Use case 13: Subcontracting with direct payment or payment delegation
Subcontracting scenario where the end buyer pays the subcontractor directly under payment delegation.
Description
In this use case, a subcontractor sends invoice F1 to the seller or contractor (titulaire). The end buyer (maitre d'ouvrage) pays the subcontractor directly, a practice known as payment delegation under Article 14 of Law No. 75-1334 of 31 December 1975 (Title II) for private contracts.
Two distinct invoices exist in this scenario:
- F1
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The subcontractor issues this invoice to the contractor for the subcontracted work.
- F2
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The contractor issues this invoice to the end buyer for the complete project, including subcontracted portions.
The F2 invoice total with VAT (BT-112) covers the full amount. BT-113 (prepaid amount) equals the subcontractor amount to be paid directly, and BT-115 (net amount payable) equals the contractor's own portion.
A direct payment request with the Cross Domain Acknowledgment and Response (CDAR) lifecycle status code 224 may be transmitted from the subcontractor's PA-E to the end buyer's PA-R, with the F1 invoice attached. This informs the end buyer of the direct payment obligation.
- Key characteristics
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- Two invoices
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F1 (subcontractor to contractor) and F2 (contractor to end buyer).
- F1
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BG-4is the subcontractor,BG-7is the contractor,EXT-FR-FE-BG-02is the end buyer (as payer). -
BT-23isS1(submission of a service invoice) orS5(subcontractor sends a service invoice to be directly paid by the end buyer, with tacit approval).
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- F2
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BT-112is the total with VAT (full project), BT-113 is subcontractor amount paid directly by the end buyer, and BT-115 is the net amount payable to the contractor. - Direct payment request
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A direct payment request with the CDAR status code 224, which is required for B2G and recommended for B2B.
- Subcontracted work
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If subcontracted work qualifies, reverse charge (autoliquidation) with
VATEX-FR-AE. - F1 and F2
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Payment statuses reference both F1 and F2 for proper tracking.
- Relationship to other use cases
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Use case 13 extends use case 3 (third-party payer) with construction-specific complexity. The end buyer acts as payer for F1 (similar to use case 3). Use case 14 (co-contracting) is related but involves co-contractors rather than a hierarchical subcontracting relationship. The approval mechanism in use case 14 does not apply to use case 13, where validation is contractual. Use case 8 (factoring) shares the concept of payment redirection but serves a completely different business purpose.
Business and tax context
- Legal and regulatory framework
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For private contracts (B2B), payment delegation is governed by Article 14 of Law 75-1334. The contractor must validate the subcontractor's invoice, either explicitly or through contractual tacit validation. For construction works subject to reverse charge, the subcontractor uses
VATEX-FR-AEwith the mention of reverse charge. - Common business scenarios
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- Construction
- The subcontractor performs earthwork, the contractor manages the overall building project.
- IT projects
- The subcontractor delivers the software component, the contractor manages the system integration.
- Infrastructure
- Multiple levels of subcontracting in large civil engineering projects.
- Tax and accounting implications
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If reverse charge applies (construction work between taxable persons), F1 has zero VAT with
VATEX-FR-AE. The contractor applies the reverse charge on F1 then declares full VAT on F2. Encaissée (payment received) status management requires coordination. The subcontractor transmits the Encaissée for F1 when paid by the end buyer. The contractor transmits two Encaissée statuses for F2: One for their portion, one for the subcontractor portion paid directly.Important:The contractor must attach the direct payment certificates and potentially the F1 invoice to F2 (BG-24). The end buyer uses this documentation to organize split payments to the contractor and the subcontractor.
Key data requirements
- Invoice F1 (subcontractor to contractor)
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Field ID Description Value BT-3 Invoice type code 380 (Standard) BG-4 Seller subcontractor BG-7 Buyer contractor (titulaire) EXT-FR-FE-BG-02 Payer End buyer (maitre d'ouvrage) BT-23 Billing framework S1 or S5 BT-11 Project or lot reference Construction site reference BT-17 Tender or lot reference BT-18 Invoiced item, with qualifier in BT-18-1 and a long United Nations Trade Data Interchange Directory (UNTDID) 1153 list BT-121 VATEX VATEX-FR-AE (if reverse charge) - Invoice F2 (contractor to end buyer)
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Field ID Description Value BT-3 Invoice type code 380 BG-4 Seller contractor (titulaire) BG-7 Buyer End buyer BT-112 Total with VAT Full project amount (subcontractor and contractor) BT-113 Prepaid amount Subcontractor amount (paid directly by the end buyer) BT-115 Amount due Net amount payable to the contractor BG-24 Attachments Direct payment attestation, F1 copy
Implementation considerations
- Seller considerations
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The subcontractor must use
EXT-FR-FE-BG-02to designate the end buyer as payer in F1. -
The subcontractor must include project and site references (BT-11, BT-17, BT-18) for grouping.
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The contractor must create the F2 with direct payment certificates attached (BG-24).
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- Buyer considerations
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The end buyer must process the F2 and the associated direct payment request for F1.
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Organize split payments to the contractor and the subcontractor.
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- General considerations
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The PA-E must support direct payment request (CDAR code 224) creation and transmission.
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The PA-R must support receiving a direct payment request from a third party, without having the invoice.
Important:The subcontractor and the Maitre d'Oeuvre (MOE, if applicable) require access to invoices and lifecycle statuses across both F1 and F2. The Sovos solution handles this through its user interface with granular role-based permissions, so subcontractors can track their F1 direct payment status and MOEs can validate invoices across the construction dossier.
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- SCI mapping
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Field SCI path BT-3 invoice type Invoice/InvoiceTypeCodeBG-4 seller Invoice/AccountingSupplierParty/PartyBG-7 buyer Invoice/AccountingCustomerParty/PartyEXT-FR-FE-BG-02 payer Invoice/PaymentMeans/PaymentMandate/PayerPartyBT-23 billing framework Invoice/InvoicePeriod/DescriptionCodeBT-11 project reference Invoice/ProjectReference/IDBT-112 total with VAT Invoice/LegalMonetaryTotal/TaxInclusiveAmountBT-113 prepaid Invoice/LegalMonetaryTotal/PrepaidAmountBT-115 amount due Invoice/LegalMonetaryTotal/PayableAmount
