1. Timeline and Strategic Shifts in the French E-Invoicing Rollout
France’s journey toward mandatory e-Invoicing is progressing steadily, despite a recent National Assembly vote on April 11, 2025, that rejected a proposed amendment to delay the 1st September 2026 deadline. This rejection signals the French government’s unwavering commitment to the timely implementation of e-Invoicing and e-Reporting systems.
As of now, significant operational steps are underway, with 87 Partner Dematerialization Platforms (PDP) already registered to facilitate the transmission and exchange of e-Invoices. However, the timeline is far from smooth sailing, and some of the most crucial challenges are still ahead. The e-Invoicing system’s full rollout will require businesses to adapt to new regulations, technological tools, and testing protocols, all while navigating the potential for delays and issues within the infrastructure.
The roadmap is as follows:
- 2025: Testing Phase and Directory Pilot
Starting in February 2025, a pilot phase will allow selected PDPs to begin testing the Directory functionality, which will later serve as the primary data hub for all French businesses. This testing phase will extend until April 2025 when all PDPs may join the pilot. During this time, the Directory will be open to businesses for connectivity testing.
- October 2025: Interoperability Testing
A critical milestone will be reached in October 2025, when businesses, in cooperation with their chosen PDPs, will begin rigorous testing to ensure the interoperability of the system. The ability to exchange e-invoices across different platforms will be tested intensively in this phase. The results from this testing will determine whether the system is ready for the official launch or whether adjustments need to be made to avoid any delays.
- February 2026: Full Functionality Testing
By February 2026, businesses and their PDPs will be required to conduct full-scale testing with a sandbox environment to simulate real-world e-invoice exchanges. This testing will confirm the robustness of the platform and ensure the system’s readiness for the full launch in September 2026.
- September 2026: The First Phase Launch
The first phase of the e-invoicing rollout is scheduled for September 2026. During this phase, large and medium-sized businesses, defined as those with over 250 employees or annual turnovers exceeding €50 million or balance sheets of €43 million, will be required to accept e-invoices. There is an option to extend this deadline until December 2026 to accommodate any final delays or technical challenges.
- September 2027: The Second Wave Launch
The second wave of implementation will target smaller businesses with fewer than 250 employees, or those with lower financial thresholds, in September 2027. Again, businesses will have the option to request a three-month extension until December 2027.
Though businesses have a few years to prepare, the clock is ticking, and many firms will need to start engaging with accredited PDPs immediately to ensure smooth integration. The adoption of e-invoicing is an imperative for France, driven not only by national tax reforms but also by the desire to modernize administrative processes and reduce fraud.
2. The Role of Partner Dematerialization Platforms (PDP) and the Establishment of the French Peppol Authority
A key feature of France’s e-invoicing system is the establishment of the French Peppol Authority, announced on December 13, 2024. This development is part of France’s commitment to ensuring that its e-invoicing framework aligns with EU standards for cross-border electronic invoicing, particularly with the use of the Peppol network. Peppol is a global interoperability framework that ensures the seamless, secure exchange of invoices between trading partners in different countries.
The French Peppol Authority will be responsible for ensuring that all PDPs operate under the same standardized protocols and are fully certified to handle e-invoices. This certification process will be critical in ensuring that e-invoices are exchanged securely and that businesses can seamlessly integrate with the system.
However, significant changes to the original e-invoicing model were announced in October 2024. The Direction Générale des Finances Publiques (DGFiP) declared that it would no longer offer free access via the Portal Public de Facturation (PPF), which had initially been proposed as a choice for businesses to either use a free PPF platform or nominate an accredited PDP.
Instead, the PPF will now focus on providing a Business Directory, serving as the central data hub for transmitting information to the DGFiP. The transition to a 5-corner model means that businesses must find an accredited PDP themselves, either through their own accounting/ERP vendors or other third-party service providers. This change in direction is largely in response to concerns about meeting the ambitious September 2026 deadline.
The revised e-invoicing model means that businesses will no longer be able to rely on the free PPF for invoicing exchanges. Instead, they must partner with an accredited PDP who will manage the exchange of e-invoices. These PDPs, which include both large accounting firms and ERP providers, will be tasked with ensuring that businesses can send and receive invoices securely, and in compliance with French tax regulations.
Key steps for businesses moving forward include:
- Selecting a PDP: Businesses will need to partner with one of the accredited PDPs registered for the French e-invoicing system. It’s essential to review options and ensure that the PDP provides the necessary technological infrastructure to meet France’s invoicing standards.
- Testing Interoperability: Businesses will need to participate in the interoperability testing scheduled for October 2025 to ensure their chosen PDP can work with other platforms in the ecosystem. This is a critical step to ensure seamless transactions on the day of the official rollout.
- Full Certification by 2026: PDPs will be expected to have full certification by Q2 2026, meaning that they will be prepared to exchange invoices with businesses on a national scale. Businesses must ensure they’re ready to go live with their chosen PDP before the official launch in September 2026.
The establishment of the French Peppol Authority and the scaling back of the free PPF service may present challenges, but it is clear that this transition will modernize the way businesses in France handle invoices. By complying with the e-invoicing regulations, businesses will not only streamline their administrative processes but also align with broader EU initiatives to standardize digital invoicing across borders.
Key Takeaways for Businesses:
- Act Now to Avoid Delays: Begin engaging with an accredited PDP immediately to ensure that you are ready for the testing phases in 2025 and the official launch in September 2026.
- Testing and Integration: Ensure that your chosen PDP is ready for interoperability testing in late 2025 and that your systems are compatible with the new French e-invoicing framework.
- Understanding the New Model: With the scaling back of the free PPF service, businesses must now take responsibility for selecting a PDP and managing their e-invoicing exchanges.
By preparing early and engaging with the right partners, businesses can navigate the complex transition to e-invoicing smoothly and stay ahead of the curve as France moves toward digital invoice compliance in the coming years.
