The French Tax Authority (DGFIP) has released detailed guidance on the upcoming pilot phase for the French CTC reform, marking a significant milestone in the country’s transition to mandatory electronic invoicing. This pilot represents the first real testing of the CTC ecosystem before the phased mandatory rollout beginning September 2026.
Pilot Phase Overview
The pilot phase will run from late February 2026 through the end of August 2026, providing a six-month window for accredited service providers (PAs) and their customers to test the new e-invoicing ecosystem in live conditions. Notably, this pilot will use only real business data—no test data will be permitted—ensuring that the testing environment accurately reflects actual market conditions.
Only PAs that have successfully completed end-to-end testing with the Public Portal (PPF) will be eligible to participate.
Having successfully completed the rigorous PA accreditation process in France, including comprehensive interoperability testing, Sovos will participate in the pilot phase. This participation enables users to gain hands-on experience with the new framework ahead of mandatory compliance while contributing to the ecosystem’s refinement.
Prerequisites for Participation
Each participating PA must sign a charter committing to pilot participation standards, and critically, must obtain explicit consent from their customers for both inbound and outbound invoice processing.
The Central Directory must contain effective addresses, meaning customers must be ready to receive and process electronic invoices through their designated platforms, even though no data will be communicated by the PPF to the French Tax Authority during the pilot phase. This approach allows all parties to verify that data transmission works correctly between platforms and with the PPF without creating premature tax reporting obligations.
Technical Framework
At the beginning the pilot phase will follow version 3.0 of the external specifications (published December 2024). From June 2026 onward, the pilot will transition to version 3.1 (published November 2025).
Throughout the pilot, invoice and lifecycle status exchanges will follow AFNOR standards XP Z12-012 and XP Z12-014. These standards define the technical specifications for invoice formats (UBL, CII, and Factur-X) and lifecycle management rules. Version 1.1 of these standards, published in July 2025, will govern the pilot’s initial phase, with version 1.2 (published November 2025) from June 2026.
Recent Regulatory Simplifications Measures Reflected
The pilot phase specifications incorporate several simplification measures announced by the French government in August 2025. Most notably, the number of transactions in e-reporting transmissions has been made optional, and the optional reference to previous transmissions in e-reporting flows has been removed for PAs.
Strategic Importance
This pilot phase represents the French government’s commitment to ensuring a smooth transition to mandatory e-invoicing. By allowing PAs and taxpayers to test the full infrastructure with real data for six months before the mandatory deadline, the reform aims to identify and resolve operational challenges in a controlled environment.
For businesses preparing for compliance, the pilot phase offers valuable insights into the practical requirements of the new system. Companies considering their platform selection should pay close attention to which providers participate in the pilot, as early participation demonstrates both technical readiness and commitment to supporting customers through the transition.
