The French text is the legally binding one. This page is a working guide for a reader who does not read French; it is not a substitute for the instruments themselves, and wherever a decision turns on wording, the French wording governs.
What exactly took effect on 1 September 2026?
| Date | Obligation | Who |
|---|---|---|
| 1 September 2026 | Reception | Every business that is a taxable person for French VAT, whatever its size |
| 1 September 2026 | Issuing + e-reporting | Grandes entreprises (GE) and entreprises de taille intermédiaire (ETI, mid-caps) |
| 1 September 2027 | Issuing + e-reporting | PME, TPE and micro-entreprises |
Two misreadings circulate constantly in English-language material and are worth killing immediately.
The first presents September 2026 as a reception-only milestone. That is wrong. For GE and ETI, issuing and e-reporting started the same day.
The second calls 2027 "the SME wave", as though smaller businesses had a later step of their own. The administration groups small and medium-sized enterprises together with micro-enterprises: there is no separate, later milestone for the smallest, and the 2027 date covers e-reporting as well as issuing. E-reporting never begins at reception.
Which entity in a group structure is actually caught?
This is the first question a group finance function outside France gets wrong, and the answer is unusually mechanical.
The unit assessed is the unité légale, identified by its SIREN number — the French legal entity, not the group, not a consolidated set, not your EMEA reporting unit. Size is assessed at 1 January 2025, on the last financial year closed before that date. That reference date is frozen: it did not move with the timetable, so an entity that crossed a threshold in 2025 or 2026 still belongs to the category determined at 1 January 2025.
The thresholds are those of décret n° 2008-1354:
- Micro-entreprise — fewer than 10 employees, and turnover ≤ €2m or balance sheet total ≤ €2m
- PME — fewer than 250 employees, and turnover ≤ €50m or balance sheet total ≤ €43m
- ETI — fewer than 5,000 employees, and turnover ≤ €1,500m or balance sheet total ≤ €2,000m
- GE — everything above the ETI thresholds
Three consequences follow for a multinational, and none of them is obvious from the English-language commentary.
A large group can hold French entities in both waves. Because each SIREN is assessed separately, a group with three French legal units may find one in the September 2026 issuing obligation and two in the 2027 one. Plan per SIREN, not per country.
Nothing that happened after 1 January 2025 changes the answer. An acquisition, a reorganisation, a carve-out or a growth year does not move an entity between waves. Determine the category once, record the evidence — the accounts used and the closing date — and treat the result as static configuration rather than a rule that recalculates. A system that queries current headcount or current turnover will be wrong at exactly the category boundaries where being wrong costs money.
Reception is universal. Whatever category your French entity falls into, it has had to be able to receive since 1 September 2026. A dormant French subsidiary that issues nothing at all is still caught by the reception limb.
Why is "PDP" the wrong word now?
Décret n° 2026-677 and the arrêté of 27 July 2026, published in the Journal officiel of 28 July 2026, replaced the designation opérateur de plateforme de dématérialisation partenaire (PDP) with plateforme agréée (PA). The tax administration switched vocabulary with them, including in the titles of its own pages.
For anyone producing documentation, contracts or sales material this is not cosmetic. Using PDP as a live term dates a document to before the summer of 2026 and signals it has not been reviewed since. If your audience needs the bridge, write "plateforme agréée (formerly PDP)" once, then use the current term throughout. Vendors selling into France in English should audit their own product pages and RFP responses on this point: as at 3 September 2026, most still say PDP. Our running list of terminology and factual corrections is at corrections, and the definitions sit in the glossary.
Keep the PA distinct from the opérateur de dématérialisation (OD), a service provider that is not registered and cannot transmit to the administration on its own. An OD has to sit behind a plateforme agréée. In vendor conversations, "we are a dematerialisation operator" and "we are an approved platform" are materially different answers.
What happened to the free public portal?
This is the structural change that English-language coverage has integrated least well. Article 123 of the loi de finances pour 2026 definitively settled the abandonment of the free public issuing and receiving portal. The portail public de facturation (PPF) retains two functions, and two only:
- the central annuaire, the directory of invoice recipients — CGI, art. 289 bis;
- the concentrateur, the dedicated facility for collecting data and statuses — CGI, art. 242 nonies G.
So every B2B flow passes through a plateforme agréée, and there is no free public option for issuing. For a foreign parent that expected a state-operated channel — the assumption a reader coming from Italy's or Poland's model naturally brings — this means a procurement exercise, a contract, a budget line and a vendor risk assessment, for each French entity, before anything can be issued. Chorus Pro remains the public-sector (B2G) platform and is unaffected by this change.
More than 140 platforms are registered. The number moves week to week, so consult the official list rather than any fixed count. Two cautions when choosing:
- The official list distinguishes operators meeting all conditions, interoperability tests included, from those whose file is complete but whose definitive registration remains conditional on passing those tests — registration sous réserve, subject to conditions.
- The number of platforms genuinely offering issuing on 1 September 2026 was materially lower than the registration count, because a share of operators position themselves on infrastructure or white-label supply. Verify that your provider covers the use case you actually need, and not only reception.
The annuaire itself has been live since June 2025, with a lookup service open since September 2025. It carries the platform responsible for routing and the electronic invoicing address to use; it is populated by the plateformes agréées and maintained by the State. More than a million businesses had registered a receiving address by May 2026. If your French entity is not in it, invoices addressed to you have nowhere to go.
How do cross-border and intragroup invoices work?
Here is the distinction that decides most of a multinational's design work, and the French articles treat it as obvious because for a domestic filer it is.
E-reporting — formally, the transmission of transaction data — follows the issuing dates, not the reception dates: GE and ETI since 1 September 2026, PME, TPE and micro-entreprises from 1 September 2027. It covers:
- operations with a non-taxable person (B2C);
- international operations: with a taxable person not established in France, exports, intra-Community supplies and transfers;
- payment data for supplies of services.
Excluded are: imports of goods, VAT-exempt activities such as health and training, operations under the OSS and IOSS one-stop shops, and operations classified for defence purposes.
The practical reading for a group: an invoice from your French entity to a German, British or US group company is not inside the domestic e-invoicing mandate at all. It is an e-reporting transaction — a data feed to the administration, not a document routed through the annuaire to a counterparty platform. Teams that model every intragroup flow as an e-invoice build a channel they do not need and miss the reporting obligation they do.
E-reporting frequency depends on the VAT regime, and the rhythm surprises groups used to monthly filing: under the régime réel normal with monthly VAT, transmission is per decade, within ten days — three filings a month. With the quarterly option it is monthly, before the 10th; under the simplified regime, monthly, between the 25th and the 30th of the following month; under franchise en base, bimonthly, between the 25th and the 30th after the period ends.
What are the penalties, and is there a grace period?
The fines, raised by the loi de finances pour 2026, have applied since 1 September 2026.
| Failure | Amount | Annual cap | Basis |
|---|---|---|---|
| Failure to issue in electronic form | €50 per invoice | €15,000 | CGI, art. 1737 |
| Failure to transmit (e-reporting) | €500 per transmission | €15,000 | CGI, art. 1788 D |
| Failure to use a plateforme agréée | €500 after a three-month formal notice, then €1,000 every three months until regularised | — | — |
A first-offence relief applies: no penalty for a first offence committed during the current calendar year and the three preceding years, provided it is put right spontaneously or within thirty days of a first request from the administration. That is one protection on a rolling four-year window, and it is spent the first time it is used.
Keep these amounts separate from the pre-existing penalty of €15 per omission or inaccuracy in the mandatory particulars of an invoice, capped at 25% of the invoice value. The two regimes do not merge.
The tolérance de démarrage is not a postponement
The DGFiP has been explicit: the tolérance de démarrage, the start-up tolerance, is "neither a postponement nor a suspension of the obligation". During the start-up phase, penalties are not applied "immediately, automatically and blindly" to businesses able to demonstrate good faith and corrective measures already under way. The directorate summarised the objective as adherence to the reform rather than penalties and fines.
The practical consequence is sharp, and it is the opposite of how a deferral would work. What protects you is not the calendar; it is your ability to document good faith and a remediation path. An empty file at the moment of a check attracts no tolerance whatever. For a group whose French entity is behind, the useful artefact is a dated remediation plan with owners, a platform contract in progress and evidence of testing — not a note saying enforcement is expected to be light.
Is 1 September 2027 a settled date?
It should not be planned as one, and this is the point on which we differ most from confident English-language timelines.
Every previous slippage in this reform arrived through a loi de finances. The projet de loi de finances pour 2027 had not been tabled as at 3 September 2026. No measure has been announced concerning the 2027 deadline — but that is the window in which one would appear, and it is the window to watch. If you are building a deployment plan on that date, put an explicit checkpoint after PLF 2027 is published, and do the work that is already obligatory or contractually slow before then. A plan that assumes a deferral is a plan with no fallback.
Where does France sit in the EU picture?
Useful context for a group running several EU mandates, and absent from most domestic French coverage because a domestic filer does not need it.
France's mandate originally rested on a derogation. Council Implementing Decision (EU) 2022/133 of 25 January 2022 authorised France to introduce a special measure derogating from Articles 218 and 232 of Directive 2006/112/EC — the provisions that otherwise let a recipient decline an electronic invoice. That legal route has since been overtaken: the VAT in the Digital Age package, Council Directive (EU) 2025/516 of 11 March 2025, entered into force on 14 April 2025, and from that date Member States can introduce mandatory e-invoicing under specified conditions without a derogation.
Two later EU dates belong on a group roadmap alongside the French ones. Digital reporting requirements for cross-border B2B transactions apply from 1 July 2030. Member States operating a domestic real-time transaction reporting obligation must align their systems with the EU model and standards by 1 January 2035. France's design is therefore a national build inside a frame that is still moving, which argues for treating the plateforme agréée as a replaceable channel rather than as your system of record.
What does a foreign group finance function do differently?
- Inventory the French SIRENs and fix each entity's category once, against 1 January 2025, with the evidence attached.
- Prove reception works with a live test invoice from a supplier already in production — not a vendor assurance.
- Check the annuaire entry for every French SIREN, including dormant entities.
- Contract a plateforme agréée per entity, confirming it covers issuing and e-reporting and checking whether its registration is sous réserve.
- Route intragroup cross-border flows to e-reporting, not to the e-invoicing channel.
- Derive the e-reporting calendar from each entity's VAT regime, and staff for a per-decade rhythm where it applies.
- Fix the evidence rule before volume arrives — see our note on the audit trail across ERP, plateforme agréée and recipient.
- Update the vocabulary in policies, RFPs and integration documentation, and diarise the PLF 2027 checkpoint.
In practice
Where these flows are automated across systems — ERP, platform API, treasury, reporting — BarzelOps runs governed cross-system workflows with durable state, approval checkpoints and tenant isolation. Tenant isolation is the relevant property for a group operating several French legal units on one automation estate.
Frequently asked questions
Is a French subsidiary of a foreign group caught?
Yes, in its own right. The obligation attaches to the taxable person for French VAT, and the unit assessed is the unité légale identified by its SIREN, not the group. Reception has applied since 1 September 2026 whatever its size; issuing depends on its own category, fixed at 1 January 2025.
Should we still say PDP?
No. Since décret n° 2026-677 and the arrêté of 27 July 2026 the official term is plateforme agréée (PA). English-language coverage still says PDP almost universally, which dates a document immediately.
Can we issue through the free public portal?
No. The PPF keeps only the central annuaire and the concentrateur. Every B2B flow goes through a plateforme agréée; there is no free public issuing option. Chorus Pro remains the B2G platform.
Do invoices to a foreign group company go through the channel?
No. A transaction with a taxable person not established in France is an e-reporting transaction, not an e-invoicing one. E-reporting also covers B2C, exports, intra-Community supplies and transfers, and payment data for services.
What is the difference between rejetée and refusée?
Rejetée is a technical rejection by a platform, typically for format or business-rule non-conformity. Refusée is a commercial refusal by the recipient, admitted on three grounds only, and the administration states it must not be used for an ordinary commercial dispute. See the glossary entry.
Is there a penalty-free period?
Not in the strict sense. The tolérance de démarrage is neither a postponement nor a suspension: penalties have applied since 1 September 2026, but are not applied automatically to businesses of good faith with a documented remediation path.
In practice
The control has to run before the invoice becomes irreversible.
An accepted structured invoice can be corrected but never deleted, and from the penalty date every defect has a price. Barzel puts the approval threshold, the duplicate check and the signed record in front of submission, so the process can be defended on the day an auditor or the tax authority asks.
338 days leftPME, TPE and micro-entreprises: issuing and e-reporting from 1 September 2027
BarzelOps
Governed workflow automation across the systems that run the business.
- Durable, idempotent execution: a timeout is retried once, never filed twice.
- Human approval checkpoints that pause the workflow and resume it.
- Isolation per entity or client, signed evidence receipts and a portable manifest; HubSpot, Xero, Gmail, Google Drive and Slack.
Free tier: 100 calls a dayPaid plans from $19 a monthLive on MCPize
BarzelVault
The AI action firewall: decide what an agent may do before it does it.
- Approval thresholds and policy checks enforced before execution; human approvals that expire and escalate.
- Cryptographically signed audit receipts: trigger, inputs, policy version, approver, outcome.
- Credential isolation, spend and action limits, and an emergency kill switch.
Free tier: 10,000 calls a monthPaid plans from $199 a monthLive on MCPize
Enterprise: written quote by email within two business days. No sales call.
Related
- Factur-X, UBL and CII: choosing a format and what each costs you downstream
- Building an audit trail across ERP, plateforme agréée and recipient
- Keeping control when AI agents issue invoices into an irreversible national system
- The 2027 wave: what a smaller French entity of a foreign group needs ready
- AI agent governance: control before execution, evidence after
Sources
- Article 123 de la loi n° 2026-103 du 19 février 2026 de finances pour 2026, Légifrance.
- Décret n° 2026-677 du 27 juillet 2026 and arrêté du 27 juillet 2026, Journal officiel of 28 July 2026.
- impots.gouv.fr, Facturation électronique et plateformes agréées; FAQ Je découvre and J'approfondis, versions of 1 September 2026.
- impots.gouv.fr, Spécifications externes B2B, version 3.2 of 30 April 2026.
- impots.gouv.fr, Liste des plateformes agréées.
- CGI, art. 289 bis (annuaire) and art. 242 nonies G (concentrateur); art. 1737 and art. 1788 D; décret n° 2008-1354 (size thresholds).
- entreprendre.service-public.gouv.fr, news item of 20 February 2026 (penalties).
- Council Implementing Decision (EU) 2022/133 of 25 January 2022 authorising France to derogate from Articles 218 and 232 of Directive 2006/112/EC.
- Council Directive (EU) 2025/516 of 11 March 2025 amending Directive 2006/112/EC as regards VAT rules for the digital age; European Commission, VAT in the Digital Age (ViDA) implementation timeline.
- AFNOR standards XP Z12-012, XP Z12-013 and XP Z12-014, and European standard EN 16931 — paywalled, with no free official full text; not linked.
This article is for information and does not constitute tax or legal advice. The French text is the binding one.