Executive summary

The publication of Decree No. 2026-677 and Order of 27 July 2026 (the Decree and Order) marks a further milestone in the implementation of the French electronic invoicing and e-reporting reform. These texts provide anticipated clarifications on the target architecture, operating procedures for accredited platforms, the role of the central directory, portability mechanisms between platforms, and the technical formats to be used for electronic invoice exchanges and tax data reporting.

Beyond these technical clarifications, the new texts definitively confirm the evolution of the French model toward an ecosystem based on interconnected accredited platforms, with the tax authorities no longer acting as a direct invoice exchange platform.

Note, however, that the substance of the Decree and Order had already been known to the ecosystem — accredited platforms, advisers and software providers — following several announcements that the French tax authorities (DGFiP) made on 15 October 2024 and again in summer 2025. For businesses, these developments therefore do not call into question the workstreams already underway.

Decree 2026-677 of 27 July 2026: key developments

Confirming the "accredited platforms" model

The main substantive change concerns the removal of the Public Invoicing Portal (Portail Public de Facturation or PPF) as a platform for issuing and receiving electronic invoices. The regulatory texts note that this information is not new, as the DGFiP had already announced it in October 2024.

It is therefore confirmed that the system will now rely on:

• Accredited platforms responsible for issuing, receiving and transmitting invoices
• A central directory enabling the routing of flows
• A dedicated solution operated by the tax authorities to receive tax data, transaction data, payment data and processing statuses

Implications for businesses

Selecting an accredited platform is a key part of building a compliant operating model. Groups that have not yet finalized their platform strategy will need to confirm their target scenarios quickly, secure their integration roadmap and anticipate the related contractual and operational impacts.

Introducing a comprehensive framework for portability between platforms

The Decree creates several new articles dedicated to changing accredited platforms. This formalizes some regulatory text positions that the DGFiP has announced since summer 2025.

This new framework introduces:

• The obligation to obtain the client's formal agreement
• Regulatory transfer timelines
• Controlled objection mechanisms
• An arbitration role for the tax authorities in the event of a dispute
• Service continuity obligations for 12 months after migration

Why is this topic strategic?

Until now, reversibility was mainly addressed through supplier contracts.

The legislature is now introducing a regulatory framework designed to prevent situations of excessive dependency (referred to as "vendor lock-in") and to help guarantee the portability of businesses between platforms.

Strengthening requirements for accredited platforms

The Decree confirms the conditions for registration and continued accreditation of platforms, in addition to introducing some new points, including:

• An ISO 27001 certification requirement, clarifying the accreditation conditions applicable to certification bodies (Note: ISO 27001 is a voluntary international standard to improve information security.)
• A requirement to, in all cases, identify the persons exercising control over an accredited platform to register the platform
• An obligation to declare any "substantial modification"
• The addition of annual surveillance audits between two registration renewals

Central directory becomes a critical component

The new provisions detail the content of the central directory as well as the mechanisms for managing electronic invoice receipt addresses.

In particular, the text formalizes the rules for identifying businesses, defining invoice-recipient addresses, using routing codes to send invoices to the correct place, handling companies that belong to a value-added tax (VAT) group or similar single taxable person, updating directory information and managing changes when a business changes platforms.

Order of 27 July 2026: key developments

Stabilizing the French technical framework

The Order provides the technical clarifications that had been expected for several years. In particular, it confirms that accredited platforms must comply with both the required formats and applicable profiles and must:

• Use EN16931 profiles (CII, UBL, Factur-X)
• Comply with the French "EXTENDED-CTC-FR" profile, and therefore to develop this extension
• Follow the specifications of French Standardization Association (Association Française de Normalisation or AFNOR) standard XP Z12-012
• Follow the specifications of standard XP Z12-013 relating to application programming interfaces (APIs)
• Follow the specifications of standard XP Z12-014 relating to use cases, if the accredited platform decides to develop them

The requirement relates not only to European EN16931 standard for electronic invoicing, but also to its specific implementation in the French context.

Clarifying data expected in invoices

The Order confirms a gradual increase in the granularity required for the data in electronic invoices.

First stage

From the start of the system, on 1 September 2026, identification data and key tax data must be transmitted in structured form.

Second stage

From 1 September 2027, more detailed information must also be available in structured form, including the description of goods or services, quantities, unit prices, discounts, surcharges, delivery address and specific environmental data.

In practice, many businesses and accredited platforms have already organized the development of their solutions at the line-item level in anticipation of the reform's target requirements.

Strengthening compliance checks

The Order specifies the checks that accredited platforms must perform.

Among the main checks previously announced — consistency of VAT amounts, validity of identifiers and compliance with prescribed formats — an additional check on uniqueness of the numbering of invoices has been added.

Conclusion

The Decree and Order provide the regulatory clarity needed to finalize compliance projects. They confirm the central role of accredited platforms and the central directory, while strengthening requirements relating to data quality, governance and interoperability.

For businesses, the challenge is no longer to understand the future architecture of the system, but to secure its operational execution. Organizations that start work now to address data and governance should be better positioned to achieve a successful transition to the new French electronic invoicing model.