Long confined to specific sectors—large-scale retail, agricultural cooperatives, business referral networks—self-billing is now finding its place in a growing number of paperless invoicing systems. The principle is simple and appealing: the customer, not the supplier, prepares and issues the invoice. For the customer, this system primarily helps avoid data discrepancies between the order, delivery, and invoicing stages. For the supplier, it saves valuable time and often ensures faster payment.

However, the supplier remains the legal issuer of the invoice and is solely liable to the tax authorities. If not properly managed, self-billing thus exposes the supplier to tax adjustments and fines. The stakes are all the higher given that the widespread adoption of electronic invoicing is changing the landscape: self-billing, which until now has been governed by private contracts between the parties, must be adapted to comply with the new transmission rules.

This article explains what self-billing is, how it works legally in France, its benefits for businesses, and the conditions for implementing it.

Key takeaways

• Self-billing is a mechanism that inverts the traditional invoicing model. The customer prepares and issues the invoice on behalf of the supplier.
  
• This practice is legal in France as long as a self-billing mandate is signed, a procedure for accepting invoices is established, and the notation “autofacturation” (self-billing) is included on each document issued.
  
• Self-billing is particularly well-suited to certain situations—notably high-volume recurring orders, marketplaces, and transactions with suppliers that have limited technical infrastructure.
  
• Self-billing offers numerous benefits to both parties: a shorter billing cycle, fewer errors and disputes, less administrative work for the supplier, and greater certainty regarding the customer’s right to deduct value-added tax (VAT).
  
• The advent of the electronic invoicing reform is profoundly transforming the self-billing process, as self-issued invoices will now have to be transmitted in a structured format via an approved platform (PA).
  

What is self-billing?

Self-billing is a system whereby a customer is authorized by a supplier to issue invoices in the supplier’s name and on its behalf. Though the customer prepares the document, the supplier remains the legal issuer and bears sole responsibility for Value Added Tax (VAT) obligations.

Self-billing (i.e., “autofacturation”) thus reverses the traditional invoicing process, in which the supplier issues the invoice and sends it to the customer.

Self-billing differs from two related concepts:

• Subcontracting of billing: In this approach, the supplier entrusts the preparation and issuance of invoices to a specialized third party, such as an invoicing service provider or a firm, rather than to the customer. While the legal mechanism is similar, the party acting on the supplier's behalf differs.
  
• VAT reverse charge: In the case of the VAT reverse charge mechanism, the customer becomes liable for the VAT and must report and pay this tax directly to the tax authorities.
  

Is self-billing legal in France?

Self-billing is legal in France under Article 289 I-2 of the General Tax Code (CGI), which authorizes suppliers to have customers prepare invoices. However, the validity of invoices is contingent upon three conditions: a billing mandate, an acceptance procedure, and a special notation on invoices.

To be valid, self-billing relies on three pillars:

• A billing mandate: The supplier must issue the customer a mandate authorizing them to issue invoices in the supplier’s name and on its behalf (Article 242 nonies, Appendix II of the CGI).
  
• An acceptance procedure: Any invoice issued in the supplier's name and on its behalf must be accepted by the supplier, in accordance with terms freely agreed upon by the parties.
  
• A self-billing (autofacturation) notation: The word “autofacturation” (self-billing) must appear on every invoice issued by the customer (Article 242 nonies A, I-14° of Appendix II of the CGI).
  

Failure to meet these requirements undermines the validity of an invoice and puts it at risk of being contested by the tax office. Depending on the severity of the violation, tax authorities could refuse a VAT deduction. Even when a customer prepares and issues an invoice, the supplier retains full responsibility for the invoicing and VAT obligations. In the event of an error, or if an invoice is noncompliant, it’s the supplier that’s held accountable by the tax authorities.

When should self-billing be used?

Self-billing is useful when the customer has a better grasp of the transaction details than the supplier, such as with recurring, high-volume orders, prices determined after shipping, business referral networks, marketplaces, or purchases from certain small service providers.

Here are the most common situations where self-billing offers value for both the customer and the supplier:

• Recurring, high-volume orders
  When a customer receives hundreds of shipments each month from the same supplier, self-billing can help prevent discrepancies between delivery slips and invoices. It can also speed up invoice processing times, which is one of the most common reasons for using self-billing, especially for those in the mass retailer sector.

• Prices determined by customers upon receipt
  In some industries (e.g., agrifood, metals, waste, and recycling), the invoice price can depend on weighing, calibrations, or analyses performed by the customer. Since the customer holds the data needed to calculate the price, they’re better positioned to issue the invoice.

• Referral and commission networks
  When a business pays commissions to multiple partners such as sales agents, affiliates, or business referrers, it often knows the exact amount due better than the partners themselves and can therefore self-bill those commissions on behalf of each partner.

• Marketplaces and platforms
  A platform that pays numerous third-party sellers or service providers has every reason to streamline its invoicing process. Integrating self-billing into its systems ensures that documents are consistent and compliant.

• Purchases from suppliers with limited technical infrastructure
  When dealing with individual service providers or very small businesses that don’t have compliant invoice software, the customer can ensure the process runs smoothly by issuing complete, accurate invoices themselves.

What are the benefits of self-billing?

Self-billing offers numerous benefits for both the customer and supplier. For the supplier, it speeds up the billing process, reduces errors and disputes, improves the reliability of accounting data, and reduces administrative burden. For the customer, it ensures that invoices match purchase orders, thereby helping secure the right to a VAT deduction.

The primary benefits of self-billing are as follows:

• Shorter billing cycle
  The customer no longer has to wait to receive an invoice from the supplier; instead, they issue the invoice themselves as soon as the transaction is complete. The time lag between delivery and billing is reduced, which speeds up payment and improves liquidity for both parties.

• Fewer errors and disputes
  Invoices are prepared using actual data held by the customer, such as quantities received, prices charged, and terms and conditions negotiated. This greatly reduces discrepancies between orders, deliveries, and invoices, thereby reducing the number of invoices rejected due to mismatches.

• Improved reliability of accounting data
  Invoices must follow a standardized format and numbering system, as defined by the customer and integrated into their electronic system. This standardization reduces data entry errors and facilitates automated reconciliation, verification, and archiving of invoices.

• Reduced administrative burden for the supplier
  By eliminating the need to draft and issue invoices, the supplier saves time that can be reinvested in higher-value-added tasks, such as production, business development, or customer relations. This is particularly beneficial for small businesses that lack a dedicated billing department or invoicing software.

• More secure VAT deduction for customers
  By controlling the content of invoices, the customer can ensure they include all the required information to support their right to deduct VAT. This helps minimize the risk of their VAT deduction being challenged due to an invoice error or omission.

How to self-bill

To ensure self-billing compliance, in addition to standard invoicing rules—such as mandatory information and record-keeping requirements—it’s necessary to meet certain obligations: a prior written agreement in the form of a billing mandate, an invoice acceptance procedure for the supplier, and inclusion of the term “autofacturation” (self-billing) on every document.

The requirements for self-billing are as follows:

• Establish a written billing mandate in advance
  The mandate must be prepared and signed before any invoices are issued. The mandate must state that the supplier remains solely responsible for its billing and VAT obligations, and it must establish a time period for the supplier to contest invoice content.
  If the supplier and customer work together only occasionally, the law permits a tacit mandate, as long the invoices in question are issued as soon as the billable event occurs and are not invoiced on a recurring basis.

• Establish an acceptance procedure
  With written mandates, the parties are free to define the terms of invoice acceptance (e.g., implied acceptance upon the expiration of the dispute period). With tacit mandates, particularly in the context of occasional business dealings, invoices must be accepted expressly and formally. A message confirming receipt is sufficient for electronic invoices.

• Include the “autofacturation” (self-billing) notation
  Every invoice issued by the customer on behalf of the supplier must clearly bear the notation “autofacturation.”

• Include all standard mandatory details
  The invoice must include the customer’s information and the supplier’s information, including company name, address, intracommunity VAT number, and SIRET (establishment directory identification system) number. It must also specify the goods or services provided, their quantity, the unit price excluding tax, the applicable VAT rate and amount, and the total amount (excluding and including tax). Lastly, it needs to include the payment terms and deadlines.

• Retain invoices for 10 years
  As with all accounting documents, self-billed invoices must be retained for 10 years, under conditions that ensure their legibility, integrity, and traceability.

What is the impact of the electronic invoicing reform on self-billing?

Under the electronic invoicing reform, self-billed invoices are no longer documents exchanged directly between parties but are instead structured files transmitted through an approved platform, with statuses synchronized between the customer and the supplier.

Thus, the electronic invoicing reform transforms the way in which invoices are generated and transmitted. As of September 1, 2026, large companies and intermediate-sized enterprises must issue their invoices electronically (for example, in Factur-X format) via an approved platform (plateforme agréée, PA). As of September 1, 2027, this reform applies to very small enterprises, small and medium-sized enterprises (SMEs), and microenterprises.

This means that customers must issue invoices in electronic format and use a PA to configure the routing of self-billed transactions. Suppliers must be able to receive, via a PA, electronic invoices issued on their behalf.

To prepare for the reform’s requirements, both parties should update their self-billing mandates to include the selected PA, invoice formats, acceptance procedures, and status management methods. They should also test new billing processes before the reform takes effect.

How Stripe Invoicing can help

Stripe Invoicing simplifies your accounts receivable (AR) process—from invoice creation to payment collection. Whether you’re managing one-time or recurring billing, Stripe helps businesses get paid faster and streamline operations:

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Learn more about how Stripe can simplify your accounts receivable process, or get started today.