in France: novelties as of October 1st

As of October 1, 2019, the regulations applicable to invoices are changing.

New feature :

As of October 1st, the invoices issued must include not only the address of each party (the seller’s registered office and the buyer’s registered office or domicile) but also the billing address of the latter when it is different. In addition, when a purchase order has been issued, its number must be mentioned on the invoice.

Please note: the purpose of adding these mentions is to speed up the payment of invoices (direct sending to the competent department, which is not always located at the head office) and to facilitate their processing.

Another new feature:
To be more dissuasive, the penalty imposed for a breach of the regulations applicable to invoices (absence of invoicing, lack of mandatory information) will consist, as from 1 October 2019, in an administrative fine of a maximum amount of €75,000 for an individual and €375,000 for a legal person (company, association). Until then, it was a criminal fine (of the same amount), which was rarely imposed. The administrative fine is intended to be more systematic and easier to impose by the administrative authority responsible for competition and consumer affairs.

Finally, until then, the French Commercial Code provided that the invoice had to be issued “as soon as the sale or provision of services was completed”. However, the General Tax Code stipulates that the invoice is issued “as soon as the delivery or provision of services is completed”. The administration had also accepted that the invoice could be issued at the latest on the day of delivery in the case of a sale, and at the latest on the day of execution in the case of a provision of services.

For the sake of harmonization with the General Tax Code, and to put an end to any uncertainty, the law now provides that the invoice must be issued “as soon as the delivery or provision of services is completed”.