The great e-invoicing toll, 1/5: the severed public portal

In August 2022, France’s Finance Ministry announced the construction of a public portal that would give businesses, particularly the smallest ones, a free minimum service for the switch to electronic invoicing. Two years later, the state kept the central directory and tax-data concentrator while removing the gateway intended for businesses. Approved private platforms would handle B2B invoice issuance and receipt.

The public record shows that the change went well beyond a technical adjustment. In May 2022, the Interministerial Digital Directorate, or DINUM, found that the state had yet to settle the boundary between its free service and the private operator market. Its first review covered only part of the project so that implementation contracts could be launched. The main contract was signed in August. Five months later, the estimated cost had risen sharply and the project’s critical path was still described as “ambiguous or uncertain”.

The missing figure is narrower than the €267.7 million now associated with the whole reform: how much did the state pay for the public gateway it ultimately removed?

This first installment opens The Great E-Invoicing Toll, a five-part investigation. It reconstructs the French decision from DGFiP reports, DINUM reviews, transformation agreements, procurement notices and government answers to Parliament. It separates what the documents establish from the costs they still leave unknown.

Key points

• The free portal formed part of the French compromise from the report submitted to Parliament in 2020.
• Its stated purpose was economic as well as technical: limiting the entry cost for microenterprises and SMEs without suitable software.
• In May 2022, DINUM was still considering two possible projects, one minimal and one highly ambitious, without a clear decision between them.
• The main construction contract was awarded on 9 August 2022 to Capgemini Technology Services and CGI France.
• In October 2024, the Finance Ministry removed the public B2B gateway while retaining the directory, concentrator and tax-data collection.
• Published procurement values do not reveal how much was paid, ordered, accepted or reused. The cost of the removed component remains unknown.

The 2020 compromise

The French reform began with four promises: automate the fight against VAT fraud, reduce administrative work, prepare pre-filled VAT returns and give the state a faster view of economic activity.

The DGFiP report submitted to Parliament in October 2020 examines two architectures. Under the V model, every invoice passes through the public platform. Under the Y model, certified private operators may transmit invoices directly while the public platform centralises the information sent to the tax authority.

France chose the Y model. The aim was to preserve the existing ecosystem without leaving less-equipped companies behind. In every scenario it examines, the report provides for a free public platform through which a business can transmit, upload or enter an invoice online and receive invoices. For small firms still working with paper, a word processor or PDF files, the portal was also meant to provide data entry and conversion into a structured format.

The report treats this function as the social component of the compromise. Equipped companies could continue using their existing operators. Companies starting from scratch would have a public route for meeting the mandate without immediately buying an accounting suite or an additional subscription.

It also identifies the underlying tension. Representatives of e-invoicing operators wanted the public portal to remain limited to regulatory functions. Other organisations, including SME representatives, considered its functions essential. The project therefore had to draw a boundary between a free public baseline and private value-added services.

The transformation agreement funded by the Public Action Transformation Fund turns that promise into four components:

1. an e-invoicing function to submit, transmit and track invoices;
2. a directory to find the recipient’s electronic address;
3. an e-reporting function for transactions outside domestic B2B invoicing;
4. a concentrator feeding the DGFiP information system.

The component removed in 2024 can therefore be identified precisely: the business-facing e-invoicing gateway available directly to private companies. The directory, concentrator and transmission of tax data remain under construction or in operation.

May 2022: the state’s role is still unsettled

The first DINUM review, dated 19 May 2022, changes the project timeline.

The body responsible for reviewing major state digital systems received an incomplete file. Scoping for the second workstream, which had to adapt DGFiP systems to collect and use the new data, was unfinished. DINUM states that this partial submission departed from the principle that a project’s viability should be assessed across its full scope.

The reason appears in the document: the state wanted to launch the implementation contracts for the first workstream without delay, under the responsibility of the State Financial IT Agency, or AIFE.

At that stage, the project targeted about four million companies and two billion B2B invoices a year. Construction was estimated at €86 million, rising to €132.9 million with two years of operation. The first workstream alone was estimated at €44.3 million.

The amount did not settle the portal’s intended role.

DINUM distinguishes two options. The first is a minimalist state platform that leaves advanced functions and a substantial share of the market to private operators. The second is an ambitious state platform capable of covering almost every need and attracting a large share of users.

The documents supplied to DINUM leave that choice unresolved. Information given orally appeared to be steering the team towards the ambitious option.

DINUM’s reservation is explicit. Before finalising the choice, the state should tell private providers which functions it would cover and which ones it would leave open, allowing them to invest without fearing a competing free public offer.

It identifies two risks:

• a higher public bill if the portal became the dominant solution;
• political or legal challenges from companies that believed they had been shut out.

The review establishes an economic tension. It provides no evidence of covert lobbying, favouritism or collusion with operators: the boundary between public service and the private market was an explicit economic choice that remained incompletely settled while the state was preparing to engage the contractors building the system.

The same review says the MAREVA assessment did not yet include every cost. DINUM therefore described the €86 million construction budget as incomplete. The Budget Directorate asked for the project’s funding and recurring expenditure to be secured.

The first contract is awarded

On 9 August 2022, AIFE awarded the main contract to a consortium formed by Capgemini Technology Services and CGI France. The award notice in the Official Journal of the European Union covers three tasks:

• designing and developing the public B2B platform;
• providing application and technical maintenance;
• migrating Chorus Pro data and B2G activity to the new platform.

The procedure had been estimated at €40 million. The published award value was €21.17 million. Two bids were received.

An award value describes the selected contract, not expenditure already incurred. An IT contract can combine fixed-price work, purchase orders, options, work triggered in stages, price revisions and amendments. The amount ultimately paid cannot be reconstructed from the award notice alone.

Eight days later, the Finance Ministry presented the award as a decisive step. Its release still promised businesses a choice between a private platform and the public portal. The latter was meant to give the smallest companies a minimum service at limited cost.

The announcement did not mention the incomplete scoping identified three months earlier or DINUM’s request to clarify the space reserved for the market.

January 2023: €122 million and an uncertain critical path

The second DINUM review, issued on 12 January 2023, finally covers the whole project.

The estimate had reached €122 million for construction and €210 million including two years of operation, based on annual running costs of €44 million once fully operational.

The first four reservations were considered resolved. A map now separated covered functions, the “green list”, from excluded functions, the “red list”. The competitive dialogue had also led AIFE to revise the split between fixed-price work and purchase orders before the 9 August award.

Neither list appears in the public documents reviewed for this article. They matter because they would allow a comparison between the public-private boundary settled in 2022 and the scope removed in 2024.

The remaining findings were serious.

The team still lacked baseline indicators for tracking progress, performance or impact. The critical path for the complex project remained “ambiguous or uncertain”. Some preliminary studies were unfinished. Architectural choices, the testing strategy, the security analysis, migration of existing invoices and data minimisation still had to be finalised.

DINUM also found that the possible uses of the data had not been described in detail beyond pre-filled VAT returns and visualisation. Developing those uses could alter the schedule, budget and structural choices.

The DGFiP workstream’s infrastructure did not comply with the state’s “cloud at the centre” doctrine and had no exemption. The accessibility target was 75% compliance with the RGAA standard even though the rules required full compliance. A comprehensive security risk analysis still had to be carried out.

These findings do not show that the platform was doomed. They fix the chronology: the main contract had been signed for five months when a state review was still reporting missing baseline indicators, unfinished studies and an uncertain critical path.

OCR and the removed gateway

Optical character recognition may sound secondary. It sat at the centre of the promise made to small companies.

A microenterprise that creates an invoice in a word processor or spreadsheet can export it as a PDF. A human can read that file, but it may not contain the structured data required by the reform. The public portal was therefore expected to extract the information, present it to the user for validation and produce a compatible invoice.

In May 2022, DINUM set out a particularly expensive operating-cost path for PDF processing: €21 million in 2025, €27.1 million in 2026, €17.6 million in 2027 and €10.5 million in 2028, followed by an assumed fall to zero in 2029 as structured formats became standard.

Those amounts were operating projections, not the price of a contract or cash outlays.

AIFE then launched procurement AO_OCR_2022. Its European award notice describes a SaaS service specifically for PDF invoices submitted through the PPF, including configuration, maintenance and reversibility.

The requirement was estimated at €18.5 million over six years. The purchase-order portion could reach €30 million. Everial won the contract on 20 April 2023 with a published value of €7.54 million.

Three separate figures therefore coexist:

• DINUM’s modelled path for usage costs;
• the procurement estimate;
• the value of the selected bid.

None reveals the amount AIFE actually ordered or paid.

The OCR contract remains the lead most directly connected to the removed function. Its stated purpose was to process PDFs submitted by businesses through the public gateway. Direct B2B submission disappeared after October 2024.

The documentary question is specific:

How much was paid to develop, configure and operate the B2B gateway’s OCR service, and was that service stopped, reduced or reused for Chorus Pro and public-sector invoicing?

Calling the €7.54 million “wasted” would be unsupported. Answering the question requires purchase orders, invoices, acceptance records, usage statistics, amendments and reversibility documents.

The 2023 delay leaves the promise intact

On 28 July 2023, the government delayed the launch that had been scheduled for July 2024.

The release cited the time required to make the reform successful. It still described the public portal as the guarantor of a minimum service at limited cost. Private platforms and the public gateway officially continued to coexist.

One month later, in an answer published by the Senate, the Finance Ministry again defended the public choice. It said the portal would address SME concerns, enable adoption at limited cost and provide more limited invoice storage than private offers. The government also cited a favourable response to the solution during a trial with small businesses.

Thirteen months before the gateway was removed, the government was still presenting it as a safeguard for less-digitised companies.

This sequence leaves a question of timing. The government announced the delay in July 2023, and stakeholders understood that the PPF had fallen behind. When did the administration conclude that the direct business service should disappear? When were ministers informed? The press releases do not answer either question.

Steering committee minutes, notes sent to the Budget Directorate and ministerial decisions would locate the change between summer 2023 and October 2024.

October 2024: the public gateway disappears

The 15 October 2024 announcement runs to only a few paragraphs.

More than 70 private platforms had received provisional registration at that point. The Finance Ministry treated that as evidence of an ecosystem sufficiently prepared to meet business needs. The public project would focus on the recipient directory and the concentrator transmitting data to the administration.

The official explanation combined timing and budget: refocusing the project was intended to meet the September 2026 deadlines while remaining within the resources allocated.

The word “abandonment” can mislead. The PPF remains a major public infrastructure. It holds the directory showing where each invoice must be routed. It receives the regulatory data extracted by the platforms and feeds DGFiP. Chorus Pro also continues to serve public-sector invoicing.

The part that disappeared was the interface private businesses would have used themselves to issue, receive and track B2B invoices.

A government answer published by the National Assembly in June 2025 completes the rationale. It says developing the full portal had become financially hard to sustain under tight budget conditions and could threaten the timetable. Some platforms had announced free basic offers or services included with management software, invoicing software or bank accounts.

The government added that public financial support for companies would undermine the sustainability of commercial offers and distort the emerging platform market.

The rationale had reversed.

In 2020, the free public platform was supposed to limit small businesses’ entry costs while preserving a private market for advanced services. By 2025, free or bundled private offers were being used to justify removing the public route, while a budget subsidy was presented as a threat to the market.

This reversal documents a policy shift. It does not show that operators imposed their preferred solution. The economic trade-off identified by DINUM in 2022 ultimately produced a mandatory private gateway.

Procurement records reflect the change

The October 2024 decision also appears in procurement records.

In October 2023, AIFE had launched a procedure covering the operation of its cloud applications and the creation of a security operations centre. The initial scope included the PPF and PISTE, the state’s API platform.

The procedure was cancelled on 20 November 2024. The official BOAMP information notice for the replacement procurement gives the reason: the requirement had been redefined after the e-invoicing project changed direction and the application scope changed with it. The security operations centre was removed from the new contract.

A cloud operations contract was then relaunched. It covers the PPF, PISTE and several public procurement applications. This pooling means its entire value cannot be attributed to the e-invoicing reform.

In December 2024, AIFE also launched a new application and technical maintenance contract for the PPF. The official BOAMP award notice gives a bid value of €17.73 million for Sopra Steria and a €54.17 million framework ceiling. The contract was concluded on 1 July 2025.

That contract is not the bill for the abandoned gateway. The refocused PPF still needs maintenance, fixes and adaptation. The figures become useful only if the work can be allocated between the directory, concentrator, Chorus Pro, inherited components and developments that no longer serve a purpose.

Contract	Published purpose	Published value	What it does not establish
AIFE_DC_AC_FE_2022	Build the B2B PPF, maintenance, Chorus Pro migration	€21.17m	The amount paid or the share devoted to the removed gateway
AO_OCR_2022	OCR for PDFs submitted to the PPF	€7.54m	Purchase orders used or whether the service was reused
25_AIFE_TMPPF	Maintenance of the refocused PPF	€17.73m; €54.17m ceiling	Spending up to the ceiling or a cost exclusive to B2B invoicing

Adding these values would produce a meaningless figure. They correspond to different contracts, periods and execution terms.

The €267.7 million covers the whole reform

The Senate budget report on the 2026 Finance Bill puts the reform’s total cost to the state at €267.72 million from 1 March 2021 to 31 December 2028.

Its published breakdown reports €84.3 million in personnel expenditure and €183.59 million outside personnel. Those two subtotals add to €267.89 million, €0.17 million above the stated €267.72 million total. The budget table therefore contains an arithmetic inconsistency in this breakdown. Its €267.72 million total covers the full construction and rollout of the reform, including DGFiP systems, the directory, concentrator, teams, operations and functions that remain in service.

Presenting €267.7 million as the price of a portal thrown away would be false.

The published estimates still form a path that calls for explanation. The 2021 FTAP agreement put construction work for the public platform at €19.6 million within its own scope and overall investment at €72.83 million. DINUM then estimated construction at €86 million in May 2022 and €122 million in January 2023. The parliamentary budget eventually placed the full 2021-2028 project at €267.72 million.

The scopes change. The time horizons change. Personnel and operating expenditure are treated differently. A careful reading treats them as four separate snapshots, not as a homogeneous series of overruns.

The useful question is narrower:

Within the €267.72 million, how much relates to interfaces, data-entry functions, B2B receipt, PDF processing, tracking, storage, testing and support designed for the direct public gateway and later abandoned or reassigned?

The aggregate budget leaves that question open. So do the award notices.

The missing records

The public file allows the change in direction to be reconstructed, but not the amount of any resulting loss.

Eight sets of records are needed:

1. the green and red lists defining the public scope after the competitive dialogue;
2. the full DINUM submission files and their MAREVA annexes;
3. minutes from executive, strategic and steering committees;
4. the decision memorandum leading to the 15 October 2024 announcement;
5. purchase orders, amendments, paid invoices and acceptance records for the Capgemini-CGI contract;
6. the same records for Everial’s OCR contract;
7. an inventory of components developed, deployed, abandoned or reused;
8. the transition, migration, reversibility and decommissioning costs caused by the new architecture.

Those records would allow three separate hypotheses to be tested.

The first is significant waste: completed and paid-for functions may have been abandoned.

The second is substantial reuse: most of the code and infrastructure may have been used for the directory, concentrator or Chorus Pro, limiting the net loss.

The third lies between the two: the refocusing may have avoided future spending after several years of sunk costs, contract changes and delay.

The investigation should choose among these scenarios only after obtaining the records.

Mandatory use of approved platforms

From 1 September 2026, every company within the reform’s scope must be able to receive electronic invoices. Large companies and intermediate-sized enterprises must also issue them electronically. SMEs and microenterprises follow for issuance on 1 September 2027.

The French model now requires an approved platform for B2B exchanges covered by the reform. Companies may choose among private providers; the public option designed in 2020 has disappeared.

The state retains the components serving its own direct needs: the directory, standards, data collection and transmission to the tax administration. Private providers handle the operational relationship with businesses.

This architecture can work. It may deploy faster and offer better tools than the original minimum public service. The number of approved platforms and the availability of free or bundled offers do not resolve the historical question.

For several years, the Finance Ministry built a hybrid project in which the free gateway was specifically meant to protect small businesses from entry costs. DINUM identified the tension between that offer and the private market at an early stage. Contracts were launched before full scoping was complete. Costs rose. The reform was delayed. The state then removed the public gateway to protect the timetable and budget while keeping the tax-data control tower.

The missing figure is more precise than €267.7 million: the amount paid for the public gateway that was ultimately removed.

That amount, and the date when the Finance Ministry concluded it would not deliver the promised gateway, must now be established from the administrative record.

The second instalment maps the technical and ownership dependencies hidden behind the register’s 147 names.

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Main sources

• DGFiP, VAT in the Digital Age in France, October 2020.
• DITP, DGFiP and AIFE, e-invoicing transformation agreement, 2021.
• DGFiP and AIFE, external B2B specifications, version 1.0, September 2021.
• DINUM, binding review 2022-CMR-015, 19 May 2022.
• AIFE, main contract award notice, August 2022.
• French Finance Ministry, announcement of the award and construction launch, 17 August 2022.
• DINUM, binding review 2023-CMR-02, 12 January 2023.
• AIFE, OCR contract award notice, April 2023.
• French Finance Ministry, announcement of the delay, 28 July 2023.
• French Senate, government answer on the competitive framework, 31 August 2023.
• French Finance Ministry, announcement refocusing the PPF, 15 October 2024.
• BOAMP, information notice on the replacement AIFE cloud operations procurement, January 2025.
• French National Assembly, government answer on the effect of dropping the PPF, 3 June 2025.
• BOAMP, PPF maintenance contract award notice, 2 March 2026.
• French Senate, budget report on the 2026 Finance Bill.

Limitations

• This investigation relies on public records accessible on 22 August 2026. The green and red lists, purchase orders, invoices, acceptance records and reversibility documents were not public in the material reviewed.
• Award values, estimates and framework ceilings measure neither the amount ordered or paid nor the share allocated to the removed B2B gateway.
• The documents establish an economic trade-off between public service and the private market. They provide no evidence of covert lobbying, favouritism or coordinated action by operators.
• The €267.72 million covers the full reform between 2021 and 2028. It cannot be attributed solely to the abandoned public gateway.