France is the only regime in Europe where you cannot transmit a business invoice at all without first contracting a state-accredited intermediary. There is no government channel to fall back on, no manual route, and no exception. It has been live since September 2026.
Every French VAT-taxable person has had to be able to receive electronic invoices since 1 September 2026. That is not phased by size — it landed on everyone at once, and it requires a contracted platform.
The sanctions grace period expires on 31 December 2026. It covers companies in genuine difficulty, and it is the only thing standing between a non-compliant French entity and a per-invoice penalty.
In Germany you can e-invoice from an email inbox. In France you cannot invoice at all until you have signed a contract with a company the tax authority has approved. That single difference is worth more planning time than every format question combined.
A plateforme agréée is immatriculated by DGFiP against fiscal, IT and security criteria including ISO 27001 or SecNumCloud certification, two-factor authentication and EU data residency. Accreditation runs three years and is renewable.
A group operating its own in-house platform must itself be immatriculated. You do not get to self-serve because you are large or technical — you get to go through the same accreditation, against the same security criteria, on the same three-year cycle.
For almost every group the answer is to contract an accredited provider. The question worth asking is not whether to use one but how quickly you can get through their onboarding, because DGFiP publishes no lead time and the providers are all onboarding at once.
Three obligations, two of which arrive together and one of which is widely overlooked.
| Obligation | Who | From | Format |
|---|---|---|---|
| Receiving | Every French VAT-taxable person. No size phase-in. | 1 September 2026 | Through a plateforme agréée, routed via the annuaire |
| Issuing | Grandes entreprises and ETI first; PME, TPE and micro a year later | 1 September 2026, then 1 September 2027 | UBL, CII or Factur-X |
| E-reporting | Grandes entreprises and ETI | 1 September 2026 | Transaction and payment data for flows outside domestic B2B |
E-reporting is the one groups miss. It is not invoicing — it is reporting transaction and payment data for everything that falls outside domestic B2B, which for an international group is a large share of its French activity. A project scoped only around invoices will not have covered it.
Company size for the phase-in was fixed as at 1 January 2025, on the last closed financial year. It is not reassessed.
So a company that has grown past a threshold since then does not move into an earlier wave, and one that has shrunk does not get a later one. If you have been working from current headcount or current turnover, check the figure that actually applies — it is nearly two years old.
France originally planned a free government portal that would transmit invoices. That is no longer what it does.
The Portail Public de Facturation is now the directory — the annuaire that resolves routing between platforms. It does not transmit your B2B invoices. Chorus Pro remains for B2G only.
Anyone whose French plan still includes "use the free government portal" is working from guidance that has been overtaken. That assumption is the single most common one I see, and it has no fallback once discovered.
Two separate penalty regimes, for two separate failures.
A sanctions grace period runs for the remainder of 2026 for companies in genuine difficulty. It expires on 31 December 2026.
Read that as a deadline rather than a concession. A French entity that is not connected by the new year is exposed from the first invoice of 2027, and the reception penalty compounds every three months until it is fixed.
The e-reporting penalty could not be read from Légifrance and is deliberately not stated here.
In order. The first item blocks everything else.
Every row was checked against DGFiP's own guides and fiches on 4 October 2026. The e-reporting penalty could not be confirmed from a primary source and is not stated.
Every row behind this guide sits in the obligation tracker. See also the France reference page, and the German guide for the opposite extreme — a regime with no platform and no accreditation at all.
Take it into the meeting. The same guide as a Word document you can edit, circulate or paste into a board pack.
Download the Word versionIf you are sequencing a European e-invoicing rollout, the order matters — some regimes take weeks to connect to and some take minutes. The scoping tool shows you which is which across your whole footprint.