A foreign-owned French company can change its authorized e-invoicing platform, but cancelling an old software subscription is not enough. The legal change runs through the French central directory that tells platforms where an electronic invoice must be addressed. Under the rules in force on 29 August 2026, the incoming platform has two working days to notify the outgoing platform after receiving the company’s formal agreement; the outgoing platform has five working days to oppose on limited grounds; and the incoming platform then has fifteen working days from the express or tacit agreement to update the directory. That is a regulated transition, not an informal handover between two vendors. The issue is especially sensitive for a French subsidiary, branch or SAS (société par actions simplifiée, a flexible private company) managed by a founder and finance team abroad: the wrong SIREN (legal-entity identifier), SIRET (establishment identifier), VAT number or mandate can send supplier invoices to the wrong place while the group believes the migration is complete. This article explains the legal sequence, the evidence to preserve, the role of the former platform, the cross-border boundary and the response when a provider refuses or misses a step. It complements our general reception and platform checklist for foreign founders and links back to the French company formation and corporate structuring service.

I. How can a foreign-owned French company start a platform change?

A. Does the French e-invoicing mobility procedure apply to a company owned abroad?

The location of the shareholders is not the decisive test. The first question is whether the recipient is a business established, domiciled or habitually resident in France for the transactions covered by the French electronic-invoicing rules. A French subsidiary normally has its own French legal identity even when its parent company is incorporated in the United States, the United Kingdom, the United Arab Emirates or another country. A French branch is different because it is not a separate legal person. Its establishment, VAT registration and invoice-routing data must therefore be mapped carefully rather than copied from the foreign head office.

Article 289 bis of the French General Tax Code (CGI, Code général des impôts) is the starting point. Its current text provides that, for the covered operations, “L’émission, la transmission et la réception des factures électroniques s’effectuent en recourant à une plateforme agréée.” In English, the legal channel is an authorized platform, not a shared mailbox, an ordinary PDF exchange or an overseas accounting application that has not been connected to the French system. The same article creates the central directory and expressly provides for the procedures governing a change of authorized platform.

A “plateforme agréée”, or PA, is an authorized platform recognized for the French reform. Some commercial material still uses the older expression PDP, meaning plateforme de dématérialisation partenaire, or partner dematerialization platform. A foreign group should ask the provider to identify its current legal status and confirm that the exact French entity is onboarded as the recipient. A reseller, enterprise resource planning system or invoice-automation tool may sit in front of the PA, but it does not automatically replace the PA.

The reform distinguishes the entity receiving a domestic French business-to-business invoice from a foreign company that has no French establishment. The French tax administration’s guidance for foreign businesses without a French establishment describes a different analysis: the foreign business may be outside domestic e-invoicing while still facing e-reporting where it is liable for French VAT on a transaction in France. A foreign parent must not use that exception to remove its French subsidiary from the reception system. Conversely, the subsidiary must not create a domestic e-invoice route for every invoice issued by the parent when the transaction belongs to the foreign-transaction or e-reporting regime.

The following terminology prevents common migration errors:

• SIREN: the nine-digit identifier of the French legal unit.
• SIRET: the fourteen-digit identifier of a specific establishment, combining the SIREN with an establishment number.
• VAT number: the value added tax identifier used for the French tax relationship; it is not interchangeable with a SIREN or SIRET.
• Kbis: the official extract evidencing information recorded in the French commercial register; the greffe is the registry office that handles court-register formalities.
• RNE: the Registre national des entreprises, the national register of businesses.
• INPI: the French National Institute of Industrial Property, which operates the Guichet unique, the single online portal for many business formalities.
• ERP: the group’s enterprise resource planning or accounting system, which may connect to the authorized platform but does not itself prove that the French routing record is correct.

URSSAF, the organization that collects most French social-security contributions, and BODACC, the official bulletin publishing many civil and commercial notices, do not determine an e-invoice platform change. They may appear in a wider French compliance file, but they should not be confused with the central invoice directory. This distinction matters when a parent’s shared-services team attempts to use a general corporate database as the source of every French identifier.

The company should record a short scope memo before it signs anything. The memo should identify the French legal name, legal form, SIREN, every relevant SIRET, VAT number, registered office, establishments, current platform, proposed platform, foreign entities in the invoicing chain and the persons authorized to instruct the platform. It should state which flows are domestic e-invoicing, which are e-reporting or reverse-charge flows, and which are outside the French company’s reception perimeter. A director living abroad can sign or give a mandate, but the file should show why that person has authority to act for the French company.

This memo is also the right place to identify the reason for the move. The reason may be an ERP migration, a platform’s service failure, a group procurement decision, an inadequate SIRET configuration, a need for better support in English, or a change of accountant. The reason does not give the company a right to bypass the directory procedure. It does, however, help demonstrate that the request was deliberate and that the incoming platform is not trying to take over an account without the customer’s authorization.

A company that has already read our guide to a foreign supplier invoice rejected by a French platform should treat the present article as the next operational step. Rejection handling concerns a particular invoice. Platform mobility concerns the address and control environment through which the company expects to receive future invoices. The two files should cross-reference each other, but they are not the same legal event.

B. What formal agreement and timeline are required to change the platform?

The company begins by selecting the incoming PA and agreeing the perimeter of the change. The perimeter may include the whole French legal entity, a group of establishments, one establishment, or a set of invoice-addressing lines. It should not be left to a sales quotation. The incoming provider should state exactly which SIREN, SIRET, VAT number, electronic address and, where relevant, network protocol records will be updated.

Article 242 nonies E bis of Annex II to the CGI requires the incoming recipient platform to have the company’s formal agreement before updating the central directory. The provision states: “L’accord formel est daté et signé par l’assujetti destinataire des factures électroniques ou son mandataire.” The agreement must contain the identity data of the recipient, the new platform and, where applicable, the former platform; the date from which the new platform may update the addressing information; and the perimeter of the addresses covered. It is numbered and retained by the new platform.

For a foreign-owned company, “mandataire” means more than an employee who has access to a software account. The person may be an accountant, legal representative, group finance officer or other agent, but the file should contain the mandate and its scope. If the company’s articles of association or a board resolution limits the director’s authority, the platform should receive the document that allows the instruction. If a parent company signs, the file should identify the French entity on whose behalf it acts.

The same rules require the recipient platforms to provide their customers with free documentation about mobility between platforms. Ask for that documentation before signing, then compare it with the provider’s commercial exit terms. The regulatory mobility process changes invoice addressing; it does not automatically settle the fees, notice period, data-export terms or other contractual questions between the company and its old provider.

The actual sequence is set out in Article 242 nonies E ter of Annex II to the CGI. The text begins: “L’assujetti destinataire des factures électroniques peut, à tout moment, demander la modification des informations d’adressage de ses factures figurant dans l’annuaire central.” The words “at any time” do not mean “without a controlled effective date”. The remainder of the provision organizes the exchange between the incoming platform, the outgoing platform and, in a contested case, the tax administration.

Stage	Responsible actor	Legal timing and evidence
Formal agreement	French company and incoming PA	Dated and signed agreement identifying the entity, platforms, effective date and address perimeter.
Notification of the outgoing PA	Incoming PA	Within two working days after receiving the formal agreement, it communicates the agreement number to the outgoing PA.
Possible opposition	Outgoing PA	Five working days to oppose; the objection must relate to the company’s intention to change, such as a more recent formal agreement.
Directory update	Incoming PA	Within fifteen working days from the outgoing PA’s express or tacit agreement, it enters the new addressing information and informs the company.
Network synchronization	Platforms, where relevant	Records used for network exchange are synchronized; the first applicable date must leave the incoming PA at least three working days for coherent execution.

The two-day, five-day and fifteen-day periods must be read in order. The fifteen-working-day period is not necessarily counted from the day on which the founder accepts the incoming provider’s proposal. It starts after the outgoing platform has expressly agreed or after its opposition period has produced a tacit agreement. The company should therefore ask for four dated confirmations: receipt of the formal agreement, notification by the incoming platform, express or tacit agreement by the outgoing platform, and effective directory update.

The outgoing platform’s opposition is not a general veto over a customer’s commercial decision. Article 242 nonies E ter limits it to elements capable of calling the customer’s intention into question, including the existence of a more recent formal agreement. If the outgoing provider claims that the company owes a subscription fee, that may be a contractual dispute, but it should not automatically be presented as evidence that the company did not intend to move. The provider should state the legal or factual basis of its objection in writing.

If an opposition is raised, both platforms must inform the company without delay of the reasons. The company may sign a new formal agreement if the first one is outdated or incomplete. The platforms may refer the matter to the tax administration by letter or email, with the formal agreement. The administration may ask for additional information; the platforms have two working days to provide requested elements, and the administration has ten working days from receipt of all necessary information to identify which platform may change the directory data. While those periods are running, the addressing information cannot be modified.

This is why a foreign founder should not simply tell suppliers, “We changed provider.” Until the directory change is effective, a supplier following the directory may still send an invoice to the outgoing platform. A supplier that is manually given the new address may send a second copy, use an unrecognized route or create a duplicate workflow. The company should use the effective-date notice supplied by the incoming platform and communicate a controlled message to key suppliers, the accountant and the parent’s finance team.

There is also a continuity rule. Article 242 nonies E quater of Annex II to the CGI states that, after a platform change, the former platform’s status-management services are maintained for one year. It also provides that the former platform supplies, on request and within five working days, information in its possession that can ensure continuity of the customer’s activity. The old provider should therefore not be treated as irrelevant on the day the directory changes. Its status records, message history and continuity information may be needed to reconcile an invoice received before, during or after the cutover.

Article 242 nonies E ter also makes a contractual boundary explicit: the directory modification “does not prejudge the validity, performance or termination” of the contracts between the company and the platforms. The company should run two tracks at once. Track one is the regulated addressing change. Track two is the notice, fees, data export, confidentiality, service credits and termination obligations under the old and new contracts. Finishing track one does not prove that track two has been settled.

For a company with a French finance manager and a founder abroad, the best approval file is short but complete: board or shareholder authorization if required, signed mandate, legal-entity identifiers, platform perimeter, chosen effective date, confirmation of the new provider’s authorized status, outgoing notification, no-opposition or opposition record, directory update notice and supplier communication. Store the file in the French company’s compliance repository, not only in an individual founder’s mailbox.

II. How should a foreign founder secure the migration and respond to failure?

A. What must be tested before the new platform becomes the invoice address?

The migration should be treated as a legal-entity and evidence project, not merely as an API project. Before the formal agreement is signed, export or otherwise preserve the old platform’s invoices, readable renderings, structured files, delivery messages, status history, correction records and user-access history. Record the export date, the account from which it was made, the file format and a checksum or other internal integrity control where the group uses one. The company should verify that the export contains the French entity’s records rather than a consolidated parent-company archive that cannot distinguish the subsidiary’s obligations.

The legal foundation is Article 289 of the CGI. It requires the taxable person to ensure that an invoice is issued for the relevant operations, and its current wording states: “L’authenticité de l’origine, l’intégrité du contenu et la lisibilité de la facture doivent être assurées.” The same article treats a document or message that specifically and unambiguously modifies the initial invoice as an invoice for the relevant purposes. A migration plan should therefore preserve not only final invoices but also credit notes, corrected invoices, rejection messages and the link between the correction and the original document.

The incoming PA must provide more than a login. Under Article 242 nonies E of Annex II to the CGI, an authorized platform must offer services that protect authenticity, integrity and readability, identify recipients through the central directory, transmit invoices to the recipient’s chosen platform and make received invoices available. It must also manage processing statuses. The statutory formulation requires the platform to “Assurer la gestion des statuts de traitement des factures électroniques en garantissant” access to status information, the ability to update status information where appropriate, and transmission of status information to the administration and the platforms of the transaction parties.

Ask the incoming provider to demonstrate each of those functions for the French company, not just for a generic demo tenant. The test should show the legal name, SIREN, one or more SIRET values, VAT number, registered office, establishment address and the authorized users. It should show how a user in France and a user abroad see the same invoice, how the user’s authority is recorded, how a rejection is explained, how a correction refers to the initial invoice and how the company exports a status history.

A useful test pack contains at least the following scenarios:

1. A French supplier addresses an invoice to the company’s legal name and SIREN.
2. A supplier addresses an invoice to a particular establishment using a second SIRET.
3. A supplier uses the company’s trading name instead of its registered legal name.
4. A supplier sends a corrected invoice that specifically identifies the original.
5. A supplier issues a credit note after a cancellation, discount or partial return.
6. An invoice arrives during the interval between the outgoing platform’s agreement and the directory update.
7. The incoming platform receives a platform status or rejection that requires a human correction.
8. The parent’s finance team reviews an invoice while the French accountant posts it in the French ledger.
9. A French branch and its foreign head office appear in the same commercial workflow but have different legal or VAT identities.

These tests should have named expected results. For example, the invoice for the subsidiary’s SIREN should enter the subsidiary’s queue, not the parent’s queue; an invoice for the second establishment should retain the correct SIRET; and a correction should be linked to the original rather than treated as an unrelated expense. Keep screenshots or platform-generated reports showing the actual route and status. If a test fails, postpone the effective cutover where possible or document an interim control agreed with the accountant and platform.

The company should also test its supplier communication. The communication should give the legal entity name, SIREN, relevant SIRET, VAT number, effective date, new PA identity and the instruction to follow the official directory rather than a manually typed address. The message should ask suppliers not to resend invoices merely because they have received a migration notice. A duplicate invoice creates accounting and VAT reconciliation work, particularly where the parent’s shared-services team and the French accountant use different systems.

The official tax-administration guidance on authorized platforms explains the operational role of a PA, including receiving invoices, exchanging them with other platforms and transmitting information to the administration. The company should compare the provider’s service description with that official role. A software supplier that promises to “make invoices digital” may still depend on another PA for the regulated route. The contract and technical diagram should identify that dependency.

Do not confuse the central directory with the Kbis or the RNE. A change in the registered office, a new establishment, an INPI filing or a new Kbis may affect the facts that the company must report, but it does not automatically prove that the e-invoice routing data has been updated. Conversely, a platform directory update does not amend the public commercial register. The French company should reconcile the identifiers in the PA, the accounting system, the tax account, the INPI/RNE record and supplier master data, while retaining the date on which each source was checked.

The timing of the formal agreement should be coordinated with the group’s accounting close. If the cutover takes place at month-end, the company should decide which platform owns invoices received before the effective date, which platform retains status history, which system posts late-arriving invoices, and who approves VAT adjustments. The decision should be written in a cutover protocol. It should also name an owner for each exception: an invoice routed to the old platform, an invoice routed to the new platform too early, a duplicate, a missing status, a rejected SIRET and an invoice that belongs to the foreign parent rather than the French company.

Records must remain usable after the founder changes accountant or the group changes finance personnel. Article L. 102 B of the Tax Procedure Code requires relevant books, documents and supporting pieces to be kept for six years; when they are established or received electronically, they must be retained in that form for the statutory period. Its wording states that they “doivent être conservés pendant un délai de six ans” and that electronic records are retained under the same period. The migration archive should therefore include the structured files, the readable versions, platform messages and the evidence explaining why a transaction was routed or corrected.

The evidential value of electronic material is not theoretical. In Conseil d’État, 9 December 2022, no. 461887, concerning a tax-return penalty rather than e-invoicing, the court held that “Tant le principe de responsabilité personnelle que le principe de personnalité des peines s’opposent à ce que des pénalités fiscales” be imposed on a taxpayer who did not participate in the conduct punished. The decision also states that a taxpayer cannot be charged with the penalty where it did not personally take part in the late filing. That does not eliminate the French company’s responsibility for its own platform controls. It does show why the file should identify who signed the agreement, who controlled the account, who received the incident notice and who could correct an identifier.

In Cour de cassation, Commercial Chamber, 26 February 2013, no. 12-14.771, the court held that documents connected with the accounting records are not limited to accounting entries in the narrow sense. The decision refers to “toutes celles qui ont une corrélation certaine avec les données de la comptabilité commerciale” and expressly includes invoices and related orders, contracts and amendments. A French company should apply that logic to its migration file: the agreement, platform notices, supplier communications, original invoice, correction, payment and VAT analysis should be retrievable as one transaction chain.

The company should retain the former platform’s data even when the new platform promises a full migration. A vendor-to-vendor transfer may preserve a usable invoice image but omit a status event, rejection reason, user identity or correction message. The former platform’s one-year status-continuity period under Article 242 nonies E quater is a legal minimum, not a reason to delay an independent export. Ask for a written confirmation of the last invoice and status imported into the new system, then reconcile a sample from both systems.

For invoices drafted in English or another foreign language, the French company should keep the original structured data and readable document, together with the commercial explanation needed by its accountant. Article 289 allows the tax service to require a French translation for control purposes when a bill is written in a foreign language. The platform migration does not change that rule. It also does not turn an English invoice into a French domestic e-invoice when the transaction falls into a foreign or e-reporting category.

B. What should the company do if the outgoing platform objects or the migration fails?

The first step is to classify the failure. There are at least five different situations:

1. The company has not produced a signed formal agreement or the agreement omits the address perimeter.
2. The incoming platform did not notify the outgoing platform within two working days.
3. The outgoing platform has raised an opposition during its five-working-day period.
4. The outgoing platform agreed or did not oppose, but the incoming platform did not update the directory within fifteen working days.
5. The directory changed, but invoices, statuses or historical records are not reaching the right accounting workflow.

For the first situation, correct the agreement rather than asking the platforms to improvise. Confirm the French legal entity, address perimeter, effective date and mandate. For the second or fourth situation, request a dated explanation from the incoming platform and preserve the contractual and statutory timeline. For the third situation, ask for the precise reason and test whether it concerns the company’s intention or merely an unrelated commercial disagreement. For the fifth situation, open an incident with both the new and former platforms, notify affected suppliers and reconcile the official directory status with the invoice records.

The company should not sign a second agreement simply because a sales representative says that the first one is “lost”. A later agreement can affect the legal sequence and may become the more recent agreement relied on by an outgoing platform’s opposition. If a new agreement is necessary, label it clearly, identify the previous agreement and obtain advice on the effective date and address perimeter.

The relevant statute also sets the boundary for a dispute. Article 242 nonies E ter provides that the addressing change based on the formal agreement “does not prejudge” the validity, performance or termination of the contracts between the company and the platforms. The company may need to pay a contractual invoice, challenge a service failure or give notice under the old contract even while it asks the tax administration to allow the directory change. Those issues should be documented separately so that a commercial dispute is not mistaken for a lack of customer consent.

Sanctions must be analysed by obligation. Article 1737 of the CGI, in the version in force for the transition period, states that failure by the taxable person to use an authorized platform for reception first leads to a formal notice with a three-month compliance period. Persistent non-compliance can lead to a €500 fine, then a €1,000 fine after a further three-month period, with further €1,000 fines after successive periods. The same article provides a €50-per-invoice fine for failure to issue an invoice electronically under Article 289 bis, subject to the annual cap and first-infringement repair rule specified in the text. The exact obligation, date and statutory version should be identified before the company assesses exposure.

For transactions falling under e-reporting, Article 1788 D of the CGI provides an amende of €500 per transmission for non-compliance with Article 290 or Article 290 A, subject to a €15,000 annual cap for the relevant taxpayer obligations. The provision states: “Le non-respect par l’assujetti des obligations prévues à l’article 290 donne lieu à l’application d’une amende égale à 500 € par transmission.” A foreign parent’s e-reporting exposure and the French subsidiary’s platform-reception exposure should not be combined into one generic “e-invoicing fine”.

The transmission chain is separately addressed by Article 289 E of the CGI, which states: “Les données des factures électroniques émises en application du I de l’article 289 bis sont transmises à l’administration par la plateforme agréée choisie par l’assujetti.” In practical terms, a platform migration should include a reconciliation of the data that the platform says it transmitted with the company’s invoice register, VAT records and accounting entries. A technical “delivered” status does not by itself prove that the tax classification, amount or payment information is correct.

A foreign-owned company should react quickly to a platform notice because its internal decision chain is often slower than the French statutory clock. The founder may be in another time zone, the accountant may need a mandate, and the group’s finance team may not know who controls the French SIRET. Establish a named French contact, a backup user, a person authorized to sign a corrected agreement and a person responsible for informing the tax adviser. Store the notice with the time zone, receipt timestamp and platform account used.

If the platform is unavailable, preserve the invoice at the moment it is received, record the failed delivery attempt and use the documented incident or fallback procedure. Do not silently convert every invoice into an email PDF and assume the problem has disappeared. The company should ask the platform what status will be recorded, whether the directory remains unchanged, how suppliers are to be informed and how the incident will be reflected in the final audit trail. If the failure affects a VAT return, payment date or correction, ask for a targeted legal and accounting review.

If the old platform refuses to provide continuity information, make a written request referring to the one-year status-management obligation and the five-working-day response period in Article 242 nonies E quater. If the new platform refuses to update the directory after the statutory sequence has completed, request its internal timeline, the agreement number, the outgoing platform’s response and the precise missing element. The tax administration referral process described in Article 242 nonies E ter may become relevant, but it should be supported by a complete evidence file rather than a general complaint that the vendor is unhelpful.

The company should also preserve proof that the problem was repaired. Article 1737 contains a first-infringement rule for specified omissions or failures when the issue is repaired spontaneously or within thirty days after a first request from the administration, in the conditions set by the statute. That is not a universal immunity. It is a reason to date the corrective action, keep the confirmation of repair and avoid overstating what a platform ticket proves.

A practical escalation matrix is:

Problem	Immediate action	File to preserve
Wrong SIREN, SIRET or VAT number	Correct the master data and ask both platforms to confirm the directory perimeter.	Registry/tax evidence, correction request, confirmation and affected invoices.
Outgoing PA opposition	Obtain the reason, compare agreements and decide whether a new formal agreement or administration referral is required.	Signed agreement, agreement numbers, timestamps, opposition and platform messages.
Directory not updated	Ask the incoming PA for its statutory timeline and advise key suppliers which route remains effective.	Effective-date notices, directory screenshots, supplier notices and incident ticket.
Invoices missing after cutover	Search both platforms, obtain continuity data from the former PA and reconcile the accounting queue.	Structured invoice, readable rendering, status history, export report and ledger entry.
Cross-border classification doubt	Separate domestic e-invoicing, e-reporting, reverse charge and foreign-parent flows with the accountant.	Transaction memo, contract, VAT analysis, tax advice and transmission record.

The final governance point is responsibility. The founder may outsource platform administration to an accountant, but the French company should retain visibility over the legal entity, mandate, directory perimeter and incident response. The Service Public preparation guidance recommends mapping billing flows and choosing a platform suited to the business. For a foreign-owned company, the map should add the human chain: founder, director, accountant, group finance team, platform administrator and substitute contact. It should be possible to identify who could approve a change before a supplier’s invoice is lost.

Where Paris or Île-de-France is the company’s registered or operating location, the platform procedure itself remains national. The local location may matter for the company’s adviser, accountant or court file, but it does not create a separate Paris directory. The company should not create a second platform route merely because the registered office, a coworking address and a Paris establishment use different commercial labels. The decisive controls remain the legal entity, establishment identifiers, authorized mandate and official directory entry.

Conclusion

A foreign-owned French company can change its authorized e-invoicing platform, and the law provides a defined mobility route. The company must identify its French legal entity and address perimeter, choose the incoming PA, sign a dated formal agreement, allow the incoming platform two working days to notify the outgoing platform, account for the outgoing platform’s five-working-day opposition period and monitor the incoming platform’s fifteen-working-day directory-update period. The fifteen days are part of a sequence; they are not permission to switch the invoice address informally.

The safe migration file contains the signed agreement and mandate, SIREN/SIRET/VAT evidence, the old and new platform confirmations, directory and supplier notices, test results, exported structured records, statuses, corrections and an incident log. The former platform remains relevant for one year for status continuity and must provide qualifying information on request. Contract termination, data export and service disputes should be handled alongside, but separately from, the regulated directory change.

For an overseas founder, the practical objective is simple: after the effective date, a supplier following the official directory should reach the correct French entity, the finance team should see the same status and the company should be able to reconstruct the transaction years later. If a platform objects, misses a statutory step or loses a status record, preserve the timeline and obtain a focused response before the problem becomes a VAT, accounting or penalty dispute.

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