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France · PA mobility, cutover and handover

How to change a French approved e-invoicing platform

Change your French approved platform safely: formal consent, directory cutover, evidence export, testing and backlog reconciliation.

Quick verdict:
  • • Control point: approve one migration register for every recipient identifier.
  • • The greatest risk is an unreconciled invoice crossing the routing boundary.
  • • First, freeze a verified directory and open-backlog baseline.
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Last checked: 15 August 2026Based on official sourcesClear summaryBusiness guidance, not legal advice
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What you need to know

Guide

1. Set the migration boundary before contacting either platform

Start with a written scope: the reason for moving, desired effective date, legal entities and electronic addresses. Separate a full group migration from a phased move by SIREN, establishment, business unit or flow. Record which entities receive and issue invoices and whether AP, AR, e-reporting or payment-data processes change. Name exclusions explicitly; an address omitted from formal consent should not be assumed to follow. Use decision criteria such as regulatory coverage, operational readiness, disputes, ERP release windows and month-end close. The central directory indicates whether an entity is connected to a PA and lists its invoice addresses, so scope must match directory identifiers rather than an account name. Treat 1 September 2026—when all affected businesses must receive and large and mid-sized businesses must issue—as a constraint, not a reason to rush. SMEs and microbusinesses issue from 1 September 2027.

Guide

2. Build a baseline of routes, systems, contracts and open work

Create one controlled inventory before change. Export the directory view for every SIREN, SIRET and electronic address; identify both PAs; and map ERP tenants, API endpoints, connectors, certificates, credentials, middleware and support contacts. Capture formats and transformations, including Factur-X, UBL and CII. Catalogue payloads, attachments, acknowledgements, lifecycle statuses, e-reporting records and payment data, with retention location and export method. Build a backlog register for invoices sent but not delivered, received but not posted, rejected items, pending credits, disputed statuses and submissions awaiting confirmation. Link each item to a stable business key, not only a platform ID. Review contracts for notice, termination, export, assistance, fees, access and deletion without confusing those terms with statutory mobility. Establish control totals by entity, flow, status and tax period; reconcile them before the routing request proceeds.

Guide

3. Execute the formal agreement and regulated directory sequence

The recipient business, or an authorized agent, gives a dated and signed formal agreement identifying the business, incoming PA, outgoing PA where applicable, effective date and exact electronic addresses. The incoming PA retains and numbers it, then informs the outgoing PA within two working days. The outgoing PA has five working days to object, only on limited grounds concerning whether consent is real and current; silence means agreement. Once agreement is express or deemed, the incoming PA has 15 working days to update the central directory and notify the business. The effective date must allow at least three working days for synchronization with applicable network registers. These are working-day steps: schedule them with both PAs rather than promising a fixed calendar duration. If the outgoing PA objects, both platforms inform the business and either may refer the case to the tax administration; directory data remains unchanged during review. Retain consent, notices, timestamps, objections and confirmation.

Guide

4. Run contract exit and directory mobility as separate workstreams

A directory change neither terminates nor validates either commercial contract. Send notices through the required channels and confirm subscription, support, archive and connector end dates. Do not infer notice periods, exit fees or export rights from mobility law; they depend on contract and facts. Ask each PA for a migration owner and escalation route. Every PA serving recipients must provide free, unconditional mobility documentation explaining roles, deadlines, required information and complaint routes. Use it to challenge vague hand-offs. In a practical RACI, the business is accountable for consent and acceptance; the incoming PA is responsible for the directory request and new route; the outgoing PA handles regulated responses and continuity information; ERP teams own credentials and tests. Customer buying questions include: Which usable exports and ID mappings are available? What remains accessible after switch? Who resolves disputed statuses? Which transition services are chargeable?

Guide

5. Preserve evidence and control the data handover

Do not assume invoice history, ERP master data or audit evidence transfers automatically. Request exports of invoices, original payloads, attachments, acknowledgements, status events, e-reporting, payment-data transmissions, user activity and relevant configuration. Verify completeness using hashes, file counts, date ranges, entity totals and independently opened samples. Keep a chain-of-custody log with requester, source, extraction time, transfer method, recipient, checksum and validation. The outgoing PA must continue specified continuity and access services for one year after the switch and, during that period, provide information needed for business continuity within five working days of a request. Maintain a numbered request register with due dates and responses; this duty does not prove every desired historical field will migrate. The evidence pack should hold consent, authority, directory snapshots, notices, export manifests, hashes, test results, reconciliation sign-offs, incidents and approvals, protected under applicable governance.

Guide

6. Design a controlled cutover with explicit rollback criteria

Prepare a timed runbook for inbound and outbound routes: incoming account activation, ERP and middleware credential changes, address synchronization and monitoring ownership. Map SIREN- and SIRET-level addresses exactly; do not assume two PAs can actively own one address. Avoid ungoverned dual-send and freeze only configuration affecting routing. Go/no-go evidence should include confirmed directory update, synchronized network registers, tested credentials, accepted reference invoices, active monitoring and available support. Define rollback as a decision process, not a promise of instant directory reversal. Pause submissions and escalate if addresses resolve inconsistently, acknowledgements disappear, duplicates breach tolerance, critical posting fails or totals diverge. Because an objection leaves directory data unchanged during review, keep the outgoing route operational until the effective state and technical acceptance are evidenced.

Guide

7. Test business acceptance, not merely connectivity

Use a traceable matrix for representative Factur-X, UBL and CII invoices, attachments, taxes, references and credits. Test inbound AP from receipt to ERP posting and outbound AR from creation through acknowledgement and returned lifecycle statuses. Verify e-reporting and payment data separately; invoice success does not prove those flows. Cover rejection, correction, cancellation and resubmission, plus headquarters, establishment and multi-entity combinations. Compare timestamps and identifiers across ERP, middleware, PA and counterparty evidence. Acceptance requires correct statuses, complete payloads, no unexplained transformations, auditable linkage and balanced totals—not merely an HTTP success. Ask providers to demonstrate original-document access, status normalization, entity segregation, format conversion and API/export evidence. Record result, defect owner, severity, workaround and retest. A failed critical route blocks go-live; a cosmetic portal defect need not if processing and evidence remain sound.

Guide

8. Reconcile every in-flight item across both platforms

At cutover, snapshot open items from both PAs and the ERP. Match by invoice number, supplier or customer, amount, currency, issue date and reliable technical IDs. Classify each as completed, pending, rejected, unknown, duplicated or requiring credit and reissue. Never resend solely because a status is late; first establish whether the recipient accepted it. Quarantine suspected duplicates and assign a finance owner before issuing credits. Reconcile status events as well as documents, because an invoice may exist while its acknowledgement or payment event is missing. Compare e-reporting totals and confirmations by period across both PAs to prevent gaps or double reporting. Maintain one exception ledger with age, value, entity, owner, next action and evidence link. Exit criteria: no unexplained high-value items, agreed treatment for unknowns, no uncontrolled duplicates, balanced counts and values, and signed AP, AR, tax/reporting and IT acceptance.

Guide

9. Stabilize a multi-entity move for 30 days

Consider a group with three SIRENs and twelve establishments. It pilots one low-volume entity after approving its address list and consent, keeps the others on the outgoing route, validates AP, AR and reporting, then moves remaining addresses in waves. It does not reuse consent, assume establishment addresses followed or cancel the contract when the directory changes. Common mistakes include incomplete scope, premature credential revocation, reliance on portal counts, missing original payloads, resending unknown invoices and closing reporting exceptions early. For 30 days, track delivery and rejection rates, acknowledgement latency, posting failures, duplicate count and value, unknown-status age, reporting confirmations, continuity requests and support response by entity. Review daily first, reducing frequency only after stable results. Then close the backlog, archive evidence, settle contractual obligations, remove obsolete access through change control, confirm continuity contacts, record lessons and obtain finance, tax/reporting, IT and business-owner sign-off. Escalate breaches against pre-agreed tolerances.

Checklist

Confirm every migrating legal entity and exact electronic address.

Snapshot directory routes and establish invoice and value control totals.

Review both PA contracts independently of the mobility timetable.

Obtain numbered, dated and signed consent with documented authority.

Schedule the working-day sequence and register-synchronization window with both PAs.

Export payloads, statuses, reporting evidence and configuration with checksums.

Approve a route-specific cutover runbook and measurable rollback triggers.

Pass AP, AR, format, status, e-reporting and payment-data acceptance tests.

Reconcile pending, unknown, duplicate, rejected and credited items across both PAs.

Monitor entity-level controls for 30 days and retain signed closure evidence.

FAQ

Can a business change its approved platform in France?

Yes. The July 2026 texts establish a formal procedure for changing electronic-addressing information in the central directory. The business or its authorized agent gives precise, dated and signed consent to the incoming PA. Operational migration still requires separate contract, data, integration, testing and reconciliation work.

Who updates the central directory when the PA changes?

The incoming PA updates the directory after the outgoing PA agrees or is deemed to agree. It has 15 working days for the update and must inform the business. The selected effective date must allow at least three working days for synchronization with applicable network registers.

How long does switching an approved platform take?

There is no responsible universal calendar answer. The regulated sequence includes two, five and 15 working-day steps, plus at least three working days for register synchronization, but objections, commercial notice, integration work, tests and backlog clearance affect the overall plan. Schedule actual dates with both PAs.

Does changing the directory route cancel the old PA contract?

No. The legal texts separate directory mobility from commercial termination. Follow the outgoing contract’s notice and exit provisions and confirm costs, access and support in writing. Likewise, a directory update does not by itself prove that the incoming commercial agreement is valid or fully implemented.

What happens to invoice history after the change?

Do not assume it transfers automatically. Export original invoices, attachments, status trails and reporting evidence in a form the business can retain and verify. The outgoing PA has specified one-year continuity and access duties, but export scope, format, retention and historical-data migration depend on the service and circumstances.

What if the outgoing PA objects to the change?

An objection is limited to grounds concerning whether consent is real and current. Both PAs inform the business, and either may refer the matter to the tax administration. The directory remains unchanged during review, so preserve the existing route and avoid premature credential or contract shutdown.

How can lost or duplicate invoices be avoided during cutover?

Use a single approved routing boundary, prohibit uncontrolled dual-send, snapshot open items and match records across both PAs and the ERP. Treat unknown status as an investigation, not an automatic resend instruction. Reconcile counts, values, acknowledgements, credits, e-reporting and payment-data confirmations before closure.

What should be requested from a PA before buying or renewing?

Ask for the free mobility documentation, usable export samples, status and identifier mappings, API and credential cutover steps, entity/address handling, evidence availability, continuity support, complaint routes and named escalation. Then distinguish included statutory duties from chargeable contractual migration or integration assistance.

Key regulations, formats and terms

FranceFrench tax administrationDGFiPimpots.gouv.frapproved platformplateforme agrééePDPFactur-XUBLCIISIRENVATe-reportingSMEmicro-enterpriseaccounting softwareEuropean CommissioneInvoicingEN 16931Directive 2014/55/EUstructured electronic invoiceVAT automationcross-border tradeFrance approved-platform change and migration cutover

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