Twenty-five days after September 1, 2026, real production has exposed what test environments never showed. Large enterprises and mid-market companies (ETI) required to issue structured invoices have found, in their platform logs, a series of anomalies that the AIFE (Agence pour l’Informatique Financière de l’État) pilot programs had not anticipated at scale. Meanwhile, a significant share of businesses still had no connection to a Plateforme Agréée (PA — Certified E-Invoicing Platform). This D+25 report documents the factual lessons from this first mandatory production period — without official figures (the DGFiP has not published any yet), but drawing on professional press and legal commentary available in the field.
What Was Expected on September 1, 2026
Three Obligations That Went Live
France’s reform introduced three distinct obligations, entering into force on September 1 for large enterprises and ETI:
- Structured-format emission: every invoice issued to a French VAT-registered buyer must transit through a PA, in Factur-X, UBL 2.1 or CII format. A PDF sent by email is no longer an invoice in the legal sense.
- Native reception: since September 1, every VAT-registered business in France — including SMBs and micro-enterprises — must be technically capable of receiving inbound invoice flows via a PA. This is not an emission obligation, but it is a real one.
- VAT e-reporting: for transactions outside the e-invoicing scope (B2C sales, foreign customers), transaction data must be transmitted to the DGFiP (French tax authority) via the PA or the Portail Public de Facturation (PPF — the public invoicing portal), on a strict schedule: every ten days for transactions, monthly for payments.
Companies in Scope at This Date
On September 1, 2026, emission obligations applied to large enterprises (more than 250 employees or turnover above €50 million) and ETI (50 to 250 employees). SMBs, micro-enterprises, and sole traders have until September 1, 2027 to activate emission — but their reception obligation was already in effect.
For the detailed record of which ERPs maintained or lost their Certified Platform status at launch, see our D+7 report — which ERPs delivered on the September 2026 deadline.
First Technical Anomalies Surfaced in Production
Three weeks after go-live, incidents multiplied to the point of generating nascent litigation. Paris-based business attorney Maître Reda Kohen published a series of four articles between September 22 and 25, 2026, documenting real cases of rejected, blocked, or disputed invoices (kohenavocats.fr, 22–25 September 2026). The volume of publication — unusual for a tax law firm — reflects the scale of incoming client inquiries.
Missing or Malformed SIREN Numbers
The PPF’s central directory routes invoices using SIREN and SIRET identifiers (the French national business and establishment codes). A missing, incorrect, or outdated directory entry is enough to trigger an automatic rejection — error code DEST_INC (unknown recipient in directory) or SIRET_ERR (incorrect SIREN/SIRET). This type of error has been among the most frequently documented rejection causes on professional forums since September 1.
The root cause is usually in the issuing ERP: a SIREN entered in a free-text field, an old customer record carrying the head-office SIRET instead of the destination-site SIRET, or a misconfigured export that truncates the identifier to 8 digits instead of 9. The outcome is the same: the invoice does not arrive, it sits with “rejected” status in the issuing PA, and the supplier is not paid (compta-online.com, AFNOR XP Z12-012 rejection codes).
Missing Mandatory Fields
The AFNOR XP Z12-012 standard — which normalizes 45 platform rejection codes across six families — includes several codes for missing legal fields. Two sectors concentrate the reported incidents:
- Public procurement: the “contract reference” field (public contract or purchase order number) is mandatory for invoices issued under public-sector contracts. Companies accustomed to billing local authorities through Chorus Pro discovered that switching to a private PA does not waive this field.
- Subcontracting and VAT self-assessment: invoices using VAT reverse-charge (common in construction) require an explicit mention in the XML flow. ERPs that handled this correctly in their PDFs had omitted it from their Factur-X exports.
Calculation Errors and Encoding Problems
The CALCUL_ERR code has appeared in multiple reports: rounding to two decimal places line by line can introduce a €0.01 gap with a globally rounded total. That micro-discrepancy is enough to invalidate the invoice under schematron validation rules. Several vendors deployed patches within days of the first reports.
Character encoding remains a problem for legacy ERP systems. Some older platforms still export in ISO-8859-1 (Latin-1) where the Factur-X standard requires UTF-8. The result: company names with accented characters corrupt inside the XML flow and trigger a semantic rejection (REJ_SEMAN).
Unconnected Recipients
The NON_TRANSMISE code — recipient not connected to any platform — has emerged as a structural problem. An invoice issued by a compliant large enterprise reaches a PA… which has no counterpart to route it to the recipient, because that SMB customer has not yet subscribed to a PA. The invoice is in limbo: issued, not received, but technically transmitted (compta-online.com, rejection codes).
What Certified Platforms Had to Fix Urgently Post-Launch
Format Corrections Deployed Within the First 15 Days
Several platforms pushed corrective updates in the two weeks following launch. The most common fixes addressed schematron validation of BR-FR business rules (France-specific rules), ISO country code handling, and VAT calculation algorithms for discounts and credit notes. These updates generally required no action on the client side, but some temporarily shifted validation rules — creating a window during which previously valid invoices became invalid, or vice versa.
Rejection Handling Procedures
The AFNOR XP Z12-012 standard defines 7 corrective action codes (from NOA for “no action required” to NIN for “issue a corrected invoice”). In practice, few accounting teams were familiar with these codes before go-live. The first few weeks exposed a training gap in rejection management — a process distinct from bookkeeping that involves supplier, customer, and sometimes both platforms in sequence.
Variable Communication Across Vendors
The quality of post-launch communication has varied significantly across vendors. Platforms that prepared real-time status portals and rejection-code knowledge bases absorbed the support surge with less friction. Those that replied with an English-language error email containing a raw XML code generated team burnout — the same pattern observed during Belgium’s April 2026 launch.
Companies Not Ready: What Is Actually Happening
DGFiP Tolerance: Formalized but Conditional
The DGFiP has held its pre-announced tolerance stance: no automatic penalty for companies acting in good faith while adapting (itsocial.fr, September 2026). This tolerance is expected to extend through end of 2026. It is conditional: the company must document its difficulties (support tickets, PA contracts in progress), maintain an active compliance trajectory, and not treat non-compliance as a permanent state.
38% of companies had still not taken concrete steps ahead of September 1, 2026 (swiftediflow.com, September 2026 start-up analysis). For these businesses, the DGFiP tolerance is a window — not an amnesty.
Operational Transition Solutions
For large enterprises and ETI not yet connected, three transition solutions remain viable today:
- Third-party PA mandate: delegate emission and reception to a PA on a transitional basis without changing ERP. Several PAs offer onboarding in 2 to 4 weeks.
- Pooled PA: some accounting firms and professional associations have subscribed to a PA on behalf of their clients or members.
- Chorus Pro: France’s public invoicing portal remains accessible for companies not yet connected to a private PA — but its B2G (public-sector) scope and manual-entry constraints make it a stopgap, not a target.
Concrete Legal Risks
Article 1788 D of France’s Code général des impôts sets the penalties: €50 per invoice not issued in electronic format (capped at €15,000/year), €500 per missing e-reporting transmission (same cap), with a quarterly escalation for companies that remain unconnected after formal notice (compta-online.com). While the tolerance is active, these penalties are not applied automatically. But suppliers whose invoices are rejected and who go unpaid can use that rejection to contest compliance — and potentially claim late-payment penalties calculated from the original issue date.
First Volume Figures (D+1 to D+25)
The DGFiP has not yet published official statistics on invoice volumes processed between September 1 and 26, 2026. The first aggregated results are expected in late October 2026, in line with the administration’s usual publication calendar.
What is already known: during the pilot phase preceding mandatory go-live, only 3,800 entities had issued e-invoices and 3,400 had received them — out of a total of more than 11 million economic actors ultimately in scope, a participation rate of around 0.025% (Basware compliance map France, 2026 pilot data). This pilot figure does not represent production, but it illustrates the low system readiness when the mandatory switch occurred.
PAs that communicate on their volumes remain vague for commercial reasons. Without consolidated DGFiP data, any success-rate or volume figures circulating on professional networks should be treated with caution.
What This Means for the Next Deadline: SMBs in 2027
September 1, 2027 is the next key date: SMBs (fewer than 50 employees), micro-enterprises and sole traders will need to activate their emission obligation. The lessons from the first 25 days of large-enterprise/ETI production have direct value for these entities.
What large enterprises learned — and what SMBs must apply:
- Clean customer records (SIREN, site-level SIRET, PA directory address) before activating flows — not in reaction to first rejections
- Test UTF-8 encoding of ERP exports on a pilot batch before going live
- Train accounting teams on all 45 rejection codes, not just the emission procedure
- Verify that the recipient’s PA is properly connected for strategic customers
3 priority actions for an SMB starting now:
- Choose a PA and sign a contract before end of 2026: vendor queues remain long. Onboarding started in January 2027 risks missing the September deadline.
- Audit customer records for ETI and large-enterprise clients: these customers are already under mandatory emission. If your reception PA is not correctly configured, you are not receiving their invoices — and they may not know it.
- Activate e-reporting at the same time as e-invoicing: the two obligations have distinct PA configuration paths. Do not repeat the mistake of ETI companies that configured e-invoicing but not e-reporting.
For the full reform timeline, read our D+5 report — what the first week revealed, our D+7 ERP compliance report, and our 2026–2027 France e-invoicing roadmap: PAs, directory, and e-reporting.
