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1.12.2026

Mandatory electronic invoicing: What sets the 5-corner CTC Model adopted by France apart


VAT is the primary source of tax revenue for most countries, accounting on average for 34% of public revenue. It is also the main source of tax losses: globally, the VAT gap, the difference between what should be collected and what is actually collected, reaches 20–30% of expected revenue.

To address this, many countries have adopted electronic invoicing and digitalized tax controls. France, however, has chosen a particularly ambitious approach: the decentralized CTC and 5-corner exchange model. This strategic choice is not just fiscal or economic. It anticipates the upcoming European ViDA regulation, which could adopt this model as a European standard for invoice flows, and provides a solid foundation for the industrialization of Finance AI. Here’s why.

Electronic invoicing: A lever for compliance and efficiency to reduce the VAT gap

The VAT gap mainly depends on:

  • The size of the informal economy, i.e., all economic activities that escape official state control and are underreported or not reported at all to tax authorities
  • The effectiveness of tax administrations
  • The digital maturity of tax processes

Every euro not collected represents a direct loss for the state. Digitalized controls, combined with an interoperable and standardized model, secure revenue while generalizing electronic invoicing practices nationwide for greater operational efficiency.

Experience has shown significant results. According to the latest Billentis report, digital tax compliance programs have reduced the VAT gap by up to 50%. Recent declines in Europe are partly cyclical (COVID-19, Brexit), but the structural lever is clear: digitalization is the sustainable engine to secure tax revenues.

Examples of impact:

Italy


+€6 billion in annual tax revenue thanks to e-invoicing

Brazil


+$58 billion USD

Chile, Mexico


nearly 50% reduction in VAT gap

Colombia


50% reduction in tax evasion

Electronic invoicing is one of the most effective anti-fraud tools ever deployed.

From tax control to economic value: The CTC electronic invoicing model

Continuous Transaction Controls (CTC) go far beyond simple tax compliance. According to Billentis, a country adopting the 5-actor model could generate 5 to 11 times more economic gains than the additional VAT revenue alone, thanks to automation and optimization of B2B business processes. The benefit is therefore not only fiscal, but also economic and operational.

Overview of CTC electronic invoicing models

Over the years, the way taxpayers submit their tax data has evolved significantly. VAT and other indirect taxes must now be reported via what is called Digital Reporting Requirement (DRR). This follows a clear trend: moving from Periodic Transaction Controls (PTC), such as traditional VAT filings or SAF-T formats, to Continuous Transaction Controls (CTC). The main advantage for tax authorities is near-real-time access to data, allowing more effective fraud detection and prevention.

Since 2005, several CTC e-invoicing models have emerged:

Principles:

  • Rapid reporting of invoices to the tax authority or designated agency
  • Central platform managed by the tax authority
  • Use of accredited software to process data
  • Full or partial submission of invoice data within 24–72 hours
  • Flexibility in the dataset submitted (invoice data alone or supplemented)

Advantages:

  • Transparency and near-real-time tracking
  • Encourages electronic invoicing and improves economic efficiency

Disadvantages:

  • Requires separate systems for real-time reporting
  • Including additional data (e.g., financial accounting) increases initial and maintenance costs
  • Operational complexity for businesses

Adopting countries:

  • Hungary
  • South Korea

Principles:

  • Verification of tax compliance before or after invoice submission:
    • Pre-validation: before sending to the recipient
    • Post-validation: after approval by tax authorities
  • Simplex (issuer only) or duplex (issuer + recipient) models
  • Mandatory use of a structured format for submission to the central platform

Advantages:

  • Tax compliance guaranteed before transmission
  • Centralized data storage by the tax authority

Disadvantages:

  • Specific format not standardized for all invoices
  • No automation for business-to-business exchanges
  • Significant operational burden on the issuer
  • Does not inherently facilitate accounts payable/receivable management

Adopting countries:

  • Chile
  • Mexico

Principles:

  • Central platform acts as an intermediary for B2B and B2G invoice transmission
  • Platform validates tax compliance and business rules
  • Validated invoices transmitted to the buyer via the platform or third-party providers

Advantages:

  • Centralized control of invoices and tax compliance
  • Standardization of invoice formats

Disadvantages:

  • Risk of dependence on a single platform (downtime, monopoly)
  • Companies need to adapt their systems to central format
  • Possible disruption of business automation

Adopting countries:

  • Italy
  • Serbia
  • Turkey

Emergence of a new model: Decentralized CTC & 5‑Corner exchange

Based on these experiences, a next-generation model has emerged: the decentralized CTC and exchange model, called the 5-actor model (5 corners/pillars, simplex or duplex). While its implementation is the most complex, this model combines benefits for tax authorities and businesses, allowing companies to optimize business processes.

Today, this model forms the foundation of France’s implementation and could be adopted by many countries by 2030, potentially becoming an international standard for electronic invoicing and continuous tax controls.

Principles:

  • Validation and exchange of data via certified providers, not directly by the tax authority
  • Subset of data transmitted to the central tax platform
  • Simplex (seller only) or duplex (seller + buyer)
  • Interoperability standards between providers for document exchange

Advantages:

  • Progressive deployment
  • Tax audit based solely on strictly necessary data
  • Suitable for SMEs (low-cost or free services for a limited number of invoices)
  • No single point of failure
  • Opportunity to accelerate and optimize the automation of the commercial cycle.

Disadvantages:

  • Dependence on certified providers for transmission to the tax platform
  • Requires provider certification under technical and financial standards

Adopting countries:

  • Emerging model, expected adoption in many countries by 2030, including France

Why choose this model despite its complexity?

Because beyond digitalizing transactions, states aim to:

Implement structural anti-fraud measures

Gain near-real-time VAT visibility

Ensure long-term ViDA compatibility

Enable Finance AI industrialization and accelerate automation of financial processes

The 5-corner CTC model: Preparing for ViDA and Finance AI

According to Billentis, this model will be adopted by many countries by 2030 as it not only secures VAT but also creates a robust fiscal and economic ecosystem with “orchestrated” tax models where data flows better, faster, and generates economic value beyond compliance.

This model also aligns with the European ViDA reform. While ViDA does not mandate a single technical model (clearance, centralized, or 5-corner), it envisions strong digital data reporting (DRR) with structured electronic invoicing, precisely the principles of Continuous Transaction Controls (CTC). France’s decentralized CTC and continuous e-reporting model is fully in line with ViDA’s European vision.

It also lays the groundwork for Finance AI industrialization which requires four conditions:

Structured data

Large, continuous data flows

Clear governance

Stabilized processes

The decentralized CTC & 5-corner exchange model meets these requirements for scalable AI:

Standardized data (Factur-X, EN 16931, enriched) for high-quality inputs

Near-real-time flows for dynamic AI learning

Governance of certified platforms (audited to ensure compliance)

Separation of flows, enabling specialized, scalable AI (fraud, expense reports, cash, DPO)

This model prepares the future of intelligent, interoperable, European finance.

As a fully certified platform, Medius supports mid-sized and large companies to both ensure compliance with the reform and enhance automation of their procure-to-pay, accounts payable, and expense management processes.

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