Iter Advisors

French reform · CFO perspective

Factur-X, UBL and CII: understanding invoice formats

Factur-X combines a readable PDF and structured XML data in one document. An ordinary PDF sent by email is not enough to establish the statutory electronic-invoicing circuit. Check the format, content and routing together.

Sébastien Doat

By Sébastien Doat, founding partner and CFO

Key facts

  • 1 September 2026: invoice receipt within the French scope.

  • 1 September 2027: issuing and e-reporting for French SMEs and micro-enterprises.

  • Factur-X, UBL and CII: check formats with the PA.

« The first mistake to avoid is assuming the software covers every flow without listing the sales sources. »

Sébastien Doat, CFO · Quote translated from French

What does a Factur-X invoice contain?

The hybrid standard uses a PDF/A-3 containing an XML file. The visual representation serves the reader; structured data supports automation. Profiles provide different levels of detail. The vendor and platform should confirm the profile and data required for your use.

How do you check an invoice and its credit note?

A credit note must remain linked to its original invoice and consistent with structured data. Teaching example: a service is invoiced and later partly credited. We check the original reference, amounts, VAT and recipient, followed by returned status and accounting entry.

Which acceptance checks should you run on formats?

Acceptance testing checks document, data, technical rules and process. We separate these four checks to identify an anomaly’s cause precisely.

  • Document: are the stated format and XML actually present?
  • Data: are amounts, identifiers and references consistent?
  • Technical: do structural and business-rule checks pass?
  • Workflow: does the invoice reach the right recipient with usable feedback?

How do Factur-X, UBL, CII and PDF differ?

The difference concerns data structure and software readability. XML means extensible markup language. UBL means Universal Business Language; CII means Cross Industry Invoice. Factur-X combines a PDF representation and a CII XML file. We ask the vendor which format and profile the actual process accepts.

An ordinary PDF contains a visual representation, not necessarily the required structured data. Character recognition can help read a document but does not, alone, turn an emailed file into a regulatory process. We distinguish document, data and transmission. This avoids judging compliance from appearance alone.

How do Factur-X, UBL, CII and PDF differ?
FormatContentFinance check
Ordinary PDFReadable representationDoes not demonstrate structure or regulated routing
Factur-XPDF/A-3 with embedded CII XMLConsistency between visual and structured data
UBLStructured XML dataFields, references and business rules
CIIStructured XML dataFields, references and business rules

Which fields should you check in a structured invoice?

Checks cover party identity, references, dates and amounts. SIREN identifies a French business using nine digits; SIRET identifies an establishment using fourteen. We distinguish legal entity, establishment and process recipient. A similar legal name is insufficient to assign an invoice to the right counterparty.

VAT must be consistent with lines and totals. We compare net amounts, tax and gross total. For a credit note, check the original invoice reference and correction direction. Rounding and discounts should be tested against the format’s business rules rather than changed arbitrarily to obtain validation.

Checks retain references needed for accounting reconciliation and payment. Ask how they travel between ERP, approved platform and accounting software. A technically accepted file may remain difficult to use if purchase-order or invoice references disappear. We include this requirement in the acceptance scenario.

« Electronic invoicing does not create disorder; it makes it visible and obstructive. »

Sébastien Doat, CFO · Quote translated from French

Why does format alone not prove receipt?

An invoice must be structured and delivered to the correct recipient through the required process. The approved platform (PA), formerly called PDP, performs regulatory functions; PDP meant plateforme de dématérialisation partenaire. The public invoicing portal (PPF) provides directory and data-concentration functions. The electronic invoicing address serves routing beyond an email contact.

The test follows an invoice from the source tool to a response finance can use. We check recipient, status and retained references. For a rejection, the procedure specifies where to correct and how to retry without duplication. A file in an export folder does not demonstrate receipt or reconciliation.

Formats do not change a transaction’s tax scope. A B2C sale or international transaction may fall within e-reporting, while payment data has its own conditions. File, flow matrix and calendar must therefore be tested together. We avoid treating all documents as domestic B2B invoices.

How do you document format acceptance testing?

Acceptance testing associates an expected result with each file and retains the actual outcome. We recommend a simple invoice, credit note, deposit and rejection as relevant. Record format, profile, tool version and test date. The record should allow replay after a connector or configuration change.

Finance validates business consistency; the vendor confirms technical capabilities and accepted formats. We connect these checks in the test record, with anomalies and resolutions. A PDF screenshot can complement the record but does not replace XML checks or the platform response.

The final test concerns team autonomy. An operator must identify a rejection, locate the source and retain correction evidence. We recommend attaching the procedure to the acceptance record. The control then remains usable during closing, absence or a change of software contact.

How do you verify the invoice’s return to accounting?

The accounting return must preserve counterparty identity, invoice reference and reconciliation amounts. We recommend following a test invoice through to its display in the accounting tool. Check that the viewable document matches imported data. Platform acceptance does not demonstrate that your environment retains information needed for matching. Record which reference links the source invoice, transmitted invoice, accounting entry and eventual payment, so finance can follow one transaction rather than four disconnected records.

A credit note must reach the correct invoice and entity. A partial payment must be explainable without changing the original sales amount. We test document transmission and reconciliation separately. Retain references before and after tool processing to locate breaks in ERP, connector or accounting import. Where the returned file omits a useful reference, ask the vendor whether configuration or mapping can preserve it before accepting manual rework as the operating solution.

The control procedure must remain readable to finance. It describes the expected document, essential data and action when a reference is missing. We recommend keeping teaching examples separate from actual documents and retaining the company’s test record. This makes controls easier to resume during closing, after configuration changes or when contacts change. A reproducible check should state where the evidence is stored and how a later operator can replay the same scenario.

Frequently asked questions

Is a PDF sent by email sufficient?

No, an ordinary PDF emailed to a customer does not constitute the French regulatory process. Data must be structured and routed through an approved platform for relevant transactions. Factur-X combines readable PDF and XML data, but routing still needs checking.

Does Factur-X contain an XML file?

Yes, Factur-X combines a readable PDF/A-3 and an embedded CII XML file. Data must remain consistent with the visual representation. Confirm the accepted profile with the vendor and PA.

Are UBL and CII structured formats?

Yes, UBL and CII describe structured XML data. They are not plain PDFs. Check fields, business rules and process compatibility.

Does a valid file prove the customer received the invoice?

No, routing and returned status also need checking. Retain recipient address, references and outcome. File validity and receipt are separate controls.

When is implementation complete?

Implementation is ready when representative scenarios work and the team can handle a rejection from start to finish. Retain the test record, resolved anomalies and procedure. Activating a subscription is insufficient.

When must an SME issue electronic invoices?

1 September 2027 for SMEs and micro-enterprises within the French scope. Receipt has been required since 1 September 2026 for relevant VAT-taxable businesses. Large and intermediate-sized businesses follow the 2026 issuing deadline.

Sources and references

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