France's E-Invoicing reform: The PA/PPF architecture explained

France's e-invoicing reform is one of the most structurally ambitious mandates in Europe. Rather than routing every invoice through a government hub (the approach Italy took with SDI), France built a decentralised network of accredited private platforms that exchange invoices with each other, while simultaneously reporting regulatory data to a central public portal. The architecture has a name: the 5-corner model, or Y-model. Understanding it is a prerequisite for anyone building or connecting billing infrastructure for French B2B transactions.

The mandate applies to domestic B2B transactions between VAT-registered entities. It runs alongside a separate e-reporting obligation for B2C and cross-border transactions. The phased rollout begins in 2026.

The 5-Corner Model

Five participants make the system work:

1. The supplier issuing the invoice

2. The supplier's Accredited Platform (PA-e) validating and transmitting the invoice

3. The buyer's Accredited Platform (PA-r) receiving and delivering the invoice

4. The buyer receiving the invoice

5. The Public Invoice Portal (PPF) receiving regulatory data and maintaining the Central Directory

Invoices travel directly between accredited platforms (PA-e to PA-r). In parallel, the supplier's platform sends a defined regulatory data subset to the PPF. The government never receives the full commercial invoice; it receives the fields it needs for VAT compliance monitoring.

The "Y" shape of the model describes the data flows: invoices move horizontally between platforms along the top of the Y, while regulatory data flows down the stem to the PPF.

The Key Actors

1. Accredited Platforms (PA) are the only entities authorised to exchange domestic B2B e-invoices, transmit mandatory data to the administration, manage invoice lifecycle statuses, and perform e-reporting. Every in-scope business must appoint at least one PA. A business can act as its own PA if it obtains accreditation, but most companies will use a third-party platform.

2. The Public Invoice Portal (PPF) is the government infrastructure. It does two things: it maintains the Central Directory of VAT-registered businesses and their electronic invoicing addresses, and it acts as the data concentrator that receives invoice and transaction data from PAs and makes it available to the tax administration. The PPF does not exchange invoices between businesses. That function belongs exclusively to PAs.

3. Compatible Solutions (SC) are ERP systems, billing tools, and accounting software that help businesses create and structure invoices. They are not PAs. A Compatible Solution cannot connect directly to the PPF or exchange invoices in the regulated network. It must operate through a PA. For billing teams, this means your ERP or billing system connects to your chosen PA, which handles the regulated transmission.

4. Platform-to-platform interoperability is built on the PEPPOL framework. Any business must be able to exchange invoices with any other business regardless of which PA each has chosen. PEPPOL accreditation is not explicitly mandated in the legislation, but the interoperability requirements effectively require PEPPOL-compatible infrastructure.

The Central Directory (Annuaire)

The Central Directory is how the network routes invoices to the right destination. Every VAT-subject business in scope of the mandate registers in the Directory with an electronic invoicing address. The address follows the format SchemeID:Identifier.

For French domestic B2B invoicing, the scheme ID is always 0225. Four address formats are supported:

Each electronic address can be associated with only one PA at any given time. Every invoice must include both the recipient's electronic address (for delivery) and the issuer's electronic address (so lifecycle status messages route back correctly).

For billing teams onboarding French customers, collecting the correct SIREN and SIRET at signup is no longer optional. Routing fails if the buyer's address isn't in the Directory or doesn't match the format the PA expects.

Invoice Formats

Three structured formats are accepted under the reform:

UBL (Universal Business Language): XML-based, widely used across the EU. CII (Cross Industry Invoice): XML-based, used in Germany and France. Factur-X: A hybrid format embedding structured XML data inside a human-readable PDF. The PDF satisfies human readers; the XML satisfies machine processing requirements and regulatory validation.

A plain PDF does not comply. The invoice data must be structured and machine-readable from creation.

The Two Core Data Flows

Flow 1 (PA-e to PPF): The supplier's platform transmits a defined regulatory data subset to the Public Invoice Portal. This happens in parallel with invoice transmission. The PPF receives the data it needs for VAT monitoring without the full commercial invoice passing through the government.

Flow 2 (PA-e to PA-r): The supplier's platform routes the invoice to the buyer's platform using the buyer's electronic address from the Central Directory. The buyer's platform validates the invoice and makes it available to the buyer.

Both flows are mandatory. An invoice that reaches the buyer but doesn't transmit regulatory data to the PPF is non-compliant. An invoice that reaches the PPF but not the buyer is also non-compliant.

Invoice Types Covered

The mandate covers several invoice types for domestic B2B transactions:

• Standard invoices

• Down payment invoices (factures d'acompte)

• Self-billing (auto-facturation)

• Factoring invoices (affacturage)

Corrections are handled through credit notes (avoir) or rectificative invoices (facture rectificative). Both must reference the original invoice number and generate their own lifecycle events.

Invoice Lifecycle Statuses

The reform introduces a structured lifecycle for every invoice. Beyond simple transmission, invoices move through defined statuses tracked across the network.

Four statuses are mandatory and must be reported to the PPF:

The Cashed status is only mandatory in two cases: invoices for services where the supplier hasn't opted to pay VAT on invoice issuance (TVA sur les débits), and invoices for down payments on goods or services (where VAT is always due on receipt of the acompte regardless of the supplier's general VAT election).

Other statuses (Received, In Dispute, and others) exist in the framework but are not mandatory for PPF reporting.

Operational Edge Cases

Buyer not yet on a platform. Every business in scope is legally required to choose a PA and receive invoices electronically. If a buyer is registered in the Directory but hasn't yet selected a PA, the supplier still must issue the e-invoice. The supplier's platform transmits data to the PPF and generates a Deposited status with the reason NON_TRANSMISE. The supplier remains compliant. The buyer can't demand a paper invoice as a workaround. To get paid, the supplier can contact the buyer directly and send a duplicate outside the platform. If the buyer sets up a PA quickly, the supplier's platform can optionally replay the transmission so the invoice arrives through the regulated network.

Buyer not in the Directory. If a VAT-registered buyer is absent from the Central Directory due to administrative delays or technical issues on the government's side, the supplier can temporarily treat them as a non-taxable person and submit the transaction through the B2C e-reporting flow rather than the B2B e-invoicing flow. Neither party faces penalties in this case, provided the e-reporting data is correctly submitted. This tolerance also covers entities without a SIREN number.

What This Means for Billing Infrastructure

For any company billing French B2B customers, the reform requires changes at multiple layers of the billing stack.

Your invoices must be produced in UBL, CII, or Factur-X format natively or via a certified transformation. Your billing system needs a connection to an accredited platform. Customer records must store SIREN and SIRET numbers, not just names and addresses. Your system needs to handle lifecycle status callbacks from the PA: rejected, refused, and cashed events need to flow back into your accounts receivable workflow, not disappear into a compliance black box. And archiving needs to store the original structured file, not just a PDF rendition.

For companies already using a modern billing infrastructure that separates metering, invoicing, and payment collection, connecting a PA as a transmission layer is the cleaner path. For companies where billing and invoicing are tightly coupled in legacy ERP systems, the reform is often the trigger for a more substantial infrastructure rework.

FAQ

Q: What is the PPF and does it replace accredited platforms?

The PPF is the government portal that receives regulatory data and maintains the Central Directory. It does not exchange invoices between businesses. That function is reserved exclusively for Accredited Platforms (PAs). Businesses connect to a PA, not directly to the PPF.

Q: Can a business act as its own accredited platform?

Yes, if it obtains accreditation. The requirements for accreditation are substantial: technical, security, and operational standards set by the French tax administration. Most businesses will use a third-party PA rather than seek accreditation themselves.

Q: What is the difference between e-invoicing and e-reporting under the French reform?

E-invoicing covers domestic B2B transactions between VAT-registered entities. E-reporting covers transactions outside B2B domestic scope: B2C transactions and cross-border B2B. Both obligations run in parallel and use different data flows. A supplier issuing an invoice to a foreign customer must submit e-reporting data to the PPF rather than route through the B2B e-invoicing flow.

Q: When does the French reform apply to my business?

The reform rolls out in phases starting in 2026, with large companies first and smaller businesses following. Issuance obligations (sending e-invoices) phase in before reception obligations (receiving them). All in-scope businesses must be able to receive e-invoices from the first phase regardless of their own issuance timeline.

Q: How does PEPPOL relate to the French reform?

The reform requires interoperability between platforms, and the technical framework for that interoperability is built on PEPPOL. PAs must support PEPPOL-compatible communication to ensure that invoices can flow between any two platforms regardless of which each party has chosen. For companies with billing infrastructure already connected to PEPPOL for other markets, the French reform uses the same network layer.

Q: What are the penalties for non-compliance?

The reform includes financial penalties for non-issuance and non-transmission of e-invoices. The French tax administration has also reserved the right to conduct automated controls using the data received through the PPF, making VAT gap detection more systematic than under paper-based regimes.

Here are three commercial-intent Q&As for each article. You can drop them into the FAQ sections.

Q: Is Solvimon an accredited platform under the French e-invoicing reform?

Solvimon's infrastructure is built to support the French mandate, including the structured invoice formats (UBL, CII, Factur-X), the PA connectivity layer, and the lifecycle status flows (Deposited, Rejected, Refused, Cashed) that the reform requires. If you're preparing your billing stack for the French rollout, speak with the Solvimon team about how we connect into the PA/PPF architecture for your specific setup.

Q: We bill French B2B customers today on a usage-based model. What changes when the mandate goes live?

Your invoices need to shift from PDF to structured format, your billing system needs to connect to an accredited platform, and your customer records need SIREN/SIRET identifiers for every French B2B account. For usage-based billing, the line-item data requirements are more demanding than for flat subscriptions: each consumption item needs to be structured and machine-readable, not just a total amount on a PDF. Solvimon handles usage-based billing with the structured data granularity the French reform requires.

Q: How early should we start preparing for the French e-invoicing rollout?

Earlier than most teams think. Collecting SIREN and SIRET numbers from existing customers takes time, especially for accounts that were onboarded before these fields were required. Connecting to an accredited platform and testing the PA-to-PA flows before the mandate deadline avoids the compliance risk of scrambling at go-live. Solvimon is already working with customers on French mandate readiness. Now is the right time to map your billing infrastructure against what the reform requires.