France Completes Its E-Invoicing Rulebook: Decree No. 2026-677 and the Order of 27 July 2026 Abolish the Public Portal as an Exchange Route

Country Update — France  |  3 August 2026  |  Topic: E-Invoicing / Digital Tax Reporting

On 28 July 2026, the French Journal officiel (JORF no. 0174) published Décret no. 2026-677 du 27 juillet 2026 and the Arrêté du 27 juillet 2026, both relating to the generalization of electronic invoicing. The two texts, which took effect the following day, are the final pieces of secondary legislation for the reform.

They are made for the application of Articles 289 bis, 289 E, 290, 290 A and 290 B of the French General Tax Code (CGI) as amended by Article 123 of the Finance Act for 2026, and they update the earlier texts of 7 October 2022 and Décret no. 2024-266 of 25 March 2024. With five weeks to go before the 1 September 2026 go-live, the legal framework is now complete.

Background

France’s B2B e-invoicing and transactional e-reporting reform has been through several redesigns since it was first legislated in the 2020 Finance Act. The most consequential change came in October 2024, when the DGFiP abandoned the plan for the Portail Public de Facturation (PPF) to act as a free exchange platform, leaving it as a directory and data concentrator only.

Article 123 of the Finance Act for 2026 then fixed the operative dates. What remained outstanding was the secondary legislation: until late July 2026, the decree and order in force still reflected the pre-2024 architecture and carried superseded dates.

That gap mattered. Approved Platforms, software vendors, and in-house SAP teams were building against technical specifications and draft texts rather than against published law. The 27 July texts close the gap, although they do so uncomfortably close to the go-live date.

The Legislative Change

The decree and order make four substantive changes to the framework.

• The PPF is formally removed as an exchange route. The ecosystem is now built entirely around Approved Platforms (Plateformes Agréées). Every taxable person must contract with at least one; there is no free public alternative for transmitting invoices.
• The format baseline is anchored in law. Compliant invoices must conform to EN 16931 and, for the French CTC flows, to the EXTENDED-CTC-FR profile defined in AFNOR standard XP Z12-012. The texts also refer explicitly to XP Z12-013 (standardized APIs) and XP Z12-014 (business use cases). Factur-X, UBL, and CII remain the accepted syntaxes.
• Platform mobility is codified. Switching between Approved Platforms now requires a formal switching agreement, is subject to binding deadlines, and obliges the outgoing platform to maintain a minimum of one year of service continuity. Transfers of directory information require signed taxpayer authorization.
• Platform supervision is tightened. A new mid-cycle audit is introduced for Approved Platforms, sitting between initial registration and the three-yearly renewal, alongside adjusted registration requirements and refinements to the invoice and e-reporting data fields.

The order also performs the housekeeping that the reform’s history made necessary, replacing the superseded commencement dates in the October 2022 texts with the dates now set by Article 123 of the Finance Act for 2026.

Scope

The obligation covers domestic transactions between persons established in France who are taxable for VAT purposes.

Transactional e-reporting covers B2C sales, cross-border transactions with parties outside the domestic e-invoicing perimeter, and the associated payment data. The e-reporting stream known as Flux 10 carries the B2C, international, and payment data; AIFE published its official Schematron validation tool for Flux 10 in late July 2026, giving vendors an authoritative conformance reference for the first time.

Timeline

• 25 June 2026 — Law no. 2026-534 on combating social and tax fraud is enacted, extending record retention to ten years from 1 January 2027 (covered separately).
• 27 July 2026 — Decree no. 2026-677 and the Order of the same date are signed.
• 28 July 2026 — Both texts are published in the Journal officiel (JORF no. 0174).
• 29 July 2026 — The texts take effect.
• 1 September 2026 (Wave 1) — All established taxable persons must be able to receive structured electronic invoices. Large and mid-sized enterprises must issue compliant electronic invoices and transmit e-reporting data. A soft-landing enforcement period applies.
• 1 September 2027 (Wave 2) — The issuing and e-reporting obligations extend to small and micro enterprises.

Businesses Affected

Every business established in France and registered for French VAT is affected from 1 September 2026, because the receiving obligation applies to all of them from day one regardless of size. Non-established businesses holding a French VAT registration fall outside the e-invoicing obligation but may still have e-reporting duties depending on their transaction profile.

The heaviest lift falls on multinationals running centralized ERP landscapes. The requirement is not simply to produce a compliant XML file; it is to support the full invoice lifecycle — issuance, transmission, acceptance and rejection statuses, payment reporting, and archiving — through an Approved Platform, across every French entity in the group.

Required Actions

• Confirm that your Approved Platform is registered under the final framework and has implemented the July 2026 versions of XP Z12-012, XP Z12-013, and XP Z12-014 rather than the February 2026 drafts. Specifications changed twice in 2026; conformance testing performed against superseded versions should be re-run.
• Re-validate ERP output, mapping tables, and validation routines against the current standards. In SAP terms this means re-checking the eDocument configuration, the mapping to the EXTENDED-CTC-FR profile, and the handling of lifecycle status messages returned by the platform.
• Integrate the AIFE Flux 10 Schematron into your test cycle if you have material B2C, export, or import activity. This validation tool arrived late, so it is unlikely to have been part of earlier test rounds.
• Review your platform contract against the new mobility rules. The switching agreement, deadlines, one-year continuity obligation, and directory-authorization requirements should be reflected in the terms you have signed.
• Verify master data quality now — SIREN and SIRET identifiers, routing addresses, and directory entries. Under a CTC model, master data errors surface as rejected invoices and delayed cash collection rather than as a reconciling item at month-end.
• Document your transition approach. The DGFiP has confirmed that PDF and paper invoices remain valid and VAT-deductible during the ramp-up, but a documented plan is what demonstrates good faith if the treatment is later reviewed.

Practical Implications

The abolition of the PPF as an exchange route is the change with the most commercial consequence. Every French taxable person now depends on a commercial intermediary to transact, which makes platform selection a continuity risk rather than a procurement decision.

The mobility rules are the counterweight: the one-year service continuity obligation and the formal switching process are designed to prevent lock-in, and they are worth reading closely before signing a multi-year contract.

The timing is the other practical issue. Publishing the definitive secondary legislation on 28 July for a 1 September go-live leaves a five-week window that overlaps the French summer shutdown.

Teams that assumed the March 2024 decree still described the operative framework will find several details have moved. The soft-landing enforcement period provides cover for imperfect execution, but it does not suspend the legal obligation, and the tolerance is expected to narrow from early 2027.

Expected Next Steps

Attention now shifts from legislation to operational readiness: completion of Approved Platform registrations, publication of any remaining DGFiP and AIFE guidance, and the practical experience of the first weeks of Wave 1.

The DGFiP has signaled further transitional simplifications where the ecosystem proves not to be ready. KGT will report on the operation of the soft-landing period, on any adjustment to the 1 September 2027 Wave 2 date, and on subsequent releases of the AFNOR specifications.

How Can KGT Support You?

KGT implements French e-invoicing and e-reporting directly from SAP through our SAP-integrated add-ons and supports SAP Document and Reporting Compliance (DRC) rollouts. We can map your ERP output to the EN 16931 / EXTENDED-CTC-FR profile under XP Z12-012, connect your SAP landscape to your chosen Approved Platform through the XP Z12-013 APIs, test your flows against the business use cases in XP Z12-014, and build the e-reporting streams for B2C, cross-border, and payment data. Where a platform switch is on the table, we can also design the migration so that directory data, invoice lifecycle statuses, and archives survive the move intact.

Official sources

• impots.gouv.fr – Réforme de la facturation électronique : documentation juridique (reference documents, including Décret no. 2026-677 and the Arrêté of 27 July 2026): View source
• Légifrance – Décret no. 2026-677 du 27 juillet 2026 relatif à la généralisation de la facturation électronique: View source
• Légifrance – Arrêté du 27 juillet 2026 relatif à la généralisation de la facturation électronique: View source
• Légifrance – JORF no. 0174 du 28 juillet 2026 (table of contents): View source
• impots.gouv.fr – Facturation électronique (main reform portal): View source

This publication is provided for general informational purposes only and does not constitute tax, legal, or professional advice. Please consult your advisor before acting on any information contained in this update.