I. Executive Summary
France is progressively implementing a comprehensive e-invoicing and e-reporting mandate, expanding from its existing Business-to-Government (B2G) system to encompass Business-to-Business (B2B) and Business-to-Consumer (B2C) transactions. The primary objectives are to “modernise administrative processes, reduce VAT fraud, and align with broader EU initiatives for digital invoicing, such as ViDA (VAT in the Digital Age).” (French E-Invoicing and E-Reporting Mandate Study Guide). Despite proposals for postponement, the French National Assembly rejected an amendment to delay the Continuous Transaction Control (CTC) mandate, affirming the current phased rollout schedule commencing in September 2026. A significant strategic shift has altered the role of the Portail Public de Facturation (PPF), moving from a direct exchange platform to a “Business Directory” and “central data hub for transmitting information to the DGFiP” (French E-Invoicing and E-Reporting Mandate Study Guide), necessitating businesses to engage with accredited Partner Dematerialisation Platforms (PDPs) for invoice exchange.
II. Key Themes and Most Important Ideas/Facts
A. Mandate Objectives and Scope
- Primary Purpose: The mandate aims to “modernize administrative processes, reduce VAT fraud, and align with broader EU initiatives for digital invoicing, such as ViDA (VAT in the Digital Age).” (French E-Invoicing and E-Reporting Mandate Study Guide). This will give the government “better oversight of business activities and streamline compliance.” (France’s E-Invoicing and E-Reporting Mandate).
- Expanded Scope: The reform extends mandatory e-invoicing from B2G transactions (already active since 2020 via Chorus Pro) to B2B transactions. Additionally, it introduces a new e-reporting system for B2C and international B2B transactions (French E-Invoicing and E-Reporting Mandate Study Guide).
B. Timeline and Rollout Phases
- Rejected Postponement: On April 11, 2025, the National Assembly “rejected an amendment to postpone the French CTC mandate by one year.” (French E-Invoicing and E-Reporting Mandate Study Guide). This decision “confirmed the government’s commitment to the original rollout schedule” (France’s E-Invoicing and E-Reporting Mandate).
- Current Rollout Schedule:September 1, 2026: Obligation for all companies to be able to receive e-invoices, and for Large (Grandes Entreprises) and Intermediate (Entreprises de Taille Intermédiaire) companies to issue e-invoices. This date “may be postponed by a decree until December 1, 2027, at the latest” (Excerpts from “E-invoicing compliance in France | Pagero”).
- September 1, 2027: Obligation for Small, Medium (Petites et Moyennes Entreprises), and Micro (Très Petites Entreprises) companies to issue e-invoices. This date “may be postponed by a decree until December 1, 2028, at the latest” (Excerpts from “E-invoicing compliance in France | Pagero”).
- Testing and Pilot Phases:February – April 2025: Pilot phase for selected PDPs to test the Directory functionality, open to all PDPs from April 2025. Businesses can also test connectivity (France’s E-Invoicing Rollout: Key Milestones and Strategic Shifts Ahead).
- October 2025: Critical milestone for “interoperability testing” between businesses and their chosen PDPs (French E-Invoicing and E-Reporting Mandate Study Guide).
- February 2026: “Full-scale testing with a sandbox environment” for businesses and PDPs to simulate real-world e-invoice exchanges (French E-Invoicing and E-Reporting Mandate Study Guide).
C. The French E-Invoicing Model and Infrastructure
- Five-Corner Model: France is transitioning to a “5-corner model” for e-invoicing, meaning businesses must use an accredited PDP for invoice exchange (French E-Invoicing and E-Reporting Mandate Study Guide).
- Partner Dematerialisation Platforms (PDPs):PDPs are “accredited private service providers essential for the secure transmission and exchange of e-invoices and e-reporting data between businesses.” (France’s E-Invoicing and E-Reporting Mandate).
- Businesses are “required to select and partner with a PDP” as the PPF no longer handles direct invoice exchanges (France’s E-Invoicing and E-Reporting Mandate).
- As of April 2025, “87 PDPs are already registered” (French E-Invoicing and E-Reporting Mandate Study Guide), with “full certification by Q2 2026” expected (France’s E-Invoicing Rollout: Key Milestones and Strategic Shifts Ahead).
- Portail Public de Facturation (PPF) – Strategic Shift:The PPF was “originally intended to have a central part in the distribution of e-invoices and would offer a free-of-charge alternative” (Excerpts from “E-invoicing compliance in France | Pagero”).
- However, a “strategic shift announced in October 2024” significantly altered its role. The DGFiP “no longer offer[s] free direct access via the PPF” (French E-Invoicing and E-Reporting Mandate Study Guide).
- The “PPF will now primarily function as a Business Directory and a central data hub for transmitting information to the Direction Générale des Finances Publiques (DGFiP)” (France’s E-Invoicing and E-Reporting Mandate). It “will not handle the direct exchange of e-invoices between businesses.” (French E-Invoicing and E-Reporting Mandate Study Guide).
- French Peppol Authority:Established on December 13, 2024 (France’s E-Invoicing Rollout: Key Milestones and Strategic Shifts Ahead), and confirmed on July 2025 (France updates PDPs on e-invoicing reform).
- Responsible for “ensuring that all Partner Dematerialisation Platforms (PDPs) operate under standardised protocols and are fully certified for e-invoice handling.” (France’s E-Invoicing and E-Reporting Mandate).
- Its purpose is to “align France’s e-invoicing framework with broader EU standards, particularly the Peppol network, to enable seamless and secure cross-border electronic document exchange.” (France’s E-Invoicing and E-Reporting Mandate).
- Mandatory Formats: From September 1, 2026, the mandatory formats for B2B e-invoices are “UBL 2.1, CII 3.0, and FacturX” (French E-Invoicing and E-Reporting Mandate Study Guide; Excerpts from “E-invoicing compliance in France | Pagero”).
- Digital Signature: “Not required, but common” (Excerpts from “E-invoicing compliance in France | Pagero”).
- Archiving Period: Legally “6 years,” but “it is common for both issuers and recipients to store them for 10 years” due to “potential varying interpretations of specifications established in different French legal codes” (France’s E-Invoicing and E-Reporting Mandate; Excerpts from “E-invoicing compliance in France | Pagero”). Archiving abroad is allowed under conditions (Excerpts from “E-invoicing compliance in France | Pagero”).
D. E-Reporting System
- Scope: Required for “data related to international B2C and B2B transactions” (French E-Invoicing and E-Reporting Mandate Study Guide; Excerpts from “The electronic invoice in France | EDICOM Global”).
- Timeline: Follows the same compliance schedule as the electronic invoice mandate (French E-Invoicing and E-Reporting Mandate Study Guide).
III. Key Actions for Businesses
- Act Now: Businesses should “begin engaging with an accredited PDP immediately” to prepare for the upcoming testing phases and the official launch (France’s E-Invoicing Rollout: Key Milestones and Strategic Shifts Ahead).
- Testing and Integration: Participate in “interoperability testing (October 2025) and full functionality testing (February 2026)” to ensure system compatibility with the new framework and chosen PDP (French E-Invoicing and E-Reporting Mandate Study Guide).
- Understand the New Model: Recognise that “the free PPF service will not handle direct invoice exchanges, necessitating a partnership with an accredited PDP for e-invoicing” (French E-Invoicing and E-Reporting Mandate Study Guide).
- Data Archiving: Ensure compliance with the recommended 10-year archiving period for electronic invoices (French E-Invoicing and E-Reporting Mandate Study Guide).
- See also
- Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
