DGFiP e-invoicing Pilot: Everything You Need to Know
The e-invoicing reform reaches a new operational stage with the launch of the national pilot program led by the DGFiP.
After several months of regulatory, technical, and functional preparation, this phase allows for testing the future system under near real-world conditions, before the gradual implementation of the reform starting from September 1, 2026.
For businesses, Certified Platforms, and software publishers, this pilot represents an important step. It allows for verifying the flow of electronic invoices, the proper functioning of the directory, exchanges between platforms, the transmission of mandatory data, and status management.
ICD International is actively participating in this pilot phase alongside its volunteer clients, to test the processes of exchange, transmission, and processing of electronic invoices with DEMATRUST, its Certified Platform dedicated to the reform.
In this article, we highlight the key points to remember:
- what the DGFiP pilot is;
- what changes for businesses;
- the conditions for participation;
- best practices to prepare for the transition to September 2026.
What is the DGFiP pilot?
The DGFiP pilot is a testing phase overseen by the tax administration.
Its objective is to verify the functioning of the future national e-invoicing system before its widespread implementation.
It is not merely a theoretical test. The pilot allows volunteer platforms and businesses to replicate the processes envisioned by the reform: issuance, reception, transmission, consultation, statuses, interoperability, and data reporting.
This phase therefore allows the system to be tested against the operational realities of businesses.
Specifically, it aims to test:
- electronic invoice exchanges between businesses;
- the ability of Accredited Platforms to communicate with each other;
- invoice routing via the directory;
- data transmission to the hub;
- invoice lifecycle statuses;
- business use cases;
- any anomalies or areas for improvement before widespread implementation.
An experiment supervised by the administration
The pilot project is conducted under the auspices of the DGFiP.
It allows for the gradual validation of the entire system before the regulatory obligation.
For participating businesses, it's an opportunity to test their flows with their Accredited Platform in a controlled environment, yet close enough to production conditions to identify the real impacts.
For Accredited Platforms, this is also a crucial phase. They must demonstrate their ability to manage exchanges, statuses, connections, and the data required by the administration.
Do you want to better understand the role of a platform in the reform? Consult our definition: AP – Accredited Platform.
The new role of the PPF: directory and hub
In the current version of the system, the Public Invoicing Portal — PPF — no longer serves as the free issuance and reception portal initially envisioned.
Its role is now refocused on two core functions.
The national directory
The directory allows for identifying, for each VAT-registered company, the platform chosen to receive its electronic invoices.
It plays an essential role in invoice routing.
Specifically, when a company issues an electronic invoice, the directory indicates which Approved Platform the invoice should be sent to.
Incorrect directory configuration can lead to routing errors, delays, or rejections.
The concentrator
The concentrator is responsible for collecting mandatory data transmitted by Approved Platforms.
It centralizes, in particular, the data required by the tax authorities for:
- e-invoicing;
- e-reporting;
- transaction data;
- payment data, where applicable.
The pilot allows for verification of the consistency of these exchanges between Approved Platforms, the directory, the concentrator, and company systems.
A testing ground for interoperability
One of the major challenges of the reform is interoperability.
Not all companies will use the same Approved Platform. Therefore, it is essential to ensure that an invoice issued by one company via a platform can be successfully received by another company, even if the latter uses a different platform.
Without interoperability, the reform cannot function on a large scale.
The pilot therefore allows for testing:
- communication between platforms;
- invoice routing;
- the use of exchange standards;
- status consistency;
- rejection handling;
- connection robustness;
- the ability to handle real-world use cases.
The Peppol network plays an important role in this interoperability framework. It standardizes and secures electronic exchanges between connected parties.
ICD International is a certified Peppol Access Point and supports companies with their dematerialization, EDI, and e-invoicing projects.
What's changing for businesses
The launch of the pilot marks an important milestone: the reform is entering its operational phase.
Companies are no longer just in a period of waiting or theoretical preparation. The initial tests now allow for concrete verification of how exchanges will operate from September 2026.
For large companies and mid-sized businesses (ETIs), who will be the first affected by the issuance obligation, the signal is clear: projects must be launched or finalized quickly.
For SMEs, VSEs, and micro-enterprises, the issuance schedule is more gradual, but the reception obligation will apply from September 1, 2026.
This means that all companies must now anticipate their platform choice and their ability to receive electronic invoices.
Is participation in the pilot mandatory?
No, participation in the DGFiP pilot is not mandatory.
It is a voluntary initiative, designed for businesses that want to test their data flows before the reform comes into effect.
Participating in the pilot notably allows for:
- checking flow compliance;
- testing interoperability with partners;
- observing the behavior of their ERP or accounting tool;
- validating exchanges with their Approved Platform;
- identifying anomalies before widespread implementation;
- prepare teams for new processes;
- ensure a smooth transition to production.
Companies that do not participate will nevertheless be able to benefit from the pilot's feedback, through their service provider, their Approved Platform, or official communications.
Why participate in the pilot?
Participating in the pilot can be a significant advantage for companies already engaged in their compliance project.
This allows for testing the flows before the mandatory deadline and identifying the necessary adjustments without waiting until September 2026.
The pilot is particularly useful for companies with:
- a large volume of invoices;
- multiple legal entities;
- complex customer and supplier flows;
- multiple ERP systems;
- specific use cases;
- international flows;
- lengthy approval processes;
- significant e-reporting challenges;
- integration needs with multiple systems.
The more complex the flows, the greater the benefit of the pilot.
A few reminders on the reform timeline
The reform timeline remains phased.
Starting from the September 1, 2026, all VAT-registered businesses must be able to receive electronic invoices.
On the same date, large companies and medium-sized enterprises will be required to start issuing their electronic invoices.
As of September 1, 2027, SMEs, VSEs, and micro-enterprises will, in turn, be required to issue their electronic invoices.
This phased approach should not be interpreted as a reason to wait.
Receiving electronic invoices will be mandatory for all businesses starting in 2026. It is therefore essential to choose an Approved Platform, prepare the data, and train teams in advance.
For businesses looking for a simple start, ICD International offers DEMATRUST Light, a solution designed for VSEs and SMEs.
Penalties for Non-Compliance
The reform introduces a system of penalties for non-compliance with obligations.
Penalties may include:
- issuing a non-compliant invoice;
- failure to issue invoices in electronic format when required;
- failure to transmit mandatory data;
- repeated failures attributable to the company.
Even if the amounts are capped, the main challenge is not just financial.
Poor preparation can also lead to processing delays, rejections, loss of invoice visibility, payment difficulties, or strained relationships with customers and suppliers.
Compliance should therefore be approached as an operational project, not just a regulatory constraint.
To better understand the risks associated with the reform, you can refer to our article on penalties related to electronic invoicing.
Are you already involved in the reform?
If your company has already chosen an Approved Platform or launched its compliance project, the pilot can be an opportunity to verify that your system is ready.
It specifically helps to confirm:
- that your platform is properly connected to the necessary services;
- that your flows are correctly structured;
- that your data is compliant;
- that your internal systems communicate correctly;
- that your statuses are properly received and actionable;
- that anomalies can be detected and handled;
- that your teams understand the new processes.
This phase can also help adjust certain settings before the general rollout.
Do you want to assess your readiness? ICD International offers e-invoicing support to audit your flows, define your project scope, and secure your transition.
How to participate in the DGFiP pilot?
To participate in the DGFiP pilot, several conditions must be met.
The process is straightforward in concept, but it requires structured preparation.
1. Be supported by a participating Approved Platform
The first condition is to use an Accredited Platform participating in the pilot.
The company must ensure that its AP is able to support it during this testing phase.
The key points to validate include:
- the AP's active participation in the pilot;
- connection to the necessary services;
- the ability to manage inbound and outbound flows;
- access to the directory;
- data transmission to the concentrator;
- interoperability with other platforms;
- the ability to provide status and feedback.
With DEMATRUST, ICD International supports its voluntary clients in this pilot phase to test exchanges under representative conditions.
2. Define the flows to integrate into the pilot
The company must then identify the flows it wishes to test.
The goal is not necessarily to integrate everything from the start, but to select representative cases of its actual activity.
The flows to analyze may include:
- domestic B2B invoices;
- credit notes;
- advance payment invoices;
- recurring invoices;
- multi-entity invoices;
- supplier flows;
- customer flows;
- self-billing cases;
- e-reporting data if applicable to the company;
- lifecycle statuses;
- invoice processing events.
This selection allows for testing the most significant cases and identifying any weaknesses before full implementation.
3. Prepare the technical environment
Before transmitting flows as part of the pilot, the company must prepare its technical environment.
This step often involves finance, accounting, tax, IT teams, and ERP managers.
This includes:
- configuring exchanges;
- verifying data formats;
- ensuring the quality of customer and supplier repositories;
- checking SIREN, SIRET, and VAT identifiers;
- verifying billing addresses in the directory;
- connecting internal systems;
- synchronizing test environments;
- define the handling of returns and anomalies;
- organize status tracking.
This preparation is essential to prevent the pilot from revealing only data or configuration issues that could have been anticipated.
4. Test exchanges throughout the pilot phase
During the pilot phase, participating companies can test exchanges according to the channels planned by the reform.
This allows for verification of:
- the issuance of electronic invoices;
- the receipt of invoices;
- routing via the directory;
- exchanges between platforms;
- the transmission of mandatory data;
- status tracking;
- feedback from the concentrator;
- anomaly management;
- interoperability with partners.
This phase must be rigorously monitored.
It is recommended to document errors, slowdowns, comprehension difficulties, blockages, and necessary adjustments.
This feedback will help improve configurations and prepare for the production launch.
5. Prepare for the transition to September 2026
Upon completion of the pilot, participating companies will have a clearer understanding of their readiness.
The lessons learned from the pilot can be used to adjust:
- settings;
- data formats;
- technical connections;
- internal processes;
- validation workflows;
- status management;
- control rules;
- anomaly handling procedures;
- the accounting and financial structure.
The objective is to have a stabilized, tested, and team-understood system by September 1, 2026.
DEMATRUST: supporting companies through the pilot and the reform
With DEMATRUST, ICD International supports companies in their transition to mandatory e-invoicing.
DEMATRUST centralizes, automates, and secures electronic invoice flows.
The solution notably covers:
- the issuance of electronic invoices;
- the reception of supplier invoices;
- the management of regulatory formats;
- status tracking;
- transmission of mandatory data;
- integration with ERPs;
- traceability of exchanges;
- support for business use cases;
- interoperability with the reform ecosystem.
For VSEs and SMEs, ICD International also offers DEMATRUST Light, a simple and progressive solution to prepare for receiving and issuing electronic invoices.
Key takeaways
The DGFiP pilot marks a pivotal step in the implementation of electronic invoicing in France.
It allows for testing, under near real-world conditions, the operation of the future national system: directory, concentrator, platform exchanges, statuses, mandatory data, and interoperability.
Participation is not mandatory, but it offers willing companies a valuable opportunity to check their level of preparedness before September 2026.
Even without direct participation, companies should follow the lessons learned from the pilot, as these will help secure the widespread adoption of the reform.
Electronic invoicing is now entering its operational phase. To succeed in this transition, it is essential to choose an Approved Platform, ensure data reliability, map out workflows, and involve business and IT teams.
Do you wish to participate in the pilot, check your level of preparedness, or structure your electronic invoicing project? Discover DEMATRUST or connect with our experts via our electronic invoicing support.
