Your client invoices France: the four questions to ask this month

On 1 September 2026 France switched on its e-invoicing obligation. Since that date every business established in France must be able to receive e-invoices, and large and mid-sized companies must also issue them and e-report; small and micro companies follow on 1 September 2027. Between French businesses, emailing a PDF, even one with XML embedded, no longer satisfies the rule.

Most of the coverage has been written for French companies. This piece is written for the accountant of a Dutch or Belgian company that sells to France, because that is where the question lands first and where it is easiest to miss.

The point that gets missed is simple. France’s e-invoicing obligation applies only when both supplier and customer are taxable persons established in France. A company in Eindhoven without a French establishment is outside it, even with a French VAT number. Its French business customer reports the purchase through e-reporting instead. What does change is how that customer now receives invoices.

Which of your clients are affected

You can answer this from the administration, without asking anyone.

Look in the debtor ledger for VAT numbers starting with FR. Any client with French VAT-registered customers sells to businesses that now receive e-invoices through an approved platform. Whether the client itself falls under the obligation turns on one question: does it have a French establishment? Without one it is outside, even with a French VAT number.

Two groups usually surface:

1. Regular exporters. They know they sell to France, and they will often already have had a question from a French customer. These are the ones you can help most concretely.
2. Occasional exporters. One or two French invoices a year, usually not on anyone’s radar. These are the ones who will be caught by surprise in a quarter, because nothing about their process looks like it needs changing until an invoice comes back.

The second group is larger than most firms expect.

The four questions

For each client with French customers, four questions settle the position. They take about ten minutes per client.

1. Are your French customers reachable on Peppol?

This is checkable, per VAT number, without contacting anyone. The Peppol Directory is public, and a lookup returns a yes or a no in seconds. You can run it on our free Peppol check one number at a time; no account, no credit card.

A customer who is reachable can receive a structured invoice today. A customer who is not either routes through an approved platform that has not published a Peppol address, or is not ready. Which brings you to question two.

2. If not reachable, which approved platform has that customer chosen?

France did not build a Peppol-only, four-corner model like Belgium and the Netherlands. It uses a network of approved platforms around a public portal, with three roles:

• PPF (Portail Public de Facturation): the public portal. It no longer exchanges invoices, but runs the central directory and passes invoice data to the tax authority.
• PA (plateforme agréée, formerly PDP): approved private platforms that businesses connect to. Approved platforms interconnect with each other and pass data to the PPF.
• OD (Opérateur de Dématérialisation): non-approved providers that ride on an approved platform.

Every e-invoice between French businesses must travel through an approved platform (plateforme agréée, PA); the public portal (PPF) no longer exchanges invoices but runs the central directory and passes invoice data to the tax authority. Direct EDI between two parties, with no approved platform, does not satisfy the rule either.

So your client’s French customer has to have chosen an approved platform. If they cannot name one, they are behind, and your client should plan for manual handling in the meantime. That is a useful thing to know in September rather than in November.

3. Can your client’s own system produce a structured invoice at all?

France accepts three base formats on equal terms: UBL, CII and Factur-X.

Most accounting packages sold in the Netherlands and Belgium can produce UBL, because the Belgian mandate of 1 January 2026 forced the issue. Whether the specific export profile satisfies EN 16931 is a separate question, and it is worth validating one real invoice rather than trusting the vendor’s feature list.

4. How does the invoice actually reach France?

For most non-French SMEs the path of least resistance is the Peppol bridge. Several approved platforms accept Peppol BIS Billing 3.0 invoices. The sending company does not have to integrate with the French stack directly: it sends to its own Peppol Access Point, the customer’s platform receives, the customer is reachable.

That is worth stating plainly to a client who is bracing for a French integration project. In many cases there isn’t one.

When the answer is no

If a client cannot send structured invoices to a French customer today, the practical order is:

1. Confirm which specific customers are affected. Usually it is fewer than the client fears.
2. Ask each of those customers which approved platform they use and whether that platform accepts Peppol. Most do.
3. Check what the client’s own accounting package can already export, and validate one real invoice against the format before relying on it.
4. Agree what happens in the meantime, so the invoice does not stall in the customer’s accounts payable.

Point four is the one that moves people. The compliance argument is abstract; a stalled receivable is not.

The timeline, on one column

• 16 January 2026: the tax authority published its first 101 approved platforms.
• 1 September 2026: receiving obligation for every business established in France. Sending and e-reporting obligation for large and mid-sized companies (mid-sized: fewer than 5,000 people and turnover of at most €1.5 billion or a balance sheet of at most €2 billion).
• 1 September 2027: sending and e-reporting obligation extended to small and micro companies (small: fewer than 250 people and turnover of at most €50 million or a balance sheet of at most €43 million).
• E-reporting (transaction data for B2C and cross-border trade) follows the same calendar as sending: 1 September 2026 for large and mid-sized companies, 1 September 2027 for small and micro companies.

The date that surprises people is the first one, and it lands on your client’s customer rather than on your client. Even a small French company not yet obliged to send electronically is obliged to receive from its French suppliers. An invoice from your client, without a French establishment, stays outside that rule; the customer reports it through e-reporting.

What this means for your firm

This is a ten-minute conversation per client that most of them do not know they need. Running the VAT numbers takes an afternoon across a whole client base, and it produces a short list of names with a concrete, dated problem.

France is also not the last of these. Belgium went live on 1 January 2026, Poland’s KSeF in February and April 2026, and the German B2B regime is phasing in. The clients you map now are the same clients you will map again for the next jurisdiction, and the work gets cheaper each time.

If you want to start with the part that needs no preparation, take the twenty largest French customers across your client base and check their Peppol reachability. The ones that come back negative are your conversation list for this month.

Who wrote this, and what we do

This article comes from SealDoc, and it is fair to ask what that is before you click a link. Two things, and it helps to keep them apart.

The first is e-invoicing. Generating and validating invoices in Peppol BIS Billing 3.0, Factur-X, ZUGFeRD and XRechnung, through an API or through n8n and Make. The free Peppol check above runs on that same engine, as does the validator where you can hold an existing invoice against the format.

The second is the evidence layer underneath, and that is where it gets interesting for a practice. Every document that passes through becomes a PDF/A-3B, validated against ISO 19005-3, timestamped by default with RFC 3161, and recorded in a SHA-384 hash chain and a chain of custody that capture who did what and when. That exports as a single Evidence Pack: the document, the audit trail and the manifest, in a form you can hand to an auditor.

The reason it exists is prosaic. A PDF in a folder proves you have a file. It does not prove when the file came into existence, nor that not one byte has changed since. For an invoice that has to survive seven years or more, that is a difference you only notice at the moment someone asks. By then it is too late to arrange.

Everything runs on European infrastructure. If you want to see what it is without installing anything, the Peppol check and the validator need no account and no credit card. A fuller explanation is on what is SealDoc.