Validate your Factur-X before 1 September 2026: the checklist
What actually changes on 1 September 2026, the four mentions France adds on top of EN 16931, the profile traps — and how to test your invoices today without sending them to anyone.
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What actually changes on 1 September 2026
Two obligations start on the same day, and they are routinely confused. RECEIVING an e-invoice becomes mandatory for every VAT-registered business, with no size threshold. ISSUING becomes mandatory for large enterprises and mid-sized companies (ETI). SMEs and micro-enterprises only issue from 1 September 2027 — but they must be able to receive from 2026.
Invoices travel through an approved platform (plateforme agréée / PDP). The 2026 Finance Act dropped the public portal (PPF) as an exchange platform: it is now only a recipient directory. There is no free state route for B2B. Chorus Pro remains what it always was — the channel for invoicing the public sector (B2G).
Accepted formats are Factur-X (PDF/A-3 + CII XML), UBL 2.1 and CII. Factur-X dominates in France because it stays human-readable: a person sees a PDF, a machine reads the embedded XML. It is also where most mistakes hide, for one simple reason — the PDF looks right even when the XML is wrong.
The four mentions France adds on top of EN 16931
This is the part most articles skip: being EN 16931 compliant is not enough to be compliant in France. The tax code adds four mandatory mentions that are nowhere in the European standard's rules. Mind the calendar: these mentions follow the issuing obligation. They bind large and mid-sized companies (ETI) from 1 September 2026, and SMEs and micro-enterprises from 1 September 2027.
1. The buyer's SIREN
Until now only the seller's SIREN was required. The buyer's is now mandatory too. It is the easiest mention to check — and the one most often missing from the files we see. A SIREN carries a Luhn check digit: a wrong number is detectable instantly, without asking anyone.
2. The delivery address of the goods
Mandatory when it differs from the buyer's address. On a service invoice its absence is perfectly normal — which is why nobody can make it blocking without knowing the nature of the transaction.
3. The category of operation
The invoice must state whether the operations are exclusively supplies of goods, exclusively services, or both. It is a statement, not a computation: no tool can guess it for you.
4. The option to pay VAT on debits
To be carried only if the seller has exercised that option. The file alone never reveals whether they did: that is for you to declare, not for a validator to infer.
The three traps that sink a compliant invoice
None of these three produces an "invalid" file in the sense of the standard. They produce a valid file… that gets refused.
The profile is too thin
Factur-X has five profiles. MINIMUM and BASIC WL carry neither line detail nor the required identifiers: they cannot convey the French mentions, so compliance simply cannot be demonstrated from them. Issue in BASIC or EN 16931 (COMFORT).
The PDF looks fine, the XML is wrong
The visual rendering is not what the rules check: the embedded XML is what counts. An invoice whose PDF shows a correct total and whose XML carries a wrong one gets rejected on the XML, and nobody understands why by looking at the document.
Testing after 1 September
Rejections should not be discovered in production: past that date, a rejected invoice is an unissued invoice. The only useful time to test is now, on your real invoices.
The checklist, in order
Five checks, run against a real invoice — not against your vendor's sample file.
- 1Open one of your recent invoices in a validator and look at the declared profile (BT-24). If it says MINIMUM or BASIC WL, stop there: nothing else matters until the profile changes.
- 2Check that the buyer's SIREN is present and that its check digit passes. It is the new mention most frequently forgotten.
- 3Check the seller's SIREN — that one was already mandatory, which does not stop it from being wrong sometimes.
- 4Check EN 16931 compliance itself (totals, VAT breakdown, code lists) against the official Schematron, not against an approximate re-implementation of the rules.
- 5Ask your approved platform how it carries the category of operation and, where applicable, the debit option. Neither can be derived from the file: they are configured.
If all five pass, your issuing chain is ready well ahead of the deadline. If one fails, you still have time to fix it — which is the whole point of finding out in July rather than in September.
Test a real invoice, now
Drop a Factur-X PDF: EN 16931 validation and the French mentions are checked inside your browser. Nothing is uploaded — your invoices never leave your machine.
Open the Factur-X validatorFrequently Asked Questions
I am an SME: am I concerned from 1 September 2026?
Yes, for reception. Every VAT-registered business must be able to receive an e-invoice from 1 September 2026, whatever its size. The obligation to ISSUE only applies to SMEs and micro-enterprises from 1 September 2027.
Can I keep using Chorus Pro?
For invoicing the public sector (B2G), yes: Chorus Pro remains the channel, and remains free. For B2B, no: business-to-business invoices go through an approved platform (PDP). The public portal was dropped as an exchange platform by the 2026 Finance Act.
My invoice is EN 16931 compliant. Am I compliant in France?
Not necessarily. EN 16931 is the European standard; France adds four mandatory mentions on top (buyer's SIREN, delivery address when it differs, category of operation, and the debit option where applicable). An invoice can pass every rule of the standard and still miss these.
Is the MINIMUM profile enough?
It does not carry the necessary fields: neither line detail nor the identifiers the French mentions require. Compliance therefore cannot be demonstrated from the file. In practice, issue in BASIC or EN 16931 (COMFORT).
Where must the category of operation sit in the XML?
It is a statement, and how it is carried depends on your issuing tool and your platform: it may travel as a free-text note or in an EXTENDED-profile field. We never block on its absence — asserting a single location without an official source would produce false rejections. Ask your approved platform.
What happens if my invoice is rejected after 1 September 2026?
A rejected invoice is an unissued invoice: the lifecycle restarts, with the accounting and cash-flow consequences that follow. Which is precisely why rejections should be found now, on test files, and not in production.
Do I have to send my invoices to a third-party service to test them?
No. ValidateFin runs entirely in your browser: the PDF is read locally, the XML is extracted locally, and validation executes locally. No data is transmitted to a server — which spares you from sending customer invoices to a third party just to run a test.
What exactly does your validator check?
Two layers. EN 16931 compliance, checked with the standard's official Schematron (not an in-house rewrite of the rules). And a French layer, kept separate from the EN 16931 verdict, which checks the mandate's mentions: buyer and seller SIREN (with their Luhn check digit), presence of the delivery address, and the category-of-operation statement. The last two are never blocking, and we explain why rather than inventing a rule.