Last update June 5, 2026
- Executive Summary
France is implementing a comprehensive and mandatory B2B e-invoicing and e-reporting reform, building on its earlier success with B2G e-invoicing via Chorus Pro. The initiative, primarily governed by Article 26 of the Finance Law 2022 (and subsequent amendments), adopts a unique “Y-Schema” or “5-corner model.” This hybrid system integrates centralized oversight by the Portail Public de Facturation (PPF) with a decentralized network of certified private platforms (Plateformes Agréées, PAs) for B2B invoice exchange. The reform is designed to address a significant VAT gap, combat fraud, modernize tax administration, and ultimately enable the pre-filling of VAT returns.
The implementation is phased:
- From 1 September 2026, all businesses must be capable of receiving e-invoices. Large enterprises and intermediate-sized enterprises (ETI) must also begin issuing e-invoices and e-reporting.
- From 1 September 2027, small and medium-sized enterprises (PME), micro-enterprises, and auto-entrepreneurs must begin issuing e-invoices and e-reporting.
France is positioned as an early mover in digital tax compliance, aligning its framework with the EU’s VAT in the Digital Age (ViDA) initiative, set to introduce mandatory cross-border B2B e-invoicing from 1 July 2030.
- Rationale and Objectives of the Reform
The mandate stems from several strategic objectives aimed at enhancing fiscal efficiency and modernizing the French economy:
- VAT Gap Reduction: “France’s VAT gap was estimated at €12.784 billion in 2022 (6.0% of total VAT liability). The reform introduces Continuous Transaction Controls (CTC) to close this gap.”
- Fraud Prevention: The real-time transmission of invoice and payment data will enable the DGFiP to “cross-check declared VAT against actual invoices, strengthening fraud detection capacity.”
- Administrative Modernisation: The initiative is projected to yield “estimated savings of approximately €4.5 billion, with expected savings of €7–10 per invoice through process digitalisation.”
- Simplification of VAT Obligations: A key long-term objective is “the pre-filling of VAT returns based on e-invoicing and e-reporting data.”
- Improved Economic Intelligence: “Near-real-time data on business transactions allows more precise economic policy steering.”
- Operating Model: The Hybrid Y-Schema
France’s chosen model is a distinctive “Hybrid / Decentralised Interoperability Model (Y-Schema / 5-corner model) with centralised oversight,” differing significantly from purely centralized systems seen elsewhere in Europe (e.g., Italy’s SDI).
- Portail Public de Facturation (PPF): This public platform, operated by the DGFiP, serves multiple central functions:
- Central Directory (Annuaire): It lists all companies subject to the mandate and their designated Plateformes Agréées (PAs).
- Data Concentrator: It aggregates invoice and reporting data for the DGFiP.
- B2G Hub: It continues to handle B2G invoicing flows via Chorus Pro.
- Fallback Portal: It provides a basic, free portal for smaller businesses, particularly for receiving invoices and limited e-reporting.
- Crucially, the PPF “does NOT directly handle B2B invoice exchange between private parties (this role was removed in October 2024).”
- Plateformes Agréées (PA): These are “certified private platforms that validate, transmit, and route B2B e-invoices between businesses.” They are accredited by the tax administration for renewable 3-year periods and are responsible for reporting required data to the PPF/DGFiP. As of mid-May 2026, 146 PAs were registered.
- Solutions Compatibles (SC): These are businesses’ in-house or third-party software solutions that generate invoices and connect to one or more PAs. SCs cannot connect directly to the PPF.
- Invoice Lifecycle: The process involves the seller’s system (or SC) generating an e-invoice, submission to the seller’s PA for validation, routing by the seller’s PA to the buyer’s PA (using the PPF’s directory), and simultaneous data reporting to the PPF. An invoice is considered legally issued “upon deposit with the PA.”
- Scope of the Mandate: Transactions and Taxable Persons
The reform encompasses a broad range of transactions and entities established in France.
- Transactions in Scope:Domestic B2B: “All domestic B2B transactions between taxable persons established in France and subject to French VAT” are mandatory. Paper invoices and simple PDF invoices will be invalid for these transactions once the mandate applies.
- Domestic B2G: Mandatory since 2020 via Chorus Pro. From September 2026, suppliers can choose to use a PA or Chorus Pro.
- Self-billing (autofacturation): Permitted and “falls within the e-invoicing mandate,” requiring processing through the PA/PPF system with a prior agreement and specific mention.
- Special Transactions: Advance payments, triangular/chain transactions (where domestic legs occur), and margin scheme transactions (for specific goods) are also explicitly included.
- Transactions Subject to E-Reporting (but not E-Invoicing):Domestic B2C: “Excluded from the mandatory e-invoicing obligation” but subject to e-reporting of daily aggregated transaction data.
- Cross-border B2B (Intra-EU & Exports Outside the EU): “Not subject to e-invoicing” but require e-reporting of transaction data. Simplification measures announced in August 2025 removed line-item e-reporting for international incoming invoices, effective until ViDA’s DRR in 2030.
- Intra-Community Acquisitions: Not subject to domestic e-invoicing but generally require e-reporting (with line-item reporting removed under simplification measures).
- Excluded or Exempt Transactions:VAT-exempt transactions under Articles 261 to 261 E CGI (e.g., certain banking, financial, medical, or educational services) that are not subject to an invoicing obligation are excluded from both e-invoicing and e-reporting.
- Importations of goods (non-EU): Excluded from e-reporting (customs declarations serve this purpose).
- Transactions subject to foreign VAT between France-established taxable persons: Excluded from e-reporting by August 2025 simplification measures.
- Taxable Persons in Scope:Established Domestic Entities: “All businesses established in France and subject to French VAT are in scope, regardless of size, legal form, sector, or VAT regime,” affecting “More than 10 million economic actors.” This includes entities operating under the franchise en base de TVA (small business VAT exemption).
- Non-Established Entities: Foreign entities with a fixed establishment in France are subject to e-invoicing for domestic B2B. Those registered for VAT in France without a fixed establishment are outside e-invoicing scope but have e-reporting obligations, postponed to September 2027 by simplification measures.
- Implementation Timeline
The reform’s phased rollout is critical for businesses to understand:
- 1 September 2026 (Phase 1):Reception of e-invoices: Mandatory for ALL businesses, irrespective of size (including micro-enterprises and those benefiting from VAT exemption). This is cited as “the most commonly overlooked requirement.”
- Issuance of e-invoices & E-reporting: Mandatory for large enterprises (criteria: >5,000 employees, or >€1.5 billion turnover, or >€2 billion balance sheet) and intermediate-sized enterprises (ETI) (criteria: 250–4,999 employees within defined thresholds).
- 1 September 2027 (Phase 2):Issuance of e-invoices & E-reporting: Mandatory for ALL remaining businesses, including PME (<250 employees), TPE (<50 employees), micro-entrepreneurs, and auto-entrepreneurs.
- Grace Periods & Enforcement: The DGFiP has adopted a “pragmatic enforcement approach,” confirming on 7 May 2026 that “no penalties will be imposed from 1 September 2026.” Instead, businesses showing “genuine implementation efforts will receive contact before any enforcement action.” A “case-by-case leniency approach is in place during onboarding.” The legal framework also offers a “first-infraction exemption” if corrections are made spontaneously or promptly.
- Pilot Phase: A national pilot programme in “live conditions” launched in “late February 2026” (from 27 February) to allow businesses and PAs to test end-to-end flows.
- Key Obligations and Requirements for Businesses
Compliance demands several core actions from businesses:
- E-Invoice Issuance: Generate e-invoices in one of the three mandated structured formats and transmit them via a certified PA. Four new mandatory fields are introduced: customer’s SIREN, delivery address (if different), category of operation (goods/services/both), and VAT payment regime.
- E-Invoice Reception: From 1 September 2026, all businesses must be able to receive e-invoices through their designated PA.
- E-Reporting: Transmit specific data for B2C transactions (daily aggregated), cross-border B2B transactions (invoice level), and payment data for services where VAT is due on collection. “No blank e-reporting is required if no taxable transactions occurred” (simplification measure).
- Mandatory Invoice Statuses: PAs track required lifecycle statuses: “Déposée” (Submitted), “Rejetée” (Technical refusal), “Refusée” (Commercial refusal), and “Encaissée” (Payment Received).
- Digital Signature & Integrity: No per-invoice qualified electronic signature is required. Integrity and authenticity are ensured by the platform infrastructure and structured data exchange.
- Master Data Management: Ensure accurate and up-to-date SIREN/SIRET data in the central directory.
- Acceptable E-Invoice Formats and International Standards
France mandates three structured e-invoice formats, all compliant with European standard EN 16931:
- Factur-X: A hybrid format combining a human-readable PDF/A-3 with embedded structured XML. It is “popular for both small and large businesses.”
- UBL 2.1 (Universal Business Language): An international XML standard “widely used in the Peppol network.” Peppol BIS Billing 3.0 is accepted.
- UN/CEFACT CII (Cross Industry Invoice): A “global cross-industry XML standard for electronic data exchange.”
- Invalid Formats: “Unstructured formats (PDF, paper, Word, Excel) are NOT legally valid for in-scope domestic B2B transactions once the mandate applies to the issuing entity.”
- EDIFACT: Not a mandated format for direct exchange, but companies can continue using it voluntarily via a PA, which must convert it to a mandated format.
- Penalties and Enforcement
While a pragmatic grace period is in effect from September 2026, significant penalties are outlined for non-compliance post-grace period, as “reinforced” by Article 123 of the Loi de Finances pour 2026:
- Failure to issue an e-invoice: €50 per invoice, with an annual cap of €15,000 per business.
- Failure to transmit e-reporting data: €500 per transmission, with an annual cap of €15,000 per business per calendar year.
- Failure to designate a PA for reception: After a 3-month notice, an initial fine of €500, followed by €1,000 every 3 months if non-compliance persists.
- Missing or inaccurate invoice information: €15 per error, capped at 25% of the invoice value.
- Penalties are cumulative, meaning multiple infractions can apply simultaneously.
- Impact on SMEs and Startups
The reform acknowledges the unique challenges faced by smaller businesses:
- Phased Onboarding: SMEs, TPE, micro-enterprises, and auto-entrepreneurs benefit from a “12-month deferral for issuance obligations (September 2027 vs. September 2026).” However, the critical “reception obligation applies from September 2026 — SMEs must be ready.”
- Government Support & Free Tools: The PPF web portal offers a free basic option for receiving invoices and basic e-reporting. Other support includes a national helpline, DGFiP fact sheets for TPE/PME, and online self-assessment tools.
- Compliance Costs: “No specific government grants, tax credits, or subsidies” have been announced. Costs vary widely; simple browser-based solutions are available for minimal fees, but ERP integration for larger SMEs can be substantial.
- Long-Term Benefits: Despite initial “significant” burden, “long-term simplification is substantial,” including faster invoice processing, reduced payment delays, elimination of manual tasks, and eventual pre-filled VAT returns, with estimated net savings of €7-10 per invoice.
- Relationship with ViDA (VAT in the Digital Age)
France is well-prepared for and a leader in digital tax reporting, positioning itself “ahead of the ViDA timeline.”
- Alignment: France’s mandated formats (UBL 2.1, CII, Factur-X) and its status as a Peppol Authority ensure compatibility with EN 16931 and ViDA’s envisioned cross-border infrastructure. France has already “transposed ViDA through Ordonnance n° 2025-1247.”
- Future Adaptations: While France’s domestic mandate precedes ViDA’s cross-border B2B e-invoicing (1 July 2030) by several years, its national system will need adaptation to feed into the enhanced VIES system for EU-wide reporting.
- Temporary Simplifications: France’s e-reporting simplifications (e.g., removal of line-item detail for international incoming invoices) are explicitly temporary and will remain in effect “until ViDA’s DRR enters into force on 1 July 2030.”
- Archiving and Retention Requirements
Businesses must ensure meticulous electronic archiving:
- Responsibility: “The PPF stores invoice data for tax authority purposes. However, central storage by the PPF does NOT relieve taxpayers of their separate archiving obligations.” Businesses remain fully responsible.
- Format & Retention: Invoices must be archived in their “original structured format” for a minimum of 6 years (tax law) and ideally 10 years (commercial law).
- Integrity: Archives must guarantee “authenticity of origin, integrity of content, and human readability” throughout the retention period. AFNOR FD Z42-029 (published May 2026) provides guidance.
- Audit Accessibility: Archived invoices must be accessible to tax authorities upon request, either online or by providing records.
- Correction of Errors
The process for correcting errors depends on the type of error:
- E-Invoice Corrections: A technically “Rejetée” (rejected) invoice must be corrected and resubmitted as a new invoice with a new invoice number; the original XML cannot be edited and resent. Commercial “Refusée” (refused) invoices by the buyer require the seller to issue a new, corrected invoice. Formal corrective invoices (credit notes/avoir) must also be processed through the PA.
- E-Reporting Corrections: Follow the standard VAT return correction process. The CA3 VAT return remains the definitive document and can regularize discrepancies.
- Conclusion and Critical Next Steps
The French e-invoicing and e-reporting reform represents a profound transformation in tax compliance. The critical date for all businesses to note is 1 September 2026 for the reception of e-invoices.
Recommended Preparatory Actions:
- Select a Plateforme Agréée (PA): Choose a certified private platform that meets your business needs.
- Data Cleansing: Validate and update master data, particularly customer and supplier SIREN/SIRET numbers.
- System Integration: Adapt ERP and accounting systems to generate and process invoices in mandated structured formats and connect with the chosen PA.
- Testing: Participate in pilot programs or conduct extensive internal testing of end-to-end e-invoicing and e-reporting flows.
- Training: Provide comprehensive training to finance, accounting, and IT teams on new processes and system functionalities.
- Review Archiving: Ensure current archiving solutions comply with new structured data retention requirements.
Successful implementation will not only ensure compliance but also unlock long-term operational efficiencies and position businesses favorably for future EU-wide digital tax initiatives.
Disclaimer: This briefing document is compiled from the provided source material as of June 2026. It is intended for informational purposes only and does not constitute legal, tax, or professional advice. Businesses should consult with qualified tax and legal professionals and continuously monitor official DGFiP publications for the latest guidance and updates.

INDEPTH ANALYSIS
1. Introduction & Country Context
1.1. Overview of France’s Tax Digitalisation Journey
France’s journey toward mandatory e-invoicing and e-reporting has been progressive and deliberate. The foundation was laid in 2008 with the Loi de modernisation de l’économie (Law n° 2008-776), which enabled state services to accept electronic invoices. In 2014, Ordonnance n° 2014-697 transposed EU Directive 2014/55/EU, extending the obligation to all public entities and progressively mandating B2G e-invoicing between 2017 and 2020 via the Chorus Pro platform. By 1 January 2020, all suppliers to French public authorities were required to submit e-invoices through Chorus Pro.
Building on the success of B2G, France embarked on the most ambitious B2B e-invoicing reform in Europe. Article 153 of the Finance Law 2020 first signalled the intent to generalise e-invoicing. Article 26 of Finance Law n° 2022-1157 of 16 August 2022 provided the core legislative basis, later amended by Article 91 of the Finance Law 2024 (Loi n° 2023-1322 of 29 December 2023), and most recently by Article 123 of the Loi de Finances pour 2026 (Law n° 2026-103 of 19 February 2026), which finalised the scope, penalties, and platform architecture.
1.2. Rationale Behind the Mandate
- VAT gap reduction: France’s VAT gap was estimated at €12.784 billion in 2022 (6.0% of total VAT liability). The reform introduces Continuous Transaction Controls (CTC) to close this gap.
- Fraud prevention: Real-time transmission of invoice and payment data enables the DGFiP to cross-check declared VAT against actual invoices, strengthening fraud detection capacity.
- Administrative modernisation: The reform targets estimated savings of approximately €4.5 billion, with expected savings of €7–10 per invoice through process digitalisation.
- Simplification of VAT obligations: A key long-term objective is the pre-filling of VAT returns based on e-invoicing and e-reporting data.
- Improved economic intelligence: Near-real-time data on business transactions allows more precise economic policy steering.
1.3. Position Within the Broader Landscape
France is an early mover among EU Member States, alongside Italy (SDI since 2019) and Poland (KSeF, repeatedly delayed). However, France has chosen a fundamentally different model. While Italy and Poland opted for fully centralised clearance systems, France adopted a hybrid ‘Y-Schema’ (also called 5-corner model) that combines centralised oversight with a decentralised network of accredited private platforms. This approach balances scalability, automation, and comprehensive tax visibility.
France’s system is well-aligned with the EU’s ViDA (VAT in the Digital Age) framework, adopted by the EU Council on 11 March 2025, which envisions mandatory cross-border B2B e-invoicing from 1 July 2030. France became a Peppol Authority on 8 July 2025, signalling commitment to international interoperability. The reform also aligns with OECD CTC principles.
1.4. Supranational Authorisation
France obtained Council Implementing Decision (EU) 2022/133 of 25 January 2022, authorising a special measure derogating from Articles 218 and 232 of the VAT Directive (Directive 2006/112/EC), pursuant to Article 395(1). The derogation authorises France to introduce mandatory electronic invoicing for all taxable persons established in its territory. The authorisation covers the period from 1 January 2024 to 31 December 2026. Given ViDA’s adoption (which removes the need for individual derogations once the EU-wide framework takes effect), this derogation is expected to be superseded by the harmonised EU rules.
2. Regulatory Framework
2.1. Primary Legislation
- Article 153 of the Finance Law 2020 (Loi n° 2019-1479 du 28 décembre 2019): Initial legislative provision signalling mandatory B2B e-invoicing.
- Article 26 of the Amending Finance Law 2022 (Loi n° 2022-1157 du 16 août 2022): Core legal act establishing the framework for mandatory e-invoicing and e-reporting, amending Articles 289 bis and 290 of the Code Général des Impôts (CGI).
- Article 91 of the Finance Law 2024 (Loi n° 2023-1322 du 29 décembre 2023): Amended the implementation timeline, company-size classifications, and platform architecture.
- Article 123 of the Loi de Finances pour 2026 (Loi n° 2026-103 du 19 février 2026): Most recent amendments — broadened the scope of e-reporting, integrated simplification measures announced in August 2025, confirmed the central role of private Plateformes Agréées (PA), and significantly reinforced the sanctions regime.
- Ordonnance n° 2025-1247 du 17 décembre 2025: Transposition of the ViDA Directive (EU) 2025/516 into French law, recodifying French VAT law into the Code des impositions sur les biens et services (CIBS) and modernising e-invoicing and reporting provisions.
- CGI Articles 289-0, 289, 289 bis, 242 nonies A and B (Annex II CGI), and Article 290 A: Core tax code provisions governing invoicing obligations, electronic invoicing rules, and payment data reporting.
2.2. Implementing Regulations, Decrees & Orders
- Decree n° 2022-1299 of 7 October 2022 (as amended by Decree n° 2024-266 of 25 March 2024): Implementing regulations governing the technical framework, platform registration requirements, system usage rules, invoice lifecycle statuses, and data transmission obligations. Published in JORF n° 0235 of 9 October 2022.
- Arrêté of 7 October 2022 (NOR: ECOE2218934A): Ministerial order on the generalisation of electronic invoicing in transactions between taxable persons, specifying technical standards, format requirements, and platform obligations. Published in JORF n° 0235 of 9 October 2022.
- External Specifications (Spécifications Externes) v3.2 (published 30 April 2026): Detailed technical specifications issued by the DGFiP governing how Plateformes Agréées interact with the PPF and Chorus Pro, including API specifications, data schemas, and lifecycle management.
2.3. Circulars, Official Guidance, Administrative Rulings & FAQs
- DGFiP Fact Sheets for TPE/PME (updated November 2024): A series of 8 explanatory fact sheets covering all aspects of the reform for small businesses.
- DGFiP FAQ on Partner Dematerialisation Platforms: Detailed guidance on PDP/PA selection, registration, and operational requirements.
- 10 Simplification & Tolerance Measures (announced 29 August 2025): Key easements including removal of line-level e-reporting for international incoming invoices, no blank e-reporting required, postponement of non-established taxpayer obligations to September 2027, simplified margin-scheme calculation for B2C e-reporting, and exclusion of non-EU transactions between France-established taxable persons from e-reporting.
- DGFiP Enforcement Guidance (7 May 2026 — E-Invoicing Day): Director General Amélie Verdier confirmed that no penalties will be imposed from 1 September 2026, with a pragmatic enforcement approach — businesses showing genuine implementation efforts will receive contact before any enforcement action.
- National Helpline: 0 806 807 807 (free service + call price) — opened to answer business questions on e-invoicing obligations.
- DGFiP ‘Know my obligations in 4 clicks’ tool: Online self-assessment tool launched in 2026 for e-invoicing and e-reporting readiness.
2.4. Supranational / International Legal Basis
- Council Implementing Decision (EU) 2022/133 of 25 January 2022: Derogation from Articles 218 and 232 of the VAT Directive, valid 1 January 2024 – 31 December 2026.
- Directive 2014/55/EU: Transposed via Ordonnance n° 2014-697 for B2G e-invoicing (Chorus Pro).
- ViDA Directive (EU) 2025/516: Adopted 11 March 2025. France transposed via Ordonnance n° 2025-1247. ViDA introduces mandatory cross-border B2B e-invoicing from 1 July 2030 and harmonised Digital Reporting Requirements (DRR).
- EN 16931: European standard for e-invoicing, supported by the French mandate through Factur-X, UBL 2.1, and CII formats.
- Peppol: France became a Peppol Authority on 8 July 2025. Peppol BIS Billing 3.0 (a profile of UBL 2.1) is accepted as a valid format under the mandate.
3. Scope of the Mandate
3.1. Transactions in Scope
3.1.1. Domestic B2B
Mandatory. All domestic B2B transactions between taxable persons established in France and subject to French VAT must be processed through the e-invoicing system. This covers supplies of goods and services located in France for VAT purposes. Paper invoices and simple PDF invoices are no longer valid for in-scope transactions once the mandate applies to the issuing entity. Only structured electronic formats (Factur-X, UBL 2.1, CII) transmitted through a certified Plateforme Agréée (PA) are accepted.
3.1.2. Domestic B2G
Mandatory since 2020 via Chorus Pro. The B2G mandate predates the B2B reform and operates through the existing Chorus Pro platform. From September 2026, suppliers to the public sector will have the choice of submitting invoices either via an accredited PA or directly through Chorus Pro (for management of public sector legal commitments). The PPF continues to handle B2G flows.
3.1.3. Domestic B2C
Not subject to e-invoicing. B2C transactions are excluded from the mandatory e-invoicing obligation. However, they are subject to e-reporting: businesses must transmit transaction data (and, where applicable, payment data) to the tax administration for B2C sales. Reporting is typically done as daily aggregated data (by SIREN, by day, by VAT rate) rather than invoice-by-invoice.
3.1.4. Cross-border B2B (Intra-EU)
Not subject to e-invoicing (as both parties are not established in France). However, cross-border B2B transactions are subject to e-reporting. Outbound intra-EU supplies must be reported to the tax administration. Following the August 2025 simplification measures, the obligation to e-report inbound international invoices at line-item level has been removed — this applies to purchases from both EU and non-EU suppliers. This exemption remains in effect until ViDA’s cross-border DRR enters into force on 1 July 2030.
3.1.5. Cross-border B2B (Exports Outside the EU)
Not subject to e-invoicing. Exports are subject to e-reporting (transaction data). Import invoices for goods (importations) were initially excluded from the e-reporting obligation. Non-EU transactions between taxable persons established in France that are subject to foreign VAT have been excluded from e-reporting scope under the August 2025 simplification measures.
3.1.6. Intra-Community Acquisitions
Invoices received from foreign EU suppliers are not subject to the domestic e-invoicing mandate (the foreign supplier is not established in France). Line-item e-reporting for such inbound invoices has been removed by the August 2025 simplification measures. Businesses will continue to receive paper or PDF invoices from suppliers not subject to e-invoicing mandates in their home countries.
3.2. Special Transactions in Scope
- Self-billing (autofacturation): Self-billing is permitted under French VAT law (CGI Article 289) and falls within the e-invoicing mandate. Self-billed invoices for domestic B2B transactions must be processed through the PA/PPF system in one of the mandated structured formats. A prior agreement between supplier and buyer is required. The e-invoice must include a specific mention indicating self-billing (‘autofacturation’).
- Triangulation and chain transactions: Invoices issued by domestically registered entities as part of triangular or multi-party chain transactions are in scope to the extent that the transaction is between two taxable persons established in France and located in France for VAT purposes. Where the transaction involves a non-established party, e-reporting obligations apply instead.
- Margin scheme transactions: Deliveries at public auction of second-hand goods, works of art, collectors’ items or antiques are explicitly included in the e-invoicing scope. For B2C margin-scheme sales, e-reporting applies with a simplified calculation method (average margin rate rather than sale-by-sale calculation), as per the August 2025 simplification measures.
- Advance payments (acomptes): Advance payments relating to in-scope supplies of goods or services are explicitly within the e-invoicing scope.
3.3. Excluded or Exempt Transactions
- B2C transactions: Excluded from e-invoicing (subject to e-reporting instead).
- VAT-exempt transactions under Articles 261 to 261 E CGI that are not subject to an invoicing obligation: Certain banking/financial transactions, insurance transactions, VAT-exempt medical/healthcare services, VAT-exempt educational services, and transactions by non-profit organisations with disinterested management are excluded from both e-invoicing and e-reporting.
- Importations of goods (non-EU): Excluded from e-reporting (customs declarations serve as the reporting mechanism).
- Transactions subject to foreign VAT between France-established taxable persons: Excluded from e-reporting under the August 2025 simplification measures.
- OSS/IOSS transactions: Suppliers not established in France but with VAT obligations who have opted for OSS are excluded from e-reporting for those transactions.
4. Taxable Persons in Scope
4.1. Established Domestic Entities
All businesses established in France and subject to French VAT are in scope, regardless of size, legal form, sector, or VAT regime. This includes: corporations, partnerships, sole traders, micro-entrepreneurs, auto-entrepreneurs, and entities benefiting from the franchise en base de TVA (small business VAT exemption scheme). Being under the VAT exemption scheme does not remove a business from the reform — they remain ‘assujettis’ (taxable persons) even if they do not charge VAT. More than 10 million economic actors fall within scope.
4.2. Non-Established Entities
- Foreign entities with a fixed establishment in France: Subject to e-invoicing for domestic B2B transactions conducted through that establishment. Company size classification for timeline purposes is based on the turnover, balance sheet, and workforce linked to the French establishment.
- Foreign entities registered for VAT in France but without a fixed establishment: Generally outside the domestic e-invoicing scope (as the mandate targets transactions between taxable persons ‘established’ in France). However, they are subject to e-reporting obligations. Under the August 2025 simplification measures, non-established taxpayers’ e-reporting obligations have been postponed to September 2027 (regardless of their size classification).
- Foreign entities without domestic VAT registration: Excluded from both e-invoicing and e-reporting obligations.
4.3. Voluntary Participation
Businesses are permitted to comply with the mandate earlier than their mandatory date on a voluntary basis. There is no formal voluntary registration regime or incentive programme; early adoption is simply a matter of operational readiness. The pilot programme (running from late February 2026 to August 2026) is available for testing.
4.4. Sector-Specific Rules & Exemptions
Sectors already exempt from VAT invoicing obligations (such as certain healthcare, education, and banking services under Articles 261–261 E CGI) are generally not affected for those specific exempt services. However, if an entity in these sectors also performs taxable transactions, the mandate applies to those taxable transactions. There are no broad sector-specific exemptions beyond the general VAT invoicing exemptions. Overseas territories have nuanced treatment — some are outside VAT for local operations, potentially placing them outside e-invoicing for those operations, but e-reporting may still apply where transactions are deemed located in mainland France.
5. Implementation Timeline
5.1. Legislative History
- 2019-2020: Article 153 of Finance Law 2020 — initial legislative provision.
- 25 January 2022: Council Implementing Decision (EU) 2022/133 — EU derogation granted (valid 1 Jan 2024 – 31 Dec 2026).
- 16 August 2022: Article 26 of Finance Law 2022 — core legal framework adopted.
- 7 October 2022: Implementing Decree n° 2022-1299 and Arrêté — technical framework established.
- 29 December 2023: Article 91 of Finance Law 2024 — timeline amendments, company-size classifications refined.
- 25 March 2024: Decree n° 2024-266 — amending implementing decree.
- October 2024: DGFiP announces repositioning of PPF from full exchange platform to directory/data concentrator role, confirming the central role of private PAs.
- 29 August 2025: 10 simplification and tolerance measures announced.
- 8 July 2025: France becomes a Peppol Authority.
- 17 December 2025: Ordonnance n° 2025-1247 — ViDA transposition.
- 19 February 2026: Loi de Finances pour 2026 (Article 123) — latest amendments promulgated.
- 11 April 2025: French National Assembly rejects an amendment proposing a further postponement to 2027-2028 — dates confirmed as final.
5.2. Voluntary or Pilot Phases
- October 2025 – January 2026: Interoperability testing, including completion of PA certification.
- Late February 2026 (from 27 February): National pilot programme launched in live conditions. Businesses and PAs can test end-to-end flows in a real production environment.
- February – August 2026: Pilot phase — businesses encouraged to test PDP connectivity, SIRET directory registration, ERP XML extraction, supplier onboarding, and lifecycle status reconciliation.
- No formal incentives (e.g., faster VAT refunds) have been announced for voluntary early adoption or pilot participation.
5.3. Mandatory Go-Live Dates
Phase 1 — 1 September 2026:
- Reception of e-invoices: Mandatory for ALL businesses, regardless of size (including micro-enterprises, auto-entrepreneurs, and entities in franchise en base de TVA).
- Issuance of e-invoices: Mandatory for large enterprises (grandes entreprises: >5,000 employees, or >€1.5 billion turnover, or >€2 billion balance sheet) AND intermediate-sized enterprises (ETI: 250–4,999 employees within defined thresholds).
- E-reporting: Mandatory for large enterprises and ETI (same population as issuance).
- E-reporting for non-established large/intermediate-sized taxpayers: Also begins September 2026.
Phase 2 — 1 September 2027:
- Issuance of e-invoices: Mandatory for ALL remaining businesses — PME (<250 employees), TPE (<50 employees), micro-enterprises, and auto-entrepreneurs.
- E-reporting: Mandatory for all remaining businesses.
- E-reporting for non-established micro, small, and medium-sized taxpayers: Also begins September 2027.
5.4. Grace Periods & Transitional Provisions
- DGFiP has confirmed a pragmatic enforcement approach: no penalties will be imposed from 1 September 2026. Businesses showing genuine implementation efforts will receive contact before any enforcement action. A case-by-case leniency approach is in place during onboarding.
- The first-infraction exemption: Penalties are not applicable in case of a first infraction committed during the current calendar year and the three preceding years, provided the infraction has been corrected spontaneously or within 30 days following a first request from the administration.
- The legal framework allows for a theoretical postponement of up to 3 months by decree (to 1 December 2026 for Phase 1, and 1 December 2027 for Phase 2), but as of June 2026, the DGFiP has denied any delay and maintains the September dates.
5.5. Pre-Mandate Milestones
- Spring 2024: Publication of first list of approved PA providers (then called PDP).
- October 2025 – January 2026: Interoperability testing.
- February 2026: Pilot launched; PA renamed from PDP to PA under LFI 2026.
- 30 April 2026: External Specifications v3.2 published.
- May 2026: 146 PAs registered by the DGFiP (as of mid-May 2026).
- 6 May 2026: AFNOR publishes FD Z42-029 on e-invoice archiving.
5.6. Known or Anticipated Postponements
- The original go-live date of 1 July 2024 was postponed (announced 28 July 2023) due to insufficient readiness of the ecosystem, the complexity of the PPF platform, and concerns about the certification of private platforms.
- The reform has been delayed three times since 2020.
- On 11 April 2025, the French National Assembly rejected an amendment proposing a further delay to 2027-2028.
- As of June 2026, despite questions raised at the Journées de la Facture Électronique conference (June 2026) about limited pilot participation, the DGFiP has explicitly denied any further delay. However, a de facto grace period until at least January 2027 (or longer) is taking shape through the announced leniency approach.
6. How E-Invoicing & E-Reporting Really Work — The Operating Model
6.1. Overview of the Operating Model
France has adopted a Hybrid / Decentralised Interoperability Model (Y-Schema / 5-corner model) with centralised oversight. This is neither a pure centralised clearance model (like Italy’s SDI) nor a pure post-audit model. The key characteristics are:
- The Portail Public de Facturation (PPF) serves as the central directory (Annuaire), data concentrator, and routing hub for the tax authority. It does NOT directly handle B2B invoice exchange between private parties (this role was removed in October 2024). The PPF continues to handle B2G flows via Chorus Pro.
- Plateformes Agréées (PA — formerly PDP) are certified private platforms that validate, transmit, and route B2B e-invoices between businesses. They also report required data to the PPF/DGFiP. PAs are immatriculated (registered) by the tax administration for renewable 3-year periods.
- Solutions Compatibles (SC) are in-house or third-party software solutions that create invoices and connect to one or more PAs. SCs cannot connect directly to the PPF.
- The DGFiP receives data from PAs through the PPF and uses it for VAT compliance monitoring, fraud detection, and (in the future) pre-filling of VAT returns.
6.2. Step-by-Step Invoice Lifecycle
- Step 1 — Invoice Creation: The seller’s ERP or accounting system (or SC) generates an e-invoice in one of the three mandated formats: Factur-X, UBL 2.1, or CII. If the ERP cannot produce a mandated format, the PA or SC can convert it.
- Step 2 — Submission to Issuer’s PA: The invoice is transmitted to the seller’s designated PA. The PA validates format compliance and data completeness (SIRET/SIREN, VAT number, payment terms, mandatory fields). The invoice receives the status ‘Déposée’ (Deposited/Submitted).
- Step 3 — Validation: The PA performs schema validation, business rule checks, and calculation verification. If validation fails, the invoice is rejected (‘Rejetée’) with error codes. A rejected invoice must be corrected and resubmitted with a new invoice number — the original XML cannot be edited and resent.
- Step 4 — Routing & Delivery: The issuer’s PA queries the central directory (Annuaire) to identify the buyer’s PA and routing address, then transmits the invoice to the buyer’s PA. The PA simultaneously reports the required data to the PPF for the DGFiP. There is no separate ‘clearance’ step — the invoice is legally issued upon deposit with the PA.
- Step 5 — Delivery to Buyer: The buyer’s PA receives the invoice and delivers it to the buyer’s ERP or SC. The invoice may be accepted (‘Acceptée’ — optional status) or refused (‘Refusée’ — commercial refusal by the buyer).
- Step 6 — Payment Tracking: When payment is received, the status ‘Encaissée’ (Payment Received/Cashed) is updated. This is particularly important for services where VAT is due on collection.
- Step 7 — Archiving: Both parties are responsible for archiving invoices in compliance with French retention requirements. PAs may offer archiving services. The PPF stores data for tax authority purposes but this does not relieve taxpayers of their own archiving obligations.
6.3. Mandatory Invoice Statuses
The AFNOR standard XP Z12-012 defines 14 potential statuses, but only four are mandatory:
- Déposée (Deposited/Submitted): Invoice successfully submitted and timestamped by the issuer’s PA.
- Rejetée (Rejected): Technical refusal — validation failure at the platform level.
- Refusée (Refused): Commercial refusal from the buyer.
- Encaissée (Payment Received/Cashed): Payment confirmed as received by the supplier.
6.4. Offline / Contingency Mode
Detailed contingency provisions for platform unavailability have not been fully published in the External Specifications as of June 2026. In practice, PAs are expected to provide uptime guarantees. If a PA is temporarily unavailable, the invoice cannot be legally issued until it is deposited on the platform. Businesses should ensure their PA has adequate SLAs and consider contingency arrangements (e.g., secondary PA). The PPF can serve as a fallback for basic operations.
6.5. Buyer-Side Workflow
Buyers retrieve e-invoices from their designated PA (via API, portal, or SC integration). Buyer acceptance is not required for the invoice to be legally valid — the invoice is legally issued upon deposit with the PA. However, the buyer can refuse the invoice (‘Refusée’ status), triggering a commercial dispute process. A refused invoice requires the seller to issue a new corrected invoice.
6.6. QR Code Requirements
No specific QR code requirement has been mandated for e-invoices exchanged through the PA system. The structured data within the e-invoice format serves as the verification mechanism. For B2C transactions (which are outside e-invoicing), existing receipt/ticket requirements continue to apply.
7. Acceptable E-Invoice Formats
7.1. Mandatory Formats (Socle Minimal)
France mandates three structured e-invoice formats:
- Factur-X: A hybrid format combining a human-readable PDF/A-3 with embedded structured XML. Popular for both small and large businesses, ensuring readability while supporting automation. Factur-X is a Franco-German standard (also known as ZUGFeRD in Germany). ZUGFeRD 2.5 is scheduled for release on 20 May 2026, aligning with EN 16931.
- UBL 2.1 (Universal Business Language): An international XML standard widely used in the Peppol network. Ideal for cross-border trade and companies already using Peppol.
- UN/CEFACT CII (Cross Industry Invoice): A global cross-industry XML standard for electronic data exchange. Common for international B2B transactions.
- Unstructured formats (PDF, paper, Word, Excel) are NOT legally valid for in-scope domestic B2B transactions once the mandate applies to the issuing entity.
7.2. Relationship to International Standards
- EN 16931: All three mandated formats comply with or are derived from the European e-invoicing standard EN 16931.
- Peppol BIS Billing 3.0: A profile of UBL 2.1, accepted as a valid format. France’s Peppol Authority status supports this.
- AFNOR Z12-012 and Z12-014 schemas: National schemas published by AFNOR ensuring interoperability with the PPF.
- National extensions: France has introduced four new mandatory invoice data fields beyond standard EN 16931 requirements (customer SIREN, delivery address, goods/services category, VAT on debits option).
- EDIFACT: Not a mandated format. Companies wishing to continue using EDIFACT (e.g., D96A, D07A) can do so voluntarily via a PA, which must convert the EDIFACT invoice to a mandated format for delivery and reporting.
7.3. Voluntary / Legacy / Transitional Formats
For transactions outside the e-invoicing mandate (B2C, cross-border), businesses may continue to use any format for the customer invoice; only the e-reporting data transmitted to the tax authority must be structured. EDIFACT remains possible on a voluntary basis via a PA for B2B exchange, with mandatory conversion to a permitted format for delivery. During the transition, Factur-X’s hybrid nature (PDF + XML) provides a bridge for businesses accustomed to visual PDF invoices.
7.4. Attachments
Attachments are permitted within the Factur-X format (embedded within the PDF/A-3 container). For UBL and CII, attachments can be referenced or embedded as specified in the technical schemas. Attachments are considered supplementary documentation, not formal invoice components. The PA validates the structured data, not the attachment content.
8. Technical & Functional Requirements
8.1. E-Invoice Specifications — Mandatory Data Fields
In addition to the standard mandatory invoice mentions under Article 242 nonies A of Annex II CGI, the reform introduces four new mandatory fields:
- Customer’s SIREN number (9-digit company identifier).
- Delivery address (when different from billing address).
- Category of operation: whether the invoice covers goods, services, or both.
- VAT payment regime: indication of whether the supplier has opted for VAT on debits.
- Standard mandatory fields include: seller/buyer identification (SIREN/SIRET, VAT number), invoice number, issue date, line item details (quantities, unit prices, descriptions), net/gross amounts, VAT rates and amounts, payment terms, delivery details, and currency.
- Data must conform to the AFNOR Z12-012 and Z12-014 schemas for interoperability with the PPF.
8.2. E-Reporting Specifications
- E-reporting data is transmitted through the PA to the PPF. The format depends on the transaction type:
- B2C transactions: Daily aggregated data by SIREN, by day, by VAT rate (amount and VAT). The number-of-transactions field has been eliminated under the simplification measures.
- Cross-border B2B: Reported at invoice level rather than as daily aggregates. Line-item detail for international incoming invoices has been removed (simplification measure).
- Payment data: For services where VAT is due on collection — payment date and amount collected by VAT rate.
- Filing frequency varies by VAT regime: monthly VAT regime (every 10 days — 3 submissions per month); quarterly VAT regime (monthly, before the 10th); simplified VAT regime (monthly, by the 25th-30th); VAT exemption regime (bimonthly, by the 25th-30th).
- No blank e-reporting is required if no taxable transactions occurred (simplification measure).
8.3. Digital Signature & Integrity Requirements
No per-invoice qualified electronic signature is required under the mandate. Integrity and authenticity are ensured by the platform infrastructure (PA validation, timestamping, lifecycle tracking) and the structured data exchange protocol. The Ordonnance n° 2025-1247 (ViDA transposition) reinforces that invoices must be stored with guaranteed authenticity of origin, integrity of content, and human readability.
8.4. Real-Time or Near-Real-Time Processing
The system is designed for near-real-time processing. E-invoices are transmitted and validated upon deposit. E-reporting follows periodic schedules (every 10 days for monthly VAT regime). The DGFiP aims for real-time data visibility through the CTC model. Platform performance targets (uptime, capacity, response times) are specified in the External Specifications but detailed SLAs are contractual between PAs and their clients.
9. Correction of Errors
9.1. E-Invoice Corrections
- A rejected invoice (Rejetée status) must be corrected and resubmitted as a new invoice with a new invoice number. The original XML cannot be edited and resent.
- Corrections to issued invoices must be made via formal corrective invoices (credit notes / avoir) processed through the PA, referencing the original invoice.
- The correcting invoice must include: reference to the original invoice number, nature of the correction, and corrected amounts.
- Traditional corrective notes (simple email or letter corrections) are not valid for in-scope transactions — all corrections must go through the e-invoicing platform.
9.2. E-Reporting Corrections
Corrections to e-reporting data follow the standard VAT return correction process. The CA3 VAT return remains the definitive document and can regularise discrepancies compared to e-reporting data. Specific correction mechanisms for e-reporting files are defined in the External Specifications. Amended VAT returns can be filed to correct errors, subject to standard correction timelines and penalty provisions.
10. Transmission & Workflow
10.1. Central Platform
The Portail Public de Facturation (PPF) is operated by the DGFiP with the support of the Agence pour l’Informatique Financière de l’État (AIFE). The PPF serves as: (a) the central directory (Annuaire) listing all companies and their designated PAs; (b) the data concentrator aggregating invoice and reporting data for the DGFiP; (c) the B2G invoicing hub (via Chorus Pro); and (d) a basic fallback portal for smaller businesses.
10.2. Transmission Channels
- Plateformes Agréées (PA): The primary channel for B2B e-invoice exchange. 146 PAs registered as of mid-May 2026.
- PPF web portal: Available as a basic, free tool for smaller businesses for limited operations (receiving invoices, basic e-reporting).
- Solutions Compatibles (SC): Software connected to a PA, enabling businesses to create and manage invoices without direct platform access.
- Peppol Access Points: Supported through France’s Peppol Authority status; Peppol BIS (UBL 2.1 profile) is accepted.
- Chorus Pro: Continues for B2G invoicing.
10.3. Accredited Service Providers
- Use of a PA is mandatory for B2B e-invoice exchange (businesses cannot exchange invoices directly).
- PA certification (immatriculation) is granted by the DGFiP after a complex and costly certification process demonstrating compliance with security, interoperability, and technical requirements.
- Immatriculation is valid for 3 years and must be renewed (renewal dossier filed within 5 months before expiry).
- The official list of registered PAs is published on impots.gouv.fr.
- Businesses may use one or several PAs and may also authorise third parties (accountants, fiscal representatives) via a formal mandate model.
10.4. Interoperability
The PPF ensures interoperability between PAs through the central directory and standardised formats. PA-to-PA exchange is the standard operational model. Peppol interoperability is supported. The system interoperates with Chorus Pro for B2G flows. Cross-border interoperability will be further developed as ViDA’s DRR requirements take effect from 2030.
10.5. Deadlines & Timing
- E-invoicing: Near-real-time — invoices are transmitted upon deposit with the PA. No specific T+X reporting delay; the invoice is legally issued upon deposit.
- General invoicing deadline: Invoices must be issued in accordance with existing CGI rules (generally at the time of supply or, for services, at the time the service is completed or the payment is received).
- E-reporting filing deadlines: Every 10 days (monthly VAT regime), monthly (quarterly/simplified regime), bimonthly (exempt regime). Specific deadlines detailed in Section 8.2.
- Payment e-reporting: Monthly for all regimes (before the 10th of the following month), except simplified (by 25th-30th) and exempt (bimonthly, by 25th-30th).
11. Self-Billing
- 1. Self-billing is permitted under the French e-invoicing mandate. CGI Article 289 allows self-billing (autofacturation) where there is a prior agreement between supplier and buyer.
- 2. Self-billed invoices for domestic B2B transactions must be processed through the PA/PPF system in one of the mandated structured formats, like any other e-invoice.
- 3. A prior written agreement between the supplier and the buyer is required. The agreement must specify the terms under which self-billing will operate. No specific platform registration or notification form has been published beyond the standard PA registration.
- 4. Self-billed invoices must include all mandatory invoice mentions plus a specific notation indicating ‘autofacturation’ (self-billing).
- 5. A specific mention/flag in the e-invoice format identifies the document as self-billed. The External Specifications define the relevant code in the structured data.
- 6. For foreign buyers without a domestic SIREN, the August 2025 simplification measures have introduced tolerance measures for entities without SIREN or for which the SIREN is not yet present in the Directory.
- 7. The supplier must validate and confirm the self-billed invoice. The standard lifecycle statuses apply.
12. Triangulation & Special Scenarios
12.1. Triangulation Transactions
Invoices issued by domestically registered entities as part of triangular transactions are in scope for e-invoicing to the extent the transaction is between two France-established taxable persons. Where the intermediary is established in France and invoices a non-established party, the cross-border leg falls under e-reporting rather than e-invoicing. The intermediary’s reporting obligations depend on where each supply is located for VAT purposes.
12.2. Chain Transactions
Multi-party chain transactions follow the same logic: each domestic B2B leg between France-established parties requires e-invoicing; cross-border legs require e-reporting. Documentation must clearly identify the transaction type and the parties involved.
12.3. Cross-Border Reverse Charge
- Outbound invoices with reverse-charge notation (intra-EU supplies, Article 196 VAT Directive): Not subject to e-invoicing (counterparty not established in France). Subject to e-reporting.
- Inbound reverse-charge invoices from foreign suppliers: Not subject to e-invoicing. Line-item e-reporting for inbound international invoices has been removed (simplification measure). The recipient’s reverse-charge obligations are handled through the VAT return.
- Payment e-reporting does not apply to reverse-charge operations.
12.4. Zero-Rated and Exempt Supplies
Zero-rated supplies (exports, intra-EU supplies) are not subject to e-invoicing but are subject to e-reporting. The e-invoice format includes specific codes and exemption basis fields to identify the nature of the supply (goods/services, VAT regime, exemption reason). VAT-exempt supplies under Articles 261–261 E CGI that are not subject to an invoicing obligation are excluded from both e-invoicing and e-reporting.
12.5. Local Nuances & Special Cases
- VAT groups: France does not currently have a general VAT grouping regime (except for financial services). Intra-group transactions between separately registered entities follow standard rules.
- Fiscal representatives: Foreign entities may appoint fiscal representatives. The fiscal representative’s role in the e-invoicing/e-reporting process is not yet fully detailed in published guidance.
- Call-off stock / consignment stock: Movements of stock follow standard intra-EU rules; the invoicing leg follows e-invoicing or e-reporting depending on whether both parties are France-established.
- Construction reverse charge: Domestic construction reverse-charge transactions between France-established taxable persons are within e-invoicing scope, with appropriate reverse-charge notation.
- Expense reports (notes de frais): Represent a grey zone. Invoices in the company’s name must go through e-invoicing. Invoices in the employee’s name are treated as B2C (e-reporting). Till receipts are reportable under e-reporting but rarely support VAT deduction above €150 (excl. VAT).
- Overseas territories: Nuanced treatment — some territories are outside VAT scope for local operations.
13. Archiving & Retention
13.1. Central Archiving by the Platform
The PPF stores invoice data for tax authority purposes. However, central storage by the PPF does NOT relieve taxpayers of their separate archiving obligations. Businesses remain fully responsible for maintaining compliant archives of all invoices issued and received.
13.2. Mandatory Archiving Format
Invoices must be archived in their original structured format (the XML/structured data as transmitted through the PA). The AFNOR FD Z42-029 (published 6 May 2026) provides practical guidance on electronic archiving within the reform framework. Key requirements include: preserving invoice integrity and authenticity throughout the retention period, ensuring long-term readability of structured formats, maintaining evidential value, and securely storing invoices and associated status data. The FD Z42-029 articulates with the existing NF Z42-013 standard on electronic archiving.
13.3. Retention Period
Standard French VAT retention period: 6 years from the date of the last transaction recorded in the books (Article L102 B of the Livre des procédures fiscales). Commercial law requires retention of commercial documents for 10 years (Article L123-22 of the Code de commerce). In practice, businesses should retain e-invoices for at least 10 years to satisfy both tax and commercial requirements.
13.4. Storage Location Requirements
Under existing French rules, invoices may be stored within France or within the EU/EEA, provided the tax authority has immediate online access. Storage outside the EU requires prior authorisation from the tax administration. The reform does not change these requirements.
13.5. Integrity, Authenticity & Readability
The Ordonnance n° 2025-1247 (ViDA transposition) reinforces that invoices must be stored with guaranteed authenticity of origin, integrity of content, and human readability throughout the retention period. The FD Z42-029 provides detailed practical guidance. Specific technologies are not mandated, but audit trails, access controls, and non-alteration guarantees are expected.
13.6. Audit Accessibility
Archived invoices must be accessible to tax authorities upon request. The DGFiP has real-time access to data stored in the PPF. For taxpayer-archived invoices, on-demand access must be provided within the timeframes specified in the Livre des procédures fiscales. Records must be presented or sent to the tax administration upon request.
14. Penalties & Enforcement
14.1. Grace Period / Transitional Enforcement
On 7 May 2026 (E-Invoicing Day), DGFiP Director General Amélie Verdier confirmed that no penalties will be imposed from 1 September 2026. The administration will first contact businesses before any enforcement action. A pragmatic, case-by-case leniency approach applies during the onboarding period. Additionally, penalties are not applicable for a first infraction committed during the current calendar year and the three preceding years, if corrected spontaneously or within 30 days of a first administrative request.
14.2. & 14.3. Penalties for Non-Compliance (Post-Grace Period)
As established by Article 123 of the Loi de Finances pour 2026 (Law n° 2026-103):
- Failure to issue an e-invoice: €50 per invoice (previously €15). Annual cap: €15,000 per business.
- Failure to transmit e-reporting data (transaction or payment): €500 per transmission (previously €250). Annual cap: €15,000 per business per calendar year.
- Failure to designate a PA for reception: After a 3-month notice period, an initial fine of €500. If non-compliance persists, €1,000 fine, recurring every 3 months.
- Missing or inaccurate invoice information (mandatory mentions): €15 per error, capped at 25% of the invoice value.
- Failure by a PA to transmit/receive invoices: €50 per invoice. Annual cap: €45,000 per PA.
- Failure by a PA to transmit e-reporting data: €750 per failed transmission. Annual cap: €100,000 per PA.
- Penalties are cumulative — format non-compliance + missing mentions + e-reporting omission + absence of PA can all apply simultaneously.
- Fraudulent invoicing carries additional heavy penalties under existing CGI provisions.
14.4. Article References
CGI Articles 1737 and 1788 B (as amended by Article 123 LFI 2026). Loi n° 2026-103 du 19 février 2026, Article 123. Service-public.gouv.fr: ‘Facturation électronique : les sanctions évoluent’ (published 20 February 2026).
15. Pre-Filled VAT Returns
- 1. France does NOT currently offer pre-filled periodic VAT returns. The CA3 VAT return remains the definitive document filed by the taxpayer.
- 2. Not applicable — pre-filled returns are not yet available.
- 3. Pre-filling of VAT returns is a stated long-term objective of the reform. However, the DGFiP has indicated that pre-filled draft VAT returns are unlikely before 2030, despite the mandate beginning in September 2026. The data collected through e-invoicing and e-reporting will gradually build the foundation for pre-filling.
- 4. The dependency is clear: e-invoicing data (domestic B2B) and e-reporting data (B2C, cross-border) together will provide the DGFiP with the comprehensive dataset needed for pre-filling. The CA3 return can regularise discrepancies compared to e-reporting data.
- 5. ViDA’s provisions include pre-filled return capabilities at the EU level. France’s domestic data collection infrastructure is designed to be compatible with future EU-wide pre-filling requirements.
16. Readiness for ViDA — Digital Reporting Requirements
16.1. Country Position Relative to ViDA
France is ahead of the ViDA timeline. The ViDA Directive (EU) 2025/516 was adopted on 11 March 2025 and requires mandatory cross-border B2B e-invoicing from 1 July 2030. France’s domestic mandate begins 1 September 2026 — four years earlier. France has already transposed ViDA through Ordonnance n° 2025-1247 of 17 December 2025, which recodifies VAT law into the CIBS and introduces key ViDA provisions.
16.2. Alignment with ViDA Requirements
- Format alignment: France’s mandated formats (UBL 2.1, CII, Factur-X) are fully compatible with EN 16931, the standard specified by ViDA for cross-border e-invoicing.
- Peppol alignment: France’s Peppol Authority status and acceptance of Peppol BIS 3.0 ensure compatibility with ViDA’s envisioned cross-border exchange infrastructure.
- Model differences: France’s decentralised PA model differs from ViDA’s proposed central VIES-based reporting. Adjustments may be needed to feed national platform data into the EU-wide system.
- Potential gaps: France’s e-reporting simplifications (removal of line-item detail for international incoming invoices) are explicitly temporary — they will remain in effect until ViDA’s DRR enters into force on 1 July 2030.
16.3. Cross-Border Digital Reporting
From 1 July 2030, ViDA requires EU-wide cross-border B2B transaction reporting. France’s national e-reporting for cross-border transactions already captures much of this data. The national system will need to be adapted to feed into the supranational VAT information exchange system (enhanced VIES). OpenPeppol has published the first ViDA Tax Data Document Semantic Model, which France will need to implement.
16.4. Implications for Businesses
- Businesses complying with the French mandate are building infrastructure (structured formats, PA connectivity, ERP integration) that is largely compatible with future ViDA obligations.
- Additional adjustments will be needed when ViDA’s DRR takes effect: cross-border invoices will need to be issued in EN 16931 format and reported within a shorter timeframe (likely T+2 days).
- Early adopters benefit from: established platform relationships, tested data quality, trained teams, and proven ERP integrations — reducing the marginal cost of ViDA compliance.
- Businesses should ensure their PA supports Peppol interoperability as a future-proofing measure.
17. Impact on SMEs and Startups
17.1. Phased Onboarding
SMEs (PME: <250 employees), TPE (<50 employees), micro-enterprises, and auto-entrepreneurs benefit from a 12-month deferral for issuance obligations (September 2027 vs. September 2026). However, ALL businesses must be able to receive e-invoices from 1 September 2026 — this is the most commonly overlooked requirement.
17.2. Government Support & Free Tools
- PPF web portal: Free basic portal for receiving invoices and performing basic e-reporting. Suitable for businesses with limited invoice volumes.
- National helpline: 0 806 807 807 (free service).
- DGFiP fact sheets for TPE/PME: 8 detailed explanatory documents covering all aspects of the reform.
- DGFiP educational videos: Published on YouTube and government portals.
- ‘Know my obligations in 4 clicks’ tool: Online self-assessment.
- AFNOR FD Z42-029: Published May 2026 and made available free of charge to all businesses.
- gouv.fr: Comprehensive guides on e-reporting and e-invoicing for SMEs.
17.3. Simplified Regimes & Threshold-Based Exemptions
There are no threshold-based exemptions from the mandate — all VAT-registered businesses are in scope, including those under the franchise en base de TVA. However, the simplified VAT regime and VAT exemption regime have adapted e-reporting frequencies (monthly and bimonthly respectively, vs. every 10 days for the standard regime).
17.4. Subsidies or Financial Support
No specific government grants, tax credits, or subsidies to offset compliance costs have been announced as of June 2026. The free PPF portal and free PA tools (basic tiers offered by some PAs) serve as the primary cost-reduction measures for micro-businesses.
17.5. Compliance Costs
- One-time costs: Software upgrades or ERP integration, PA selection and onboarding, data cleansing (SIREN/SIRET validation), employee training. For micro-businesses using basic tools, costs can be minimal. For larger SMEs with existing ERP systems, integration costs vary significantly.
- Ongoing costs: PA subscription fees (ranging from free basic tiers to €49-199+/year for cloud solutions), maintenance, and potential format conversion costs.
- For very small businesses: A simple browser-based Factur-X generator or affordable cloud plan (typically €19-35/month) is sufficient. No expensive ERP, IT department, or SAP certification is needed.
17.6. Cash Flow & Operational Benefits
- Faster invoice processing and reduced payment delays.
- Elimination of paper handling, postage, and manual data entry.
- Improved invoice compliance and reduced disputes.
- Automated data import into accounting systems.
- Earlier error detection through platform validation.
- Long-term: potential for faster VAT refunds once pre-filled returns are implemented.
17.7. Administrative Burden vs. Simplification
Initial burden is significant for SMEs: platform selection, system adaptation, data quality improvement, and staff training. However, long-term simplification is substantial — automated processing, reduced manual reconciliation, fewer invoice disputes, and eventual pre-filled VAT returns. The government estimates net savings of €7-10 per invoice and total economic benefits of approximately €4.5 billion.
17.8-17.9. Market Impact & SME Readiness
The reform drives accelerated digitalisation across the French economy. Early adopters gain competitive advantages through streamlined processes. Questions about SME readiness were raised at the June 2026 Journées de la Facture Électronique conference, with concerns about limited pilot participation. The DGFiP’s pragmatic enforcement approach reflects awareness of these readiness challenges. No formal government assessment of SME preparedness has been published, but the 76% of French companies that do not use an ERP system represent a significant implementation challenge.
18. Official References & Sources
18.1. Government Portals
- PPF / Chorus Pro: https://portail.chorus-pro.gouv.fr/
- DGFiP e-invoicing information: https://www.impots.gouv.fr/ (section on electronic invoicing)
- Ministry of Economy: https://www.economie.gouv.fr/tout-savoir-sur-la-facturation-electronique-pour-les-entreprises
- Service-Public.fr (business): https://entreprendre.service-public.gouv.fr/actualites/A15683
- France Num (SME digital guidance): https://www.francenum.gouv.fr/
- List of registered PAs: Published on impots.gouv.fr
18.2. Legislative Texts
- Légifrance — Arrêté of 7 October 2022: https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000046383471
- Council Implementing Decision (EU) 2022/133: https://eur-lex.europa.eu/eli/dec_impl/2022/133/oj/eng
- CGI Articles 289, 289 bis, 290 A: Available on Légifrance
- Loi de Finances pour 2026 (Article 123): Loi n° 2026-103 du 19 février 2026
18.3. Technical Specifications
- External Specifications (Spécifications Externes) v3.2: Published by DGFiP, April 2026
- AFNOR Z12-012 and Z12-014 schemas
- AFNOR FD Z42-029 (archiving guidance): Published 6 May 2026, available free of charge
- AFNOR NF Z42-013 (electronic archiving standard)
18.4. Tax Authority Publications
- DGFiP Fact Sheets for TPE/PME (8 sheets, updated November 2024)
- DGFiP FAQ on PDPs/PAs
- DGFiP English-language overview: https://www.impots.gouv.fr/sites/default/files/media/1_metier/6_english/62_professional/presentation_de_la_reforme_english_2.pdf
- DGFiP English-language guidance: https://www.impots.gouv.fr/internationalenbusiness/i-want-understand-electronic-invoicing
18.5. Advisory Firm Newsletters & Analysis
- KPMG Avocats: ‘Facturation électronique: aménagement des obligations et renforcement des sanctions’ (Droit fiscal n° 10, 6 March 2026)
- EY: ‘France announces simplification for September 2026 e-invoicing’ (11 September 2025) — https://www.ey.com/en_gl/technical/tax-alerts/french-government-announces-simplification-measures-as-part-of-september-2026-e-invoicing-mandate
- Vertex: ‘France’s 2026 E-Invoicing Mandate: Requirements, Timeline, and Compliance Guide’ (November 2025) — https://www.vertexinc.com/resources/resource-library/frances-2026-e-invoicing-mandate-requirements-timeline-and-compliance-guide
- SEEBURGER: ‘France: Mandatory B2B E-Invoicing and E-Reporting from 2026’ white paper — https://www.seeburger.com/fileadmin/pdf/white-paper/seeburger-white-paper-france-reporting-from-2026-en.pdf
- ClearTax: ‘e-Invoicing in France 2026’ (June 2026) — https://www.cleartax.com/fr/en/e-invoicing-france
- Marosa VAT: ‘E-Invoicing in France: Complete Guide’ — https://marosavat.com/vat-news/e-invoicing-france
- com: Multiple articles including ‘Transposition of ViDA EU Directive 2025/516 into French Law’ (December 2025) — https://www.vatupdate.com/2025/12/23/transposition-of-vida-eu-directive-2025-516-into-french-law/
- VATCalc: France country updates — https://www.vatcalc.com/category/france/
- EU Commission: eInvoicing in France — https://ec.europa.eu/digital-building-blocks/sites/spaces/DIGITAL/pages/467108885/eInvoicing+in+France
19. Summary & Key Takeaways
19.1. Scope
All domestic B2B transactions between taxable persons established in France are subject to mandatory e-invoicing. B2C, cross-border B2B, and export transactions are subject to e-reporting. B2G has been mandatory since 2020 via Chorus Pro. More than 10 million economic actors are in scope. VAT-exempt transactions under Articles 261–261 E CGI not subject to invoicing obligations are excluded.
19.2. Format
Three mandatory structured formats: Factur-X, UBL 2.1, and UN/CEFACT CII — all compliant with EN 16931. Paper and simple PDF invoices are no longer valid for in-scope transactions. EDIFACT may be used voluntarily via a PA with conversion to a mandated format.
19.3. Timeline
- 1 September 2026: All businesses must receive e-invoices. Large enterprises and ETI must issue and e-report.
- 1 September 2027: SMEs and micro-enterprises must issue and e-report.
- De facto grace period with pragmatic enforcement from September 2026.
19.4. How It Works
Hybrid Y-Schema / 5-corner model. Invoices exchanged via certified Plateformes Agréées (PA). PPF serves as central directory and data concentrator. Near-real-time CTC with mandatory lifecycle statuses. PA-to-PA exchange is the standard operational model.
19.5. Key Obligations
- Issue e-invoices in mandated format via a PA.
- Receive e-invoices via a designated PA (from September 2026 for ALL).
- Transmit e-reporting data for B2C and cross-border transactions.
- Report payment data where VAT is due on collection.
- Maintain compliant electronic archives (6-10 years).
- Ensure correct master data (SIREN/SIRET) in the central directory.
19.6. Main Risks
- Penalties: Up to €50/invoice for non-issuance, €500/transmission for e-reporting failures, progressive fines for non-PA designation.
- Invoice rejection: Missing or incorrect SIREN, format errors, or data mismatches cause immediate rejection on the platform.
- Operational disruption: Inability to receive invoices from suppliers who have transitioned.
- VAT deduction risk: Invoices issued outside the platform may not support VAT deduction claims.
- Cash flow impact: Refused invoices delay payment processing.
19.7. SME Implications
Free PPF portal and affordable PA solutions available. 12-month deferral for issuance (September 2027). But reception obligation applies from September 2026 — SMEs must be ready. No subsidies announced. Long-term benefits include reduced administrative burden and potential faster VAT refunds.
19.8. ViDA / International Readiness
France is well ahead of ViDA’s 2030 timeline. EN 16931 and Peppol compatibility ensure future-proofing. Some adjustments will be needed for cross-border DRR from July 2030. Businesses complying now are building ViDA-compatible infrastructure.
19.9. Critical Dates & Next Steps
- NOW (June 2026): Finalise PA selection, complete SIREN/SIRET data cleansing, test end-to-end flows, train staff.
- 1 September 2026: ALL businesses must receive e-invoices. Large/ETI must issue and e-report.
- 1 September 2027: SMEs and micro-enterprises must issue and e-report.
- 2030 (indicative): Pre-filled VAT returns expected. ViDA cross-border DRR enters into force (1 July 2030).
- Recommended preparation: Audit master data, select and test PA connectivity, map ERP data to mandated schemas, configure B2C and cross-border e-reporting flows, establish archiving procedures, and train AP/finance teams.
Disclaimer: This analysis is based on publicly available sources as of June 2026. It does not constitute legal advice. Businesses should verify requirements with qualified tax/legal counsel and monitor official DGFiP publications for the latest updates
Key documents
Other guides
- See also
- Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
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