What is the Fichier d’Ecritures Comptables (FEC) ?
The Ministry of the Economy and Finance published a decree dated August 1, 2013, in the context of tax audits initiated as of January 1, 2014, which precisely defines the details relating to the obligation to make the digital file of accounting entries (FEC) and the expected format immediately available.
All accounting data and entries recorded in all accounting journals in respect of a financial year are to be submitted in a single file, the accounting entries file, in which the entries are arranged in chronological order.
Failure to submit the file will incur a fine and, in the event of an adjustment, a surcharge of 10% of the amount adjusted. All companies are concerned.
Reference texts:
- Loi n° 2012-1510 du 29 décembre 2012 des finances rectificative pour 2012 (1)
- Order of July 29, 2013 amending the provisions of article A. 47 A-1 of the tax procedures book relating to standards for copying files on computer media.
It is necessary to be able to make this file available for the last three accounting years as soon as the Tax Authorities ask you to do so.
The FEC is an offshoot of SAFT-T (Standard Audit File for Tax), an OECD recommendation. It comprises 62 fields and covers a wide range of business areas (accounting, purchasing, sales, management control, inventory, fixed assets). It is very likely that in the medium term we will have to communicate more information than is requested today.
What are the technical elements of the FEC?
- The expected format of the FEC includes 18 mandatory zones in a predefined order (Journal Officiel)
- Flat file with sequential organization and zoned structure
- Characters used must comply with ASCII, ISO 8859-15 or UTF-8 (Unicode) standards.
- The FEC is named according to the nomenclature: SirenFECAAYYMMDD
- Siren à le code SIREN (9 chiffres)
- AAYYMMDD à la date de clôture
What are the solutions on the market?
Choice 1 – SAP standard solution (SAP OSS note using DART)
Choice 2: Customized solution via DART
- DART program (standard data extraction and display tool)
- Specific customization programs (possibility of adding additional zones for specific extractions)
- Carry-forward program (prerequisite)
- Standard extraction for FISC
- Specific extraction with your own specific fields
- The FEC must comply with French accounting standards only: do not take into account entries relating to other standards (IFRS, IAS, US GAAP…)
- Management of entry document status (actual, maintained, etc.)
- Check number range sequence
- Miscellaneous parts journal (OD)
- The problem of archived data in SAP
Points of attention
TIP:
We strongly suggest that you carry out these extractions as soon as your tax years are closed, so as to give yourself the time you need for the operation (not to block the operation of your ERP due to the need for resources), to check the quality of the data, to anticipate possible obstacles with the auditors, to prepare arguments for them and to store the files properly.
Answer Applium : A 4-step packaged offer
Analyze your Information System
- System mapping
- Interfaces for loading accounting entries from external systems into SAP
- Volumetric accounting data:
- Companies
- G/L accounts
- Accounting vouchers
Implement the solution of your choice
With or without specifics, run the carry-forward program and DART to reproduce the FEC.
Check that the extraction is in the expected format and check the quality of the extraction
- Volumetric checks
- Comparative study with accounting tables (BKPF, BSEG…)
- Qualitative checks:
- Standard statement of line items
- Standard statement of balances
- Check income statement and balance sheet account balances before and after retained earnings
Make the file available on your archive and training server for future use
The possible options available
In addition to our basic service offering, we can assist you with additional requirements:
- Modification of SAP settings in the event of major accounting anomalies detected during a tax audit
- FEC archiving:
- OpenText archiving solution
- SAP archive server implementation
Average time to completion :
In project mode and with the appropriate resources, the various stages can be carried out on a continuous basis within 8 to 12 working days, to be adjusted according to the customer’s context (number of SAP instances, use of the New Ledger or not, interfacing with external systems compressing accounting entries in your main IS, etc.).
Once you’ve completed these checks, you can add other fields to the mandatory ones, for more advanced management control purposes. Indeed, some of your company’s departments may be interested in this type of extraction for analysis purposes. For example, you could carry out a tax analysis prior to any DVNI request.
- Every company must have a daybook, a general ledger and an inventory book. Entries in the journal book, which record all movements affecting the company’s assets, are entered in the general ledger and broken down according to the chart of accounts.
- Companies must keep all supporting documents, whether internal or external to the company, for a period of 10 years, to back up each accounting entry.
- Companies must be able to guarantee the security of computerized documents, notably through specific numbering and validation procedures.
- Computerized accounting systems must make it possible to reconstitute the elements of the accounts, statements and information subject to verification from the supporting documents supporting the data entered, or to retrieve the data and supporting documents from these elements of the accounts, statements and information.
- Companies are required to close their accounts annually, producing a balance sheet, income statement and notes, which form an indivisible whole. A control procedure must be in place to ensure that the chronology is fixed and that the accounting data is not altered.
Reminder of accounting obligations :
Applium has been involved in FEC implementation for a number of SAP customers, including Sagemcom, Bongrain, Schuco, Volkswagen, Motul, Glon, Eau Ecarlate, 5sur5 – Groupe SFR, EBP…