Regulatory updates - France

On March 24, 2025, a draft amendment was adopted by the French committee of National Assembly. The amendment proposes to delay the initial introduction of the French CTC mandate on September 1, 2026, by the following timelines:

• September 1, 2027: Large and Intermediate companies
  • This date may be postponed by a decree until December 1, 2027, at the latest;

• September 1, 2028: Small, Medium and Micro companies
  • This date may be postponed by a decree until December 1, 2028, at the latest.

The main reason for this potential delay proposed by the amendment has to do with the changes to the PPF (Portail Public de Facturation), the Government’s e-invoicing platform, in October of last year. Previously, it was intended that the PPF would have a central part in the distribution of e-invoices and would offer a free-of-charge alternative for companies to choose. This is no longer the case, and the draft amendment aims to give companies more time to prepare, considering the changes that happened.

It is uncertain if the draft amendment will pass the next steps of the legislative process in its current form, but if it does, it would mean yet another delay to the French reform. The final vote on the draft amendment is expected in April 2025.

On Friday, December 13, 2024, it was announced that France will have their own Peppol Authority. Until the administration is ready to assume the role, OpenPeppol will be acting as an interim Peppol Authority for France.

The role of a Peppol Authority is to oversee and manage the implementation and operation of the Peppol network within a designated country. The key responsibilities of a Peppol Authority within its jurisdiction include:

• The accreditation of Peppol access points and service providers;
• Ensuring participants follow Peppol standards and regulations;
• Providing support and guidance to businesses and the public sector on how to use Peppol.

The creation of the Peppol Authority in France is yet another step toward Peppol becoming the main interoperability framework and infrastructure between the certified service providers (PDPs) in the French mandate. Additionally, OpenPeppol, supported by FNFE and GENA, has also been conducting a successful Proof of Concept (PoC) in France, testing the use of the Peppol network on the requirements of the French mandate over the last two years. With the PoC concluding in Q4 2024, its results will help shape the technical development of Peppol in France.

On 15 October, the General Directorate of Public Finances (DGFiP) announced that there would be a major change in the upcoming French e-invoicing and e-reporting mandate. According to the announcement from the DGFiP, the role of the public invoicing platform (PPF) is being shifted towards data collection and aggregator, and will no longer have a central role in the distribution of invoices between buyers and suppliers.

In short, France is moving from a hybrid invoicing model with a central platform and decentralized certified service providers (PDPs) towards a pure 5-Corner model only using the PDPs for invoice distribution and data extraction. The PDPs will be responsible for facilitating transmission between buyers and suppliers and handling the e-reporting of the transactions to the PPF.

This means that software providers and businesses who intended to connect directly to PPF to exchange invoices will no longer be able to do so. Instead, they will have to contract the services of a PDP platform.

At this point, there are over 70 registered PDPs, with more coming. The DGFiP has expressed their full confidence that these certified service providers will offer the security and quality to bear the bulk of the functions with the upcoming mandate and help businesses comply.

Although it has yet to be officially confirmed by the administration, Peppol is now expected to be the main framework and infrastructure used to ensure interoperability between the PDPs for the mandate. It is filling the gap for the PDPs on what protocols and communication channels should be used for sending and receiving e-documents between themselves.

The current timeline for the introduction of the French mandate remains the same.

• 1 September 2026 - obligation for all companies to be able to receive e-invoices and for large companies and mid-sized companies to issue e-invoices;
• 1 September 2027 - obligation for small and medium-sized enterprises and microenterprises to issue e-invoices.

There are many more ramifications with this new change in policy and more to come. Stay tuned with Pagero for the latest updates on the French mandate.