France (CII(AR)): Overview

Read about how to use the Application Response Document Type with the French CII CDAR D.22B format.

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Caution

You must use the Vertex e-Invoicing Messaging API to use this feature. This API is explained in the Vertex e-Invoicing Messaging API: Overview section.


B2B and B2C mandate is a continuation of the electronic invoicing obligation for all commercial relations with the public sector (Business to Government (B2G)).

The new legal framework for electronic invoicing in France, as part of its wider digital transformation and VAT gap reduction strategy is set through Ordinance No. 2021-1190 of 15 September 2021, and defined by Article 26 of Law No. 2022-1157 of August 16, 2022, a rectifying finance law, as modified by Article 91 of Law No. 2023-1322 of December 29, 2023.

The reform mandates that all domestic B2B invoices be issued and received electronically (e-invoicing), while selected transactions and payment data (e-reporting) must also be reported to the French tax authority (DGFiP).

The rollout was originally scheduled to begin on 1 July 2024 for large enterprises, followed by mid-sized companies from 1 January 2025, and small/microenterprises from 1 January 2026. However, in October 2023, the government proposed a delay to this timeline (18 months delay, start in Sept. 2026) due to the complexity of implementation and feedback from industry stakeholders. Although a draft amendment proposed a one-year postponement (to 2027/2028), this was officially rejected by the French National Assembly on 11 April 2025. As a result, the original timeline remains in force.

Initially, the French model included the Portail Public de Facturation (PPF) as a key component in invoice exchange, acting as both a validator and a delivery platform. However, the architecture has since evolved into a PA-exclusive exchange model. In this updated design, Accredited Platforms (PAs) are responsible for the direct exchange of e-invoices between suppliers and buyers. The PPF’s role has been repositioned to focus solely on the collection of mandatory data for tax reporting purposes and global directory maintenance (Annuaire), rather than being involved in the transport layer of invoice exchange.

To participate in this ecosystem, PAs must undergo a formal registration and approval process by the DGFiP called immatriculation. They are also responsible for maintaining up-to-date information in the Annuaire, the central directory of French businesses and their preferred invoice delivery endpoints. This directory is critical for routing invoices correctly and includes SIREN/SIRET/Code routage identifiers and the recipient's PA.

All invoice data must be validated and transformed to ensure that it meets French technical and legal standards before submission. Traceability and audit trails must also be maintained throughout the lifecycle of each invoice. This is achieved by interchanging status messages, which are called lifecycle flows.

The lifecycle flow conveys the statuses of business objects, which are necessary for all participants in the invoicing chain to track the progress of processing.

Depending on the situation, this flow may be:

  • Transmitted by the supplier to the issuer PA
  • Transmitted by the buyer to the receiver PA
  • Generated by the platforms (PAs)

Every platform (PA) is required to transmit to the PPF the mandatory statuses conveyed by this lifecycle flow. The PPF verifies this flow and then forwards it to the tax administration. The PPF also generates lifecycle flows for all business objects it receives from the platforms.

This documentation covers the VRBL format requirements for the e-Invoice Lifecycle Messages.

Description

In terms of compliance and interoperability, PAs are required to support at least three invoice core formats: Factur-X, a hybrid of PDF and XML; UBL 2.1; and CII. The lifcycle messages use the CII CDAR format (D.22B). VRBL uses the UBL 2.4 ApplicationResponse to represent the French Lifecycle messages.

Restrictions

You must use the Vertex e-Invoicing Messaging API to use this country, format and Document Type. More information about the API is provided in the Vertex e-Invoicing Messaging API: Overview section.

In this section

TopicDescription
France (CII(AR)): OverviewRead about about to use the Application Response Document Type with the French CII CDAR D.22B format.
France (CII(AR)): ReceiverRead about the Receiver used for the Application Response Document Type.
France (CII(AR)): Configuration OverviewGet an overview of the configuration tasks for France (CII(AR)).
France (CII(AR)): Example DocumentsThese examples are for the ApplicationResponse Document Type.
France (CII(AR)): RulesRead about the Rules used for the Application Response Document Type.