
Article Summary
Guide to France's September 2026 e-invoicing mandate for non-French businesses. Covers the rollout timeline, invoice formats, penalties, and how to prepare.
France's e-invoicing mandate requires every business operating in France to receive structured electronic invoices beginning September 1, 2026. Large companies must also issue e-invoices from that same date, with mid-size companies following in September 2027 and small businesses completing the rollout in September 2028. Businesses that fail to comply face penalties of EUR 50 per invoice, capped at EUR 15,000 per year.
Most guidance available today focuses on French businesses and their obligations to send compliant e-invoices. This guide takes a different approach. It is written specifically for non-French businesses, whether based in the UK, US, EU, or Australia, that purchase from French suppliers and will begin receiving structured e-invoices under the France e-invoicing mandate 2026. If your accounts payable team processes invoices from French vendors, you need to understand what is changing, what these new invoice formats look like, and how to adapt your workflows before the first compliant invoices arrive.
What follows is a practical breakdown of the mandate's requirements, timeline, invoice formats, platform infrastructure, penalties, and preparation steps for your AP process.
What France's E-Invoicing Mandate Requires
France's e-invoicing mandate, administered by the DGFiP (Direction Générale des Finances Publiques), requires all B2B transactions involving at least one party established in France to use structured electronic invoices. This is not a voluntary modernization program. It is a legal obligation backed by enforcement mechanisms and a defined compliance timeline.
The primary motivation is fiscal: closing France's VAT gap. According to the European Commission's VAT Gap report, France lost an estimated EUR 12.1 billion to VAT non-compliance in 2023, representing 5.6% of expected VAT revenue. Structured e-invoices give the DGFiP real-time visibility into transaction data, making it far harder to underreport or misclassify taxable activity. Mandatory e-invoicing is the government's direct response to that revenue shortfall.
The reform introduces two distinct but related obligations. E-invoicing covers the exchange of structured electronic invoices between businesses for domestic B2B transactions. E-reporting requires businesses to report transaction data directly to tax authorities for categories not covered by e-invoicing, specifically B2C transactions and cross-border B2B transactions where structured invoice exchange is not mandatory. Both obligations are part of the same regulatory package and share overlapping compliance deadlines.
France is not acting in isolation. The EU's VAT in the Digital Age (ViDA) directive is establishing a union-wide framework for digital reporting and e-invoicing. France is among the first member states to implement a national mandate ahead of the EU-wide timeline, which means its requirements are already live while other countries are still in consultation phases. For businesses operating across multiple EU markets, France serves as an early indicator of where regulation is heading continent-wide.
The mandate also builds on existing infrastructure. France has operated Chorus Pro since 2017 for public-sector e-invoicing, requiring suppliers to government entities to submit structured electronic invoices through a centralized platform. The new mandate extends this principle to all B2B transactions between private-sector parties, a significant expansion in scope that affects hundreds of thousands of businesses. For readers wanting broader context on how structured e-invoicing works across different regulatory environments, our complete guide to e-invoicing fundamentals covers the core concepts and global trends.
The Phased Rollout Timeline
France's e-invoicing mandate does not arrive all at once. The rollout is split across two distinct obligations with different effective dates, and understanding the difference is critical for planning.
The two obligations are:
- The obligation to receive structured e-invoices
- The obligation to issue (send) structured e-invoices
The receiving obligation has a single, universal start date. The issuing obligation is staggered by company size over three phases.
| Date | Who Must Receive | Who Must Issue |
|---|---|---|
| September 1, 2026 | All businesses operating in France, regardless of size | Large enterprises (grandes entreprises) and large mid-size companies (entreprises de taille intermédiaire, ETI) |
| September 1, 2027 | Already in effect for all | Mid-size companies (PME, petites et moyennes entreprises) |
| September 1, 2028 | Already in effect for all | Micro-enterprises and small businesses |
The receiving obligation is the universal trigger. On September 1, 2026, every company doing business in France must be capable of accepting structured e-invoices. There are no size-based exemptions or delays for this requirement.
The issuing obligation follows a graduated schedule. Large enterprises and ETIs begin issuing structured e-invoices on September 1, 2026. Mid-size companies follow one year later. Micro-enterprises and small businesses have until September 1, 2028.
For businesses outside France that receive invoices from French suppliers, the practical effect is straightforward. September 1, 2026 is the date that matters most. That is when large French suppliers will begin sending structured e-invoices in Factur-X, UBL, or CII formats. The volume of structured invoices arriving in your AP workflow will then increase in September 2027 as mid-size French suppliers come online, and again in September 2028 when micro-enterprises and small businesses join.
A brief note on the history: France originally planned to launch the mandate in July 2024. That timeline was postponed to give businesses and platform providers more preparation time. The current September 2026 start date reflects the confirmed schedule following simplification measures the DGFiP announced in August 2025. While the dates above represent the official timeline, businesses should monitor updates from the DGFiP for any further adjustments.
How the Mandate Affects Non-French Businesses
The France e-invoicing mandate is domestic legislation, but its effects reach well beyond French borders. Whether your business has direct compliance obligations or simply receives invoices from French suppliers, your finance operations will change starting September 2026. The distinction hinges on one question: does your company have a tax presence in France?
Companies with a French Tax Presence
If your business holds a French VAT registration (identified by a SIREN number) or maintains a permanent establishment in France, you fall within the mandate's scope regardless of where your headquarters are located. This applies to UK, US, EU, and Australian companies alike.
These businesses face direct obligations:
- Receiving structured e-invoices: From September 2026, you must be able to receive invoices in one of the approved structured formats (Factur-X, UBL, or CII) through the public invoicing portal (PPF) or an approved partner platform.
- Issuing structured e-invoices: You will need to send compliant e-invoices to your French business customers according to the phased rollout timeline, with dates determined by your company size classification in France.
- E-reporting for cross-border transactions: Certain cross-border sales and purchases may trigger e-reporting obligations, requiring you to transmit transaction data to the French tax authority even when the counterparty is outside France. The main categories that trigger e-reporting include B2C sales to French consumers, intra-community supplies and acquisitions, and transactions where the reverse charge mechanism applies.
Foreign companies with a French VAT registration should verify that their SIREN number is correctly registered with their chosen platform. Depending on your situation, you may also need to appoint a fiscal representative in France to manage compliance on your behalf.
Companies with No French Tax Presence
The larger category, and the one most often overlooked, includes every business that buys goods or services from French suppliers without holding a French VAT registration or permanent establishment. These companies have no direct compliance obligations under the mandate. France's tax authority cannot impose requirements on a business with no French tax nexus.
The impact is indirect but unavoidable: your French suppliers will begin sending invoices in structured e-invoice formats instead of, or alongside, the traditional PDFs your AP team is accustomed to processing.
Here is what that looks like in practice. A Factur-X invoice arrives as what appears to be a normal PDF, but it contains an embedded XML file carrying all the invoice data in a machine-readable structure. Your team can still open and read it visually, but the real data lives in the XML layer. UBL and CII invoices take this further. They are pure XML files with no visual PDF component at all. An AP clerk who receives one will see raw markup rather than a formatted document.
For teams that currently process supplier invoices through manual data entry or traditional OCR on flat PDFs, this shift requires updated workflows. OCR tools designed to read text from scanned images do not extract embedded XML. Pure XML invoices have no visual text to scan in the first place. Your data extraction process needs to handle structured formats natively.
Beyond Standard Invoices
The mandate does not stop at invoices. French suppliers will also issue e-credit notes, corrective invoices, and other financial documents through the same structured formats. If your AP process treats credit notes differently from invoices, or routes them through separate approval workflows, those processes need to accommodate the new formats too. For teams already working to understand the differences between these document types, understanding credit notes versus invoices provides useful background on how they relate.
Regardless of which category your business falls into, the operational challenge is the same: can your AP systems handle the structured invoice formats that French suppliers will start sending?
Factur-X, UBL, and CII: Understanding the E-Invoice Formats
France's e-invoicing mandate accepts three structured formats, all compliant with the European standard EN 16931. Understanding what each format looks like and how it carries data will determine how your AP team processes invoices from French suppliers.
Factur-X: The Hybrid Format You Will Most Likely Receive
Factur-X is the format most non-French businesses will encounter first. It is a hybrid: a standard PDF with structured XML data embedded directly inside the file.
Open a Factur-X invoice, and it looks like any traditional PDF invoice, with headers, line items, totals, and supplier details laid out visually. But hidden within that same file is an XML payload containing the identical invoice data in a machine-readable structure.
This dual nature gives AP teams two paths for extracting data. You can process the PDF visually, using OCR or manual review, exactly as you would with any scanned invoice today. Or you can parse the embedded XML directly, pulling structured fields without relying on OCR at all. The XML path is faster and more reliable because the data is already categorized into defined fields rather than requiring interpretation from a visual layout.
Factur-X is a joint French-German standard. In Germany, the same format goes by the name ZUGFeRD. It defines multiple conformance profiles (Minimum, Basic WL, Basic, EN 16931, and Extended) that control how much detail the XML layer contains. A Minimum profile carries only essential identifiers, while EN 16931 and Extended profiles include full line-item detail, tax breakdowns, and payment terms. The profile your French supplier uses will determine how much data you can extract automatically from the XML.
UBL and CII: Pure XML Formats
The other two accepted formats under the mandate are UBL (Universal Business Language) and CII (Cross Industry Invoice). Unlike Factur-X, both are pure XML with no PDF visual component.
UBL is the more widely adopted standard internationally. It underpins the Peppol network and is already mandatory in several countries for business-to-government invoicing. If your organization transacts across European borders, you may already have some exposure to UBL.
CII is maintained by UN/CEFACT and serves as the underlying XML schema that Factur-X itself builds upon. It is less common in day-to-day cross-border commerce than UBL but is fully recognized under the French mandate.
When a French supplier sends a UBL or CII invoice, your team receives a raw XML file. There is no visual PDF to open and read. Processing these invoices requires software capable of parsing the XML structure, mapping fields to your accounting system, and rendering the data into a readable format for review.
Format Comparison
| Format | Structure | Visual Component | Key Characteristic |
|---|---|---|---|
| Factur-X | PDF + embedded XML | Yes | Human-readable and machine-readable in one file |
| UBL | Pure XML | No | Widely adopted internationally, used in Peppol |
| CII | Pure XML | No | UN/CEFACT standard, basis for Factur-X XML layer |
What This Means for Data Extraction
Regardless of which format arrives, the underlying invoice data is structured. This is a significant shift from traditional invoice processing, where AP teams rely on OCR to interpret scanned PDFs or paper documents, with all the error rates and manual correction that entails.
Factur-X invoices offer the most flexibility: your existing PDF-based workflows continue to function, while the embedded XML opens a parallel path for automated extraction. UBL and CII invoices require XML processing capabilities, but the data arrives pre-structured and validated against EN 16931, which means fewer extraction errors and less manual cleanup.
For organizations that handle different types of invoices in business across multiple countries and suppliers, this move toward structured data represents a measurable improvement in extraction reliability, even if it requires updating your intake processes.
The Platform Landscape: PPF and Approved Platforms
France's e-invoicing system routes invoices through a structured network of platforms rather than directly between businesses. Understanding this infrastructure is essential for knowing how French e-invoices will actually reach your organization.
Two types of platforms form the backbone of the system:
Portail Public de Facturation (PPF) is the state-operated public invoicing platform, built as the successor to Chorus Pro. Any business operating in France can use the PPF to send and receive e-invoices at no cost. Beyond its role as an exchange platform, the PPF functions as the central directory: businesses register on it to declare their chosen platform and specify how they want to receive invoices.
Plateforme Agréée (PA) refers to approved private platforms certified by the French tax authority to handle e-invoice exchange. These were previously known as Plateforme de Dématérialisation Partenaire, or PDP, before the terminology was updated in 2025. If you encounter references to "PDP" in older documentation or competitor guides, it refers to the same concept. As of early 2026, over 100 platforms have received approval. These range from major ERP providers (SAP, Sage, Cegid) that have embedded e-invoicing into their existing platforms, to specialized invoicing services built specifically for the French market.
How Invoice Routing Works
When a French supplier issues an e-invoice, it passes through their chosen platform, whether that is the PPF or a PA. That platform then routes the invoice to the recipient's registered platform. The routing logic is straightforward: the PPF directory stores each business's platform preference, and invoices are delivered accordingly. If a recipient has not registered a platform preference, invoices default to delivery through the PPF.
What This Means for Non-French Businesses
For businesses outside France with no French tax presence, the platform system does not impose a registration requirement. You are not obligated to create an account on the PPF or subscribe to a PA. Your French suppliers will issue e-invoices through the French platform infrastructure on their end, but the invoice will reach you through whatever delivery channel the supplier or their platform supports. In practice, this often means receiving a Factur-X PDF via email, or receiving the invoice through PA-to-PA interoperability if your existing invoicing platform connects to the French network. The exact delivery mechanism varies by supplier and by the platform they have chosen.
However, non-French businesses that hold a French VAT registration occupy a different position. If your company is VAT-registered in France, registering on the PPF or selecting a PA is advisable to ensure invoices route to you correctly within the French system. Your platform choice directly affects how invoices are delivered to you and determines your ability to fulfill any e-reporting obligations tied to your French VAT activity.
Penalties for Non-Compliance
France's e-invoicing mandate carries specific financial penalties that take effect from the compliance dates outlined in the phased rollout. Understanding these figures is essential for assessing risk and building a business case for preparation.
The primary penalty for failing to issue a compliant e-invoice is EUR 50 per invoice. This applies to each individual invoice that should have been transmitted as a structured e-invoice but was sent in a non-compliant format or not transmitted through the required platform infrastructure. For businesses processing high invoice volumes, this adds up quickly. The penalty is capped at EUR 15,000 per year per business, which limits maximum exposure but still represents a significant annual cost, particularly for mid-size companies handling thousands of invoices monthly.
A separate penalty structure applies to e-reporting failures. Businesses that fail to transmit required transaction data face a penalty of EUR 250 per transmission, also capped at EUR 15,000 per year. This is particularly relevant for non-French businesses that hold a French VAT registration and therefore carry e-reporting obligations under the mandate.
For non-French businesses without a French tax presence, the direct penalty risk is limited. The EUR 50 per-invoice penalty applies to the issuing obligation, not the receiving obligation. Since non-French businesses without French establishment have no mandate to issue e-invoices through the French system, they are not subject to these fines. However, the penalty structure has a practical downstream effect: French suppliers face real financial consequences for non-compliance, which creates strong incentive for them to adopt structured e-invoicing on schedule. This means non-French businesses should expect to start receiving Factur-X, UBL, and CII invoices from their French trading partners as each phase takes effect.
There is no announced grace period. The penalties apply from the compliance dates in the phased timeline, and businesses should not assume informal leniency during the initial rollout. France's tax authority (DGFiP) has given several years of advance notice, and the expectation is that businesses will be ready when their phase arrives.
For non-French businesses evaluating where to invest, the calculus extends beyond direct penalty exposure. The more practical concern is operational: if your AP team cannot process incoming structured e-invoices, the result is delays in invoice processing, reconciliation errors, and missed payment terms with French suppliers. These operational costs can exceed any regulatory fine.
Preparing Your AP Process for French E-Invoices
Starting September 2026, your accounts payable team will begin receiving invoices from French suppliers in structured electronic formats: Factur-X, UBL, and CII. If your current workflow relies on manual data entry or basic OCR scanning of PDF invoices, these new formats will introduce friction unless you prepare in advance. The window between now and the first compliance deadline is the right time to assess your readiness and close any gaps.
A Practical Preparation Checklist
1. Audit your French supplier base. Identify every supplier established in France that sends you invoices. Categorize them by company size, because the mandate rolls out in phases: large enterprises begin issuing structured e-invoices from September 2026, mid-size companies from September 2027, and small businesses from September 2028. This gives you a clear picture of when each supplier's invoices will change format and how quickly your incoming volume of e-invoices will grow.
2. Assess your current invoice processing workflow. Determine whether your existing tools can ingest Factur-X (a hybrid PDF with embedded XML), UBL (pure XML), and CII (pure XML). Many AP systems built around scanning paper invoices or reading standard PDFs have no mechanism for parsing structured XML data. If your process depends on someone manually keying in line items from a PDF, that workflow will still function for Factur-X files (which retain a readable PDF layer), but you will be ignoring the machine-readable data that makes these invoices valuable.
3. Evaluate your data extraction capabilities. Factur-X invoices offer two extraction paths: you can parse the embedded XML for structured fields, or you can extract data from the visual PDF layer. UBL and CII invoices require XML parsing, as there is no PDF component. Whichever path you choose, your extraction tools must handle French-language invoices reliably. That means recognizing field labels like Numéro de facture, Date d'échéance, Montant TTC, and TVA, along with French VAT structures that include multiple TVA rates and intra-community supply rules.
4. If you hold a French VAT registration, register on a platform. Businesses with a French tax presence need to register on the Portail Public de Facturation or select an approved Plateforme Agréée before the September 2026 deadline. Confirm that your SIREN number is correctly linked and that your platform preferences are configured for both sending and receiving.
5. Test with sample invoices before the mandate takes effect. Contact your largest French suppliers and request sample e-invoices in Factur-X, UBL, or CII format. Run these through your AP workflow end to end. Identify where data gets lost, where manual intervention is required, and where formatting assumptions break down. Finding these issues in a test environment is far less costly than discovering them when real invoices are arriving at volume.
The Data Extraction Challenge at Scale
Even though Factur-X invoices look like ordinary PDFs when opened in a viewer, extracting data from them reliably at volume is a different problem. Your French supplier base may include dozens of companies, each sending invoices through different platforms, using different Factur-X conformance profiles, and structuring their line items in varying ways. When those invoices carry French field labels, multiple TVA rates per document, and formatting conventions that differ from what your AP team is accustomed to, basic extraction tools start producing errors that require manual correction.
This is where purpose-built financial document processing becomes a practical requirement rather than a convenience. A platform that can extract structured data from French supplier invoices across thousands of documents, handling French-language fields and varied formatting without manual intervention, removes the bottleneck that would otherwise slow your AP cycle as e-invoice volume increases. Invoice Data Extraction, for example, processes PDF invoices in any language and handles large batches, outputting structured data ready for direct import into accounting systems.
The multi-language dimension deserves specific attention. AP teams based outside France will receive invoices where every label, every tax description, and every payment term is written in French. Your extraction tooling needs to handle this natively, without requiring someone to translate field names before processing. For organizations already dealing with suppliers across multiple countries, the capabilities needed here overlap significantly with processing multi-language and multi-currency invoices more broadly.
Building for What Comes Next
The France mandate is not an isolated regulatory event. Germany already requires XRechnung for public sector invoicing and is expanding to B2B. Italy's FatturaPA system has been mandatory since 2019. The EU's VAT in the Digital Age (ViDA) directive will push structured e-invoicing across all member states in the coming years. Each new mandate will introduce its own format requirements, platform registrations, and compliance deadlines.
Businesses that build the right AP infrastructure now, with extraction tools that handle multiple structured formats, multiple languages, and high document volumes, will absorb each subsequent mandate as a configuration change rather than a crisis. The investment you make to prepare for French e-invoices pays forward into every European market where your suppliers operate.
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