Electronic Deposit Invoice: VAT, Tax Point and the 2026 Reform

The rollout of electronic invoicing in France is fundamentally disrupting accounting and tax practices that have been established for decades. Among the most sensitive topics is the electronic deposit invoice: this document triggers specific obligations regarding VAT, tax point and transmission to approved platforms. From 1 September 2026, all large enterprises and mid-sized enterprises (ETI) are subject to the mandatory requirement to issue invoices in structured format. SMEs and microenterprises will follow from 1 September 2027. Understanding the tax mechanisms linked to deposits, the acceptable formats and the pitfalls to avoid has become an absolute priority for finance and accounting departments. This article provides a comprehensive overview of the applicable rules, reporting obligations and best practices to secure your compliance.

What is a deposit invoice and why is it specific?

Definition and distinction from the final invoice

A deposit invoice is issued when a customer makes a partial payment before complete delivery of goods or completion of a service. It differs from the final invoice, which settles the entire transaction. From an accounting perspective, the deposit invoice constitutes income received in advance for the service provider and a prepaid expense for the client.

The difference is not merely semantic: on the tax side, the VAT regime applicable to the deposit invoice varies depending on the nature of the transaction (supply of goods versus provision of services), and this is precisely the point that the 2026 reform has clarified and tightened.

VAT tax point: the heart of the matter

In French tax law, VAT tax point (or exigibility) refers to the moment from which the tax authorities can claim payment of the tax. This moment differs depending on the type of transaction:

• Supplies of goods: VAT becomes due upon delivery (transfer of ownership). A deposit paid before delivery does not make VAT due for the goods, unless an invoice is issued before delivery — which changes the regime.

• Provision of services: VAT becomes due upon receipt of payment. Consequently, receipt of a deposit immediately triggers VAT due on that amount.

This distinction, established in Article 269 of the French Tax Code (CGI), lies at the heart of the issues surrounding electronic deposit invoices. Since the reform, the structured format of electronic invoicing enables the tax authorities (through the DGFiP) to automatically cross-reference data transmitted against VAT returns, making any anomaly immediately detectable.

New mandatory information from the reform

Ordinance No. 2021-1190 of 15 September 2021 and its implementing decrees introduced additional mandatory information on electronic invoices. For a deposit invoice, the following elements must be included:

• The invoice number: unique and sequential, assigned by the issuing system or the Partner Dematerialisation Platform (PDP).

• The nature of the transaction: the invoice must indicate that it concerns a deposit and specify the nature of the goods or service.

• The net amount, the VAT rate and the VAT amount corresponding to the deposit.

• The date of VAT tax point: mandatory information from 1 January 2026 for provision of services.

• A reference to the original order or contract.

• The SIREN identifier of the issuer and recipient.

• The delivery address if different from the billing address.

The absence of even one of these items can result in rejection of the invoice by the receiving platform, with cascading consequences for VAT deductibility for the client.

Electronic formats accepted for deposit invoices

Factur-X: the Franco-German hybrid format

The Factur-X format is now the reference format for B2B exchanges in France. It is a hybrid PDF/A-3 format incorporating data structured according to the EN 16931 standard in XML. For deposit invoices, it offers the advantage of combining human readability (the PDF) with automated processing (the embedded XML).

The EN 16931 profile (minimum legal profile) is sufficient for the majority of deposit invoices, but certain complex transactions (construction work, phased contracts) require the Extended profile, which allows additional fields to detail the breakdown of deposits and final payments.

You can verify the compliance of your Factur-X files using our free Factur-X validator, which checks the XML structure, mandatory data and compliance with the declared profile.

UBL and CII: other acceptable formats

In addition to Factur-X, two other purely structured formats are accepted by the Public Invoicing Portal (PPF) and PDPs:

• UBL 2.1 (Universal Business Language): international standard widely used in European exchanges.

• CII D16B (Cross Industry Invoice): format derived from the UN/CEFACT standard, used notably in exchanges with Germany and Nordic countries.

For deposit invoices, the choice of format depends primarily on the business sector and the technical constraints of the recipient. The approved platforms (PDPs) are required to accept and convert these three formats.

The role of the invoice lifecycle

One of the major innovations of the reform is the introduction of a standardised lifecycle for each electronic invoice. A deposit invoice can have the following statuses:

• Submitted: received by the issuer's platform.

• Made available: transmitted to the recipient's platform.

• Received: acknowledged by the recipient's system.

• Rejected: refused for technical or formal non-compliance.

• Accepted: validated by the recipient.

• Put into payment: payment triggered.

This real-time tracking is a major departure from previous practices and requires a complete overhaul of collection follow-up and recovery processes. The 2026-2027 electronic invoicing timeline details the rollout stages according to enterprise category.

VAT on deposits: the precise rules depending on the nature of the transaction

Deposit for provision of services: VAT on receipt

For service providers under the payment receipt regime (the general regime in France for VAT on receipts), receipt of a deposit immediately triggers VAT tax point. The electronic deposit invoice must therefore:

• Clearly indicate that VAT is calculated on the amount of the deposit received.

• Mention the actual date of receipt (or forecast if the invoice is issued before payment).

• Be transmitted to the platform within a maximum of 2 business days after issue (rule introduced by the decree of 7 October 2022).

Caution: a service provider who fails to declare VAT on a deposit received risks a VAT adjustment plus default interest (0.20 % per month, Article 1727 of the CGI) and, in case of repeated breach, a penalty of 40 % for deliberate failure to comply.

Deposit for supply of goods: the rule of invoice priority

For supplies of goods, VAT is in principle due only upon delivery. However, if a deposit invoice is issued before delivery, it triggers VAT due on the amount invoiced, in accordance with Article 269-2-c of the CGI. This rule, confirmed by the CJEU in the BUPA Hospitals judgment (C-419/02 of 21 February 2006), applies where the goods are identified with precision and the amount of tax can be calculated.

In the context of electronic invoicing, this anticipated tax point must be explicitly mentioned in the invoice XML via the `TaxPointDate` field (Factur-X) or equivalent UBL/CII.

The case of mixed transactions and phased contracts

Construction contracts, IT projects or long-term maintenance contracts often combine supplies of goods and provision of services. In this case, the breakdown of deposits by nature of transaction is mandatory. The Factur-X Extended format allows this breakdown through separate invoice lines with differentiated VAT categories.

Failure to comply with this rule exposes the issuer to automatic rejection by the PDP and, if accepted in error, to the risk of adjustment during a tax inspection.

E-reporting and transmission of deposit data to the DGFiP

What is e-reporting?

E-reporting is the obligation to transmit to the tax authorities data from transactions that are not the subject of a B2B electronic invoice (B2C transactions, transactions with foreign enterprises). For domestic B2B electronic deposit invoices, the data is transmitted automatically via the PDP or PPF — no separate e-reporting flow is necessary.

However, if an enterprise subject to VAT issues a deposit for a service provided to a consumer (B2C), it must transmit the data from this transaction via the e-reporting flow, including the net amount, the VAT rate and the payment date.

Frequency and transmission deadlines

E-reporting data must be transmitted according to the frequency of the enterprise's VAT return filing:

• Monthly regime: transmission within 10 days following the end of the month.

• Quarterly regime: transmission within 10 days following the end of the quarter.

These deadlines are strict. A delay in transmission results in a fine of €250 per missing invoice, capped at €15,000 per fiscal year (Article 1737 of the CGI, amended by the 2024 Finance Law).

Automatic reconciliation of deposits and final payments

One of the major contributions of the new system is the DGFiP's ability to automatically reconcile deposit invoices with the corresponding final payment invoices. For this reconciliation to work, final payment invoices must obligatorily reference the invoice numbers of the previous deposits. This documentary chain, made possible by structured formats, is verified algorithmically by the platforms before transmission to the authorities. Any break in the chain generates a compliance alert.

Legal framework applicable to the electronic deposit invoice

The electronic deposit invoice is part of a set of legislative and regulatory texts that must be understood to ensure complete compliance.

French Tax Code (CGI): Article 269 of the CGI defines the rules for VAT tax point depending on the nature of transactions. Article 289 requires mandatory information on all invoices, strengthened for electronic invoices by decree No. 2022-1299 of 7 October 2022. Article 1737 sets the penalties applicable in case of failure to comply with transmission obligations.

Ordinance No. 2021-1190 of 15 September 2021: It constitutes the founding text of the reform of electronic invoicing in France, partially transposing Directive 2014/55/EU and anticipating Directive DAC7. It introduces the requirement to use a PDP or the PPF for domestic B2B exchanges.

Decree No. 2022-1299 of 7 October 2022: It clarifies the technical modalities of implementation, the acceptable formats (Factur-X, UBL, CII), transmission deadlines and the standardised lifecycle of invoices. It makes mandatory the transmission of processing statuses between PDPs.

VAT Directive 2006/112/EC (amended by Directive ViDA, 2025/516/EU): The "VAT in the Digital Age" directive (ViDA), adopted in 2025 and applicable progressively until 2030, harmonises the rules for VAT tax point on deposits across Europe. It notably requires that any deposit invoice for cross-border intra-EU service provision immediately triggers VAT, regardless of the payment date.

eIDAS Regulation No. 910/2014 and eIDAS 2.0 (EU Regulation 2024/1183): Whilst electronic signature is not mandatory on French B2B invoices (the electronic seal of the PDP is sufficient), recourse to an eIDAS-compliant electronic signature strengthens the evidentiary value of the invoice in case of dispute. eIDAS 2.0 Regulation, applicable since 20 May 2024, introduces the European digital identity wallet (EUDI Wallet), which will eventually allow the parties to be authenticated when issuing invoices.

Standard EN 16931: European standard defining the semantic model for electronic invoices. All acceptable formats (Factur-X, UBL, CII) must comply with it. The standard includes specific elements for managing deposits (`PREPAID_AMOUNT`, `DUE_PAYABLE_AMOUNT`).

GDPR No. 2016/679: Personal data contained in invoices (contact name, email address) must be processed in compliance with the GDPR. PDPs are processors within the meaning of Article 28 and must provide a compliant DPA (Data Processing Agreement). The legal retention period for invoices is 10 years (Article L.123-22 of the Commercial Code), which requires security and integrity guarantees over this entire period.

Risks in case of non-compliance: A VAT adjustment on poorly declared deposits can reach several years of arrears, increased by 0.20 % interest per month and a penalty of 40 % to 80 % depending on severity. Non-transmission of electronic invoices via a PDP or the PPF also exposes the enterprise to a fine of €15 per invoice (minimum €60,000 per fiscal year), without prejudice to criminal proceedings in case of proven fraud.

Use cases: the electronic deposit invoice in practice

Scenario 1 — A digital transformation consulting firm managing 150 engagements/year

A 25-consultant consulting firm issues on average 3 to 4 deposits per engagement, representing 30 % to 50 % of the contract amount. Before the reform, these deposits were issued in free PDF format, without explicit mention of the VAT tax point date. The firm had to manually reconcile deposits with final invoices in its ERP.

Since the rollout of a PDP interfaced with its ERP, each deposit invoice is generated in Factur-X EN 16931 format, automatically transmitted to the client's platform, and status is updated in real time. VAT on deposits is now automatically attributed to the payment receipt period in the accounts. Result: 65 % reduction in the time spent processing deposits, zero invoice rejections over the first 6 months, and elimination of VAT timing risks that previously resulted in an average of 3 to 4 adjustments per year with the authorities.

Scenario 2 — An industrial SME manufacturing bespoke equipment

An 80-employee SME manufacturing custom industrial machinery systematically invoices 40 % deposit upon order and 40 % upon delivery. The balance of 20 % is invoiced after final acceptance. These transactions involve supplies of goods — the rule of invoice priority therefore applies: issuing the deposit invoice before delivery immediately triggers VAT due.

The challenge was to correctly configure the `TaxPointDate` field in Factur-X files to reflect the issue date (not the delivery date) as the starting point for VAT tax point. After configuration and training of the accounting team, the SME reduced its average collection delays by 18 days, thanks to real-time lifecycle tracking. Any rejections (less than 2 % of invoices) are now handled in less than 4 hours thanks to automatic PDP notifications.

Scenario 3 — A property developer managing new residential construction programmes

In the property development sector, recourse to instalment calls (forms of deposits governed by law) is systematic. A developer managing a dozen programmes simultaneously issues several hundred deposit invoices per year, addressed to professional purchasers (institutional investors, property partnerships) and private individuals.

The B2B portion is processed via a PDP in Factur-X Extended format, allowing instalment calls to be broken down by unit and by work phase. The B2C portion is transmitted via e-reporting. Integration with the programme management software enabled automation of deposit invoice generation upon validation of the construction milestone, reducing issue times from 5 days to less than 24 hours. The risks of VAT on collection (margin VAT in property development) have been secured through specific configuration of rates in the system, validated by the group's external accountant.

Frequently Asked Questions

Is VAT payable upon receipt of a deposit for the delivery of goods?

No. For the delivery of goods, VAT becomes payable at the moment of transfer of ownership, that is, upon actual delivery. A deposit paid before this delivery therefore does not trigger VAT payability, unless an invoice is issued before the delivery itself. In this specific case, the issuance of the invoice gives rise to VAT payability, which modifies the declarative obligations of the issuer.

What is the difference between a deposit invoice and a progress invoice in the construction sector?

A deposit invoice corresponds to a partial payment made before any commencement or progress of work. A progress invoice, used notably in construction, records actual and measurable progress of work at a given date. Both documents are subject to VAT on cash receipt for the provision of services, but the progress invoice must also detail the items completed, which requires additional structured fields in XML formats.

Can an electronic deposit invoice be cancelled after transmission to the platform?

An electronic invoice that has been transmitted cannot be deleted: it must be subject to a credit note referencing the original invoice. This credit note document follows the same transmission circuit as the original invoice and triggers an update of the lifecycle. Any partial correction of the amount follows the same logic, via a partial credit note followed by a new corrective invoice, in order to maintain the traceability required by the tax authorities.

How can the customer deduct the VAT shown on a deposit invoice?

For the provision of services, the customer can deduct the VAT shown on the deposit invoice as soon as it is received and the corresponding payment is made. The invoice must explicitly state the amount of VAT, the applicable rate and the date of VAT payability. In the absence of any of these mandatory particulars, deductibility may be questioned during a tax audit, regardless of whether payment has been made.

Must microenterprises issue electronic deposit invoices before September 2027?

Before their mandatory entry into force date, microenterprises are not required to issue structured electronic invoices. They nevertheless remain required to receive electronic invoices sent by their suppliers who are taxable persons. It is however recommended to anticipate the transition, as exchanges with customers subject to the obligation from 2026 can generate practical requirements for format compatibility well before the regulatory deadline.

Conclusion

The electronic deposit invoice concentrates the main challenges of the 2026 reform into itself: compliance of formats, VAT tax point depending on the nature of the transaction, documentary chain with final invoices, and real-time transmission to approved platforms. The rules arising from the 2021 ordinance and the 2022 decree, reinforced by the ViDA directive, leave little room for approximation: an error in the tax point date or the absence of mandatory information can trigger automatic rejection, a VAT adjustment or a fine.

Implementing a robust solution, interfaced with your ERP and connected to a certified PDP, is no longer optional but an operational necessity. Certyneo supports you in this transition with tools adapted to the realities of your business. Discover our pricing and start your compliance today.