Simplification and Modernisation of the DSA (Simplified Accompanying Document) for Alcohol in France

Background: The DSA in Context

Over the past decade, the movement documents required for the circulation of excisable products have been progressively digitalised, driven by European regulatory requirements.

Key milestones:

• January 2011: introduction of the Electronic Administrative Document (e-AD) for duty-suspended intra-EU movements via the EMCS system
• July 2017: extension of the e-AD to duty-suspended domestic movements in France, made mandatory for professionals
• February 2023: rollout of the Electronic Simplified Administrative Document (e-SAD) for duty-paid intra-EU movements, under Directive (EU) 2020/262

In France, since 27 June 2025, both the e-AD and e-SAD are managed via the GAMMA2 online service.

Until now, for domestic circulation of alcoholic beverages that is (i) duty-paid, (ii) between professionals, only the Simplified Accompanying Document (DSA) or its commercial variant (DSAC), in paper format, had legal validity. This document had to be systematically printed and physically accompany the excisable goods at all times.

Following a 2022 consultation with the DGDDI (French Customs), alcohol industry professionals made their expectations clear: retain the flexibility of the DSA, while making it simpler and compatible with a digital format, particularly in view of the upcoming mandatory rollout of e-invoicing in France.

In response, Decree No. 2025-590 of 27 June 2025 and its implementing order now simplify the obligations linked to the domestic circulation of alcoholic beverages in duty-paid status.

Objectives of the DSA/DSAC Reform

The overhaul of the DSA/DSAC marks a key milestone towards the digital management of duty-paid domestic alcohol movements between professionals. It pursues three main objectives, shared by both customs authorities and economic operators:

• Better traceability and security of flows: ensure the traceability and compliance of excisable products while reducing the administrative burden on businesses
• More reliable documents: provide a document that is both secure and flexible, attesting to the payment of excise duty and the quality of the information exchanged
• Future-proofing: facilitate a gradual transition towards a fully digital environment, in line with the forthcoming mandatory e-invoicing framework

The Original DSA/DSAC: Rigid Format, Extensive Fields

Before the reform, the DSA/DSAC used for domestic circulation between professionals was modelled on the document designed for intra-Community movements. Fields not relevant to domestic movements could simply be left blank.

Mandatory Fields of the DSA/DSAC for Domestic B2B Circulation

In practice, all fields of the DSA had to be completed. Only four were optional in a domestic context:

• Field 3: competent authority in the destination Member State
• Field 6: reference number and date of the declaration in the destination Member State
• Field 9: customs nomenclature code of the product
• Field 13: invoice price or value

A commercial document (DSAC) could replace the administrative document (DSA), provided it included all the mandatory DSA fields, identified by their field number. In that case, the document had to bear the following wording: “Simplified commercial accompanying document for the movement of excise goods under duty-paid arrangements.”

DSA/DSAC Field Reference Table

What Changes With the DSA Reform

To meet the expectations expressed by professionals in 2022, the French authorities have modernised the DSA/DSAC framework. This reform is part of the broader e-invoicing and document digitalisation drive.

The Decree and its implementing order introduce two major changes:

1. Simplified content: mandatory fields have been clarified and streamlined
2. Modernised format: the DSAC may now be issued in digital form

Rationalised Mandatory Fields

Under the new framework, the DSA/DSAC mandatory fields are as follows:

Consignor, consignee and carrier information:

• Name, trading name or company name
• Address
• Where applicable, the excise warehouse identification number of both the consignor and consignee

Nature and quantity of the products:

• Commercial description of the products subject to alcohol excise duty
• Number and type of containers
• Nominal volume of containers and alcoholic strength by volume

Date of issue of the document

Unique reference number: this number must allow the movement to be identified in the consignor’s commercial records and establish a single, traceable information and documentation trail for each goods movement.

Digital DSAC Now Compatible With E-Invoicing

The major new development: the DSAC no longer needs to be printed. Operators may now issue it:

• Either via the GAMMA2 online service
• Or in the form of invoices and other commercial documents that serve as the DSA

Where the DSAC previously had to be printed and physically accompany the goods, the key change is that the DSAC, whether in the form of invoices or other commercial documents, can now be issued by the consignor in digital format.

This reform makes the DSAC compatible with the forthcoming mandatory e-invoicing rollout and simplifies day-to-day operations for alcohol industry professionals.

Key Challenges for Operators

The DSA/DSAC overhaul is a major step towards digital management of duty-paid alcohol circulation, but it introduces new technical and organisational requirements. Professionals should anticipate three main areas of impact.

1. Integrating Excise Fields Into E-Invoicing Systems

Even in digital format, the DSAC must include all mandatory excise-related fields, in addition to standard VAT fields.

What to prepare:

• Billing systems must be able to capture the required excise-specific data (product description, volume, alcoholic strength, carrier details, etc.)
• Operators must work with their Approved Platform (PA), formerly known as the Dematerialisation Partner Platform (PDP), to ensure this data is correctly collected and transmitted

2. Updating GAMMA2 Filings for DTI+ Users

For operators who continue to use GAMMA2 via DTI+ mode (online declaration by file upload), files must be adapted to the new mandatory fields. Only the information required under the new Decree and its implementing order should be included.

What to prepare:

• Update XML templates or data exchange interfaces with GAMMA2
• Coordinate between business, IT and service provider teams to avoid rejections or data loss

3. Updating EDI Solutions With Certified Providers

For operators using a certified EDI provider, it is essential to verify that the provider has fully integrated the changes introduced by the DSA/DSAC reform. This covers both:

• The structure of exchanged documents
• The mandatory fields to be included

What to prepare:

An EDI solution update is essential. Check with your provider that they have:

• Taken into account the regulatory impact of the Decree and its implementing order
• Planned a deployment timeline
• Guaranteed compliance of data flows from the date the reform takes effect