France PDP and the September 2026 Deadline: How the Two-Platform E-Invoicing Model Actually Works
France goes live with mandatory B2B e-invoicing on 1 September 2026. Every business in France must be able to receive structured e-invoices that day, and the largest companies must issue them. The model France chose is unique in Europe: a network of certified private platforms that handle the actual exchange, plus a slimmed-down government portal that maintains the directory and collects reporting data. After several rebrandings and one major scope revision in 2024, the architecture is finally stable. With four months left until go-live, this is what large and mid-sized French businesses, and any foreign seller invoicing into France, need to understand.
The two waves and what each one means
| Date | Who is in scope | Obligation |
|---|---|---|
| 1 Sep 2026 | All VAT-registered businesses in France | Be able to receive structured e-invoices through a PA |
| 1 Sep 2026 | Large enterprises (GE) and mid-sized enterprises (ETI) | Issue all B2B e-invoices through a PA |
| 1 Sep 2026 | All taxpayers | E-reporting (DRR) for B2C, cross-border B2B, and import/export transactions |
| 1 Sep 2027 | Small and medium-sized enterprises (PME) and micro-enterprises (TPE) | Issue all B2B e-invoices through a PA |
The size cut-offs follow the standard French categorization. GE (Grande Entreprise) covers any company with more than 5,000 employees, or above EUR 1.5 billion turnover and EUR 2 billion balance sheet. ETI (Entreprise de Taille Intermédiaire) covers 250 to 4,999 employees and below the GE thresholds. PME covers 10 to 249 employees, and TPE covers fewer than 10. About 4,500 GEs and 6,000 ETIs go live in September 2026; roughly 4 million PMEs and TPEs follow in September 2027.
PDP, PA, PPF: a glossary that keeps changing
The French model has been re-named twice and re-scoped once since 2023. The current state:
- PA (Plateforme Agréée): the “Approved Platform”. A certified private operator that issues, transmits, receives, and validates e-invoices on behalf of taxpayers. PAs sit between buyer and seller, in a four-corner or five-corner Peppol-style exchange topology. PA is the term you should be using in technical specs and contracts. It replaced PDP (Plateforme de Dématérialisation Partenaire) in regulatory documentation.
- PPF (Portail Public de Facturation): the public invoicing portal operated by DGFiP. After the 2024 scope revision, the PPF stopped trying to be a routing platform of last resort. It is now a thin layer with three jobs: maintain the central directory of taxpayers (to look up which PA serves which counterparty), receive lifecycle status events from PAs, and collect e-reporting data.
- DGFiP: the French tax authority, which acts both as the regulator of PAs and as the French Peppol Authority (an arrangement formalized in 2025).
If you remember nothing else: private PA does the routing, public PPF does the directory and the reporting.
The exchange model in five corners
France's exchange architecture is a five-corner Peppol-style network with a directory layer:
- Corner 1: the supplier's accounting or ERP system.
- Corner 2: the supplier's PA, which validates, signs, and routes the invoice.
- Corner 3: the buyer's PA, which receives, validates again, and delivers.
- Corner 4: the buyer's accounting system.
- Corner 5: the PPF, which receives status events (issued, accepted, rejected, paid) and the reporting data.
The supplier and buyer can use the same PA or different PAs. PAs are required to interoperate with each other; you cannot pick a PA whose only customer is your own group. The directory at the PPF maps taxpayer SIREN identifiers to the PA serving them, so the supplier's PA always knows where to deliver.
The first cohort of approved PAs was published in 2024 and 2025; major operators include the platforms run by Tradeshift, Pagero, Basware, Doxis, Sovos, Generix, Edicom, Esker, and several French-domestic providers. As of mid-2026 there are over 80 approved PAs operational.
Formats: Factur-X is the practical default
Three structured formats are mandatory minimums, all conformant with EN 16931:
- Factur-X: a hybrid PDF/A-3 file with embedded XML. The human-readable PDF and the machine-readable XML are the same legal document. France co-developed Factur-X with Germany (where it is known as ZUGFeRD); the format is defined under XP Z12-012 and XP Z12-014, updated by AFNOR and FNFE-MPE in July 2025. Factur-X is the de facto choice for most French B2B invoicing because it preserves a familiar PDF visual.
- UBL 2.1: the Universal Business Language XML, an OASIS standard. Used widely in B2G and Peppol contexts; the right answer for high-volume EDI integrations.
- CII (Cross Industry Invoice): a UN/CEFACT XML standard, structurally similar to UBL. Less common in France but supported.
PAs are required to accept and emit all three. Your ERP only needs to support the format you choose to send; the PA performs format conversion if the recipient's PA prefers a different one.
Two streams: e-invoicing and e-reporting (DRR)
The mandate covers two related but distinct flows:
E-invoicing
Applies to domestic B2B invoices between French VAT-registered businesses. The structured invoice is exchanged through PAs and lifecycle status events flow to the PPF. PDF-by-email between French companies for a domestic B2B sale becomes legally invalid in scope from 1 September 2026 (issuance) and 1 September 2027 (full coverage when SMEs are also issuing).
E-reporting (DRR: Dispositif de Reporting des Données de Transaction)
Applies to transactions not covered by e-invoicing: B2C sales, cross-border B2B (intra-EU and exports), imports, and B2B sales by foreign sellers without a French establishment when the customer is French. Instead of an exchanged structured invoice, the taxpayer reports transaction-level data to the PPF on a defined cadence (typically every 10 days for large taxpayers, monthly for smaller ones). This is France's answer to the data-collection objective without requiring B2C e-invoices.
The 2026 simplifications
After business consultation in mid-2025, the French Ministry of Finance announced ten simplification measures for the 2026-2027 ramp. The most important ones for in-scope taxpayers:
- No e-reporting for non-EU intra-French transactions: certain transactions between French entities that involve a non-EU leg are exempted from DRR.
- B2C summary reporting: you no longer need to report individual transaction counts for B2C; aggregated values are sufficient.
- Nil submissions allowed: explicit zero reporting if you have no transactions in a period, removing ambiguity about whether silence equals compliance.
- Tolerance period: although the legal mandate goes live 1 September 2026, DGFiP has confirmed a tolerance window for reporting omissions in the first quarter, provided the taxpayer demonstrates good faith and reasonable preparation. The 2026 Finance Bill subsequently narrowed the original sanctions tolerance for issuance, so this softer landing applies primarily to e-reporting.
- Pilot continuation: a voluntary pilot program operating since late 2025 allows companies to test the full PA-PPF chain in production-like conditions before the September 2026 cliff.
Foreign sellers: where the obligation does and does not bite
The rules for foreign sellers split neatly along whether a French fixed establishment is involved:
- Foreign seller, no French establishment, B2B French customer (cross-border): outside e-invoicing. The French customer's e-reporting captures the inbound side. The supplier issues whatever invoice format it normally issues, although in practice large French customers will require EN 16931 anyway.
- Foreign seller, no French establishment, B2C French customer: outside e-invoicing. The supplier reports through OSS or IOSS as before; no French-specific reporting layer.
- Foreign seller with French establishment that participates in the supply: inside the mandate. Same obligations as a French-established business, including PA on the issuer side.
- Foreign seller selling to a French government body (B2G): already covered by the existing Chorus Pro mandate (in force since 2017), which continues unchanged.
The fixed-establishment test is the same EU VAT case-law test you see in the Polish KSeF rules: personnel and technical resources, sufficient permanence, and actual involvement in the supply.
What the rollout has felt like in pilot
The pilot phase from late 2025 through the first half of 2026 surfaced a consistent set of issues that companies should plan for:
- Counterparty directory lookups. The PPF directory needs to know which PA serves your customer, but onboarding lag means some smaller customers are not in the directory yet. Pilot participants saw rejection rates spike when sending to companies that had not yet picked a PA. Plan to verify counterparty PA registration before September.
- Format conversion edge cases. A Factur-X invoice routed through a PA that converts to UBL for a recipient whose PA only accepts UBL can lose certain optional fields (free-text payment terms, attachments) if the PAs handle conversion conservatively. Test critical fields end to end.
- Credit notes and corrections. The lifecycle event model treats a corrective invoice as a separate document with explicit reference to the original. Legacy systems that issue a replacement invoice with the same number need a flow change.
- SIREN versus SIRET addressing. The directory uses SIREN (entity level) identifiers, but invoices often need SIRET (establishment level). Map this in your customer master before September.
- Authentication and certificates. Most PAs require a qualified electronic seal at integration setup. Provisioning takes weeks; do not start in August for a 1 September go-live.
How France intersects with ViDA and Peppol
France is one of three or four EU member states (alongside Italy, Poland, and Belgium) running a fully-built domestic e-invoicing mandate by the time ViDA's cross-border B2B mandate kicks in on 1 July 2030. The French architecture is designed to be ViDA-compatible from day one:
- EN 16931 is the underlying standard for both French and ViDA invoices.
- DGFiP became the French Peppol Authority in 2025, signalling commitment to the broader European delivery network.
- PAs are required to interoperate with Peppol access points, which makes cross-border invoicing through a French PA practical.
- By 1 January 2035 (the ViDA hard alignment date), French formats and the PPF directory must accept EN 16931 inbound from any EU member state.
Action checklist for the four months left
- Pick your PA. If you have not contracted with a Plateforme Agréée by May or June 2026, you are late. Onboarding, certificate issuance, format testing, and counterparty directory verification take 8 to 12 weeks for a clean implementation.
- Map your invoice volume by category. Domestic B2B (in scope), B2C (e-reporting), cross-border B2B (e-reporting on French side), B2G (Chorus Pro continues). Each gets a different flow.
- Decide your format. Most French businesses default to Factur-X for human readability. UBL is preferable for high-volume EDI. CII is rare outside specific industries.
- Set up SIREN-to-PA directory verification as a pre-flight check in your invoicing pipeline. Bouncing invoices for unknown PAs in production is preventable.
- Build a credit-note flow that references the original invoice's identifier, not just your internal number.
- Plan for e-reporting cadence. Large taxpayers report every 10 days; smaller ones monthly. This is a calendar discipline, not just a system change.
- Train AP. From 1 September 2026, every domestic B2B invoice your French entity receives arrives through a PA. Email PDFs become a courtesy, not a legal document.
Frequently asked questions
When does France's e-invoicing mandate take effect?
1 September 2026 for receiving (everyone) and issuing (large and mid-sized companies). 1 September 2027 for issuing by SMEs and micro-enterprises.
What is the difference between PDP, PA, and PPF?
PA (Plateforme Agréée) is the new name for what was called PDP. It is a certified private platform that handles invoice exchange. PPF (Portail Public de Facturation) is the government portal that maintains the central directory and collects reporting data.
What e-invoice formats does France accept?
Factur-X (hybrid PDF with embedded XML), UBL 2.1, and CII, all EN 16931 compliant. PAs are required to support all three.
Do foreign sellers without a French establishment have to use a PA?
No. Cross-border B2B invoices to French customers are outside the e-invoicing mandate; the French customer captures them via e-reporting. Sellers with a French fixed establishment that participates in the supply are inside the mandate.
What is e-reporting (DRR) and when does it apply?
DRR captures transactions outside e-invoicing scope: B2C sales, cross-border B2B, imports, and exports. Taxpayers report transaction data to the PPF on a 10-day or monthly cadence depending on size. It goes live alongside e-invoicing on 1 September 2026.
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