Description

This use case addresses invoices for operations subject to professional secrecy (Article 226-13 of the Penal Code), including banking secrecy (Article L.511-33 CMF), business secrecy (Article L.151-1 of the Commercial Code), and sensitive data covered by ministerial instruction 900/ARM/CAB/NP of March 15, 2021. The solution uses the distinction between BT-153 (Item Name), which is sent in Flow 1, and BT-154 (Item Description), which is sent only in Flow 2.

Operators subject to secrecy obligations use a generic description in BT-153 (for example, "Professional service") that is sent to the tax administration through Flow 1. The detailed, confidential description is placed in BT-154, which is only present in Flow 2 and accessible to the invoice parties (seller and buyer). Other line-level data (references and attributes) also remain in Flow 2 only, preserving confidentiality.

Key characteristics

• BT-153 (Item Name): Generic description sent in Flow 1 (visible to tax administration).

• BT-154 (Item Description): Detailed or confidential description in Flow 2 only (seller and buyer only).

• Only parties named on the invoice have access to BT-154 content.

• Other line-level details (references, attributes) are also excluded from Flow 1.

• Applies to banking, legal, defense, and other regulated sectors.

• GDPR considerations apply to personal data in invoices regardless of the Flow 1 or Flow 2 distinction.

Relationship to other use cases

Use case 36 is a cross-cutting data protection use case that applies to any standard e-invoicing flow. It does not change the invoice flow or structure, only the content strategy for BT-153 vs. BT-154. You can combine the mechanism with any other use case. Use case 5 (Employee Expenses) references GDPR considerations that align with use case 36's principles.

Business and tax context

Legal and regulatory framework

Professional secrecy is governed by Article 226-13 of the Penal Code. Banking secrecy is governed by Article L.511-33 CMF. Business secrecy is governed by Article L.151-1 of the Commercial Code. The e-invoicing framework respects these obligations by limiting Flow 1 content to BT-153 (generic) while keeping BT-154 (detailed) in Flow 2 only.

Common business scenarios

Legal services

BT-153 = "Legal consultation"; BT-154 = detailed case description.

Banking services

BT-153 = "Financial advisory"; BT-154 = specific transaction details.

Defense contracts

BT-153 = "Professional service"; BT-154 = classified project details.

Medical services

BT-153 = "Healthcare service"; BT-154 = treatment details (GDPR sensitive).

Tax and accounting implications

There are no specific VAT implications. The generic BT-153 in Flow 1 is sufficient for tax pre-filling. The detailed BT-154 serves the buyer's accounting and audit needs. GDPR applies to personal data in both BT-153 and BT-154, even though BT-154 is not sent to the tax administration.

Important:

BT-153 (Item Name) is sent in Flow 1 to the tax administration. BT-154 (Item Description) is in Flow 2 only. Use BT-153 for generic descriptions and BT-154 for confidential details. GDPR applies to personal data in all invoice fields.

Key data requirements

Implementation considerations

Seller considerations

• Place generic descriptions in BT-153 (sent in Flow 1).

• Place confidential details in BT-154 (Flow 2 only).

• Use other line-level fields (references, attributes) for additional confidential data.

• Apply GDPR principles to personal data in all invoice fields.

Buyer considerations

• Full invoice details (BT-154) are available for accounting and audit.

General considerations

• PA-E must correctly extract only BT-153 (not BT-154) for Flow 1 generation.

• Systems should support distinct handling of BT-153 vs. BT-154 for secrecy-sensitive sectors.

SCI mapping

Field	SCI path
BT-153 Item Name (generic)	Invoice/InvoiceLine/Item/Name
BT-154 Item Description (confidential)	Invoice/InvoiceLine/Item/Description
BT-155 Seller Article Code	Invoice/InvoiceLine/Item/SellersItemIdentification/ID
BT-156 Buyer Article Code	Invoice/InvoiceLine/Item/BuyersItemIdentification/ID