Mandatory B2B E-invoicing in France
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Introduction to e-Invoicing in France
France is launching a major reform to modernize its invoicing system. This mandate will replace traditional paper and PDF invoices with a mandatory digital process for all companies subject to French VAT.
The primary goals of the French government (DGFIP) are to:
- Combat VAT fraud and improve tax compliance.
- Reduce administrative burdens for businesses.
- Gain real-time insight into the national economy.
This reform introduces new obligations for e-invoicing and e-reporting, which function under a specific new transmission model.
This is the obligation to issue and receive structured electronic invoices for all domestic B2B transactions in scope of the reform.
- It applies only to transactions between two French-based companies.
- Simple PDF invoices sent via email will no longer be compliant.
This is the obligation to digitally report data from transactions that are not covered by e-invoicing, as well as payment data in certain cases.
- This includes B2C transactions (sales to individuals).
- It also applies to all international B2B transactions (sales and purchases).
This is the mandatory data transmission framework. Companies can no longer send invoices directly to each other. All e-invoices and e-reports must be exchanged through a Certified Platform (Plateforme Agréée) that can exchange data with the PPF.
- PPF (Portail Public de Facturation): The Public Invoicing Portal, which administers the central directory, concentrates invoicing, transaction, and payment data as well as information relating to invoice processing statuses (life cycle) and transmits this data to the tax administration in France.
- Certified Platform (Plateforme Agréée): A service provider, like Comarch, offering invoice dematerialization services, certified by the French administration. Only PAs are authorized to transmit electronic invoices directly to recipients and to send data to the Public Invoicing Portal (PPF). They exchange invoice data, e-reporting, statuses, and directory information with other PAs, with the seller or the buyer (depending on their role), and with the PPF.
E-invoicing in France: The Official Implementation Timeline
2026End of February, 2026:
- Pilot Phase: Certified Platforms (PAs) and their customers can test live, on the production environment, with production data, e-invoicing, and e-reporting flows.
September 1, 2026*:
- Receiving Mandate: All companies, regardless of size, must be able to receive e-invoices.
- Issuing Mandate: Large (GE) and intermediate-sized enterprises (ETI) must issue e-invoices and e-reports.
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2027
September 1, 2027*:
- Issuing Mandate: The obligation to issue e-invoices and e-reports extends to small & medium-sized enterprises (PME) as well as micro enterprises.
Company Size Classifications
- Large Enterprises (GE): Companies with more than 5,000 employees, or those with an annual turnover exceeding €1.5 billion and a balance sheet total exceeding €2 billion.
- Intermediate-sized Enterprises (ETI): Companies that do not qualify as PMEs and have between 250 and 5,000 employees, with an annual turnover of less than €1.5 billion or a balance sheet total of less than €2 billion.
- Small and Medium-Sized Enterprises (PME): Companies with between 10 and 249 employees and an annual turnover not exceeding €50 million or a balance sheet total not exceeding €43 million.
- Micro-Businesses: Companies with fewer than 10 employees and an annual turnover or balance sheet total of less than €2 million.
E-Invoicing and E-Reporting Processes
- B2B E-Invoicing Process Description
1. Issuance: The seller creates an invoice in their ERP and sends it to their chosen Certified Platform, such as Comarch.
2. Transmission & Validation: The seller's Certified Platform (Plateforme Agréée) validates the invoice, converts it to one of the mandatory formats (UBL 2.1, CII, Factur-X), and:
- Sends the invoice to the buyer's Certified Platform.
- Extracts mandatory data, creates Flow 1, and sends it to the Public Invoicing Portal (PPF).
3. Reception: The buyer's Certified Platform receives the invoice and delivers it to the buyer for processing, often directly into their AP system.
4. Certified Platforms also manage lifecycle messages (statuses).
- Some statuses are generated by the Certified Platforms.
- Some are generated by the seller or the buyer (and transmitted by the Certified Platforms).
- Certain statuses must be sent to the PPF by the Certified Platform.
- E-Reporting Process Description
For B2C and international transactions, the process involves periodic data reporting to the authorities.
1. Data Extraction: The reporter aggregates all required data from B2C (e.g., end-of-day sales) and international B2B transactions and sends it to its Certified Platform.
- Certified Platforms, like Comarch, can offer a service where the data extraction is done by the Platform based on invoices sent by the reporter.
2. Report Generation: The reporter’s Certified Platform validates the e-report received from the reporter and, when applicable, aggregates the data and generates an e-report.
3. Submission: The Certified Platform transmits this e-report directly to the PPF (which then sends it to the tax administration) according to the mandated schedule (depending on the VAT regime applicable to the reporter).
A similar process exists for payment data e-reporting. Payment data needs to be reported for transactions for which tax is due upon collection.
Comarch: Your Certified Platform for French E-Invoicing
Comarch SA is officially certified as a Plateforme Agréée (Certified Platform) by the French tax authority.
This official status confirms that Comarch is a trusted partner, fully authorized to operate as a Certified Platform (Plateforme Agréée) for the 2026 mandate.
