Author: Melissa Oktay, SAP Finance Consultant at TJC Group
France’s electronic invoicing reform has moved from preparation to implementation. TJC Group covered many of these developments in its 2025 France e-invoicing update. This article looks at what has changed since then and what SAP customers need to consider now that the first phase of the reform is in effect.
Table of contents
- What changed since TJC Group’s 2025 update?
- France e-invoicing in 2026: the current position
- Scope of the French e-invoicing mandate
- The rollout dates businesses need to know
- Approved platforms and the new role of the PPF
- Peppol’s role in the French model
- Invoice formats and interoperability requirements
- E-invoicing and e-reporting are not the same obligation
- Implications for SAP customers
- SAP DRC in the French e-invoicing process
- Priorities after the September 2026 go-live
- Conclusion
Since 1 September 2026, large companies and mid-sized enterprises (ETIs) have been required to issue electronic invoices for transactions within the scope of the reform and fulfil the corresponding e-reporting obligations. At the same time, all businesses concerned by the reform, regardless of size, must be able to receive electronic invoices. SMEs and micro-enterprises move into the next phase on 1 September 2027.
For organisations that have followed the French reform for several years, the dates themselves are only part of the story. The platform model has matured, the terminology has changed, the Public Invoicing Portal has a more focused role, and the regulatory and technical framework has become much clearer.
What changed since TJC Group’s 2025 update?
Several parts of the French reform that were still developing in 2025 are now much clearer.
| Earlier position | Position in 2026 |
| The reform was still in preparation | The first phase took effect from 1 September 2026 |
| PDP terminology was widely used | The current framework uses plateforme agréée |
| The PPF originally had a broader intended role | The PPF is focused on central functions including the directory and regulatory data concentration |
| Approved platforms were still preparing and testing | Approved platforms now form part of the operational framework |
| France’s Peppol model was still developing | DGFiP is now the French Peppol Authority |
The result is a shift from interpreting a developing framework to operating within a live one.
France e-invoicing in 2026: the current position
The French reform has been through several changes in scope, architecture and timing.
Earlier TJC Group coverage followed the revised implementation timetable and the development of the French platform infrastructure. By summer 2025, attention had moved towards platform testing, PPF connectivity, AFNOR standards and growing use of Peppol for interoperability.
By 2026, many of those moving parts had become clearer.
France published further regulatory and technical updates ahead of implementation, including Decree No. 2026-677 of 27 July 2026, which amended the framework and replaced several earlier references to plateformes de dématérialisation partenaires with the current term plateformes agréées.
Most importantly, the first phase is no longer a future deadline. The obligations began to take effect from 1 September 2026.
The French administration has also introduced a period of tolerance during the initial rollout. While the obligations have been in force since 1 September 2026, businesses experiencing implementation difficulties are not expected to face sanctions during the remainder of 2026. This does not postpone the reform. It provides additional room to resolve practical issues during the first months of operation.
The priority has therefore shifted from preparing for the mandate to operating within it reliably. Invoice flows, approved-platform arrangements, master data and reporting processes now need to work within the live framework.
Scope of the French e-invoicing mandate
French e-invoicing broadly applies to domestic B2B transactions between VAT-taxable persons established in France, subject to the relevant exclusions and specific rules.
Certain VAT-exempt transactions that are also exempt from invoicing under Articles 261 to 261 E of the French General Tax Code fall outside the e-invoicing and e-reporting scope. The reform also includes e-reporting for transactions that do not pass through the domestic B2B e-invoicing process.
A French legal entity may therefore have transactions that follow different compliance routes depending on the customer, transaction type and where the counterparty is established. The detailed distinction between e-invoicing and e-reporting is covered later in this article.
The rollout dates businesses need to know
France has retained a phased implementation based on company size.
| Date | Requirement |
| 1 September 2026 | All businesses concerned by the reform must be able to receive electronic invoices |
| 1 September 2026 | Large companies and ETIs must issue electronic invoices and comply with applicable e-reporting requirements |
| 1 September 2027 | SMEs and micro-enterprises become subject to the corresponding issuance and e-reporting requirements |
The obligation to receive invoices therefore arrives earlier than the issuance obligation for many smaller businesses. A company that does not need to issue regulated electronic invoices until September 2027 must nevertheless be able to receive them through an approved platform from September 2026.
This may be arranged directly with an approved platform or through an accounting, ERP or service provider connected to one. Readiness should therefore not be assessed solely according to an organisation’s own issuance deadline. Incoming supplier flows matter too.
Approved platforms and the new role of the PPF
One of the most important changes from earlier versions of the reform is the architecture through which businesses exchange invoices.
Companies within the reform use an approved platform, or plateforme agréée, approved by the French tax administration to exchange regulated electronic invoices and transmit the required e-invoicing and e-reporting information.
The French tax authority maintains an official register of these platforms, which have a central role in both e-invoicing and e-reporting.
The terminology has also evolved. Earlier documentation and TJC Group articles commonly referred to Plateformes de Dématérialisation Partenaires (PDPs). The July 2026 regulatory changes moved the terminology towards plateformes agréées (PAs), which is now used in the updated framework.
The PPF’s more focused role
The Portail Public de Facturation (PPF) remains an important part of the French infrastructure, but businesses no longer use it as the direct invoice-exchange platform originally envisaged.
Its role is focused on central infrastructure such as invoice-routing information and the concentration of regulatory data transmitted to the administration.
Businesses instead exchange regulated invoices through their approved platforms. For SAP projects, this means organisations need to understand both sides of the process: the source application creating or receiving the transaction and the approved platform responsible for the external compliance exchange.
Peppol’s role in the French model
Peppol has become an important part of France’s interoperability landscape.
The Direction générale des Finances publiques (DGFiP) became the French Peppol Authority on 8 July 2025. France has also established authority-specific requirements for Peppol-certified service providers operating within the country.
Peppol provides a standardised network and governance framework that can support exchanges between participating service providers. However, Peppol should not be treated as the French mandate itself. France still has its own approved-platform requirements, invoice standards, reporting obligations and public infrastructure. Peppol supports interoperability within that wider framework rather than replacing it. Multinational organisations that already use Peppol elsewhere in Europe still need to account for France-specific compliance requirements.
Invoice formats and interoperability requirements
An ordinary PDF sent by email does not meet the requirements of a structured electronic invoice under the French reform.
The French framework relies on structured or hybrid invoice formats that allow invoice information to be processed electronically rather than simply read as a visual document.
The minimum framework includes:
| Format | Structure |
| UBL 2.1 | Structured XML based on Universal Business Language |
| UN/CEFACT CII D22B | Structured XML based on Cross Industry Invoice |
| Factur-X | Hybrid PDF/A-3 containing an embedded structured XML representation |
These formats implement the structured data required by the French framework, with the applicable profiles defining how that information is represented.
Invoice compliance is therefore no longer just about producing a document that looks correct to a person.
The underlying information must also be sufficiently structured and accurate for platforms, ERP systems and the wider compliance infrastructure to process it correctly.
Read more about e-invoicing formats in the article E-invoicing and e-reporting: Drivers, deployment, formats to know of.
E-invoicing and e-reporting are not the same obligation
E-invoicing and e-reporting are closely connected, but they address different types of transactions.
| Transaction | Main requirement |
| Domestic B2B transaction within the relevant French scope | E-invoicing |
| Relevant sale to an individual or other non-taxable customer | E-reporting |
| Relevant cross-border B2B transaction within the French e-reporting scope | E-reporting |
| Certain payment information | Payment e-reporting |
In an SAP environment, this classification needs to happen before information reaches the reporting channel. The underlying systems need enough reliable information to determine what kind of transaction took place, where the counterparties are established and which compliance process applies.
That makes source data a central part of the compliance process rather than a separate data-quality concern.
Implications for SAP customers
For organisations running SAP, France’s reform affects more than the final transmission of an invoice. The process starts much earlier in the ERP landscape.
Transaction classification
Organisations need to distinguish transactions that belong in the domestic B2B e-invoicing process from those that require e-reporting.
A multinational SAP environment may contain French domestic transactions, cross-border sales, B2C activity and invoices produced by non-SAP applications. Those flows cannot all be treated in the same way.
Master data
Routing and regulatory reporting depend on accurate information about suppliers, customers and legal entities. Incorrect identifiers, incomplete addresses or inconsistent tax information can therefore become operational problems once invoices move through a structured electronic process.
Compliance technology can process the information it receives, but it cannot automatically make inaccurate source data correct.
Invoice formats
Existing invoice-generation processes also need to produce or support the information required by the French formats. A PDF-based process that previously worked between a supplier and customer may therefore no longer satisfy the regulated electronic-invoicing requirement.
Approved-platform connectivity
Organisations also need to understand how their SAP landscape communicates with the approved platform used for the French process.
That includes outbound invoices, incoming supplier invoices, lifecycle statuses, e-reporting and exception handling when a document cannot be processed normally.
France’s reform is therefore an end-to-end ERP and compliance process rather than simply a change to invoice format.
SAP DRC in the French e-invoicing process
SAP provides France-specific electronic invoicing and reporting capabilities through SAP Document and Reporting Compliance (SAP DRC).
Current SAP documentation covers domestic B2B electronic invoicing as well as international B2B, B2C and relevant payment-reporting scenarios through SAP Document and Reporting Compliance, cloud edition.
For supported French scenarios and SAP environments, SAP documentation describes the cloud edition as an approved platform (plateforme agréée). It can support the exchange of electronic documents and communication with the wider French compliance infrastructure.
The exact setup depends on the customer’s SAP environment, system version, supported processes and existing invoicing architecture.
For more background on the product and wider compliance process, TJC Group’s guide to e-invoicing and e-reporting with SAP DRC explains how SAP DRC supports electronic documents and statutory reporting across SAP environments.
Priorities after the September 2026 go-live
A practical post-go-live review should cover:
- Which French entities and transactions fall within the reform
- Whether the appropriate approved platform is in place
- Customer, supplier, tax and routing data
- Domestic B2B versus e-reporting classification
- Invoice formats and required structured information
- Incoming as well as outgoing invoice processes
- Lifecycle statuses, exceptions and monitoring
- Payment-reporting requirements where applicable
- Interaction between SAP, other source systems and the approved platform
For SMEs and micro-enterprises preparing for the September 2027 phase, the first year of implementation provides additional time to test these dependencies before their own issuance obligations begin.
Conclusion
France’s e-invoicing reform has reached a different stage in 2026. Businesses now have an operational framework built around approved platforms, structured invoice formats, central public infrastructure and separate e-invoicing and e-reporting processes.
For organisations already within the first phase, the focus should be on operational reliability: correct transaction classification, accurate source data, successful platform exchange and clear exception handling.
For SMEs and micro-enterprises preparing for September 2027, the current rollout provides additional time to test those same dependencies before their own issuance obligations begin.
For SAP customers, the key is to treat French e-invoicing as part of the wider ERP and compliance process. The invoice may be the document being exchanged, but the reliability of the process depends on the systems, master data, tax logic and controls behind it.
Sources of information
French government and regulatory sources:
- DGFiP: Electronic invoicing and approved platforms
- DGFiP: Understanding the electronic invoicing reform
- DGFiP: Current e-invoicing obligations
- DGFiP: Approved platforms
- DGFiP / AFNOR: French invoice standards and formats
- AIFE: B2B electronic invoicing
- Légifrance: Decree No. 2026-677 of 27 July 2026
Peppol and SAP sources
- OpenPeppol: France country profile
- SAP Help: Electronic invoicing and reporting via approved platform in France
FAQ's
Q1. Is e-invoicing already mandatory in France?
Answer:
The first phase took effect on 1 September 2026. Large companies and ETIs are subject to the applicable issuance and e-reporting requirements, while all businesses concerned by the reform must be capable of receiving electronic invoices.
SMEs and micro-enterprises enter their issuance and e-reporting phase on 1 September 2027.
Q2. Do SMEs need to receive electronic invoices in 2026?
Answer:
Yes. The reception requirement applies from September 2026 regardless of company size for businesses within the scope of the reform.
A smaller business must therefore be able to receive regulated electronic invoices even though its own issuance obligation does not begin until September 2027.
Q3. Is a PDF sent by email an electronic invoice in France?
Answer:
An ordinary PDF sent by email does not satisfy the structured electronic-invoicing requirements of the reform.
Electronic invoices need to contain the required structured information and pass through the applicable electronic-invoicing process.
Q4. What is a plateforme agréée?
Answer:
A plateforme agréée is a platform approved by the French tax administration to exchange regulated electronic invoices and transmit the required data under the French e-invoicing and e-reporting framework.
Q5. Does France require Peppol?
Answer:
Not as a standalone obligation on every business.
Peppol forms part of France’s interoperability environment, and the DGFiP is the French Peppol Authority. However, organisations still need to comply with France-specific approved-platform, invoice and reporting requirements.
Q6. What formats are used for French electronic invoices?
Answer:
The minimum framework includes UBL 2.1, UN/CEFACT CII D22B and Factur-X.
Q7. Can SAP DRC support French e-invoicing?
Answer:
Yes, for supported environments and scenarios. SAP provides France-specific electronic invoicing and reporting processes through SAP Document and Reporting Compliance, including the use of SAP Document and Reporting Compliance, cloud edition as an approved platform in supported cases.