No. France's e-invoicing mandate applies to businesses established in France. A supplier with no French establishment has no obligation to issue electronic invoices, to use a French platform, or to report anything to the French tax authority. What the mandate changes is your customer's side: since 1 September 2026 they process invoices as structured files, they must declare your invoice to the tax authority themselves, and their platform cannot deliver anything to you. In practice that turns into one request: a Factur-X file with the right identifiers, which you can build from your existing PDF in minutes.
Where the line runs
The reform (ordonnance of 15 September 2021, décret of 7 October 2022, and the 2026 finance law) targets transactions between two businesses established in France and subject to French VAT. Three situations, from the outside:
| Your situation | E-invoicing (issuing through the network) | E-reporting (declaring to the tax authority) |
|---|---|---|
| No presence in France, you invoice French customers from abroad | Not applicable | Not applicable to you; your customer declares the purchase |
| Registered for French VAT only, through a fiscal representative, no establishment | Not applicable, and you cannot hold a reception address | Applicable to sales located in France, on the calendar of your size |
| A French establishment (branch, subsidiary) | Applicable to that establishment like any French business | Applicable |
The SIREN lookup flags the second case explicitly: a French SIREN with a foreign head office and the legal nature of a non-established company.
What your customer has to do with your invoice
Your French customer receives your invoice by email, as before, because nothing can be delivered to them through the network from abroad. Then, under the reform, they must:
- book it from structured data if they can: their accounts payable now runs on the XML layer of invoices, and a PDF without one is keyed in by hand;
- declare the purchase through e-reporting, as the buyer, with your country, your VAT number, the invoice number and date, the amounts and the VAT treatment (usually reverse charge for a service);
- self-assess French VAT on the purchase, as they did before the reform.
None of this is your job. But the first two explain the emails you receive: the Factur-X request, and the insistence on your VAT number being on the invoice.
What they will ask you for
A Factur-X file. A PDF/A-3 with an EN 16931 XML inside. Build it from the PDF you already send with the converter (step by step here), or from scratch with the invoice form; the validator checks it against the same rules their platform applies. We wrote the step by step in Your French customer asked for a Factur-X invoice.
Their SIREN on the invoice. The nine-digit French company number, one of the mentions the reform made mandatory. It goes in the buyer block, and in the XML as the buyer's legal identifier.
Your VAT number and the VAT treatment. Reverse charge for a cross-border service, coded AE in the XML with the "Autoliquidation" mention; an intra-Community supply for goods shipped from another EU country. Your customer's declaration repeats what your invoice states, so it has to be right.
Sometimes, "send it through our platform". You cannot, and you do not need to. A compliant file by email lands in the same workflow; say so once and send the file.
What you do not need
- A French platform or an account on the French network.
- A French SIREN or VAT registration, unless your business is otherwise required to register for French VAT.
- New billing software: the file is built from your PDF, or from the UBL or CII XML your system already produces, merged with the PDF by the embed tool.
- To change your numbering, your layout or your archive.
Public sector customers
Invoices to French public bodies (the state, local authorities, hospitals) go through Chorus Pro, France's public invoicing portal, mandatory for their suppliers since 2020 and open to foreign suppliers with a registration. Chorus Pro accepts Factur-X, so the same file works there. This is a separate channel from the B2B network and predates the 2026 reform.
Frequently asked questions
I am a German supplier and already produce ZUGFeRD. Is that enough?
Yes. ZUGFeRD 2.x with the EN 16931 profile is the same format as Factur-X. Add your customer's SIREN and the French operation category, check the file with the validator, and send it.
My customer is registered on Peppol. Should I send a UBL through Peppol instead?
If your customer asks for it and you have a Peppol access point, you can; Peppol delivery is a matter between you and them, outside the French network. Otherwise a Factur-X by email is what French accounts payable expects. The CII to UBL converter turns one syntax into the other when needed.
Will a plain PDF be refused?
Not by law: your customer can still receive it. In practice, more and more French buyers treat it as an exception, delay it, or send it back with a request for Factur-X.
Do I have to report anything to the French tax authority?
No, unless your company is registered for French VAT and makes sales located in France. In the usual case your customer declares the purchase.
Does the mandate change VAT on my invoices?
No. Reverse charge for cross-border services, intra-Community supply for goods, export rules for non-EU customers: the same rules as before. What is new is that the treatment is coded in the XML and checked.
What if my French customer is a small business not yet on the network?
Small French businesses must receive electronic invoices since September 2026 and will issue them from September 2027. Until then they may accept a plain PDF; a Factur-X works for them too, since it opens as a normal PDF.
Published 9 September 2026. Sources: ordonnance n° 2021-1190, décret n° 2022-1299, loi de finances pour 2026, DGFiP practical guide (September 2026). GetFacturX is not an accredited platform (Plateforme Agréée); transmission over the French network, which foreign suppliers do not need, is operated by an accredited partner platform. This article is not tax or legal advice. Dates, frequencies and amounts are those known at publication and may change; check them before relying on them.