Two Texts Complete France's E-Invoicing Rulebook: What the 27 July 2026 Decree and Order Change

The short version

On 28 July 2026 France published two texts that fill in the detail of its e-invoicing reform: a decree and an order, both dated 27 July. They have applied since 29 July. Neither changes when the reform starts. What they change is how it works.

Four things matter. The partner dematerialisation operator, the PDP of every slide deck and RFP, is now the plateforme agréée, the approved platform. The public portal that businesses could once transmit through no longer appears in these articles as a route, so every business in scope goes through an approved platform. Changing platform, which used to be a purely commercial matter, is now a regulated procedure with fixed deadlines and an appeal to the tax authority. And approved platforms take on a repeating audit, so the bar to stay approved is higher than the bar to get there.

If you buy e-invoicing rather than build it, most of this lands on your provider. The parts that land on you are worth twenty minutes: check who receives invoices on your behalf, ask your provider for the switching documentation it now has to give you free of charge, and confirm how often your transaction data is being sent.

What France published on 28 July 2026

The two texts appeared in the Journal officiel of 28 July 2026 as texts 26 and 27 of 127: decree 2026-677 of 27 July 2026 on the generalisation of electronic invoicing, and an order of the same date. Each comes into force the day after publication. Both are made for the application of the tax code articles rewritten by article 123 of the Finance Act for 2026.

They divide the work the way French texts usually do. The decree carries the conditions a platform has to meet. The order carries the technical detail underneath: what auditors check, which invoice formats are accepted, what documents must contain, how data reaches the tax authority. Read on their own, each looks like a tidying exercise. Read together, they change the shape of the French model.

The order also moves two dates into line with the reform, replacing 1 July 2024 with 1 September 2026 and 1 January 2026 with 1 September 2027. Both texts were notified to the European Commission in March 2026 under the procedure for technical regulations, and the Conseil d'État was heard on the decree, so neither arrived unannounced. For the mandate timetable itself, which neither text changes, see the France e-invoicing guide and the country profile.

The PDP is gone, and so is the public route

By volume, renaming is what these texts mostly do. Article after article, the opérateur de plateforme de dématérialisation partenaire becomes the plateforme agréée (PA), the approved platform. The rewrite reaches the grammar, since the French noun changes gender and successive provisions swap il for elle. Anyone with PDP in their slide decks has some editing to do, and the term is already used this way in the French platform guide.

The change worth noticing sits underneath. The portail public de facturation is written out of these articles. A heading that read "Le portail public de facturation" now reads "L'annuaire central et la transmission des données à l'administration". Where the portal was named as a destination, the texts now say "the administration", "approved platforms", or the shared solution used for public sector invoicing. Transmissions that could be made to the portal by one of three modes are now made through an approved platform. Data still reaches the tax authority, but by a dedicated collection solution that gathers invoicing, transaction and payment data and the processing statuses. It collects. The articles no longer describe it as a road invoices travel down.

What the texts describe instead is a set of approved platforms around a state directory. The annuaire central holds the addressing information, and the interoperability requirement is now explicitly platform to platform. Invoicing data goes to the tax authority from the sender's platform. To be registered, a platform has to prove by test that it can work with four counterparties: the central directory, the tax authority's own solution, the shared public procurement solution, and at least one other approved platform, either under a bilateral agreement or through a network protocol. Neither text names a network; that last route is the category a network such as Peppol belongs to, and it is what makes the arrangement a four-corner model rather than a hub.

Switching platform becomes a right, with a clock on it

This is the genuinely new material, and it is the part most worth reading if you are a customer rather than a provider. A business that receives electronic invoices can ask, at any time, to change the addressing details held for it in the central directory. Three new articles then set out who does what, how long each step takes, and what happens if the two platforms disagree.

Everything starts with the accord formel, the formal agreement. A platform cannot touch your entry in the directory without one. It has to identify you, the platform taking over and, where there was one, the platform leaving. It states the date from which the new platform acts for you and exactly which of your electronic addresses are covered. You or your agent date and sign it, and the incoming platform keeps and numbers it, holds it for three years after it stops having effect, and produces it to the tax authority on request.

The order goes as far as prescribing the wording. Your addresses are described on four model lines running from your main SIREN-level address down to functional addresses, and the agreement itself is filed under a set reference format. That level of prescription sounds bureaucratic, and it is, but it is what makes a switch mechanical rather than negotiable.

Then the clock runs. The incoming platform has two working days to tell the outgoing one that a signed agreement exists. The outgoing platform has five working days to object, and it can only object on grounds that cast doubt on whether you really meant to move, such as a more recent agreement signed with someone else. Silence counts as agreement. From there the incoming platform has fifteen working days to update the directory and tell you it has done so, and the effective date has to leave it at least three working days to synchronise cleanly with any network registers.

If the outgoing platform does object, both must tell you why without delay, and you can simply sign a fresh agreement. Either platform can also refer the matter to the tax authority, which can ask both sides, and you, for more information, and then has ten working days from receiving everything it needs to say which platform may make the change. Your directory entry is frozen while that runs. Separately, every platform acting for a recipient now has to give its customers documentation on switching, free and without conditions, covering each party's role at each stage, the deadlines, what you may need to supply, and how to complain.

What the outgoing platform still owes you

Moving provider raises an obvious question: what happens to everything already sent. The decree answers it. Where a platform stops serving you after a switch, the services listed at 6° of the article setting out platform obligations carry on for a year. During that year, if you ask for information it holds that you need to keep trading, it has five days to hand it over.

The decree is also careful to keep the directory and the contract apart. Changing your addressing details, done on the strength of the formal agreement alone, does not prejudge whether your contracts with either platform are valid, still running, or terminated. Moving your entry and ending your contract are two separate acts. Only the first has the deadlines above attached to it, which is worth knowing before anyone assumes a switch cancels a notice period.

Harder to get approved, harder to stay approved

This section is mostly about platforms. If you buy from one rather than run one, the short version is that the bar went up in three places, and you can now ask your provider harder questions than you could last month.

First, ownership. A platform now has to declare who controls it, in the company law sense. That applies to applications already sitting with the tax authority, and platforms already registered have two months from the end of July to say who controls them, evidenced when they come to renew. It is a transparency requirement, and it hands customers a question they could not previously ask.

Second, certification. The security certificate a platform relies on now has to come through an accredited chain: a certification body accredited by the French accreditation committee, by another national accreditation body under the EU accreditation regulation, or by an equivalent body signed up to the international recognition agreements, which the order identifies as those covering ISO/IEC 27001 under the International Accreditation Forum and the Global Accreditation Cooperation. A certificate from an unaccredited certifier no longer counts. The ISO 27001 explainer covers what the certificate itself involves.

Third, and most expensive, the audit cycle. The initial compliance audit now has to cover at least a month of real activity after the platform was registered. On top of that sits a new surveillance audit due by the end of the second year, then two more in the two years following each renewal. Where an audit finds a non-conformity, the platform has to tell the tax authority what it is doing about it, and cannot give itself more than three months. The order also adds a new thing for auditors to check: whether the platform is keeping, tracking and archiving those switching agreements properly. The paperwork from the previous section is now inside the audit scope.

Formats: five ways in, and a safety net

Most businesses will never choose between invoice formats. Your platform does that. It is still worth knowing what the shelf looks like, because the choice determines how much of your invoice detail survives the journey.

There are five options, built from two technical languages and two levels of detail. The two languages are UN/CEFACT CII and UBL, and each carries either the standard European profile or a French extension of it for data the European core cannot hold. The fifth option is the hybrid: the structured data wrapped in a PDF a person can actually read. Neither text calls it Factur-X, but that is the pattern the market knows by that name. All five sit on the same European standard and follow the same AFNOR specification.

The addition worth flagging is the safety net. When a platform converts an invoice from one format to another, detail can be lost. The order now says that where a conversion cannot strictly guarantee the data's integrity, the platform doing it must also pass on a readable copy of everything it received before converting. That runs in both directions: the sender's platform converting on the way out, and the recipient's platform reformatting on the way in. The obligation follows whoever converts, which is the right place for it.

Two smaller changes land on platforms rather than on you. Checking that an invoice number is unique becomes a required check, and a platform passing on lifecycle statuses does not have to verify that what it is passing on is valid.

Reporting: fewer fields, a firmer rhythm

The changes to how often data is sent are small in wording and easy to miss. Where the rules used to say "at least" a given number of transmissions, they now say that number. A floor became a fixed count, which matters because a fixed count can be reconciled and a floor cannot. Two-month periods become calendar two-month periods, which removes the argument about when anyone's two months start.

Two additions make the regime workable. Frequency is now assessed per approved platform, which matters for any group splitting its flows across providers and which would otherwise have looked like under-reporting at each one. And where there were no transactions in the period, no transmission is required, which settles the question of whether a nil return was expected.

The data itself is trimmed and sharpened. The transaction figure reported becomes the taxable base rather than the total amount, two data points drop out, and payment amounts are now expressly in euros. A new line covering price increases, fees and charges joins the data table, and the dates from which the listed data must be transmitted move to 1 September 2026 and 1 September 2027.

Three things for the lawyers

The rest of this piece is for everyone. This part is for whoever has to read the texts side by side, because they do not entirely agree with each other.

The order describes a surveillance audit "mentioned at article 242 nonies C bis" and points at that article's second and third paragraphs. The decree published beside it creates no such article. It puts the same audits somewhere else, and the substance matches on both sides, so the intent is not in doubt. The reference is. A second slip in the same order reproduces one article under the heading of another.

The two texts also differ on the same document. The decree says the formal agreement is signed by the recipient of the invoices or their agent; the order says it is signed by the recipient's legal representative. On certification there is a comparable gap: the decree has a certification body accredited by an accreditation body, the order says the certification is delivered by an accreditation body. Anyone designing a signature flow or a certification file will want to satisfy the stricter reading of each.

Finally, a real part of the compliance surface has moved out of the texts and into specifications published on the tax authority's website: the structure of the file carrying the reported data, and the secure protocols used to send it. That is sensible, since specifications version faster than decrees. It also means that part of the rulebook now changes without a Journal officiel entry, so anyone building against it needs to track versions rather than read once.

What to do before 1 September

If you are a business, start with your entry in the directory, because that is what the new procedure protects. Confirm which approved platform is listed as receiving for you, check which of your addresses it covers, and make sure the four levels of address in the order match how your sites and routing codes actually work. Then ask your platform for the switching documentation it now has to give you free of charge. Its quality is a fair proxy for how a move would actually go. Finally check the practical things: what you are owed for the year after a move, whether your transmission rhythm matches the new fixed counts, and whether any of your invoice data needs the French extension rather than the core profile. The platform readiness gap analysis and the e-Invoice Readiness Scorecard help find the gaps, and what finance teams get wrong about the reform sets these texts inside the wider VAT control picture.

If you operate a platform, three deadlines are already running. The ownership declaration is due within two months. The surveillance audit needs scheduling now, because it has to cover real activity inside a defined window and cannot be arranged the week before. And handling switching agreements has become something auditors check, which means numbering to the prescribed model, retention for three years, production on demand, and a two-working-day turnaround on notifying the platform you are taking a customer from. Add the fallback readable copy to the build list while you are at it.

The wider point is simple enough. The exchange path in these articles now runs entirely through approved platforms, the directory is the single record of where an invoice goes, and the rules for moving between providers are written down with deadlines attached. That makes provider choice more consequential and provider exit more predictable. Both are worth reading alongside the wider 2026 compliance picture and the ViDA timetable. If you are still choosing, the provider directory lists who serves the French market.

What is a plateforme agréée, and what happened to PDPs?

They are the same thing under a new name. The decree and order of 27 July 2026 replace opérateur de plateforme de dématérialisation partenaire with plateforme agréée (PA), the approved platform, throughout the tax code annexes. Platforms registered before the decree carry on towards renewal under transitional rules that set out what they must produce and by when. Alongside the renaming, registered platforms must declare who controls them, rely on a certificate delivered through an accredited chain, and produce a repeating surveillance audit. The exchange articles no longer name the public portal as a route, so every business in scope needs an approved platform.

Can I change e-invoicing platform in France, and how long does it take?

Yes, and you can ask at any time. You sign a formal agreement with the incoming platform. It has two working days to notify the platform currently listed in the central directory, which has five working days to object on narrow grounds. Once agreement is given or the window passes, the incoming platform has fifteen working days to update the directory, and the effective date must leave at least three working days for synchronisation. A contested move can be referred to the tax authority, which has ten working days from receiving everything it needs to decide. Your former platform keeps providing the services it owes you for a year and hands over information you need within five days of a request.

Is the portail public de facturation still used in France?

Not as a route in these articles. Data still reaches the tax authority, but through a dedicated collection solution rather than a portal businesses transmit into, and the option of sending directly by one of three modes has been replaced by transmission through an approved platform. The shared solution used for public sector invoicing stays in the picture: it appears alongside approved platforms in the directory article, and platforms have to prove by test that they can work with it. For business-to-business exchange, the invoice travels platform to platform.

Which invoice formats does France accept?

Five, built from two technical languages and two levels of detail. UN/CEFACT CII and UBL each carry either the standard European profile, called profil EN16931, or a French extension of it called profil EXTENDED-CTC-FR. The fifth is the hybrid: structured CII data together with a PDF that is the readable version of the invoice. All five follow the same AFNOR specification, and where a conversion between them cannot strictly preserve the data, the platform doing it must also pass on a readable copy of everything it received beforehand.