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

On 1 September 2026 France switched on its receiving obligation. Every French business, whatever its size, must from that date be technically able to receive a structured electronic invoice. 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 reason it gets missed is simple. The mandate does not attach to where your client is established. It attaches to where their customer is. A company in Eindhoven with no French entity, no French VAT registration and no French staff can still be caught by it, purely because it invoices a French buyer.

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 is in scope for the invoices they send to those customers. That is the whole test. Turnover does not matter, headcount does not matter, and whether the client has a French establishment does not matter.

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 a PDP that has not published a Peppol address, or is not ready. Which brings you to question two.

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

France did not build a Peppol-only, four-corner model like Belgium and the Netherlands. It uses a Y-shaped architecture with three roles:

• PPF (Portail Public de Facturation): the public portal, and the mandatory reporting point for invoice and lifecycle data to the tax authority.
• PDP (Plateforme de Dématérialisation Partenaire): certified private providers that businesses connect to. PDPs interconnect with each other and with the PPF.
• OD (Opérateur de Dématérialisation): non-certified providers that ride on a PDP.

Every French B2B invoice has to pass through a PDP or the PPF. Direct EDI between two parties, with no PDP, does not satisfy the rule either, because the lifecycle data still has to be reported.

So your client’s French customer has to have chosen a PDP. 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?

The accepted formats are Factur-X, UBL and CII. Factur-X is politically favoured in France because the standard originated there and it carries the human-readable archive layer the tax authority wants.

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 certified PDPs accept Peppol BIS Billing 3.0 invoices and translate them into the French system. The sending company does not have to integrate with the French stack directly: it sends to its own Peppol Access Point, the PDP 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 PDP they use and whether that PDP 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. An invoice that cannot be delivered structurally is an invoice that is not being paid.

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

The timeline, on one column

• 15 December 2025: PDP certification process formally opened.
• 1 September 2026: receiving obligation for all French businesses. Sending obligation for large (>5,000 employees) and mid-sized (250 to 4,999 employees) companies.
• 1 September 2027: sending obligation extended to small companies (<250 employees, <€50M turnover) and micro-enterprises.
• From September 2027: full coverage, with transactional data reporting (e-reporting) for B2C and cross-border alongside B2B e-invoicing.

The date that surprises exporters is the first one. Even where your client’s French customer is a small company not yet obliged to send electronically, they are obliged to receive. Keep emailing them PDFs and you put them on the wrong side of the rule, and increasingly they will say so.

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 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, Make and Zapier. 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, carrying an RFC 3161 timestamp, a SHA-384 hash chain and a chain of custody recording 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.