France's e-Invoicing Mandate: Approved Platforms, Peppol and What It Means for SAP
The reform went live on 1 September 2026. How invoices and reports now flow between companies, approved platforms, Peppol and the DGFiP — and what your SAP landscape has to do about it.
Client briefing · September 2026 · CFOs, Finance, PMs
Download Full Briefing (PDF)1 Sep 2026
Receiving for all; issuing and e-reporting for large and mid-sized companies
1 Sep 2027
SMEs and micro-enterprises must issue and e-report
3 formats
Factur-X, UBL and CII — all aligned to the European standard EN 16931
4 statuses
Mandatory invoice lifecycle statuses reported through your platform
Key takeaway for finance leaders: receiving is where most companies are exposed first: the obligation applies to everyone, including subsidiaries too small to issue until 2027. If a supplier sends an invoice to your platform address and nobody processes it, the invoice is still legally delivered — and the payment clock is already running.
Why France Did This
Three stated goals: fight VAT fraud, simplify VAT compliance (pre-filled returns are the long-term prize) and give the State near real-time visibility of economic activity. Digitalising invoices is the means; the tax data is the purpose.
From one portal to many platforms: the original design had a free public portal exchanging invoices for everyone. That role was dropped: the Portail Public de Facturation (PPF) no longer exchanges invoices. It keeps the two functions that hold the system together — the national directory that says which platform serves which company, and the data hub that feeds the DGFiP. Exchange itself is handled by private approved platforms (plateformes agréées, previously called PDP), registered by the State after audit. More than a hundred are registered.
Legal framework set; the reform is postponed and redesigned
The public portal drops its free exchange role — every company needs a platform
The DGFiP becomes a Peppol Authority for France
Platform registration and interoperability testing; pilot phase
Mandate live: receiving for all, issuing and e-reporting for large and mid-sized companies
Issuing and e-reporting for SMEs and micro-enterprises
What Is in Scope
E-invoicing: invoices between businesses established in France and subject to French VAT — including credit notes and self-billing. E-reporting: transactions outside that scope — B2C sales, cross-border B2B (EU and export), and payment data for services.
What Is Neither
Public-sector invoicing stays on Chorus Pro; certain VAT-exempt operations (health, education, finance, insurance, property) are out of scope.
Including small subsidiaries of large groups.
No establishment in France: outside the domestic e-invoicing obligation; e-reporting may still apply.
Penalties and the Start-up Tolerance
€50 per invoice, capped at €15,000 per year (raised from €15 by the 2026 Finance Act).
€500 per transmission, capped at €15,000 per year (raised from €250).
€500, then €1,000 per further 3-month period, applying after a formal notice to comply.
Tolerance, not exemption. The administration has said it will not apply automatic penalties during the 2026 start-up phase to companies that are genuinely engaged and can show documented difficulties — a policy statement, not a change in the law. Keep evidence of your plan and progress.
How a French Invoice Travels
Both parties choose their own platform. The sender's platform finds the customer's platform in the national directory, delivers the invoice, and reports the required data to the DGFiP. Statuses travel back the same way.
The Sender's Platform
Converts the invoice into Factur-X, UBL or CII and checks it. Looks up the customer's platform in the national directory. Delivers the invoice and extracts the data the DGFiP requires. Collects statuses and returns them to the supplier.
The Customer's Platform
Receives the invoice and makes it available to the customer's ERP. Publishes the mandatory statuses on behalf of the customer. Handles technical rejections and commercial refusals.
When Things Go Wrong
A check failed — wrong identifier, missing mandatory information, broken format. The invoice does not legally exist: correct it and resend it under the same number.
A commercial decision, with a reason. The invoice is not payable: issue a credit note and a new invoice, or resolve the dispute and reissue.
Delivery to your platform counts as delivery to you. Payment terms and late-payment interest run regardless of whether your team has opened the file.
Addressing matters. Your company is found in the directory by its SIREN or SIRET (plus a routing code for large groups with several entities or divisions). If your billing data carries the wrong identifier, the invoice reaches the wrong entity — or nobody at all.
The Approved Platform and the Public Portal
Choosing a platform is the central decision of the project: it sits between your ERP and every customer, supplier and the tax administration.
Approved Platform — What It Must Do for You
Issue and transmit invoices in a compliant format to your customer's platform. Receive your suppliers' invoices and make them available to you. Convert from and to other formats (including EDI) where needed. Manage lifecycle statuses in both directions. Extract and send invoice, transaction and payment data to the tax administration. Register and maintain your entries in the national directory.
Public Portal (PPF) — What Remains
National directory: which platform serves which company, and how each entity is addressed. Data hub: receives invoice, status and e-reporting data from platforms and feeds the DGFiP. No exchange service: the portal does not send or receive your invoices. Chorus Pro continues to handle invoices to public bodies.
A PDF a person can read with structured data embedded inside it. Companies with mixed customer bases; readable by humans and machines.
Pure structured data, the most common European syntax. Used for ERP-to-ERP and Peppol exchanges.
Pure structured data, UN/CEFACT syntax. Industry and large-volume EDI environments.
All three implement the European standard EN 16931. Your platform must accept all three; what your SAP system produces is a design decision, not a legal one.
Choosing a Platform: What to Check
Compliance
Registration confirmed and current, interoperability testing passed, and a clear position on directory management and data retention.
Fit with SAP
Native integration with your ERP, handling of statuses, inbound routing into invoice verification, and support for your document types.
Scope Beyond France
Peppol reach, other country mandates, and whether one contract can cover the group as ViDA approaches.
Onboarding with a Platform: the Usual Steps
- Contract and scope: entities, volumes, formats, service levels, data retention.
- Directory registration: each legal entity, and how each site or division is addressed.
- Connection: SAP to the platform, certificates, users and authorisations.
- Format and content mapping: what SAP sends and what the platform completes.
- Test plan: real customers and suppliers, rejections, refusals, credit notes.
- Go-live and monitoring: who watches what, and the escalation path.
Group Decision, Not a Country Decision
Many groups already run a global provider for e-invoicing elsewhere. France is a good moment to decide whether that provider becomes the group standard, whether SAP itself acts as your platform (see the SAP impact section), or whether France stays local and separate — a choice with real consequences for cost, support and future mandates.
Peppol and the Approved Platform
These are not competing options. Peppol is the road; the approved platform is the vehicle that is licensed to drive on it in France. The DGFiP became a Peppol Authority in July 2025, and Peppol is used as the interoperability layer between platforms and towards the rest of Europe.
What it gives you: reach — one connection, many partners and countries; standard formats and addressing.
What it gives you: legal compliance in France — statuses, tax data transmission, directory entries.
A Common Trap
'We are already on Peppol, so France is covered.' Peppol connectivity does not make you compliant: without an approved platform, the invoice data and lifecycle statuses never reach the DGFiP, and your entity may not even be addressable in the national directory.
Most groups end up with a single provider that is both an approved platform in France and a Peppol access point — one connection from SAP, two roles behind it.
What to Ask a Provider About Peppol
- Are you a Peppol access point as well as a French approved platform?
- Which countries' mandates do you cover through the same connection?
- How do you handle partners who are not on Peppol?
- Do you support Peppol's continuous transaction control model used in other countries?
Why This Matters Beyond France
- ViDA brings cross-border digital reporting from 2030; Peppol is the most likely channel.
- Other mandates (Belgium, Poland, Germany, Spain) are converging on the same standards.
- A group that standardises now avoids a separate project per country.
The Vocabulary, in One Place
| Term | What it means |
|---|---|
| Plateforme agréée (PA) | State-registered approved platform. Earlier documents call it PDP — same role, newer name. |
| PPF | The public portal: national directory and tax data hub. No longer an exchange platform. |
| Annuaire | The directory that maps a company (and its sites) to the platform that serves it. |
| Peppol access point | A provider connected to the Peppol network; many French approved platforms are also access points. |
| E-reporting | Transmission of transaction and payment data for flows not covered by e-invoicing. |
Requirements: Statuses, e-Reporting and Invoice Content
The invoice lifecycle: four mandatory statuses.
The invoice has been filed on the platform and passed its checks.
A technical or functional check failed. The invoice must be corrected and resent.
The customer refuses the invoice. It is not payable and must be reissued or credited.
The supplier confirms the money has been received — the status the late-payment data rests on.
Around ten further statuses are optional (received, made available, approved, in dispute, payment sent…). They are not legal obligations, but partners increasingly expect them. Statuses must be published promptly — the specifications work to a 24-hour rhythm — so this is an automation requirement, not a clerical one.
E-reporting: the Second Obligation
Transaction Data
B2C sales, and B2B sales and purchases with parties outside France (EU and non-EU). Aggregated or per transaction depending on the case; sent through your platform.
Payment Data
Payments received on services (where VAT is due on payment). Links the invoice to the cash — the same logic as the 'paid' status.
Frequency
Follows your VAT regime and filing cycle: monthly filers report more often than quarterly or simplified regimes.
A transaction out of scope for e-invoicing is not necessarily out of scope for e-reporting — where most scoping mistakes happen.
Which Obligation Applies to Which Flow
| Typical transaction | Obligation | Practical note |
|---|---|---|
| Sale to a French business subject to VAT | E-invoicing | Through your platform, with lifecycle statuses |
| Sale to a French consumer | E-reporting | Transaction data, aggregated where allowed |
| Sale to a customer in another EU country | E-reporting | The invoice itself follows that country's rules |
| Export outside the EU | E-reporting | Keep the link to customs and VAT evidence |
| Purchase from a supplier outside France (reverse charge) | E-reporting | Reported by you as the buyer |
| Services invoiced to a French business | Both | E-invoice plus payment data when VAT is due on payment |
| Invoice to a public body | Chorus Pro | Unchanged public-sector channel |
New Information Your Invoices Must Carry
Customer's SIREN: identifies the buyer and drives directory routing. Delivery address: where goods or services are delivered, when different from the billing address. Nature of the operation: goods, services or both — it determines VAT timing and e-reporting. VAT on debits option: whether the supplier accounts for VAT on invoice rather than on payment.
Archiving
Invoices and their data kept for 10 years, with a reliable audit trail.
Directory Upkeep
New entities, new addresses and closures reflected promptly.
Refusal Handling
A documented process, with a reason and a route back into billing.
Impact on SAP
SAP Document and Reporting Compliance (DRC) is the standard solution: it creates the electronic invoice from the billing document, connects to the platform through SAP Business Technology Platform, and shows every document and status in one monitor. SAP has confirmed that its cloud offering passed the French interoperability testing and can act as your approved platform — so SAP can be both the ERP and the platform, or the ERP feeding a third-party platform.
Customer Invoices (Outbound)
- Billing: invoice or credit note posted in SAP.
- eDocument: DRC creates the electronic invoice automatically.
- Format: mapped to Factur-X, UBL or CII and validated.
- Platform: sent through SAP BTP to the approved platform or Peppol.
- Statuses: submitted, rejected, refused, paid — visible in the cockpit.
Supplier Invoices (Inbound)
- Delivery: your platform receives the supplier invoice.
- eDocument: it appears in SAP as an incoming eDocument.
- Verify: matched and approved (MM, VIM or Ariba).
- Decide: accept and post, or refuse with a reason.
- Status: refusal or receipt status returned to the supplier.
Statuses in SAP: the Part Teams Underestimate
Returned by the platform after sending; shown on the eDocument. To design: who monitors the cockpit daily, and how rejections get back to billing.
Triggered from your AP process when an invoice is disputed. To design: link to the existing approval or dispute workflow; reason codes; deadline to answer.
Arrives from your customer's platform. To design: route to AR and collections; decide when to credit and reissue.
From clearing in FI — the payment run, bank statement or incoming payment. To design: which clearing events publish the status, and how partial payments are treated.
Statuses are the difference between a compliant system and a busy inbox: if nobody automates them, someone ends up publishing them by hand within 24 hours, every day.
The New Operating Rhythm
| When | What to do |
|---|---|
| Daily | Check the cockpit for rejections and refusals, process incoming invoices, publish any status that is not automated |
| Weekly | Review ageing exceptions, blocked invoices and directory changes; follow up disputes with customers and suppliers |
| Monthly | Reconcile SAP, the platform and the reported data before the VAT return; review KPIs and recurring error causes |
What Else Has to Be Right in SAP
Master Data
SIREN/SIRET on every French business partner, delivery addresses, VAT numbers, and routing codes for entities inside a group.
Tax & Classification
Tax codes and document types that separate domestic B2B, B2C, EU and export flows — this drives e-invoicing versus e-reporting.
Billing Content
The new mandatory information: nature of the operation, delivery address, VAT on debits option.
Inbound Handling
Invoices arrive as data: automatic posting where possible, exception handling where not — and an end to PDF mailboxes for domestic suppliers.
Archiving
Ten years of invoices, statuses and receipts, retrievable on demand.
Regulatory Updates
SAP delivers legal changes through notes and its regulatory change tracker — plan a recurring adoption cycle, not a one-off go-live.
Three Set-ups, One Decision
SAP DRC creates and transmits; SAP's cloud service acts as the approved platform. Fits SAP-centric landscapes, France-heavy volumes. Strengths: one vendor, native integration, statuses and e-reporting inside SAP. Watch out for: licensing and scope; confirm coverage for your flows with SAP.
SAP DRC creates and hands over to your provider, which is the approved platform. Fits groups with an established global e-invoicing provider. Strengths: the provider may already cover your other countries, EDI partners and portals. Watch out for: integration effort, status handling, and who owns directory management.
SAP for France, an existing provider for other countries (or the reverse). Fits large groups mid-way through consolidation. Strengths: lets you keep working integrations while standardising over time. Watch out for: two support models and two sets of monitoring.
What Changes, by Role
Compliance risk sits in daily finance operations; payment behaviour becomes visible to the administration. Decisions: platform strategy for the group, budget, sponsor, KPIs (rejection rate, refusals, days to post).
Invoice content and classification drive both obligations; daily monitoring of the eDocument cockpit. Decisions: who owns errors; e-reporting scoping; month-end controls.
Invoices arrive as structured data; refusals must be formal, reasoned and timely. Decisions: refusal policy and deadlines; automation targets for posting.
Customer refusals become visible and traceable; 'paid' status depends on clearing discipline. Decisions: how partial payments and netting are reported; collections process.
Platform onboarding, BTP connectivity, roles, testing, archiving, monitoring. Decisions: sequence — receiving first, then issuing, then e-reporting.
A new role: SIREN/SIRET and addressing become operational data, not reference data. Decisions: clean-up before onboarding; ongoing governance.
Lessons from e-Invoicing Projects
Start with receiving. It is mandatory for every entity today and usually the least prepared process. Master data first. Most rejections trace back to an identifier or an address. Stay on standard. Custom middleware to a platform is expensive to maintain through every legal change. Plan the roles and connections early — security and connectivity cause more delay than mapping. Automate statuses, or they become a daily manual task with a 24-hour clock. One design, several mandates. France, Spain and ViDA share the same building blocks.
Readiness Self-check
- Every French entity can receive an invoice today, and someone is accountable for processing it.
- Your directory entries match how customers actually address you.
- Rejections and refusals have an owner and a deadline.
- E-reporting flows are identified and tested, not assumed.
- The 'paid' status is produced from clearing, not typed by hand.
- Invoices, statuses and receipts are archived for ten years and retrievable.
If you also operate in Spain: Spain's own B2B mandate starts in October 2027 with a different architecture (a public repository run by the tax agency). The invoice data, numbering discipline, archiving and payment-status logic are largely the same work — designing them once, per country profile, is what keeps the second mandate from becoming a second project. See our Crea y Crece briefing.
How 30 Advisory Can Help
A founder-led boutique specialised in SAP DRC & e-invoicing compliance, S/4HANA Finance optimisation and CFO/CIO strategic advisory, with SAP DRC delivery experience in France and Germany.
Readiness assessment and platform strategy
Readiness assessment: entities in scope, current status against the 2026 and 2027 deadlines, gap list. Platform strategy: SAP as approved platform, third-party provider or hybrid, with cost, risk and group-wide implications, including Peppol reach.
Fit-gap and flow classification
Fit-gap against e-invoicing and e-reporting; flow classification (domestic B2B, B2C, EU, export, services). Finance design: invoice content, master data, document types, status triggers, archiving.
SAP DRC implementation and platform connectivity
SAP DRC implementation and configuration, platform and BTP connectivity, inbound automation, status automation. E-reporting set-up and reconciliation between SAP, the platform and the DGFiP data.
End-to-end testing with your platform
End-to-end testing with your platform: rejections, refusals, partial payments, directory changes. Cut-over, operating procedures, training for AR/AP teams, and an evidence pack for auditors.
Ongoing monitoring and roadmap to 2027
Ongoing compliance monitoring: SAP notes, DGFiP updates, KPI reporting, hypercare. Roadmap to the 2027 wave, other country mandates and ViDA (2030).
An Eight-week Readiness Sprint
| Weeks | Outcome |
|---|---|
| 1–2 | Entity and flow inventory; current state against both obligations |
| 3–4 | Platform and Peppol strategy; gap list with owners and effort |
| 5–6 | Target design in SAP: content, statuses, inbound and e-reporting |
| 7–8 | Roadmap, budget and test plan for the 2027 wave |
Already Live and Struggling?
If receiving is working but rejections, refusals or e-reporting are not, we run a short diagnostic and a remediation plan before the 2027 wave doubles the volume.
Founder-led
Finance + SAP DRC depth
SAP DRC delivery: France and Germany
Boutique agility
Legal & Auditor Roles
The State registers platforms, not your processes. Proving that your own invoicing, reporting and archiving are compliant remains your responsibility.
Scope and VAT treatment, e-reporting classification, exemptions. Platform contracts, liability, data protection and sub-processing. Mandates to act on your behalf and directory responsibilities.
Reliable audit trail, archiving and evidence for the 10-year period. Controls over statuses, rejections and reconciliation with the VAT return. Independent review — whoever builds the solution should not certify it.
Design, build and run the SAP and platform solution. Produce the evidence auditors ask for: logs, statuses, receipts, test results.
Key Dates
Live now. All companies must receive; large and mid-sized companies must issue and e-report
Start-up tolerance on automatic penalties for companies genuinely engaged
SMEs and micro-enterprises must issue and e-report
Spain's B2B mandate starts for companies over €8M turnover
EU ViDA: cross-border digital reporting
Next Steps
1. Check receiving works today — for every French entity, including the small ones. 2. Confirm your platform strategy and whether it also gives you Peppol reach. 3. Close the e-reporting gap — usually the least advanced obligation. 4. Automate statuses and monitoring before volumes grow. 5. Prepare the 2027 wave across the group, with one design per country profile. 6. Keep the evidence: plan, decisions and progress, in case the start-up tolerance is ever questioned.
Three Questions that Come Up Immediately
Not for domestic B2B. A PDF sent by e-mail is no longer a valid invoice for these transactions, whatever the customer accepts in practice.
They follow the same rules if both entities are French and subject to VAT — including entities that share a shared service centre.
Every French business must have one. If the directory has no entry for them, the invoice cannot be delivered: it is a customer master-data issue to resolve before invoicing.
What a First Conversation Needs from You
Entities
French legal entities, their size and VAT registrations.
Volumes
Customer and supplier invoices per month, and the main flows.
Systems
SAP release, DRC status, and any platform already contracted.
Pain Points
Where receiving, statuses or e-reporting are failing today.
Mandate: DGFiP practical guide 'Facturation électronique : guide pratique de démarrage au 1er septembre 2026' (impots.gouv.fr) · service-public.fr / entreprendre (obligations and penalties under the 2026 Finance Act) · ecosio, Avalara, Seeburger and EDICOM guides on the Y-model, formats and e-reporting · frenchinvoice.fr (lifecycle statuses). Peppol: the DGFiP became a Peppol Authority for France in July 2025; France does not impose Peppol's own invoice format. SAP: SAP community and SAPinsider reporting that SAP's cloud compliance offering passed French interoperability testing and is available as an approved platform; SAP DRC documentation and training material. Scope, licensing and release details must be confirmed with SAP for your landscape.
Prepared by 30 Advisory, September 2026. Information only — not legal or tax advice. Rules and platform registrations change; confirm current details before acting. 30 Advisory accepts no liability for decisions taken on the basis of this document.
Not Sure What This Means for Your SAP Landscape?
We'll map your platform strategy, e-reporting and S/4HANA roadmap against the French mandate in our free 60-minute diagnostic.
Three things to check first
- Receiving works today for every French entity, including the small ones.
- Your e-reporting is as far along as your e-invoicing: it is usually the least advanced obligation.
- Every customer has a directory entry before you invoice them.
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