In order to fight VAT fraud associated with the use of systems that enable cash receipts to be concealed, the french finance law for 2016 established the obligation, for all VAT-liable professional taxpayers who deliver goods and services to individual customers and record the corresponding payments received by means of a cash register system, to use a secure cash register system.
This system must thus be certified by an independent body accredited by COFRAC. Moreover and in the context of the finance law for 2016, product certification by an accredited body is obligatory for VAT-liable taxpayers who edit their own cash register system. That is the case of Openbravo.
As a consequence of the above, Openbravo selected the LNE, that is the French “Laboratoire National de Métrologie et D’essais", as the independent body accredited in France to certify its Retail solution.
LNE standard describes the procedures for the certification of cash register systems.
They are essentially based on article 88 of finance law No. 2015-1785 of 29 December 2015 for 2016 and the official bulletin for public finance BOI-TVA-DECLA-30-10-30-20180704, which defines the conditions of inalterability, security, conservation and archiving of transaction data that the system must satisfy.
- Data inalterability
- the software/system should evidence the authenticity and integrity of the data that may take the form of signature chaining for each record.
- Data Security
- The cash register system must allow to unequivocally identify receipts issued
- The system must provide secure traceability of receipts printed and reprinted.
- The information included in the receipts must be consistent with the payment data recorded securely by the cash register system
- All payment and traceability data as well as evidence of its inalterability must be stored for six years
- Cumulative and summary data as well as traceability data must be stored in the system.
- Payment data (excluding cumulative, summary data and traceability data) may be conserved in either the system itself or in the archives.
- Data Archiving
- The cash register system must provide an archiving function intended for users enabling the export of uneditable, time-stamped payment data in an open format
- It is a means for the taxpayer to be able to conserve their payment data independently of the cash register system used and send it to the tax authority in the event of an audit
LNE standard aims to certify these four characteristics, the characterisation of the fiscal scope of the system, the version of the system, the documentation relating to the system and the organisation CMS (Compliant Management System) implemented to ensure the production and delivery of cash register systems that comply with the certified version.
All the functionality related to above described regulation and LNE standard is delivered as an Openbravo extension module named "French Fiscal". This module needs to be installed in any retail company operating in France.
The source code of “French Fiscal" module is the code certified by the LNE, and therefore represents the fiscal scope of Openbravo cash register system.
The cash register system’s documentation must describe all of the functions and mechanisms implemented under the certification that mean it meets all the technical requirements set out in LNE standard chapter IV.
Part of this documentation is also created to describe the proper operation of cash register systems in France.
This wiki page is the framework where the organisation of this documentation is described, as shown below, and the way Openbravo conservs its documentation on electronic form.
- General design file: describes the system and its main operating principles in their entirety and the equipment associated with the system to enable payments.
- Functional specifications file: Description of the usages identified, points of attention and specific demands inherent to the system, defined during the design phase in order to validate whether the solution will properly meet the explicitly identified requirements. In particular, the specifications related to the LNE standard requirements must be included.
- Technical architecture file: describes the technical implementation of the solution in depth: technologies, algorithms, (particularly the signatures and hashes used to secure data), frameworks, protocols used; detailed architecture of the system (diagram with flows and the system’s different components); backup procedures, etc.
- Organisational file: describes what processes and organisation have been implemented for the design, development and configuration/deployment of the system.
- Maintenance file: intended to identify the monitoring of the product’s developments/corrections, processes and organisation put in place to manage vulnerabilities, licence management, methods of updating a version (corrective or progressive) and its delivery to the customer, code versioning policy mentioning the management of major/minor versions according to regulations.
- Operational file: describes of the system’s possible configurations and calibrations, its installation, the equipment prerequisites, the data backup procedures, he use and monitoring of the system by system administrators as well as the replacement of the system.
- User files:
- User manual for the end user describing the system’s functions and its operating instructions.
- User manual dedicated to the tax authorities describing precisely and simply how transaction data can be accessed by the tax authorities (with descriptions of any table fields, XML files, CSV files, etc.) This may be included in the user manual or be in a separate manual.
Openbravo committs to keep the regulatory documents until the end of the third year following the year in which the software or cash system ceases to be released.
Finally, Openbravo provides the main document attached below, as the main document describing the organisation of each documentation, and listing all relevant documents, paragraphs and page numbers for each technical requirement.
Regulatory documents in French
Regulatory documents in English
Additional documentation in English
Openbravo Compliance Management System
This Openbravo wiki page is intended to be the centralized source of information about the Openbravo Compliance Management System, implemented according to Chapter III of the LNE standard version 1.4.