The legal framework applicable to French companies underwent several shifts in 2024, with postponed reforms, new transparency obligations, and a transition towards dematerialization. Some of these changes are already in effect, while others follow a staggered timeline extending until 2027. Understanding their interplay allows for anticipating necessary adaptations rather than enduring them.
Electronic invoicing: three distinct obligations, not a single deadline
The reform of electronic invoicing is often presented as a single transition. In reality, it encompasses three distinct aspects: the receipt of electronic invoices, their issuance, and the transmission of transaction data to the tax administration. Each aspect follows its own timeline, staggered according to the size of the company.
The obligation to receive electronic invoices primarily concerns all companies subject to VAT. The issuance will be imposed gradually, with large companies leading the way before SMEs and micro-enterprises. This distinction is crucial: a small business preparing solely to issue invoices risks neglecting the adaptation of its receipt tools, which is required earlier.
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The General Directorate of Public Finances has published a dedicated guide, updated in 2024, detailing the steps for each company profile. The most common trap is to confuse the partner dematerialization platform (PDP) with the public invoicing portal: both circuits coexist, and the choice of one or the other has consequences on the data flows transmitted to the administration.
CSRD sustainability reporting: a staggered timeline that does not eliminate obligations
The European directive on sustainability reporting (CSRD) was supposed to impose a first non-financial report on a wide range of companies starting from the 2024-2025 fiscal years. The European directive 2025/794 of April 14, 2025, postponed this deadline for certain categories, and the French law n° 2025-391 of April 30, 2025, transposed this postponement.
This delay does not mean an abandonment of the system. Large companies already subject to the non-financial performance declaration (DPEF) remain required to publish their report according to ESRS standards. For medium-sized enterprises, the postponement offers a preparation period, not an exemption.
The confusion arises from the so-called “Omnibus” legislative package, which simultaneously raised thresholds and postponed dates. Some companies that thought they were affected are no longer in the short term, while others discover that they remain within the scope. Checking one’s position against the new thresholds is a step that many have overlooked after the announcement of the postponement.
Pay transparency: what the European directive changes for HR management
The European directive on pay transparency requires companies to make accessible the criteria for setting salaries and the pay gaps between women and men. Its transposition into French law is underway, with direct consequences on several aspects of human resource management:
- Job offers will have to mention a salary range or a reference salary, altering recruitment practices established for decades.
- Employees will be able to request information on average pay levels, broken down by gender, for positions equivalent to theirs.
- Companies exceeding a certain employee threshold will have to publish a report on pay gaps, with corrective measures if the gap exceeds a percentage set by the directive.
For legal and HR services, the documentation burden significantly increases. It is no longer just about complying with the existing professional equality index, but about structuring salary data that is usable and communicable upon request.
Areas of uncertainty regarding French transposition
The directive sets a framework, but national transposition will determine the exact employee thresholds, publication modalities, and applicable sanctions. At this stage, French implementing decrees have not yet specified all parameters. Companies that anticipate by structuring their salary data by category and gender now will be better positioned, regardless of the final timeline adopted.
Register of beneficial owners and data access: a subtle tightening
The access modalities to the register of beneficial owners (RBE) have been tightened. Access, once relatively open, is now subject to stricter conditions, in line with European jurisprudence on the protection of personal data.
This tightening has concrete repercussions for companies conducting compliance checks on their business partners, particularly in the context of anti-money laundering vigilance obligations. KYC (Know Your Customer) procedures must incorporate the fact that information on beneficial owners is no longer freely accessible.
For companies subject to declarative obligations with the registry, updating the RBE upon any change in shareholding remains mandatory. Non-compliance with this obligation exposes companies to criminal sanctions that have not been eased.
Business formalities and single window: a project still ongoing
The electronic single window, intended to centralize all formalities for creation, modification, and cessation of activity, has experienced repeated malfunctions since its launch. Backup procedures have had to be maintained to address technical failures.
Processing times with the registries have also evolved, particularly for universal transfers of assets (TUP) and liquidations. The new procedures extend some processing times, necessitating greater anticipation during restructuring operations.
- Starting a business theoretically goes through the single window, but technical incidents sometimes require reverting to old Cerfa forms.
- Statutory modifications (change of director, transfer of headquarters) experience variable delays depending on the registries.
- Dissolution-liquidation operations require increased vigilance regarding new publicity formalities.
The year 2024 has reshuffled the legal priorities of French companies. Between electronic invoicing, sustainability reporting, pay transparency, and the register of beneficial owners, obligations overlap with distinct timelines. The common thread of all these reforms remains the structuring of internal data: companies that invest in their legal and accounting information systems absorb these changes with less friction than those that wait for deadlines to react.
