France: Regulatory framework established for e-invoicing and digital reporting reform

Decree No. 2026-677 and Order of July 27, 2026, published on July 28, 2026, complete the regulatory framework for France’s upcoming e-invoicing and digital reporting regime. The texts do not alter the implementation timeline. However, they are significant for multinational businesses and technology providers because they establish key governance, accreditation, interoperability, platform mobility, and compliance requirements for accredited platforms (Plateformes Agréées).

Background

France introduced its e-invoicing and digital reporting mandate to modernize VAT compliance and improve transactional transparency. The reform covers domestic B2B and B2G sales, with phased implementation starting in 2026. All resident and nonresident taxpayers established in France, as well as accredited platforms, must comply with the new requirements. The continuous transactions control (CTC) model relies on a central directory for invoice routing and mandates the use of certified platforms for invoice exchange and reporting.

Overview of amendments

Platform mobility and taxpayer protections

• Formal platform-switching process: The order establishes a regulated framework for transferring a taxpayer from one accredited platform to another. This process is anchored by a formal mobility agreement, ensuring uninterrupted invoice routing and business continuity.
• Directory information safeguards: Platforms cannot modify invoice-routing information in the central directory without a signed authorization from the taxpayer. This rule protects multinational groups with complex structures from unauthorized changes.
• Detailed mobility agreement requirements: The agreement must identify the taxpayer, company registration details, departing and incoming platforms, the effective date, affected routing addresses, and include the signature of the taxpayer’s legal representative. It may cover multiple entities within a group.
• Free mobility documentation: Accredited platforms must provide clear, accessible, and free documentation explaining the mobility process, responsibilities, timelines, required information, and support procedures.
• Data integrity during format conversion: If a platform converts invoice formats and cannot guarantee data preservation, it must provide a readable version with the full original content, protecting against data loss during format transformations.

Accredited platform requirements

• Explicit certification framework: Platforms must obtain and maintain ISO/IEC 27001 certification issued by a body accredited under Regulation (EC) No. 765/2008 and recognized by international frameworks such as the International Accreditation Forum (IAF) and Global Accreditation Cooperation (GAC). This clarification is crucial for foreign providers seeking accreditation in France.
• Expanded governance responsibilities: Accredited platforms are now responsible for managing taxpayer addressing information, handling platform-switching, retaining mobility agreements, maintaining evidence of taxpayer authorizations, and ensuring proper archiving and traceability.
• Concrete interoperability requirements: Platforms must demonstrate the ability to exchange information with the central directory, the tax authority (Direction Générale des Finances Publiques (DGFiP)), and other accredited platforms during the accreditation process.
• Annual surveillance audits: The order introduces regular surveillance audits covering at least one month of recent operational activity. Platforms must also disclose any substantial changes since the previous audit, making accreditation an ongoing obligation.
• Mandatory disclosure of significant changes: Platforms must report substantial compliance-related changes between audits.
• AFNOR standards incorporated: The order makes several AFNOR standards legally binding, including:
  • Invoice formats and profiles (XP Z12-012: EN16931/CII, UBL, EXTENDED-CTC-FR, Hybrid PDF/A-3 with embedded XML)
  • Business process specifications (XP Z12-014)
  • Standardized APIs (XP Z12-013)
• Invoice-number uniqueness: The order reinforces the requirement for unique invoice numbers as part of validation controls.

Next steps

The implementation timeline for the e-invoicing and digital reporting mandate remains unchanged. Accredited platforms and taxpayers may need to review the new requirements, update compliance procedures, and prepare for the forthcoming phases of the mandate. Platforms seeking accreditation must ensure their certification and operational processes align with the clarified standards. Ongoing surveillance audits and disclosure obligations require continuous compliance monitoring.

For more information, contact a KPMG professional:

Laurent Chetcuti | laurentchetcuti@kpmgavocats.fr

Armelle Courtois-Finaz | acourtois-finaz@kpmgavocats.fr

Philippe Stephanny | philippestephanny@kpmg.com

Ramon Frias | ramonfrias@kpmg.com