If you are a French enterprise, chances are you have been analysing the impact of the new e‑invoicing and e‑reporting requirements for several years. You have also probably had to revisit that impact more than once, as timelines, scope, and documented use cases evolved.
The French e‑invoicing and e‑reporting reform, effective from September 2026, introduces a CTC‑based model covering both domestic invoicing and transaction‑level VAT reporting.
If your company is not headquartered in France but has activities there, your preparation approach may be different, even though the obligations remain the same.
Axway is officially accredited as a Plateforme Agréée (PA), or “Approved Platform” under France’s mandatory e‑invoicing and e‑reporting framework. Formally designated as a Plateforme de Dématérialisation Partenaire (PDP), this accreditation confirms Axway’s full compliance with the requirements defined by the French tax authority (DGFiP). Learn more about Axway eInvoicing.
Architecture and CTC ecosystem
The French architecture relies on a centralized platform (PPF) that connects enterprises and service providers to the VAT administration. Invoice exchanges are performed using Peppol eDelivery, unless otherwise agreed. These exchanges must be delegated to accredited service providers (Partner Platforms, or PA) and must comply with French data sovereignty requirements, including SecNumCloud.
For KYC purposes, the platform is supported by a national directory (annuaire) listing all taxpayers in France together with their appointed service providers.
The scope of transaction is for B2B domestic and intra-community, B2G/G2B, as well as B2C and additional reporting.
- Domestic VAT transactions fall within the scope of e‑invoicing.
- Intra‑Community transactions, as well as payments and transactions not backed by invoices (such as B2C or portal‑based transactions), fall within the scope of e‑reporting. Reporting data must be consolidated and transmitted in a timely manner.
- The status of transactions is tracked through life‑cycle messages exchanged between multiple parties.
France is not the only country combining a centralized reporting platform with service providers in an interoperable setup. What makes the French reform more complex than many other CTC mandates lies elsewhere?
Scope, data requirements, and timing
The main sources of complexity are the breadth of scope and the level of detail that must be exchanged within short timeframes.
France did not wait for the revision of EN-16931, nor for the final definition of ViDA Digital Reporting Requirements (DRR). Instead, the model already requires:
- a clear distinction between services and goods,
- determination of the tax point date based on actual payment receipt (for services),
- sharing transaction data with third‑party partners such as factoring providers, shared service centers, or agents.
Illustration: retail organisation with mixed B2B and B2C tranactions.
Consider a retail organisation. It must separate B2B transactions (subject to e-invoicing) from B2C transactions (reported through aggregated e-reporting). In addition, when selling vouchers such as gift cards or prepaid credit, a distinction must be made between goods and services. When the buyer is representing a public entity, the invoice should then follow the B2G channel.
A multi-purpose gift card will have VAT determination defined when redeemed for an actual purchase of goods or services, with the tax point determined at that moment.
Even if this retail organisation sells domestically, procurement of those goods is likely to be international. Intra-community acquisitions need to be reported, while purchase invoices may still be paper or PDF-based, increasing pressure on the dematerialisation process.
If invoice processing is handled by a shared service center, this may also raise questions related to data sovereignty requirements.
Alignment with European standards
As European discussions progress, the effort to align the French design with emerging EU preferences is becoming more visible.
Examples include:
- Ongoing debates around support for the Factur‑X hybrid format,
- French‑specific use cases that require extensions beyond the current EU norm,
- open questions on whether DRR should contain only invoice data or be enriched with VAT‑related information.
Before 2030, the update of EN-16931 is expected to be implemented. As a result, migration of specifications will be required.
Implications for enterprise landscapes
For organizations with a mixed portfolio of back‑office applications—and especially those already supporting CTC implementations in other countries—this means that a simple mapping exercise is unlikely to be sufficient.
This raises the question of which approach to follow.
Selecting an accredited service provider (PA)
Enterprises can choose to contract directly with a local accredited PA. To support this, France has defined a standard API for integrating back‑office systems with PAs. This API reflects the complexity of the requirements and is specific to the French context.
Alternatively, enterprises may prefer to continue working with their existing service provider. If that provider is not accredited, subcontracting to a PA is a possible model. In such cases, integration between service providers can rely on the Peppol Service Provider‑to‑Service Provider (SP2SP) interoperability standard, as promoted by the GENA association.
Orchestration of transactions
Another key consideration is how much ERP or finance logic an enterprise wants to delegate to its service provider.
Life‑cycle events are generated through collaboration between the supplier, the supplier’s PA, the buyer, the buyer’s PA, and potentially external partners such as factoring providers. At the same time, relationships between linked transactions—such as pre‑payments, invoices, credit notes, and reports—must be preserved.
This complexity is influenced by the structure of the back‑office landscape: not only the separation between P2P and O2C flows, but also the functional distribution across ERP, finance, payments, and VAT determination systems.
Illustration: a logistic business, with orchestration across systems
Take a manufacturing company with multiple production sites and a shared service center handling invoicing and payments. Sales orders may originate in an ERP system, purchase invoices in a central finance platform, approval workflow integrated in the dematerialisation solution, and payments in a separate treasury or banking solution. Under the French reform, these elements must be correlated to generate consistent life‑cycle events and reporting data.
A similar challenge exists for logistics or distribution companies handling pre‑payments, partial deliveries, and credit notes. Preserving the relationship between these linked transactions is essential for accurate VAT reporting and is difficult to achieve when responsibilities are spread across multiple applications.
When data is distributed across multiple applications, a middleware solution can take on the orchestration role and ensure that all required data is consistently available to the service provider.
Minimising risk and ensuring continuity: the pilot phase
Some aspects of the model allow for pragmatic choices. For example, payment reconciliation is primarily required to determine the tax point date for services. Enterprises may choose not to implement this initially and instead apply the invoice date as the tax point.
The French tax authorities have launched a pilot phase, giving enterprises six months to validate their environments and compliance status using real transactions. Given the regulatory requirements, participation in these pilots should be seen as a practical risk‑mitigation step rather than an overhead cost.
Final consideration
The French reform ultimately aims at a 100% VAT declaration, but this should not become a go‑live blocker. Chasing every exception upfront often delays stabilisation without materially improving compliance. A pragmatic go‑live focuses on securing standard, high‑volume transaction flows first, while addressing remaining exceptions progressively after go‑live and aligning with other ViDa roll-outs.
Axway is officially accredited as a Plateforme Agréée (PA), and can help in France, Europe, or globally.