e-invoicing

Compliance Network Implementation Guide

Use case 17b: Marketplace with billing mandate (Facturant)

In a marketplace with billing mandate, the marketplace acts as Facturant, creating and sending invoices on behalf of the seller while also handling payment collection from the buyer.

Description

This use case extends use case 17a by adding a billing mandate: The marketplace or payment intermediary not only collects payment from the buyer, but also creates and sends the sales invoice (F1) on behalf of the seller. This requires a formal billing mandate between the seller and the marketplace, making the marketplace a Facturant under the EXTENDED-CTC-FR profile.

The marketplace creates F1 using its own platform (PA-T), which acts as the PA-E for transmission. The invoice is issued in the seller's name (BG-4 = seller) but identifies the marketplace in the Facturant block (EXT-FR-FE-BG-05). The seller must get copies of all invoices created on their behalf and all lifecycle statuses for accounting and fiscal purposes. A separate commission invoice F2 is issued by the marketplace to the seller.

Key characteristics
  • The marketplace acts as both payment intermediary and Facturant (invoice creator).

  • Billing mandate required between seller and marketplace.

  • F1 is BG-4=seller, EXT-FR-FE-BG-05=marketplace (Facturant), already paid (BT-113=BT-112).

  • The marketplace's PA-T acts as PA-E: Creates Flow 1, sends Flow 2/3.

  • The seller must get invoice copies and lifecycle statuses for accounting.

  • The marketplace must know seller's VAT regime (important for franchise en base).

  • A dedicated invoice number series per seller managed by marketplace.

  • F2 is a separate commission invoice from marketplace to seller (standard flow).

Relationship to other use cases

Use case 17b combines use case 17a (marketplace payment) with use case 19a (billing mandate). The Facturant mechanism is the same as use case 19a, while the payment flow mirrors use case 17a. Use case 12 (Transparent Intermediary) is related when the marketplace acts as transparent agent for the seller. The key distinction from use case 17a is that the marketplace creates the invoice, not the seller.

Business and tax context

Legal and regulatory framework

The billing mandate is governed by BOI-TVA-DECLA-30-20-10 (articles 340-560) and BOI-TVA-DECLA-30-20-10-30 (articles 70-290). The Facturant must create invoices that conform to the e-invoicing standard and send them through a PA. The seller keeps all fiscal obligations including Encaissee creation.

Common business scenarios
E-commerce marketplace

The platform creates invoices for sellers after orders are fulfilled.

SaaS marketplace

The platform invoices on behalf of software providers.

Professional services

The platform handles invoicing for freelancers and consultants.

Tax and accounting implications

The Facturant must know the seller's VAT regime, particularly if the seller is a franchise en base (VAT-exempt small business). The seller keeps responsibility for VAT declarations and the Encaissee status. The marketplace must give the seller all invoice copies and lifecycle statuses for proper accounting.

Important: The Facturant (marketplace) must maintain a dedicated chronological invoice number series per seller. The seller keeps all fiscal obligations. The Facturant must know the seller's VAT regime.

Key data requirements

Field ID Description Value
BT-3 Invoice type code 380 (standard)
BG-4 Seller Actual seller information
EXT-FR-FE-BG-05 Facturant Marketplace identification
BT-113 Prepaid amount BT-112 (already paid through the marketplace)
BT-115 Amount due 0
BG-10 Payee Marketplace (payment intermediary)
BT-34 Seller e-address For status routing to the seller

Implementation considerations

Seller considerations
  • Set up billing mandate with marketplace; communicate VAT regime changes.

  • Monitor invoices created on their behalf for accounting and fiscal compliance.

  • Send Encaissee status when informed by marketplace of buyer payment.

Buyer considerations
  • Invoice F1 is already paid; process and approve for accounting and VAT deduction.

General considerations
  • PA-T must support Facturant invoice creation with seller identification in BG-4.

  • PA-T must support invoice or status replication to seller.

Note: The marketplace acting as Facturant requires the ability to create invoices on behalf of the seller and manage lifecycle statuses across both parties. The Sovos solution handles this through its interface with role-based permissions, letting marketplace operators create, send, and track invoices for multiple sellers while making sure each seller keeps full visibility into their own invoice portfolio.
SCI mapping
Field SCI path
BT-3 Invoice type Invoice/InvoiceTypeCode
BG-4 Seller Invoice/AccountingSupplierParty/Party
EXT-FR-FE-BG-05 Facturant Invoice/AccountingSupplierParty/Party/ServiceProviderParty/Party
BG-10 Payee Invoice/PayeeParty
BT-113 Prepaid Invoice/LegalMonetaryTotal/PrepaidAmount
BT-115 Amount due Invoice/LegalMonetaryTotal/PayableAmount
BT-34 Seller e-address Invoice/AccountingSupplierParty/Party/EndPointID