French e-invoicing checklist: what to arrange before 1 September 2026

Businesses in the Netherlands and Belgium that invoice French customers, or that run a French establishment, have just over a week left. This French e-invoicing checklist sets out what has to work on 1 September 2026. From that date, every VAT-registered business established in France must be able to receive e-invoices through a Plateforme Agréée. Roughly ten million VAT-registered economic actors fall under that receiving obligation. The preparation splits into two layers: a system test covering what your software and your platform must technically be able to do, and an administrative test covering the data your Peppol Serviceprovider or Plateforme Agréée will request during onboarding. That second layer rarely gets attention and causes most of the delay in practice.

The distinction matters. The system test covers functionality your supplier delivers. The administrative test covers data only you can supply, often held by finance, legal and IT at once. Starting on that second layer only when the onboarding form arrives costs days.

Why this French e-invoicing checklist matters right now

Since the spring of 2026, the French tax administration DGFiP has been sending waves of emails to VAT-registered businesses in France. The subject line reads: “FACTURATION ÉLECTRONIQUE : Désignation d’une plateforme de réception de factures électroniques”. The message states the company’s SIREN and notes that on the reference date the administration found no receiving platform had been designated. It then points to three routes: through an expert-comptable, bank, management organisation or other trusted intermediary, through a software vendor for invoicing, accounting or collections, or directly with a Plateforme Agréée.

That letter is why the topic became urgent inside many groups. A French subsidiary or branch receives the email, forwards it to head office, and it turns out nobody knows for certain whether the French entity already has a receiving address. That is not unusual: as of 16 January 2026, around 500,000 businesses had registered a receiving address, against a population of roughly ten million actors.

On the supply side the infrastructure is ready. On 16 January 2026 DGFiP published a first list of 101 approved Plateformes Agréées, and that list keeps growing as new applications are approved. The term Plateforme Agréée officially replaced the older designation PDP in February 2026, so documentation still using the old term refers to the same type of platform.

What changes on 1 September 2026, and for whom

Two obligations start on the same date, with different scope.

• Receiving: everyone. Every VAT-registered business established in France must be able to receive e-invoices through a Plateforme Agréée. There is no size threshold and no exemption by turnover.
• Issuing and e-reporting: large enterprises and ETIs. Large enterprises with more than 5,000 employees or turnover of at least 1.5 billion euros, and ETIs with 250 to 4,999 employees or turnover between 50 million and 1.5 billion euros, must also issue e-invoices through a Plateforme Agréée from that same date and begin e-reporting.
• SMEs, micro-enterprises and TPEs: issuing from 1 September 2027. The receiving obligation already applies to this group in 2026.

France uses a decentralised Y-model. There is no central clearing house through which every invoice passes. Businesses choose their own Plateforme Agréée, and the platforms are interconnected through the central annuaire maintained by the PPF. Since 15 October 2024 the PPF no longer transmits invoices for private businesses, but it continues to maintain the annuaire and acts as the fiscal concentrator. In practical terms, the annuaire is the source of truth for who is VAT-registered and which receiving address belongs to which Plateforme Agréée. If you are not correctly listed there, you do not exist for your counterparty.

For background on the French model, our article on the French mandate and what Plateformes Agréées are explains how the system is built. The legal anchoring and the penalty regime were covered in our report on the Finance Bill 2026.

Layer 1: the system test based on the FNFE-MPE go-live checklists

In late July 2026, FNFE-MPE published go-live checklists in three volets. They are written for the French market, but they work well for foreign businesses as an assessment framework for their own software and for their supplier.

Volet A: for every business that must be able to receive

• A rational choice of receiving addresses. FNFE-MPE explicitly recommends working with a single receiving address at SIREN level. A proliferation of addresses is flagged as bad practice.
• Being connected and contracted with a Plateforme Agréée, and correctly registered in the annuaire. Being connected without correct registration achieves nothing.
• Duplicate invoices as the first operational risk. At go-live there is a real chance the same invoice arrives through both the old and the new channel. Your processing must recognise duplicates before they are paid or booked twice.
• Correct use of lifecycle statuses. The status “Refusée” deserves strict definition. Using it loosely, for example to park an open internal question, triggers a credit note and re-invoicing cycle on the sender side that nobody intended.

Volet B: written for the Plateformes Agréées, usable as a supplier test

Volet B addresses the platforms themselves, which is precisely what makes it a good questionnaire for your own supplier.

• Identity verification of the signatory and their signing authority at onboarding. This check may be delegated to a distributor or an authorised third party, for example an accountant holding a mandate.
• A formal signed agreement for receiving, combined with updating the PPF annuaire. The signature and the registration belong together.
• Portability without interruption. If you switch Plateforme Agréée, the old and new platform must cooperate according to the modalities of the Service d’Immatriculation (SIM). Ask how your supplier handles that process before you sign, not afterwards.
• Daily synchronisation of the PPF annuaire with Peppol reference data. This is where the French and the Peppol worlds meet.
• Full support for the socle formats and the AFNOR standard XP Z12-012, plus correct handling of CDAR status messages.

Volet C: issuing and e-reporting

Volet C applies in 2026 to large enterprises and ETIs, and is relevant for SMEs that want to move ahead of 2027.

• Outbound flows compliant with the socle formats: Factur-X, UBL and CII.
• Managing status returns, in particular the BT-34 field for the electronic address. That field determines whether a status message reaches the right party.
• Being prepared for rejections and disputes in the invoice lifecycle, including the internal route a rejection follows.
• Implementing the four e-reporting flows: transaction and payment data for flows outside domestic B2B, meaning B2C and cross-border.

Layer 2: the onboarding request and why each item matters

As soon as you engage a Plateforme Agréée or a Peppol Serviceprovider for a French entity, a data request follows. The questions look administrative, but every item has an operational or fiscal reason. This is the list as it comes back in practice.

1. Legal entity name as registered with the French tax administration. Not the trading name and not the group name, but the name under which the entity is registered for tax. For a foreign company with a French establishment there is a compliance question hidden here: whether an établissement stable exists determines whether the French obligation applies to you at all. This is the same kind of question foreign suppliers faced in Belgium, where businesses without a fixed establishment fell formally outside the obligation but ended up delivering through Peppol anyway. Our review of the first lessons from Belgium after its deadline shows how quickly that practice settles in.
2. SIREN. Nine digits, identifying the company. This number is the key by which the annuaire finds your entity and by which your receiving address is published.
3. SIRET. Fourteen digits, identifying the individual establishment. It only comes into play if you have multiple establishments. Link this explicitly to the Volet A advice to choose a single receiving address at SIREN level. Creating an address per establishment without a business reason produces exactly the proliferation FNFE-MPE warns against, leaving suppliers to guess where to send.
4. French VAT number (TVA intracommunautaire). Required for validation of the entity and for the fiscal logic behind e-reporting.
5. Registered address as held by the French tax administration. Not the visiting address or the postal address of accounts payable. A deviation from the registration causes validation to stall, and that error often surfaces only after the ticket has sat with the supplier for several days.
6. Setup choice: existing environment or separate instance. Do you add the French entity to an existing environment, for example a Belgian account, or set up a separate instance? This choice affects permissions, reporting and invoicing, and is difficult to reverse once document flows are running through it. Treat it as an architecture decision, not as a setting.
7. Access: shared account or separate access per entity. A shared account is quicker to configure but makes traceability and segregation of duties harder. Separate access per entity costs more time up front and saves time during audits and staff changes.
8. Test partner. Is there a supplier or public entity that can send a test invoice to the new address? This is the item that most often comes back as “unknown” and most often delays go-live. Arrange it in advance. Ask an existing supplier to send a single test invoice, so you have seen the chain from sender to posting proposal once in full before it really counts.

The common thread: all eight items must be gathered internally and several require a decision. For a group with a French subsidiary, that means coordination between the French office and central finance or IT. Plan time for it, even if the technical connection takes a day.

How to establish that a DGFiP letter is genuine

The letter about designating a receiving platform is legitimate and is sent in bulk. There is no action embedded in the message itself: no link to click, no password, no payment. DGFiP also includes its own security instructions, which are easy to summarise.

• Never respond to an email asking for your bank card number or a copy of an identity document.
• Never share the login credentials of your professional DGFiP space.
• Always check the sender domain. It must be exactly @dgfip.finances.gouv.fr.

To verify independently, do not go through the email but through the information page “je passe à la facturation électronique” on impots.gouv.fr, or call the information line 0 806 807 807, open Monday to Friday between 8.30 and 18.00. The official list of approved platforms is also on impots.gouv.fr and is the only place where you should check a Plateforme Agréée.

One careful observation belongs with that verification step. The French Ministry of Economy and Finance confirmed that unauthorised access to DGFiP information systems took place in June and July 2026, through compromised credentials belonging to a DGFiP employee and an authorised third party. A malicious actor publicly claimed that access on 12 and 13 August 2026. Data relating to 678,000 private individuals and professionals was viewed and extracted; for businesses this concerned company names and SIREN numbers, and cadastral data was also consulted. Tax accounts on the public portal were not compromised, and taxpayers’ usernames and passwords were not obtained. DGFiP has informed CNIL.

Official statements do not identify the French e-invoicing platform or the network of Plateformes Agréées as the source of this incident. It is therefore explicitly not an e-invoicing breach, and it is not for us to suggest a link that has not been established. The relevance to this checklist is narrow but practical: company name and SIREN are precisely the details a convincing forged letter would contain. That makes domain verification of the exact sender address more important rather than less, regardless of where any data originated.

What if you are not ready in time

On 10 July 2026 DGFiP published the Guide pratique de démarrage. It sets out three principles that have to be read together, because in isolation they lead to the wrong conclusions.

1. The statutory calendar does not move. 1 September 2026 remains 1 September 2026.
2. Economic continuity is preserved. A PDF, email or paper invoice tied to a genuine transaction remains valid, payable and VAT-deductible. Your supply chain does not stop on 1 September.
3. This tolerance is not a disguised exemption. There will be no automatic penalties at the start for businesses with a demonstrable compliance trajectory, but a distinction is drawn between businesses that are demonstrably working on it and businesses that sit still or structurally avoid the obligation.

The practical translation: if you are not fully operational on 1 September but can show a signed agreement, an onboarding process under way and a scheduled test date, you are in a materially different position from a business that has taken no step at all. Document that trajectory. A file containing the contract date, onboarding correspondence and test results is the evidence that will be asked for in any review.

A practical French e-invoicing checklist in twelve points

1. Determine whether your French entity is an établissement stable and therefore whether the obligation applies to you.
2. Check whether a receiving address has already been registered and with which Plateforme Agréée.
3. Choose a single receiving address at SIREN level, unless there is a demonstrable business reason for more.
4. Verify your platform against the official DGFiP list of approved Plateformes Agréées.
5. Formalise the agreement for receiving and have the annuaire updated.
6. Collect in advance: entity name, SIREN (9 digits), SIRET (14 digits) where applicable, French VAT number and the registered address.
7. Make the setup choice deliberately: existing environment or separate instance, including the consequences for permissions and reporting.
8. Decide the access model: shared account or separate access per entity.
9. Appoint a test partner and schedule the test invoice before the deadline.
10. Configure duplicate detection for the period in which old and new channels run in parallel.
11. Agree internally when the status “Refusée” is and is not used.
12. Keep the contract, correspondence and test results as the file documenting your compliance trajectory.

Anyone working through this French e-invoicing checklist usually finds that the technology is the smallest problem and that the administrative request determines the lead time. Start with the eight onboarding data points rather than the software question. And check whether your current supplier genuinely supports the French route: the comparison tool on Peppol.now shows which Peppol Serviceproviders offer connectivity to Plateformes Agréées and which formats they support.

Sources

1. DGFiP, official list of approved Plateformes Agréées
2. DGFiP / impots.gouv.fr, information page “je passe à la facturation électronique” and information line 0 806 807 807
3. DGFiP, Guide pratique de démarrage, 10 July 2026 (PDF)
4. FNFE-MPE, go-live checklists volet A, B and C, late July 2026
5. FNFE-MPE, Check-list Démarrage volet B, 27 July 2026 (PDF)
6. economie.gouv.fr, publication of the first 101 approved Plateformes Agréées, 16 January 2026
7. Ministère de l’Économie et des Finances, information and FAQ on the illegitimate access to DGFiP systems
8. Peppol.now, French mandate 2026: what Plateformes Agréées are
9. Peppol.now, Plateforme Agréée e-invoicing France: Finance Bill 2026 enacted
10. Peppol.now, Belgium e-invoicing 2026: first lessons after the deadline
11. Peppol.now, overview and comparison of Peppol Serviceproviders

Next step

Not sure whether your current solution supports the French route? Compare certified providers on Peppol.now and check per supplier the connectivity to Plateformes Agréées, the supported formats and the onboarding support they offer.