Updated on 02/10/2025, to take account of the latest BOFiP publication clarifying the deadlines for mandatory certification.
Article 43 of French Finance Act no. 2025-127 of February 14, 2025 abolishes, with effect from February 16, 2025, the possibility of proving the secure nature of a cash register software or system by producing an individual certificate issued by the publisher. From now on, only certification will be allowed (new article 286-I-3° bis of the CGI).
In fact, a new version of the administrative doctrine on tax compliance obligations for cash register software(BOI-TVA-DECLA-30-10-30) was published on October 1, 2025: taking into account the time required to pass certification audits, the doctrine grants, as a mitigating measure, time to comply with this obligation in connection with the fight against VAT fraud in the B2C sector.
The new wording is designed to help companies achieve compliance, by introducing a transitional period before the strict application of the certification obligation from September 1, 2026 - while at the same time organizing the disappearance of the attestation as a means of proof by the end of the summer.
1) Presentation of the timetable and the different proofs of conformity accepted for each phase
a) First phase: February 16, 2025 to August 31, 2025
In order to take into account the time needed for software publishers (and companies that have developed their solutions in-house) to comply, the following may be accepted as proof of compliance:
- Certificate of conformity - supplied by an accredited body.
- Proof of commitment to the audit - provided by an accredited body (see 2° below)
- Individual certificate - supplied by the software publisher
b) Second transitional period: from September1, 2025 to August 31, 2026
Following the end of the first phase, the individual certificate - provided by the publisher - is no longer acceptable proof of software tax compliance.
The proofs accepted during this second phase, from September1, 2025 to August 31, 2026, will be as follows:
- The certificate of conformity - provided by an accredited body.
- Proof of commitment to the audit - provided by an accredited body
c) Third and final phase: from September1, 2026
From September 1, 2026, only a certificate of conformity will be accepted as proof of software conformity.
2) Proof of commitment to the audit
In response to this temperamental measure, and to ensure a reassuring system for software users, we can provide you with proof of commitment to the certification process as soon as you register.
This proof will enable you to respond in the short term (and before your audit) to users' need for acceptable, admissible proof.
In a nutshell
The 3 phases of the temperament measure in the certification obligation :
- From 16/02/2025 to 31/08/2025: a certificate of conformity, an attestation from the publisher or proof of commitment to the audit are acceptable;
- From 01/09/2025 to 31/08/2026: a certificate or proof of commitment to the audit is acceptable;
- From 01/09/2026: mandatory certification.
Have you already had your solution certified? Have you provided your customers with proof of commitment to the audit or a certificate? Let's discuss your certification project.
Find out more about the obligation to certify cash register software.
