Press release no. 010 of October 15, 2024 from the French Ministry of the Budget and Public Accounts calls into question the inter-company billing mechanism defined by law no. 2022-1157 of August 16, 2022 – art. 26.
In this press release, the French government announces that it will give priority to the ‘directory’ and ‘concentrator’ roles, in order to meet the deadlines with its own resources.
Given that this prioritization is to the detriment of the role of dematerialization platform, this amounts to saying that the State is giving up on the PPF to give the PDPs a monopoly in the exchange of invoices by 1er septembre 2026.
We denounce this decision and demand that the French government respect its commitment to deliver a Public Billing Portal (PPF) that is accessible and free to all.
The decision to abandon the PPF is further proof of the State’s inability to complete the B2B electronic invoicing project in its current form.
This hasty, unilateral announcement, which contradicts article 26 of law no. 2022-1157 of August 16, 2022, also shows that the project is taking on water from all sides.
After repeated delays, neither the scope, nor the schedule, nor the communication are properly mastered by the AIFE.
The State’s inability to meet its obligations is jeopardizing the implementation of the reform and creating a poisonous climate.
These shortcomings are a cause for concern and incredulity, when they are accompanied by soothing justifications that all these dysfunctions are being carried out for the good of the Enterprises, when in fact they are suffering the consequences.
Companies that anticipated the reform are seeing their investments called into question.
Publishers who wanted to accompany and facilitate it are plunged into uncertainty.
Only the PDPs that are cornering the market are welcoming it, but they make it clear that this is not enough.
On the substance of the problem, the initial ambitious choice to combine a centralized model ‘à la Chorus-Pro’ and an innovative decentralized model DCTCE now appears for what it is: the failure of a pretentious project that far exceeds AIFE’s capabilities.
After years of delay, everything points to the need to return to what AIFE knows how to do, i.e. a centralized model like Chorus-Pro.
- AIFE has already mastered this model with Chorus-Pro since 2017,
- It can be extended to B2B, as demonstrated by the experimental phase conducted by AIFE and DGFiP in early 2020,
- It is much simpler and faster to implement, as shown by the example of Italy, which has been using it for years,
- It is more secure, as data is grouped together by design in a single government portal, which ensures security and control.
- It is open to all players in the reform: taxable persons, publishers, ODs and PDPs included in the role of OD.
However, the AIFE would have us believe that we should give up on the PPF and continue to strive to develop a decentralized solution which it does not control, and which suffocates it with its complexity?
In this decentralized solution, the transmission of invoices would be entrusted entirely to a few private PDP companies, which the State could trust after a registration procedure and periodic checks.
Can we legitimately believe that the State can effectively control a hundred private IT platforms when it is unable to design its own within 4 years?
The implementation and operation of this solution is extremely complex, a complexity that the French government has not yet fully grasped, as the data will pass through a galaxy of heterogeneous private platforms with no direct government control, using proprietary interfaces that are not standardized.
This already entails massive costs for the State, which must put in place cumbersome legislative, technical and administrative procedures to retain a minimum of control over the data and the players in this future gas factory.
Finally, the launch of this solution will necessarily be accompanied by a phase of instability, as the PDP market contracts and becomes concentrated.
At a time of budget restrictions and the need to simplify business life, we wonder why the French government is so determined to commit its resources to the construction of a complex distributed model that favors the private sector, fractures and weakens data flows, restricts government controls and accumulates a cascade of delays…
We interpret this perseverance as a race to the front on a poorly controlled perimeter, which must be halted quickly to return to a centralized and controlled model.
Further proof of this headlong rush is provided by the new amendment n°I-2059 to the Finance Bill for 2025, proposing (yet again!) to postpone the deadlines by one year. This amendment was rejected on November 7, but it clearly shows the feverishness and lack of preparation of the authorities in charge of this subject. We can expect a new proposal to postpone the deadline for the law’s entry into force.
In conclusion…
Applium does not understand this decision to abandon the PPF, which imposes a single, costly choice on French companies and jeopardizes years of investment by numerous solution providers offering an alternative model (in particular SAP with its SAP Document & Reporting Compliance solution, already chosen by many SAP customers in France).
We will be exploring all avenues of appeal to contest this decision.
At the same time, as a last resort in the event of the French government’s position being maintained, Applium will be studying the A2C solution proposed by Applium and already used by several customers with Chorus Pro:
- the possibility of transforming the solution into a PDP (unfortunately, this would have a significant upward impact on the solution’s cost of ownership)
- the possibility of partnering with a PDP offering a reasonable business model.
We will keep our SAP customers regularly informed of developments.
