A practical guide to what your French entity must change before September 2026.
This guide covers the French e-invoicing reform for international companies and foreign subsidiaries: what the reform requires, who is affected, the accepted invoice formats, how the platform ecosystem works, the implementation timeline by company size, and how France’s approach compares with e-invoicing reforms already in place in other European countries. For EUROCAD’s support service and implementation assistance, see our E-Invoicing Compliance service page.
Two parallel obligations
E-Invoicing vs E-Reporting: Two Distinct Obligations That Apply Simultaneously
The French reform introduces two parallel obligations that are frequently confused. Understanding the distinction is the starting point for any compliance assessment.
E-invoicing (facturation électronique)
E-invoicing applies to domestic B2B transactions between companies established in France and registered for VAT. From the applicable deadline, invoices must be issued in a structured electronic format and transmitted through a certified platform. The obligation covers both issuance and reception: even a company that rarely issues invoices must be technically capable of receiving e-invoices from its French suppliers.
Included: all B2B transactions between French VAT-registered entities, sales of goods, services, and mixed supplies.
Excluded: B2C transactions, transactions with non-VAT-registered entities, international supplies (exports, intra-EU supplies), and transactions with public sector entities (already covered by the Chorus Pro system).
E-reporting (transmission des données de transaction)
E-reporting applies to the transactions not covered by e-invoicing. Rather than transmitting a full electronic invoice, companies must transmit structured transaction data to the DGFiP periodically, covering taxable amounts, VAT, counterparty information, and payment terms.
B2C transactions: sales to consumers, including all online retail and digital services supplied to French individuals.
Cross-border B2B transactions: supplies to foreign VAT-registered customers (exports and intra-EU supplies), even where no French VAT applies.
Non-VAT-registered entities: supplies to associations, public bodies not on Chorus Pro, and other non-registered counterparties.
The critical implication for international companies: if your French subsidiary has any revenue from B2C sales, exports, or intra-EU supplies — which is the case for most international groups — e-reporting obligations apply alongside e-invoicing. The two obligations share the same platform infrastructure but have different transmission frequencies and data requirements.
Scope
Who Is Affected by the French E-Invoicing Reform
The reform applies to all companies established in France and registered for VAT. There are no turnover or size exemptions: every French VAT-registered entity, from a single-employee startup to a large multinational subsidiary, must comply by its applicable deadline.
French subsidiaries of international groups
Subject to both e-invoicing (for domestic B2B) and e-reporting (for cross-border and B2C flows). The ERP integration challenge is particularly significant for subsidiaries running SAP, Oracle NetSuite, or Microsoft Dynamics 365 configured for other markets.
Foreign companies without a French entity
Subject to e-reporting obligations for their French VAT-registered transactions. E-invoicing in its strict sense does not apply, but e-reporting does if they have French-taxable B2C or certain B2B flows. See Tax Representation Services in France.
Companies already on Chorus Pro
Companies supplying the French public sector are already familiar with structured electronic invoicing through Chorus Pro. However, Chorus Pro is a separate system: it does not satisfy private-sector e-invoicing obligations, and companies will need to connect to a PA or the PPF for their private B2B flows.
Formats
Accepted E-Invoice Formats in France: Factur-X, UBL and CII Explained
France has defined three accepted structured formats for e-invoices. The choice of format has direct implications for ERP configuration and PA compatibility, it is not a purely administrative decision.
Factur-X, the hybrid PDF/XML format
Factur-X is the most widely adopted format in France and the one most PAs and accounting software providers natively support. It is a hybrid format: a human-readable PDF invoice with an embedded XML data file containing the same information in structured form. The XML embedded in a Factur-X invoice is based on the Cross Industry Invoice (CII) standard.
Factur-X exists in multiple profiles with different levels of data completeness:
MINIMUM: contains only the legally required minimum data fields. Suitable for simple transactions but not for all use cases.
BASIC WL (Without Lines): header-level data without invoice line detail. Sufficient for many standard transactions.
BASIC: includes line-level detail. The most commonly used profile for standard B2B invoicing.
EN 16931 (COMFORT): full compliance with the European e-invoicing standard EN 16931, required for public sector invoicing and recommended for cross-border EU interoperability.
EXTENDED: contains additional data fields beyond EN 16931 requirements, used for complex supply chains and specific industry requirements.
For most French subsidiaries of international groups, the BASIC or EN 16931 profile is appropriate. The MINIMUM profile may not be accepted by all PAs and does not support all VAT calculation scenarios.
UBL, Universal Business Language
UBL is an XML-based standard developed by OASIS, widely used in Northern Europe and in public procurement. It is accepted by the French e-invoicing framework and is natively supported by several international ERP systems, particularly relevant for companies that already produce UBL invoices for other European markets (Belgium, Netherlands, Denmark). If your ERP already outputs UBL for other jurisdictions, using UBL for French e-invoicing may require less configuration than switching to Factur-X.
CII, Cross Industry Invoice
CII is the pure XML version of the data standard that underlies Factur-X. Unlike Factur-X, it is machine-readable only, there is no human-readable PDF component. CII is accepted by the French framework but is less commonly used in practice because the absence of a human-readable component makes it less convenient for manual invoice review. It is primarily used in automated, high-volume B2B environments.
| Format | Key characteristic | Best suited for |
|---|---|---|
| Factur-X | Hybrid PDF + embedded XML, human and machine readable | Most French companies, widest PA support |
| UBL | Pure XML, machine readable only | Companies already using UBL in other EU markets |
| CII | Pure XML, machine readable only | High-volume automated B2B environments |
Platform ecosystem
The French E-Invoicing Platform Ecosystem: PPF, PA and OD Explained
The French e-invoicing framework relies on a three-tier platform architecture that is unique in Europe. Understanding how it works is essential for making the right platform decision for your French entity.
The PPF, Portail Public de Facturation
The PPF (previously Chorus Pro for the public sector, now extended to private sector e-invoicing) is the public platform operated by the DGFiP. It is free to use and provides basic e-invoicing functionality: invoice submission, routing to the recipient, and transmission of e-reporting data to the tax authorities. The PPF is the fallback option for companies that choose not to work with a certified private platform.
Suitable for very low invoice volumes, companies with simple invoicing needs, and SMEs that do not have the resources or need to invest in a private platform integration. Not suitable for companies with high invoice volumes, complex ERP integration requirements, or the need for advanced features such as automated reconciliation, approval workflows, or real-time status tracking.
PAs, Plateformes de Dématérialisation Partenaires
PAs are certified private platforms authorised by the DGFiP to transmit e-invoices and e-reporting data. They are the primary route for most businesses with significant invoice volumes. PAs offer capabilities well beyond the PPF: ERP connectors, automated invoice routing, real-time status tracking, archiving, approval workflows, and multi-format support. The DGFiP maintains a list of certified PAs, certification is a rigorous process, and the market of accredited PAs is still maturing.
Key criteria for PA selection:
ERP compatibility: the PA must be able to connect to your ERP, via API, file exchange (SFTP), or a native connector. Verify compatibility with SAP, Oracle NetSuite, Microsoft Dynamics 365, Sage, or Xero before committing.
Format support: the PA must support the format your ERP produces (Factur-X, UBL, or CII) without requiring you to convert formats manually.
E-reporting scope: confirm that the PA handles both e-invoicing and e-reporting obligations, some platforms focus exclusively on one or the other.
International capability: for companies with cross-border invoice flows, verify that the PA can handle foreign counterparty information and multi-currency invoices correctly.
Support model: for international subsidiaries whose IT function is based abroad, verify that the PA offers English-language support and documentation.
ODs, Opérateurs de Dématérialisation
ODs are intermediary service providers that help companies prepare and transmit invoices, they sit between the company’s ERP and a PA. They are not themselves certified to transmit to the DGFiP directly, they route through a connected PA. ODs are relevant for companies whose existing invoicing software or ERP cannot directly connect to a PA. For most international companies running standard ERP systems with PA connectors available, working directly with a PA is simpler and more cost-efficient than adding an OD layer.
Timeline
French E-Invoicing Implementation Timeline: Deadlines by Company Size
The French e-invoicing reform is being phased in by company size. The obligation to receive e-invoices applies to all companies from the start of the reform. The obligation to issue e-invoices follows a staged rollout. The DGFiP has the authority to adjust these dates via the annual Finance Law (Loi de Finances), EUROCAD monitors all official announcements and updates clients accordingly.
| Company size | Issuance deadline | Definition |
|---|---|---|
| Large companies | September 2026 | Revenue > €1.5B or > 5,000 employees |
| Mid-size companies (ETI) | September 2026 | Revenue €50M–€1.5B or 250–5,000 employees |
| SMEs and micro-enterprises | September 2027 | Revenue < €50M or < 250 employees |
| Reception obligation | September 2026 | All French VAT-registered entities, all companies |
The reception obligation is the most immediate action item for all French entities regardless of size. Even if your entity is classified as an SME and has until September 2027 to issue e-invoices, it must be technically capable of receiving e-invoices from large and mid-size French suppliers from September 2026. This requires a PA connection or PPF account to be operational before that date.
Day-to-day impact
What E-Invoicing Changes in Your Day-to-Day Accounting Workflow
E-invoicing is not simply a change in how invoices are transmitted, it changes the moment, the format, and the traceability of financial data entering your accounting system. For international companies managing French entities, understanding these workflow implications is essential for planning the implementation correctly.
The invoice lifecycle under e-invoicing
Under the current PDF-by-email model, an invoice is issued, sent, received, manually entered into the accounting system, approved, and paid, with no mandatory tracking of status between issuance and receipt. Under the e-invoicing framework, the invoice lifecycle is fully tracked through the platform:
Deposited
The invoice is submitted to the PA by the issuer.
Routed
The PA routes the invoice to the recipient’s PA or the PPF.
Made available
The recipient’s PA makes the invoice available to the recipient’s system.
Received
The recipient’s system acknowledges receipt.
Approved or rejected
The recipient processes the invoice, approval or rejection must be transmitted back through the platform.
Paid
Payment status is transmitted, enabling real-time cash flow visibility for both parties and the DGFiP.
This lifecycle tracking is mandatory, companies cannot simply receive an e-invoice and process it silently. The platform expects status updates at each stage, and failure to transmit status updates is a compliance gap.
Accounts receivable
Invoices must be generated in the correct format by the ERP or billing system before transmission. Any invoice currently issued as a free-format PDF, a common situation for project-based billing, expense reimbursements, or ad hoc charges, must be restructured into a compliant structured format. This requires a review of all invoice templates and billing scenarios.
Accounts payable
Invoices received through the platform arrive as structured data, not PDFs. The accounting system must be capable of ingesting this structured data directly, either via an ERP connector or through a manual import step. Companies whose accounts payable process relies on manual PDF entry will need to reconfigure their workflow entirely.
VAT reconciliation and the pre-filling opportunity
One long-term consequence of e-invoicing, and a key reason why the DGFiP is driving the reform, is that the tax authority will have real-time visibility of all domestic B2B invoice flows. This creates the conditions for pre-filled VAT returns (déclarations de TVA pré-remplies), similar to what already exists in countries like Mexico and Brazil. While pre-filling is not yet implemented in France, it is the stated medium-term objective. Companies should anticipate that VAT discrepancies between invoice data transmitted through the platform and the CA3 filed separately will be increasingly visible to the DGFiP, making reconciliation accuracy more important than ever.
European context
France’s E-Invoicing Reform in European Context: How It Compares
France is not the first European country to mandate e-invoicing, several EU member states have already implemented mandatory regimes, and the EU’s ViDA (VAT in the Digital Age) initiative will progressively harmonise e-invoicing and e-reporting across the EU from 2030. Understanding where France sits in this European landscape helps international groups plan a coherent multi-country response rather than treating each country as a separate compliance project.
| Country | Status | Model | Key feature |
|---|---|---|---|
| Italy | Mandatory since 2019 | Clearance (SDI) | Real-time SDI validation before delivery |
| France | From Sept 2026 | Y-model (PA/PPF) | Decentralised, PAs route between parties |
| Germany | B2B from Jan 2025 | Receive only (phase 1) | Structured receipt mandatory, issuance phased |
| Belgium | Mandatory from Jan 2026 | Peppol network | Uses existing Peppol infrastructure |
| Spain | Verifactu from 2025 | Clearance variant | Anti-fraud focus, sequential invoice numbering |
| EU ViDA | From 2030 (proposed) | Harmonised | Cross-border B2B e-reporting mandatory EU-wide |
The key difference between France’s model (the Y-model) and the Italian clearance model (SDI) is the moment of tax authority intervention. In Italy, the tax authority validates the invoice in real time before it is delivered to the recipient, the invoice does not legally exist until the SDI system has processed it. In France, the PA routes the invoice directly between parties, with data simultaneously transmitted to the DGFiP, the authority receives data in parallel rather than acting as a gateway. This makes the French model faster operationally but means the DGFiP’s visibility is slightly delayed compared to the Italian model.
For international groups already compliant with Italian e-invoicing, the French system will feel familiar in concept but different in implementation, the platform infrastructure, formats, and connectivity requirements are country-specific. A group-level e-invoicing strategy that accounts for France, Germany, Belgium, and Italy simultaneously, rather than treating each as a standalone project, is the most efficient approach for international companies operating across multiple EU jurisdictions.
Readiness checklist
E-Invoicing Readiness Checklist for International Companies in France
The following checklist covers the key preparation steps for a French entity approaching its e-invoicing implementation deadline. It is structured in chronological order, actions that should be completed 12+ months before the deadline first, immediate pre-deadline actions last.
12+ months before the applicable deadline
Assess transaction scope: map all invoice flows involving your French entity, domestic B2B (e-invoicing), B2C, cross-border B2B, and intra-EU (e-reporting). Identify which flows fall under which obligation.
Audit current invoice formats: determine what format your ERP currently produces for French invoices (PDF, CSV, XML). Identify the gap between current output and required structured formats (Factur-X, UBL, or CII).
Identify non-standard billing scenarios: project-based invoices, credit notes, advance payment invoices, and recurring charges that may not follow the standard invoice template need specific attention.
Evaluate PA vs PPF: assess whether the PPF is sufficient for your invoice volumes and complexity, or whether a certified PA is required. If a PA is needed, begin the evaluation process early, certification timelines and onboarding can take several months.
6 to 12 months before the deadline
Select and contract with a PA: finalise PA selection based on ERP compatibility, format support, e-reporting capability, and support model. Begin the technical integration project.
ERP configuration: work with your ERP provider or internal IT team to configure the system to output invoices in the required structured format. For SAP, Oracle NetSuite, and Microsoft Dynamics 365, certified connectors to major PAs are available.
Accounts payable workflow redesign: redesign the AP process to ingest structured invoice data rather than PDFs. Define how invoice approval, status updates, and payment confirmation will be communicated back through the platform.
Staff training: finance, accounting, and AP/AR teams need to understand the new invoice lifecycle, status tracking, rejection procedures, and e-reporting transmission requirements.
1 to 6 months before the deadline
Test with pilot suppliers and customers: conduct end-to-end tests with a selection of French suppliers and customers using your production or pre-production PA environment. Identify and resolve format or routing issues before go-live.
Validate e-reporting configuration: separately test e-reporting transmission for B2C and cross-border flows, these use different data schemas and transmission frequencies from e-invoicing.
Accounting reconciliation process: establish the process for reconciling invoice data transmitted through the PA with VAT declarations (CA3). The DGFiP will increasingly cross-reference these two data sources.
Confirm reception capability: even if issuance deadline is later, confirm that the system is ready to receive e-invoices from September 2026. Test reception from a large French supplier if possible.
Explore more
Related Services and Further Reading
Common questions
FAQ – E-Invoicing in France 2026
The obligation to receive e-invoices applies to all French VAT-registered companies from September 2026. The obligation to issue e-invoices applies from September 2026 for large companies and ETIs (revenue above €50 million or 250+ employees), and from September 2027 for SMEs and micro-enterprises. These dates are based on the current official schedule and may be adjusted by the annual Finance Law (Loi de Finances).
E-invoicing applies to domestic B2B transactions between French VAT-registered entities, invoices must be issued and received through a certified platform in structured format. E-reporting applies to transactions not covered by e-invoicing: B2C sales, exports, and cross-border B2B flows, for these, structured transaction data must be transmitted to the DGFiP periodically. Most French entities with any international revenue will need both.
Three structured formats are accepted: Factur-X (a hybrid PDF/XML format, the most widely supported in France), UBL (Universal Business Language, XML only, used in Northern Europe), and CII (Cross Industry Invoice, XML only, used in high-volume automated environments). Standard PDF invoices sent by email are no longer valid for domestic B2B transactions once the applicable deadline has passed.
A PA (Plateforme de Dématérialisation Partenaire) is a certified private platform authorised by the DGFiP to transmit e-invoices and e-reporting data. Companies can alternatively use the free public platform (PPF). The PPF is suitable for very low invoice volumes and simple needs. Companies with significant invoice volumes, ERP integration requirements, or the need for advanced workflow features should work with a certified PA. PA selection should be made at least 6 to 12 months before the applicable deadline to allow time for integration and testing.
E-invoicing in its strict sense applies only to transactions between companies established in France. However, foreign companies registered for French VAT, including those without a French entity, may be subject to e-reporting obligations for their French-taxable transactions. The e-reporting obligation applies from the same September 2026 deadline regardless of company size.
Italy uses a clearance model (SDI) where the tax authority validates each invoice in real time before it is delivered to the recipient, the invoice has no legal existence until the SDI processes it. France uses a Y-model where the PA routes the invoice directly between the issuer and recipient, with data simultaneously transmitted to the DGFiP in parallel. The French model is faster operationally but the DGFiP receives data slightly later than in the Italian clearance model. Both countries require structured XML-based formats.
A company that cannot issue or receive e-invoices by its applicable deadline faces financial penalties per non-compliant invoice. More immediately, non-compliant invoices may be refused by French customers or suppliers operating through certified platforms, creating commercial disruption that is more damaging in practice than the penalties themselves. Companies should aim to complete implementation and testing at least 2 to 3 months before the deadline to allow time to resolve unexpected issues.
E-invoicing gives the DGFiP real-time visibility of domestic B2B invoice flows. In the medium term, this creates the conditions for pre-filled VAT returns, a model already used in countries like Mexico and Brazil. In the near term, it means that discrepancies between invoice data transmitted through the platform and the CA3 VAT return filed separately will be increasingly visible to the DGFiP. Accurate reconciliation between e-invoicing data and VAT declarations becomes more important under the reform than it was under the current PDF-based system.
