Simplification of the DSA in France

In the context of e-invoicing and GAMMA2: understand the new rules for your excise movement documents

For several years, movement certificates for excise goods have been progressively digitalized under the impetus of European requirements.

This evolution has been marked by key milestones:

- January 2011: introduction of the Electronic Administrative Document (e-AD) for duty-suspension movements in intra-EU trade, via the EMCS system;

- July 2017: extension of the e-AD to national movements in duty suspension, where its use became mandatory for professionals;

- February 2023: generalization of the Simplified Electronic Administrative Document (e-SAD) to intra-EU duty-paid movements between professionals, under Directive (EU) 2020/262.

In France, management of e-AD and e-SAD has been operated through the online service **GAMMA2** since June 27, 2025.

For national circulation (i) under duty-paid regime (ii) between professionals (iii), the Simplified Accompanying Document (DSA) or a commercial document (DSAC) in paper format remained the only legally valid document. No digitalization option was provided, meaning the DSA had to be printed and physically accompany excise goods.

During a 2022 consultation with the French Customs Authority (DGDDI), alcohol industry professionals clearly expressed a need: to maintain the flexibility of the DSA, but simplify and digitalize it, particularly in view of the upcoming generalization of e-invoicing.

In response, **Decree No. 2025-590 of June 27, 2025** and its implementing order aim to simplify reporting obligations for national duty-paid circulation of alcoholic beverages between professionals.

Purpose of the reform

This overhaul of the DSA/DSAC marks a turning point towards digital management of national duty-paid movements of alcoholic beverages between professionals.

The simplification of the DSA addresses several objectives identified by both customs authorities and operators:

- Ensure traceability and compliance of duty-paid flows while reducing administrative burden on businesses;

- Provide a secure and flexible support document to prove excise duty payment and ensure reliable data transmission;

- Promote a progressive transition to a fully digital environment, in line with the forthcoming generalization of e-invoicing.

1. BEFORE: The original DSA/DSAC – rigid and complex

The DSA/DSAC used for national movements between professionals was modeled on the intra-EU version, from which only certain fields could be removed.

All boxes in the DSA had to be filled, with only four considered optional in domestic circulation (boxes 3, 6, 9 and 13). The DSAC could replace the DSA provided it contained all required information and carried the mandatory title.

2. NOW: What changes with the simplification?

2.1 Rationalization of mandatory information

The reform clarifies and simplifies the mandatory content of the DSA/DSAC. Required fields now include:

- Sender, consignee and transporter details (name, address, and, where applicable, excise warehouse ID);

- Product details (commercial designation, number and type of containers, nominal volume, alcohol strength by volume);

- Date of document issue;

- Unique reference number enabling traceability in commercial records.

2.2 Full compatibility with e-invoicing reform

The new framework allows DSAs to be issued either via **GAMMA2** or directly through invoices and other commercial documents, which now qualify as DSACs.

The major change: the DSAC can now be **fully digital**. Invoices or electronic commercial documents may serve as movement certificates, provided excise-related information is properly included.

3. Challenges ahead for operators

While this reform brings simplification, it also requires operational and technical adjustments for businesses.

3.1 Integrating excise data into e-invoicing

Companies using invoices or electronic commercial documents as DSACs must ensure excise information (product description, volume, alcohol strength, transporter details, etc.) is included alongside VAT data in compliance with the French e-invoicing reform.

**To anticipate:** work with your Partner Dematerialization Platform (PDP) to integrate these fields in invoice flows.

3.2 Adapting GAMMA2 filings

Operators using GAMMA2 in DTI+ mode will need to update their XML file templates and data interfaces to align with the simplified data structure.

3.3 Updating EDI solutions

Those relying on certified EDI providers must ensure their solutions incorporate the regulatory updates, both in terms of document structure and mandatory fields.

Conclusion

The reform of the DSA/DSAC paves the way for streamlined document management and better integration between excise and VAT. But it requires swift adaptation by businesses.

Whether you rely on GAMMA2, commercial DSACs or EDI solutions, close coordination with your IT teams and service providers is essential to turn this regulatory change into a performance driver.

Our VAT and excise experts are available to support you in analyzing your excise and VAT flows, adapting your systems, and ensuring compliance while optimizing operations.