On 1 September 2026, all French VAT-registered businesses must be able to receive electronic invoices in a regulated format. For large companies and mid-market firms (ETI), the obligation to issue e-invoices applies on the same date. SMEs and micro-businesses have until 1 September 2027 for the issuance requirement — but the reception obligation allows no further delay.
With sixty days to the deadline, here is a factual guide covering what actually changed with the PPF, how the decentralised Y-model works, how to choose your approved platform, and the 12 points to verify in your ERP before go-live.
Why France’s E-Invoicing Reform Is Unique in Europe
Most European e-invoicing mandates rely on a single standard format and one centralised exchange network. Italy has required XML FPA format via the SDI (Sistema di Interscambio) since 2019 — a central platform managed by the tax authority. Belgium adopted the Peppol network via certified access points. Romania launched the government portal e-Factura for domestic B2B flows.
France chose a third path: a “decentralised Y-model” where the government does not handle invoice flows itself but delegates that role to accredited private operators, while retaining fiscal oversight through a central concentrator.
The Y-Model: Architecture in Three Minutes
Sender → Approved Platform (AP) of sender → PPF (fiscal concentrator)
↓
Approved Platform (AP) of receiver → ReceiverEach business freely selects its own Approved Platform (AP — Plateforme Agréée in French, previously called PDP). Platforms interconnect via a central directory managed by the PPF. The tax authority receives normalised transaction data from all platforms without accessing the invoice content directly.
This model is distinctly French: it combines the flexibility of a competitive private market (150+ approved platforms as of June 2026) with the centralised fiscal control the administration wanted to preserve.
The PPF: Recentred, Not Removed
The Portail Public de Facturation (PPF — France’s public invoicing portal) was not “abolished.” Its role was fundamentally redefined on 15 October 2024: the original design had the PPF serving as an emission and reception platform for businesses that preferred not to use a private operator. That option was dropped.
Today the PPF fulfils two essential but invisible functions:
- The national directory: it registers all VAT-registered businesses, their linked approved platform, and their billing addresses. Without registration in this directory, your suppliers cannot send you invoices in regulated format.
- The fiscal concentrator: it receives transaction data transmitted by approved platforms and routes it to the DGFiP (French tax authority) for VAT oversight.
Chorus Pro remains operational. For B2G flows — suppliers to the state, local authorities, and public institutions — Chorus Pro continues to function normally. If you invoice the public sector, Chorus Pro remains your tool. For private B2B invoices, you must use an approved platform.
Compliance Timeline by Company Size
1 September 2026: Large Companies and ETI
Two obligations come into force simultaneously for large companies and mid-market firms (entreprises de taille intermédiaire — ETI):
- Reception obligation: connect to an approved platform and register in the PPF directory to receive structured electronic invoices.
- Issuance obligation: issue all domestic B2B invoices in regulated electronic format (Factur-X, UBL 2.1 or CII).
Official definitions: A large company exceeds 5,000 employees or revenue above €1.5 billion. An ETI covers businesses between 250 and 4,999 employees or revenue above €50 million.
1 September 2026: Reception Obligation for All Businesses
The nuance that 70% of CFOs have not yet internalised: all businesses — SMEs, micro-businesses included — must be able to receive electronic invoices in regulated format from 1 September 2026.
In practice this means:
- Having selected an approved platform
- Being registered in the PPF national directory with your SIREN number and active billing addresses
- Having connected your ERP or invoicing software to your AP for reception
An SME that believes “this only concerns us from 2027” will be non-compliant from September 2026 if it cannot receive structured invoices.
1 September 2027: Issuance for SMEs and Micro-Businesses
For businesses with fewer than 250 employees and revenue below €50 million, the obligation to issue electronic invoices is deferred by one year. But this extension covers only issuance — not reception.
How to Choose Your Approved Platform
As of 16 January 2026 the DGFiP published its list of the first 101 accredited platforms. By June 2026 that number exceeds 150 operators (impots.gouv.fr). The market is active.
Terminology note: In the final regulatory texts, the term “PDP” (Plateforme de Dématérialisation Partenaire) was replaced by “PA” (Plateforme Agréée — Approved Platform). Both terms coexist in vendor and integrator documentation — but in an RFP or contract, verify that the selected solution appears on the official DGFiP list.
Selection Criteria
Native ERP integration. A native connector reduces risk and maintenance overhead. SAP DRC integrates natively with SAP S/4HANA and ECC. Sage Network is the AP for the Sage ecosystem (requires Sage 100 v12.20 minimum). Cegid XRP Pulse has its own AP referenced by the DGFiP. For Odoo, a connection to a third-party AP (Yooz, Docaposte, or a certified French Odoo partner) is required.
Format coverage. The reform accepts three structured formats: Factur-X (PDF/A-3 enriched with an XML file), UBL 2.1 and CII (Cross Industry Invoice). Verify coverage for both issuance AND reception. Some platforms are strong on issuance but weak at managing reception rejections.
B2C and international e-reporting. The obligation does not stop at domestic B2B invoices. The reform also mandates data transmission for B2C transactions and international operations via “e-reporting.” This flow is frequently absent from initial project scopes. Confirm that your AP and ERP handle it.
Volume and pricing. Pricing models vary: per-invoice (suited to irregular volumes), monthly subscription (regular flows), or hybrid. Calculate your average monthly volume and compare total cost over three years.
SLA and support. An approved platform that is critical to your operations must offer availability guarantees (99.9% minimum) and responsive support — particularly for invoice rejections that can block payments.
What Your ERP Must Do: 12-Point Checklist
Work through these 12 points with your CIO, your ERP integrator, and your AP:
- Factur-X or UBL format: your ERP generates invoices in structured format (PDF/A-3 + XML for Factur-X, or pure UBL 2.1/CII file).
- AP connection live: your ERP is connected to your approved platform for both issuance AND reception — not just configured in theory.
- PPF directory registration: your business is referenced in the national directory with your SIREN, your AP, and your active billing addresses.
- Customer master data current: your customers’ SIRET numbers (French business location identifiers) are entered and verified — an invoice issued with an incorrect SIRET will be automatically rejected.
- Intra-community VAT numbers: your customer and supplier EU VAT codes for intra-community transactions are up to date in your reference data.
- NAF / activity codes: your activity codes are set in your ERP (mandatory field in certain regulated formats).
- E-reporting flows configured: the data flows for your B2C transactions and international sales/purchases are configured in your ERP and routed to your AP.
- Credit notes and amendments: your credit notes, deposits, and corrective invoices are handled in regulated electronic format — not just standard invoices.
- Lifecycle status processing: your ERP processes the invoicing statuses returned by your AP (issued, received, rejected, approved). Rejections must trigger an alert and a correction workflow.
- 10-year archiving process: the legal retention of electronic invoices (10 years for accounting, 6 years for VAT) is documented and compliant. Unstructured PDF invoices are no longer sufficient.
- End-to-end test completed: a full test in a qualification environment (issuance → AP → PPF directory → receiving AP → reception) has been carried out on your actual flows — not just in simulation.
- Intercompany flows covered: if you have subsidiaries or intercompany operations, these intra-group B2B flows are also within scope and must transit through APs.
Six-Step Action Plan
With 1 September 2026 sixty days away, here is a realistic sequencing:
Now (Day 0) — AP and ERP diagnostic Verify that your ERP is on a compliant version (Sage 100 v12.20+, SAP DRC activated, Cegid XRP Pulse configured) and that your vendor has an accredited AP partner. If you have no AP, start the RFP immediately — contractualisation and integration lead times are 4 to 8 weeks minimum.
Day +7 — Platform selection and contract Select your approved platform from the official DGFiP list. Sign the contract. The AP’s onboarding and production deployment timeline is generally 2 to 4 weeks after signature.
Day +14 — ERP update and connector configuration Deploy the ERP update if needed. Configure the AP connector. Update your reference data (customer SIRETs, NAF codes, intra-community VAT). This workstream is consistently underestimated: budget two weeks of effort for an SME with a standard ERP.
Day +21 — PPF directory registration Register your business in the national directory via your AP. Validate your billing addresses and e-reporting flows. Without this registration, your partners cannot send you invoices in regulated format.
Day +35 — End-to-end testing Run complete tests in a qualification environment with your 3 to 5 most important suppliers and customers. Simulate rejections and validate correction processes. Train your accounts payable/receivable teams on the AP interface.
Day +50 — Production go-live Switch to production with a limited scope (one customer or supplier type) before 1 September. Keep a documented fallback process for the first days in case of incidents.
FAQ: Questions CFOs Are Actually Asking
“We only invoice the public sector via Chorus Pro — are we affected?” Yes, if you have any private B2B customers. Chorus Pro remains mandatory for public procurement and is not replaced. But for any private customer that is VAT-registered in France, you will need to issue and receive via an AP from your applicable obligation date. Both systems coexist: Chorus Pro for the public sector, AP for the private sector.
“Our ERP vendor told us the compliance update is included in our maintenance — what should I verify?” Check your current ERP version changelog: search for “Factur-X”, “e-reporting”, “plateforme agréée”, or “réforme facturation”. If your version is not current, an upgrade is needed even if it is included in maintenance. Also verify that your ERP is connected to an AP — a software update without an active connection to an accredited platform does not make you compliant.
“What happens if we are not ready by 1 September 2026?” Article 1737 III of the French General Tax Code (Code général des impôts) provides for a fine of €15 per invoice not issued or not received in regulated format, capped at €15,000 per calendar year per business. Beyond the fine, a non-compliant invoice can be rejected by your AP or your customer’s AP, causing payment delays. For a business issuing 500 invoices per month, the direct financial exposure can reach the €15,000 cap within the first quarter.
“Our group runs a global ERP (Oracle, Microsoft Dynamics) — are we covered?” Not automatically. A globally-deployed ERP without a France-specific module does not handle Factur-X flows or DGFiP e-reporting. You need to verify with your vendor or integrator whether the France module has been activated and whether it is connected to an accredited AP. French subsidiaries of international groups are a frequent blind spot in global compliance programmes.
“Our subsidiaries exchange intercompany invoices between themselves — are they within scope?” Yes. Intercompany B2B flows between French VAT-registered entities fall within the scope of the reform. Each entity must have its own AP and be registered in the directory. Intercompany flows with non-French entities (outside France) fall under e-reporting scope (data transmission), not domestic e-invoicing.
For further reading, see our mid-2026 PA and approved platform landscape — updated 21 June 2026 with detail on each major ERP vendor — and our France e-invoicing 2026–2027 ERP roadmap for the full project sequencing. If you manage cross-border European flows, our Peppol and EU interoperability guide covers obligations in other member states.
