France: Factur-X 1.09.2 and ZUGFeRD 2.5.2 Issued on August 4, 2026, and the DGFiP Register of Approved Platforms Is Updated and Split Into Two Separate Lists

Country Update — France  |  11 August 2026  |  Topic: E-Invoicing / Formats and Platforms

Three weeks before the French e-invoicing and e-reporting reform takes effect on September 1, 2026, two further artifacts have changed. On August 4, 2026 the Forum National de la Facture Électronique (FNFE-MPE) and its German counterpart FeRD issued an updated release of the joint hybrid invoice standard, Factur-X version 1.09.2 and ZUGFeRD version 2.5.2, superseding the base release of June 10, 2026.

On August 6, 2026 the DGFiP updated its register of approved platforms and, for the first time, published it as two separate registers: operators satisfying all conditions including interoperability testing, and operators whose file is complete and compliant but whose definitive registration remains conditional on passing those tests. For any business still selecting or confirming a platform, that distinction is the material one.

Background

The French reform’s legal framework closed at the end of July 2026. Article 123 of the 2026 Finance Act, Law No. 2026-103 of February 19, 2026, rewrote the relevant articles of the General Tax Code. Decree No. 2026-677 of July 27, 2026, and the Order of the same date, both published in the Journal Officiel of July 28, 2026, completed the implementing rules, removed the public portal as an exchange route, and replaced the term partner dematerialization platform operator with approved platform throughout Annexe IV of the General Tax Code. KGT reported on both of those developments.

France operates a decentralized model in which businesses connect to approved platforms which interconnect through the public portal acting as directory and data concentrator.

The taxpayer does not test against the tax authority; it tests against the artifacts the authority and the standards bodies publish, and then against its chosen platform. Two consequences follow. First, the choice of platform is a compliance decision, not merely a procurement decision. Second, the format and validation artifacts are the practical specification, and their version history matters.

On the format side, the relevant baseline is AFNOR standard XP Z12-012 in its version 1.4.0 edition of June 30, 2026, applicable from September 1, 2026, under which Factur-X remains one of the three formats mandatory in reception alongside UBL and CII. FNFE-MPE and FeRD published the joint hybrid standard Factur-X 1.09 and ZUGFeRD 2.5 on June 10, 2026, with effect from July 1, 2026.

KGT reported on that base release. The two bodies have stated an intention to publish an updated Factur-X and ZUGFeRD version shortly after each half-yearly update of the EN 16931 code lists on the European Commission’s registry of supporting artefacts.

On the platform side, the DGFiP maintains the public register of approved platforms. Definitive registration is granted only after interoperability tests are passed in real conditions, in addition to fiscal compliance and infrastructure and data security requirements.

Until August 6, 2026 the register was presented as a single list, which meant that a business consulting it could not readily distinguish an operator that had completed interoperability testing from one that had not.

The Legislative Change

Neither development is a legislative change, and it is worth stating that plainly. The legal rulebook was completed by the Decree and Order of July 27, 2026. Everything published since operates within that framework. Both items are nonetheless binding in practice, and for different reasons.

The Factur-X and ZUGFeRD release is binding through validation. An invoice that does not conform to the applicable version of the format, and to the code lists it embeds, will be rejected by the receiving platform. Rejection in the French model is not a penalty event; it is a non-event, in the sense that the invoice has not been transmitted. The release is therefore enforced by the software estate rather than by the tax administration.

The substance of the release is a maintenance update. FNFE-MPE and FeRD published the base joint standard Factur-X 1.09 and ZUGFeRD 2.5 on June 10, 2026, and then issued an updated release, Factur-X 1.09.2 and ZUGFeRD 2.5.2, on August 4, 2026.

The official page header now reads that the standard was published on June 10, 2026 and updated on August 4, 2026, and describes the update as containing a small number of additions and corrections relative to the June version.

The release cycle refreshed code lists and validation artifacts in line with the latest EN 16931 code list publication, and added new elements to the EXTENDED profile reflecting the revised CEN EN 16931-1 data model then in the course of publication. The 1.09.2 documentation is stated to integrate the latest evolutions of AFNOR XP Z12-012 published on June 30, 2026 and applicable from September 1, 2026.

Only the three press releases dated June 10, 2026 are published; there is no separate August 4 press release, so the August step is documented by the version increment and the page update rather than by a communication of its own.

The specification downloads are behind a registration form, which means the precise list of corrections cannot be enumerated from public material; organizations should obtain the specification and confirm the corrections against their own implementation.

The register update is binding in a different sense: it determines who may lawfully transmit invoices and e-reporting data from September 1, 2026. The DGFiP updated the register on August 6, 2026 and now publishes two registers rather than one.

The first lists operators satisfying all conditions, including interoperability tests. The second lists operators that have filed a complete and compliant application and are awaiting definitive registration conditional on passing interoperability tests. Each is published in three formats. By our own count of the published tables, the first list contains 144 operators and the second contains 17; the DGFiP publishes no total, so those figures are our count and not an official statistic.

The register also carries, for each operator on the first list, the date on which its registration number was issued. Six such dates fall in the period since KGT last reported: July 3, July 8, July 9, July 15, July 21 and July 29, 2026. One data quality point is worth flagging for anyone reading the file: one entry shows a date of December 18, 2026, which is almost certainly a transcription error for December 18, 2025.

Scope

The Factur-X and ZUGFeRD release is relevant to every business issuing or receiving hybrid invoices in France, and to every business doing so in Germany, since the standard is jointly maintained and jointly applicable. In France, Factur-X is one of the three formats that an approved platform must be able to receive, which means that a French recipient may receive Factur-X whether or not it issues in that format. Receiving businesses therefore have an interest in the release even if their own issuance uses UBL or CII.

The AFNOR XP Z12-012 version 1.4.0 baseline to which the release aligns applies from September 1, 2026, and the release is dated four weeks before that. The practical scope is therefore immediate.

The register applies to every business established in France and subject to value added tax, because from September 1, 2026 every such business must be able to receive invoices through an approved platform, without any size threshold and with no free public alternative following the removal of the public portal as an exchange route. Issuance and e-reporting obligations apply from September 1, 2026 to large enterprises and to intermediate-sized enterprises, with small and micro-enterprises following on September 1, 2027.

The distinction between the two registers is of narrower but sharper scope: it matters to any business whose chosen or shortlisted operator appears on the second list rather than the first, and to any business conducting vendor due diligence in the final weeks before go-live.

Timeline

• February 19, 2026 — Law No. 2026-103, the 2026 Finance Act, Article 123, rewrites the relevant articles of the General Tax Code.
• April 30, 2026 — version 3.2 of the DGFiP external specifications for business-to-business flows; the page was last modified on July 2, 2026 and no new specification version was issued in the period covered by this update.
• June 10, 2026 — FNFE-MPE and FeRD publish the base joint standard Factur-X 1.09 and ZUGFeRD 2.5, with effect from July 1, 2026.
• June 30, 2026 — AFNOR XP Z12-012, XP Z12-013 and XP Z12-014 version 1.4.0 editions, applicable from September 1, 2026.
• July 3, 8, 9, 15, 21 and 29, 2026 — registration numbers issued to six further approved platform operators.
• July 27, 2026 — Decree No. 2026-677 and the Order of the same date; published in the Journal Officiel of July 28, 2026; effective July 29, 2026.
• August 4, 2026 — FNFE-MPE and FeRD issue Factur-X version 1.09.2 and ZUGFeRD version 2.5.2, integrating the latest evolutions of AFNOR XP Z12-012 of June 30, 2026.
• August 6, 2026 — the DGFiP register of approved platforms is updated and split into two separate registers.
• September 1, 2026 — the reception obligation applies to every business established in France and subject to value added tax; issuance and e-reporting obligations apply to large and intermediate-sized enterprises; AFNOR XP Z12-012 version 1.4.0 becomes applicable.
• September 1, 2027 — issuance and e-reporting obligations extend to small and micro-enterprises.

Businesses Affected

Every business established in France and subject to value added tax is affected by the register, because every such business must have contracted with at least one approved platform for reception by September 1, 2026.

Businesses that have contracted with an operator appearing on the second list should treat that as a matter requiring immediate clarification, not as a technicality: definitive registration is conditional on passing interoperability tests, and those tests were not complete as at August 6, 2026.

Businesses issuing or receiving Factur-X in France are affected by the 1.09.2 release. So are businesses issuing or receiving ZUGFeRD in Germany, where version 2.5.2 is the corresponding release. Groups operating in both countries should treat this as a single change rather than two, since the standard is jointly maintained.

Businesses that completed format testing against Factur-X 1.09 or ZUGFeRD 2.5 between June 10 and August 3, 2026 tested against a baseline that has since been corrected. That is the population most likely to be unaware that anything has changed, because the change was published without a press release.

Software vendors, approved platforms and internal development teams building hybrid invoice generation or parsing are affected directly, and should be the first port of call for confirming which version an organization is actually producing.

Businesses in the e-reporting perimeter — principally those with business-to-consumer and cross-border flows — are affected by the register in the same way as issuers, since e-reporting data is transmitted through an approved platform.

Required Actions

• Check whether your contracted approved platform appears on the first DGFiP register, which covers operators satisfying all conditions including interoperability tests, or on the second, which covers operators awaiting definitive registration. If it is on the second list, obtain a written position from the operator on its interoperability test status and its expected registration date, and consider a contingency.
• Repeat that check for any operator you are still evaluating. The two-list structure is new information and materially changes what the register tells a buyer.
• Obtain the Factur-X 1.09.2 and ZUGFeRD 2.5.2 specification from FNFE-MPE and perform a differential review against the version your implementation was built to. Because the corrections are not enumerated in public material, this review has to be done against the specification itself.
• Confirm which version your invoice generation currently produces, and which version your parsing accepts. In groups with several issuing systems these frequently differ.
• Refresh the embedded code lists. The release cycle refreshed code lists in line with the latest EN 16931 publication, and a stale code list is a common and avoidable rejection cause.
• Re-run format validation, including negative testing, against the 1.09.2 or 2.5.2 artifacts and against the current FNFE-MPE Schematrons. Testing completed in June or July against the base release should be treated as superseded.
• Where you operate in both France and Germany, coordinate the change. The joint standard means a single upgrade can serve both, and an uncoordinated upgrade can leave the two countries on different versions of the same format.
• Note for planning purposes that the DGFiP external specifications remain at version 3.2 of April 30, 2026 and that no new specification version was issued in this window. The moving parts are the standards-body artifacts and the register, not the DGFiP specification.

Practical Implications

The two items in this update illustrate the same point from different directions: with three weeks to go, the artifacts a French business depends on are still changing, and they are changing quietly.

A maintenance release published without a press release, and a register reorganized without an announcement, are exactly the kind of change that a readiness program built around legislative monitoring will miss.

The register split is the more consequential of the two for businesses that have not finalized platform arrangements. Until August 6 the register conflated two materially different states. A business could reasonably have consulted it, found its intended operator listed, and concluded that the operator was fully approved.

Seventeen operators were in fact awaiting definitive registration conditional on interoperability tests. In a model with no free public alternative for transmitting invoices, an operator that does not complete interoperability testing before September 1 leaves its clients unable to transmit. That is a supply risk with no workaround, and it is worth an explicit conversation with the operator now.

The Factur-X release is lower risk but broader reach. Maintenance releases of hybrid formats tend to be treated as optional, on the reasoning that a minor version cannot matter much. In a validated exchange it can, because the corrections typically concern precisely the points at which implementations diverge, and because the refreshed code lists are enforced by Schematron rather than by judgment. The cost of upgrading is low; the cost of discovering the divergence on September 2 is not.

There is also a governance implication for groups operating across France and Germany. The joint maintenance of Factur-X and ZUGFeRD is a considerable convenience and a modest trap: the same artifact serves two mandates with different legal frameworks and different timetables, and the version in production needs to be managed centrally rather than country by country.

Finally, it is worth recording what did not change. The DGFiP external specifications remain at version 3.2 of April 30, 2026, and no French legislative act or specification version was issued in this window. The French reform’s legal and specification layers have stabilized. What remains in motion is the standards and validation layer, and the readiness of the platform market.

Expected Next Steps

Further maintenance releases of Factur-X and ZUGFeRD should be expected, since FNFE-MPE and FeRD have stated an intention to publish an updated version shortly after each half-yearly EN 16931 code list update. Organizations should monitor the FNFE-MPE resources page and the joint standard page directly.

Further updates to the DGFiP register should be expected in the run-up to September 1, 2026, and specifically the migration of operators from the second register to the first as interoperability tests are completed. Businesses whose operator is on the second list should re-check the register weekly.

Further FNFE-MPE Schematron maintenance releases should be expected. The current package is version 1.4.0, most recently corrected on August 4, 2026, and a validation baseline that moved four weeks before go-live may move again.

One technical mismatch is worth watching: the companion XP Z12-013 application programming interface annexes remain at version 1.3 and were not re-versioned to 1.4 alongside the other standards. Implementers relying on those annexes should confirm with their platform how the mismatch is handled.

KGT will report separately on further Factur-X, ZUGFeRD and Schematron releases, on the completion of interoperability testing across the platform market, and on the first weeks of live operation from September 1, 2026.

How Can KGT Support You?

KGT is a specialist indirect tax technology firm. Our SAP-integrated e-invoicing and e-reporting add-ons generate, validate and transmit country-compliant structured documents directly from SAP ECC and SAP S/4HANA, keeping tax determination, document mapping, status handling and the audit trail inside the system of record rather than in a downstream converter.

Because the add-ons validate against the current national schemas, schematrons and code lists before transmission, a change of specification version becomes a configuration and regression-test exercise rather than a redesign.

We also deliver SAP Document and Reporting Compliance (DRC) services end to end: fit-gap assessment against the national mandate, activation and configuration of the relevant country versions, eDocument and eStatement setup, interface and connectivity design, master and transactional data remediation, test strategy including negative testing against the authority’s own validation artifacts, and post-go-live monitoring of rejections and status reconciliation. If you would like a readiness review against the developments described above, or an impact assessment for your SAP landscape, we would be glad to help.

Official sources

• FNFE-MPE, Factur-X and ZUGFeRD joint standard page (Factur-X 1.09.2 / ZUGFeRD 2.5.2, updated August 4, 2026): View source
• FNFE-MPE, resources page (Schematron packages and specification downloads): View source
• FNFE-MPE, official France_RFE repository (Schematron source artifacts): View source
• DGFiP, register of approved platforms: View source
• DGFiP, list of operators awaiting definitive registration conditional on interoperability tests: View source
• DGFiP, electronic invoicing and approved platforms: View source
• DGFiP, external specifications for business-to-business flows (version 3.2 of April 30, 2026): View source
• European Commission, registry of supporting artefacts to implement EN 16931: View source
• Légifrance, Journal Officiel de la République Française: View source
• AFNOR, French standardization body (XP Z12-012, XP Z12-013, XP Z12-014): 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.