Use case 36: Professional secrecy and sensitive data
Invoices subject to professional secrecy send a generic BT-153 description in Flow 1 and keep confidential details in BT-154, visible only to invoice parties in Flow 2.
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
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- 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
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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
| Field ID | Description | Value |
|---|---|---|
| BT-153 | Item name | Generic description (in Flow 1) |
| BT-154 | Item description | Confidential details (Flow 2 only) |
| BT-155/156 | Seller or buyer article codes | In Flow 2 only |
| BG-32 | Item attributes | In Flow 2 only |
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/NameBT-154 Item Description (confidential) Invoice/InvoiceLine/Item/DescriptionBT-155 Seller Article Code Invoice/InvoiceLine/Item/SellersItemIdentification/IDBT-156 Buyer Article Code Invoice/InvoiceLine/Item/BuyersItemIdentification/ID
