France E-Invoicing Mandate: September 2026 Go-Live Guide for Foreign Businesses

What changes in France on 1 September 2026

From 1 September 2026, every business established in France and liable for French VAT must be able to receive structured electronic invoices. On the same date, large enterprises (grandes entreprises) and mid-sized companies (entreprises de taille intermédiaire, ETI) must also issue them and start transaction e-reporting. Smaller French businesses get one more year: their issuing obligation starts on 1 September 2027.

That much is widely reported. What catches foreign suppliers and buyers out is the machinery underneath. Invoices no longer travel directly from seller to buyer: they pass through an accredited platform, are routed via a national directory, and leave a data trail with the tax administration. This guide covers that machinery, the duties that attach to companies without a French establishment, and the penalty amounts — which were raised in February 2026 and are still quoted at their old level in a lot of published material.

There has been no postponement

The reform has slipped before — the original date was July 2024 — so it is fair to ask whether it will slip again. As of late July 2026 it has not. The calendar sits in Ordonnance n° 2021-1190, as amended by article 91 of the 2024 finance law, and the DGFiP ran a national pilot in production conditions from February 2026.

On 11 July 2026 the minister for public action and public accounts, David Amiel, reconfirmed the deployment calendar and announced an enforcement posture described as tolérante et bienveillante for the start-up phase: businesses acting in good faith that hit a genuine difficulty and do the work to correct it will not be sanctioned at launch. That is an administrative tolerance, not a legal deferral. It does not help a company that simply does nothing, and it changes none of the dates.

Phase timeline

Date	Who	What becomes mandatory
1 September 2026	All businesses established in France	Ability to receive e-invoices through an accredited platform
1 September 2026	Large enterprises and ETI	Issuing e-invoices; transaction e-reporting on sales outside the domestic B2B scope
1 September 2027	SMEs and micro-enterprises	Issuing e-invoices and the e-reporting that goes with it
1 September 2027	Every business, any size	Buyer-side e-reporting on reverse-charge operations and intra-EU acquisitions
1 September 2027	Foreign firms without a French establishment	E-reporting on their France-taxable operations, where not already due in 2026

Company size is set per legal entity (per SIREN), not per group. In outline: fewer than 250 staff with turnover up to €50 million or a balance-sheet total up to €43 million is a PME; below 5,000 staff with turnover up to €1.5 billion or a balance sheet up to €2 billion is an ETI; anything above that is a large enterprise. Per DGFiP guidance relayed by French professional bodies, the category is assessed on the last financial year closed before 1 January 2025 and then stays fixed, so a company that grows into a larger bracket does not move to an earlier deadline.

Scope turns on establishment, not on a VAT number

This is the part most often misread outside France, and it decides how much work a German, Dutch or Italian company actually has to do.

The e-invoicing half of the reform — issuing and receiving through an accredited platform — applies to taxable persons established in France. Holding a French VAT registration is not the same thing. The DGFiP states directly that the e-invoicing component does not concern foreign companies without a French fixed establishment (établissement stable). Those companies can still be caught by the second half of the reform: e-reporting.

Your situation	E-invoicing	E-reporting	Need an accredited platform?
French subsidiary or branch (fixed establishment in France)	Yes — receive from 1 September 2026, issue on the calendar for its size	Yes, on operations outside domestic B2B	Yes
French VAT registration, no establishment	No — neither issuing nor receiving	Yes, on France-taxable operations	Yes, to transmit the e-reporting data
No French VAT registration, selling B2B into France under reverse charge	No French obligation	No — the French customer reports the purchase from 1 September 2027	No

Plateforme Agréée: the pipe every invoice goes through

France does not run a single government clearing platform. Invoices are exchanged through private accredited providers. These were originally called Plateformes de Dématérialisation Partenaires (PDP); since 2025 the official term is Plateforme Agréée (PA), and that is the wording now used in article 289 bis of the French tax code. Vendor material still says PDP everywhere, and both names refer to the same registered operator.

The public portal (Portail Public de Facturation, PPF) was originally meant to offer a free exchange route. That was dropped in October 2024. The PPF now has two jobs: it hosts the national annuaire — the directory of VAT-liable entities and their invoice reception addresses — and it acts as the data concentrator that forwards invoice, transaction and payment data to the tax administration.

How an invoice finds its recipient

Routing is directory-driven, with the SIREN number as the pivot identifier.

1. The issuer submits the invoice to its own accredited platform in one of the accepted formats.
2. The platform looks the buyer up in the annuaire and finds the reception address the buyer has registered.
3. The invoice is delivered to the buyer's platform, which hands it to the buyer's accounting system.
4. Both platforms report the required invoice data and lifecycle statuses to the administration through the PPF.

You do not register in the annuaire yourself. When you appoint a platform, that platform declares and maintains your SIREN, reception address and routing data on your behalf. Which means the practical first step for a French entity is simply: choose a platform and let it register you. Nothing else works until that entry exists.

The DGFiP publishes the authoritative list of accredited platforms and distinguishes provisional registration from definitive registration, which requires successful interoperability testing. The list grew past 100 entries during 2026 and changes continuously, so check the official list rather than a vendor's copy of it, and confirm the registration status of any provider you are about to sign with.

E-reporting explained

E-reporting is the reporting duty that covers everything the e-invoicing flow does not: sales to consumers, cross-border business transactions, and operations involving parties that are not in the French system. It comes in two separate obligations.

• Transaction e-reporting (article 290 of the tax code): summary data on B2C sales carrying French VAT, sales and services to taxable persons not established in France, reverse-charge purchases, and intra-EU acquisitions. Sales reported through the EU One Stop Shop are outside it.
• Payment e-reporting (article 290 A): the collection data for operations where VAT falls due on payment rather than on delivery — in practice, services. Ordinary goods deliveries are already captured by the invoice data, and reverse-charge operations are excluded. A seller who has opted to account for VAT on invoicing (option pour les débits) is relieved of the payment reporting for the operations that option covers.

How often you must transmit

Frequency follows your French VAT filing regime rather than your size, per the DGFiP transmission-frequency guidance.

VAT regime	Transmission rhythm
Régime réel normal, monthly filer	Three times a month, each ten-day period transmitted within ten days of its end
Régime réel normal, quarterly filer	Monthly, by the 10th of the following month
Régime simplifié	Monthly, between the 25th and the 30th of the following month

For a foreign company, this is the sting in the tail. A German business with a French VAT number and no establishment escapes the e-invoicing work entirely, then discovers it still needs a contract with an accredited platform and a monthly or ten-day data feed. Budget for the platform contract, not just for the invoice format.

Penalties were raised in February 2026

Most English-language coverage still quotes €15 per invoice and €250 per transmission. Those were the amounts set when the reform was designed. Article 123 of the 2026 finance law (law n° 2026-103 of 19 February 2026) raised them before go-live. The current figures are below.

Failure	Legal basis	Amount	Annual cap
Invoice not issued in electronic form	CGI art. 1737, III	€50 per invoice (was €15)	€15,000 per calendar year
No accredited platform designated for reception, after a formal notice left unanswered for three months	CGI art. 1737, IV bis	€500, then €1,000 for a repeat and per further quarter	No stated cap on repeats
Transaction e-reporting not transmitted	CGI art. 1788 D, I	€500 per transmission (was €250)	€15,000 per calendar year
Payment e-reporting not transmitted	CGI art. 1788 D, II	€500 per transmission	€15,000 per year, separate from the cap above
Platform fails to pass invoice data to the administration	CGI art. 1737, IV	€50 per invoice, charged to the platform	€45,000 per calendar year

Two details are worth keeping. First, the two e-reporting caps are independent, so a company that gets both transaction and payment reporting wrong faces €30,000 of exposure, not €15,000. Second, there is genuine first-mistake relief: no fine applies where the breach is the first in the current and three preceding calendar years and is corrected spontaneously or within thirty days of an administration request.

Accepted formats and the Factur-X connection

France mandates a base set (socle) of three EN 16931-compliant formats, defined through the AFNOR XP Z12-012 standard and the DGFiP external specifications — version 3.2 of 30 April 2026 is the one applicable to the 2026 launch.

• Factur-X — a PDF/A-3 file with CII XML embedded, readable by a human and by a machine at the same time.
• UBL — pure XML, the syntax most familiar to Peppol users.
• UN/CEFACT CII — pure XML in the Cross Industry Invoice syntax, now on the D22B version and backward compatible with D16B.

Other syntaxes such as EDIFACT may still be used between two platforms by bilateral agreement, but a business cannot rely on that: the three formats above are what any accredited platform must handle. Alongside the standard EN 16931 profiles, France defines a national reference profile, EXTENDED-CTC-FR, which adds French-specific fields on top of the EXTENDED profile rather than restricting it.

Factur-X and ZUGFeRD are the same technical family

For a German company this is the useful part. Factur-X and ZUGFeRD are not merely similar — the joint FNFE-MPE and FeRD publications state they are technically identical, sharing the same XML content model and the same five profiles, each with its own XSD and Schematron. The names differ by country, not by substance. The current joint release is Factur-X 1.09 / ZUGFeRD 2.5, published on 10 June 2026 and aligned with the revised EN 16931-1:2026 semantic standard.

So an accounts-payable team that already handles ZUGFeRD is handling the same file structure that a French supplier will send. What changes is not the parsing — it is the routing, the extra French invoice fields, and the reporting obligations around the document. Our Factur-X format guide covers the file itself in more depth; this article deliberately covers the system around it.

Which profile to send

The safe choice for French B2B is the EN 16931 profile (historically also called COMFORT) or EXTENDED. The MINIMUM and BASIC WL profiles carry too little structured line data to stand as a full invoice, and their status under the mandate is still argued over in the market — some sources treat BASIC WL as tolerated during the transition, others as excluded. Since neither profile gives a buyer enough data to post an invoice automatically, there is little reason to send them into France even where they are tolerated. Note also that the XRECHNUNG reference profile is a German construct: it is not the French answer.

Four invoice fields that catch foreign issuers

Four particulars were added to the French mandatory invoice content by décret n° 2024-1195 and have applied since 1 January 2025 (article 242 nonies A of annex II to the tax code). They are easy to miss because most ERP templates outside France have no field for them.

Field	Reference	When it applies
The customer's SIREN number	point 1°	Invoices between taxable persons; it is the identifier the administration matches on
Delivery address of the goods	point 7° bis	Whenever it differs from the customer's own address
Category of the operation: goods only, services only, or both	point 8° bis	Every invoice
Mention of the option to account for VAT on invoicing	point 11° bis	Where the supplier has exercised that option

Mixed goods-and-services invoices

The category indicator is not cosmetic, and it is where mixed invoices become awkward. VAT on a goods delivery falls due on the delivery; VAT on a service falls due when the customer pays, unless the supplier has opted for the invoicing basis. An invoice that carries both — a machine plus its installation, say — has to be flagged as mixed, and only the services portion feeds the payment e-reporting.

Two practical rules follow. Where a service is genuinely accessory to the goods and inseparable from them, the invoice follows the regime of the principal operation and is not mixed. Where goods and services are independent of one another, the French use-case work recommends splitting them into two invoices where the commercial relationship allows it — the accounting treatment is simply cleaner. If you cannot split, make sure your ERP can actually set the category flag; many cannot, and a review step will be needed until it can.

What the simplification package removed

The government announced simplification measures in late summer 2025 and codified them in the same article 123 of the 2026 finance law that raised the penalties. The reductions are real but narrow: they trim reporting granularity rather than the core obligation.

• Line-level e-reporting data is no longer required for incoming cross-border business invoices.
• Total counts of B2C transactions no longer have to be reported.
• Nil returns were dropped: no report is needed for a period with nothing to report.
• The VAT margin scheme for B2C can be computed on an average rate instead of sale by sale.
• Obligations for taxable persons not established in France were pushed to 1 September 2027.
• Development of the public portal as a full invoicing platform was formally discontinued, leaving accredited platforms as the exchange route.

What did not change: the calendar, the requirement for every French entity to hold at least one registered reception address, and the domestic B2B obligation itself. Reports that the reform has been watered down overstate the case — the same law that simplified reporting also tripled the per-invoice fine.

A short plan for the remaining weeks

If you are reading this in August 2026, the realistic goal is not a finished project. It is being reachable, being able to read what arrives, and having a documented plan for the rest — which is also what the announced tolerance rewards.

1. Settle your status. Establishment in France, VAT registration only, or neither. Get the fixed-establishment question confirmed rather than assumed.
2. Appoint a platform if you have a French entity or an e-reporting duty, and check its registration status on the official DGFiP list.
3. Confirm your directory entry. Your platform registers your reception address; verify it exists rather than trusting that it does.
4. Make accounts payable readable. From day one you may receive Factur-X, UBL or CII. Reading them is the obligation that applies to everyone on 1 September 2026.
5. Fix the four French fields in your outgoing invoice template, especially the customer SIREN and the operation category.
6. Map your e-reporting flows and the transmission rhythm your VAT regime implies, then dry-run one period before it counts.
7. Write down what is not ready and what you are doing about it. Documented good faith is worth more at launch than a half-finished integration.

For neighbouring deadlines, see our European deadline overview and the German 2027 and 2028 timeline, which most companies affected by France will hit next.

Where this service fits

Invoice-Converter.com converts PDF and other invoice sources into structured EN 16931 output and validates the result, including Factur-X, ZUGFeRD, UBL and CII. Because Factur-X and ZUGFeRD share one technical family, the same conversion path serves a German and a French obligation. A note on versions: generation currently follows the earlier Factur-X 1.07 / ZUGFeRD 2.3 artifact line — EN 16931-conformant, but not yet the June 2026 release 1.09/2.5 — so confirm which profile versions your Plateforme Agréée expects.

Two things it does not do, stated plainly. It is not an accredited platform: it does not transmit invoices into the French network or file your e-reporting, and you will still need a Plateforme Agréée for that. And it does not remove the review step — extraction from a low-quality source document, unusual line structures and the French-specific fields discussed above are exactly the cases where a person still has to look at the result before it goes out. What it produces is validator-compliant structured output and a place to correct the data before it becomes a legal document.

How to use this guide

Use the article as a starting point before changing a finance or ERP workflow: identify the applicable country rule or standard, decide which structured format is expected, validate the generated XML, and keep a documented exception process for invoices that require manual review.