Electronic invoicing and e-Reporting in France

B2B electronic invoicing has been mandatory in France since 1 September 2026, following a phased implementation schedule based on company size. From that date, all businesses within scope must be ready to receive electronic invoices. Large companies and mid-sized enterprises (ETIs) must also issue electronic invoices. Small businesses, microenterprises and SMEs have until 1 September 2027 to comply with the issuing obligation. As a general rule, e-Reporting follows the same implementation schedule.

Since 1 September 2026, all businesses established in France and subject to VAT must be able to receive electronic invoices, regardless of their size. This obligation applies to large companies, mid-sized enterprises (ETIs), SMEs and microenterprises. To receive invoices under the new French model, businesses must use a Plateforme Agréée (PA) to manage the receipt and electronic exchange of their invoices.

A Plateforme Agréée (PA) is a platform accredited by the French administration to manage the exchange of electronic invoices and the transmission of e-Reporting data. These platforms will act as intermediaries between businesses within the French electronic invoicing model, enabling them to issue, receive and route invoices, as well as transmit certain transaction and payment data to the administration. Businesses can choose the PA that best suits their needs, and suppliers and customers do not have to use the same platform.

PA and PDP essentially refer to the same type of platform; the difference is in the name. PDP stood for Plateforme de Dématérialisation Partenaire, the term used during the early stages of the reform. As the regulatory framework evolved, France adopted the name Plateforme Agréée (PA) to identify the accredited platforms involved in electronic invoice exchange and e-Reporting.

PA is therefore the terminology that should now be used, although the term PDP may still appear in earlier documentation on electronic invoicing in France.

The Portail Public de Facturation (PPF) is a central part of the French model's infrastructure, but it will not serve as a public platform for businesses to issue and receive B2B invoices directly. Following the change in the project's scope, its functions focus mainly on two services: the Annuaire, which enables invoices to be routed between businesses and platforms, and the data concentrator, which centralises the regulatory information transmitted by Plateformes Agréées to the DGFiP.

The Annuaire is the central directory for electronic invoicing in France and identifies how an invoice should be routed to its recipient. The directory lists the businesses and public entities included in the system, the Plateforme Agréée associated with each entity and their electronic invoicing addresses. A PA can therefore consult the Annuaire to automatically determine which platform and address an electronic invoice should be sent to. The Annuaire lookup service has been operational since September 2025.

The socle minimum, or minimum set of interoperability formats for electronic invoicing in France, is based primarily on UBL, CII and Factur-X. UBL (Universal Business Language) and CII (Cross Industry Invoice) are structured formats designed for automated data processing. Factur-X is a hybrid format that combines structured information with a visual representation of the invoice in PDF. These formats are based on the European standard EN 16931 and the technical specifications defined for the French reform.

In France, e-Reporting mainly applies to transactions that fall outside the scope of domestic B2B electronic invoicing. These include transactions with consumers or persons not subject to VAT (B2C), and certain B2B transactions with businesses not established in France. The system also covers the transmission of certain payment data, particularly for supplies of services where VAT becomes chargeable on receipt of payment. The data is transmitted to the administration through a Plateforme Agréée.

As a general rule, B2B transactions with a business not established in France do not fall within the same domestic B2B electronic invoicing process that applies between businesses established in France. However, these transactions may be subject to an e-Reporting obligation, under which certain transaction data is transmitted to the French administration. The specific obligation will depend on the nature of the transaction, its VAT treatment and any applicable exemptions. International transactions must therefore be assessed separately from domestic B2B transactions.

The impact will depend mainly on whether the Spanish company is established in France for VAT purposes and on the types of transactions it carries out. A company with an establishment in France that is subject to the reform's obligations may fall within the B2B electronic invoicing system for its domestic transactions. By contrast, a Spanish company without an establishment in France does not automatically become subject to the French obligation to issue and receive electronic invoices simply because it has a French VAT number.

However, a foreign company not established in France may be required to carry out e-Reporting when it performs certain transactions located in France for which it is liable for French VAT. Spanish companies operating in France must therefore assess separately their establishment status for VAT purposes, the type of customer, the location of the transaction and which party is responsible for declaring the tax.