Factur-X and the French e-invoicing reform: dates, platforms and formats

The calendar

• 1 September 2026: all businesses must be able to receive e-invoices.
• 1 September 2026: large companies and mid-size companies (ETI) must issue e-invoices.
• 1 September 2027: small and medium-sized businesses (PME) and micro-businesses, including micro-entrepreneurs, must issue e-invoices.

The same calendar applies to e-reporting: sending transaction data to the tax administration for sales that are not covered by e-invoicing, such as sales to consumers and to foreign customers, and for payment data in some cases.

The reform covers transactions between businesses established in France and liable to French VAT, whatever their size or legal form, including those under the VAT franchise scheme.

Approved platforms (plateformes agréées)

Invoices between businesses in France must pass through a plateforme agréée, an approved platform. These are private companies registered by the tax administration. Earlier documents call them PDP (plateformes de dématérialisation partenaires). Each business chooses its own platform to issue and receive invoices and to report data. The administration publishes the list of approved platforms on impots.gouv.fr.

You cannot send an e-invoice directly to a French business customer once the reform applies to you: it goes from your platform to theirs. The administration keeps a directory of invoice recipients that tells platforms where each business receives its invoices.

A plain PDF sent by email, or a scanned paper invoice, is not an e-invoice and will no longer meet the rules once your issuing date has passed.

The three base formats: Factur-X, UBL and CII

The reform accepts three base formats, which every approved platform must be able to receive:

• UBL: an XML file in the Universal Business Language syntax.
• CII: an XML file in the UN/CEFACT Cross Industry Invoice syntax.
• Factur-X: a mixed format that combines a PDF people can read with the structured data as an attached CII file.

All three carry the data of the European standard EN 16931.

What Factur-X is

Factur-X is a French-German standard published by the FNFE-MPE in France and FeRD in Germany, where it is called ZUGFeRD. The two are technically the same. A Factur-X file is a PDF/A-3 (an archive-quality PDF) with an XML file named factur-x.xml attached.

Factur-X has five profiles that carry more or less data:

• MINIMUM and BASIC WL: only header-level data, not a full invoice. Germany does not accept them as e-invoices.
• BASIC: adds the invoice lines.
• EN 16931: all the data of the European standard. This is the profile our tool creates.
• EXTENDED: EN 16931 plus extra data for more complex cases.

New details French invoices must show

With the reform, invoices between French businesses must also show four new details:

• The customer’s SIREN number.
• The delivery address, if it differs from the customer’s address.
• Whether the invoice is for goods, services or both.
• That you pay VAT on debits (TVA sur les débits), if you chose that option.

In the structured file, these details follow the French standard AFNOR XP Z12-012 and its validation rules published by the FNFE-MPE:

• SIRENs: the customer’s SIREN is their legal registration identifier (BT-47) with scheme 0002; yours goes in the same place for the seller (BT-30).
• Delivery address: the “deliver to” address of the European standard (BG-15), only when it differs.
• Goods, services or both: the billing framework (BT-23), with the codes B1, S1 or M1 for a normal invoice.
• VAT on debits: the VAT point date code (BT-8): 5 in Factur-X (CII) and 3 in UBL.

Our tool fills in all four for businesses established in France: SIRENs from the registration number fields with type France: SIREN (a 9-digit number is recognised automatically for French customers), an optional delivery address, What you invoice on each invoice, and the VAT-on-debits option in your business details. Before issuing, it lists what is still missing for French business customers.

Legal notes: penalties, the €40 fee and discounts

Invoices between French businesses must also state what happens if payment is late and whether there is a discount for paying early:

• Late-payment penalties. They are due without a reminder, and the rate may not be lower than three times the legal interest rate.
• The fixed recovery fee of €40 per unpaid invoice, which a business customer owes on top of the penalties.
• Early-payment discount: its conditions, or, if there is none, a statement that it is nil (“Escompte : néant”).

In e-invoices these are coded notes, as the French validation rules require: subject code PMD for penalties, PMT for the recovery fee and AAB for the discount. In Factur-X (CII) the code goes in the note’s subject code; in UBL the note starts with #PMD#, #PMT# or #AAB#.

Our tool adds all three to every invoice and credit note from a business in France, in the files and on the PDF. The standard wording is ready in Your invoice details under France: penalties at three times the legal interest rate, the €40 fee, and “Escompte pour paiement anticipé : néant”. Change it to match your own terms, for example if your penalty rate is higher.

We checked sample French invoices and credit notes from the tool against the official French rule files published by the FNFE-MPE (version 1.4, EN 16931 profile), and they met every rule. The Peppol file allows only one note, so there the three mentions are joined into that note without codes; for French customers, send the Factur-X.

How to create a Factur-X invoice with our tool

1. In our e-invoice generator, fill in Your invoice details: legal name, address, VAT ID, and your SIREN as Company registration number with Type of registration number France: SIREN. Under France, choose what Usually you invoice, tick the VAT-on-debits option if you chose it, and check the wording of the three legal notes.
2. Choose New invoice, enter the customer, and put their 9-digit SIREN in Company registration number. Choose What you invoice: goods, services or both.
3. If the goods go somewhere else, open Delivery address and fill it in. Set Language of the PDF to French if you want French labels.
4. Add the lines and VAT types. Check the box Formats for this invoice for anything still missing, then choose Check and issue.
5. Download PDF with e-invoice inside (Factur-X / ZUGFeRD). This file is your Factur-X invoice in the EN 16931 profile. The CII XML (EN 16931) download is the same data on its own.
6. Once the reform applies to you, upload the file to your plateforme agréée. Before that, you can still email it to your customer.

Sources

• impots.gouv.fr: Je découvre la facturation électronique
• impots.gouv.fr: FAQ, Je découvre la facturation électronique (PDF, version of 1 September 2026)
• Entreprendre.Service-Public.fr: Facturation électronique, ce qui change en 2026 et 2027
• FNFE-MPE: Factur-X
• FNFE-MPE: French validation rules and examples for AFNOR XP Z12-012 and XP Z12-014 (version 1.4)
• Entreprendre.Service-Public.fr: Mentions obligatoires sur une facture
• Entreprendre.Service-Public.fr: Délais de paiement entre professionnels et pénalités de retard