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UAE E-Invoicing HubIndependent guide · UAE

France E-Invoicing vs the UAE: The Two Reforms Side by Side

Last reviewed: By Kenobiz Solutions editorial team10 min read

France e-invoicing and UAE e-invoicing rest on the same idea: structured invoices, sent through an approved intermediary, with tax data passed to the tax authority. Almost everything else differs. In France, you go through an approved platform (plateforme agréée, formerly called a PDP) using Factur-X, UBL or CII, and SMEs must issue e-invoices from 1 September 2027. In the UAE, you go through an accredited service provider (ASP) using the PINT AE format on the Peppol network, and SMEs go live on 1 July 2027. If your group has a company in each country, you are running two projects two months apart.

Key facts

  • France: every business subject to VAT must be able to receive e-invoices from 1 September 2026; SMEs must issue e-invoices and start e-reporting from 1 September 2027 (statutory timetable).
  • UAE: businesses with revenue below AED 50 million must appoint an ASP by 31 March 2027 and go live on 1 July 2027.
  • Intermediaries: more than a hundred approved platforms in France (137 on 6 July 2026); 65 accredited ASPs in the UAE (list consulted on 10 October 2026).
  • Fines: €50 per invoice not issued electronically in France, capped at €15,000 a year; AED 5,000 per month of delay in implementing the system in the UAE.
A bridge between the Paris and Dubai skylines with invoices crossing both ways

How does France e-invoicing differ from UAE e-invoicing?

Both countries require structured invoices and an approved intermediary, but the players, formats and dates differ. France relies on platforms approved by the DGFiP, three formats and e-reporting for sales outside domestic e-invoicing. The UAE relies on ASPs accredited by the Ministry of Finance, the PINT AE format on Peppol, and excludes B2C for now.

FranceUAE
Who is in scopeBusinesses established in France and subject to VAT, including micro-entrepreneurs who benefit from the small-business VAT exemption (franchise en base)Any person doing business in the UAE, for B2B and B2G transactions, VAT-registered or not, free zone businesses included
Mandatory intermediaryApproved platform (PA, formerly PDP), registered by the DGFiPASP accredited by the Ministry of Finance, for 2 years
FormatsFactur-X, UBL or CIIPINT AE (XML, UBL syntax) on the Peppol network
Sales to individuals (B2C)Outside e-invoicing, but declared through e-reportingExcluded until a decision of the Minister
Invoices to the public sectorChorus Pro, the public-sector portal, since 2020, unchangedPart of the system (B2G)
What sets your dateCompany category (headcount, turnover, balance sheet) assessed on 1 January 2025Gross revenue of the latest financial year: AED 50 million threshold
SME deadlineReceive from 1 September 2026, issue from 1 September 2027Appoint an ASP by 31 March 2027, go live on 1 July 2027
Free allowanceSome platforms offer free or bundled plans100 free exchanges per year for each customer, required of every ASP

One useful common point: in both countries, a plain PDF is no longer enough between businesses, and the quality of your customer master data decides whether the project succeeds. For the UAE side in detail, read our explainer on what e-invoicing means in the UAE and check who must comply with UAE e-invoicing.

Approved platform (formerly PDP) or ASP: what is the difference?

Both play the same role of mandatory intermediary, under two separate regimes. The French approved platform is registered by the DGFiP and transmits both invoices and e-reporting data. The UAE ASP is accredited for two years by the Ministry of Finance, Peppol-certified, and reports the tax data to the Federal Tax Authority (FTA). One approval does not count for the other.

In France, the DGFiP decided on 15 October 2024 not to turn the public invoicing portal (PPF) into a free exchange platform. The PPF keeps the directory of businesses and gathers the data meant for the tax administration; only approved platforms may transmit invoices. Dematerialisation operators and other "compatible solutions" have to work through an approved platform.

In the UAE, Ministerial Decision No. 168 of 2026 has governed ASP accreditation since 1 October 2026: Peppol certification, ISO standards, insurance and 100 free exchanges a year for each customer. The supplier and the buyer each appoint an ASP. Our list of accredited ASPs in the UAE follows the official list.

Some groups appear in both countries. SAP is on the French list of approved platforms and, in the UAE, SAP Middle East & North Africa LLC is accredited. By contrast, we did not find Cegid, Sage or Pennylane, all three approved platforms in France, on the UAE list consulted on 10 October 2026. In France, Odoo is registered by the DGFiP as an approved platform. In the UAE: Odoo is expected to become an accredited ASP soon. It is not yet on the Ministry of Finance list. Until then, Odoo connects to an accredited ASP through a connector, and you can switch without changing software.

Factur-X, UBL, CII or PINT AE: which formats apply in each country?

France accepts three structured formats: Factur-X, a readable PDF with embedded XML data, plus UBL and CII, two XML formats. The UAE requires PINT AE, the UAE specification (UBL syntax) of the Peppol international invoice, with no hybrid PDF and no QR code. The same invoice file cannot be used as it stands in both countries.

FormatWhat it isFranceUAE
Factur-XReadable PDF + embedded XML dataAcceptedNot used
UBLStructured XMLAcceptedSyntax on which PINT AE is built
CIIStructured XML (United Nations standards)AcceptedNot used
PINT AEPeppol XML, UAE specification (version 1.0.4)Not applicableMandatory format

If your team is used to Factur-X, the most visible change is that the PDF disappears: in the UAE, the invoice is the data (51 mandatory fields for a tax invoice). A PDF is only needed alongside it while your customer is not yet connected to the system. The technical detail is in our guide to Peppol and PINT AE, and the field-level rules in UAE e-invoicing requirements.

Y model or 5-corner model: how do invoices travel?

In France, the invoice goes from the supplier's platform to the buyer's platform, and the tax data goes to the administration through the PPF: the set-up is often described as a "Y". In the UAE, the official 5-corner model (DCTCE) links supplier, supplier's ASP, buyer's ASP and buyer, with the FTA as the fifth corner.

Both designs are decentralised: approved private operators carry the invoices, and the State receives the data. DCTCE stands for Decentralised Continuous Transaction Control and Exchange. The differences are in the detail:

  • The directory. In France, the PPF keeps the directory of recipient businesses, which tells the sender which platform to address. In the UAE, businesses are identified on the Peppol network by their TIN, the first 10 digits of their TRN (tax registration number).
  • The scope of the data. In France, e-reporting adds sales to individuals, transactions with foreign customers and certain payment data. In the UAE, B2C is excluded for now; the ASP sends the data from your e-invoices to the FTA in near real time, according to the Ministry.

What are the deadlines in each country?

In France, the statutory timetable requires every business to receive e-invoices, and large companies and ETIs to issue them, from 1 September 2026; SMEs, very small businesses and micro-enterprises issue and start e-reporting from 1 September 2027. In the UAE, large businesses go live on 1 January 2027 and SMEs on 1 July 2027.

DateFranceUAE
1 July 2026—Pilot programme and voluntary adoption
1 September 2026Receiving for all businesses; issuing and e-reporting for large companies and ETIs—
30 October 2026—Deadline to appoint an ASP (revenue of AED 50 million or more)
1 January 2027—Go-live for businesses with revenue of AED 50 million or more
31 March 2027—Deadline to appoint an ASP (SMEs and government entities)
1 July 2027—Go-live for SMEs (revenue below AED 50 million)
1 September 2027Issuing and e-reporting for SMEs, very small businesses and micro-enterprises—
1 October 2027—Go-live for government entities

The room for manoeuvre is not the same. In France, the Finance Act for 2024 (Article 91) allows each deadline to be postponed by decree, by up to three months. In the UAE, the Ministry of Finance called the move to 30 October 2026 a "targeted and final adjustment" and ruled out any further extension. The full schedule is in our UAE e-invoicing deadlines and timeline.

What are the penalties on each side?

In France, failing to issue an invoice electronically costs €50 per invoice, capped at €15,000 a year, and each missing e-reporting transmission costs €500, with the same cap. In the UAE, the main fine is AED 5,000 per month, or part of a month, of delay in implementing the system, with no stated cap, plus fines per invoice and per day.

BreachFrance (Finance Act for 2026)UAE (Cabinet Decision No. 106 of 2025)
Not set up in timeNo connection to a platform: 3-month formal notice, then €500, then €1,000 for each further 3-month periodAED 5,000 per month or part of a month
Invoice not issued or late€50 per invoice not issued electronically, capped at €15,000 a yearAED 100 per late e-invoice or e-credit note, capped at AED 5,000 a month for each
Data not transmitted€500 per missing e-reporting transmission, capped at €15,000 a year—
Notifications—AED 1,000 per day: system failure not reported to the FTA, data change not notified to the ASP
Exemptions"Right to make a mistake" for a first offence corrected spontaneously or within 30 daysNo fines for voluntary adopters before their phase

Worked examples in dirhams are on our page on UAE e-invoicing penalties and fines, which covers Cabinet Decision No. 106 of 2025 (also referred to as Cabinet Resolution No. 106 of 2025) breach by breach. To put a figure on your own exposure, use the UAE e-invoicing penalty calculator.

Does a French company with a Dubai subsidiary need two systems?

Yes. Each entity follows the rules of the country where it is established: the French company goes through an approved platform, the UAE subsidiary through an accredited ASP. For SMEs, both projects land in summer 2027. A single multi-company ERP can carry both, as long as it is connected to the right intermediary in each country.

Take an example: a manufacturing SME in Lyon and its distribution subsidiary in Dubai, with revenue of AED 18 million.

In France. Under the statutory timetable, the Lyon company must have been able to receive e-invoices through an approved platform since 1 September 2026, and must issue them electronically from 1 September 2027. The invoices it sends to its UAE subsidiary are sales to a foreign customer: they fall under e-reporting, not domestic e-invoicing.

In the UAE. The subsidiary, below the AED 50 million threshold, must appoint an ASP by 31 March 2027 and go live on 1 July 2027. Its invoices to UAE customers go out in PINT AE through its ASP. For its export sales, including those to the parent company, the Ministry of Finance FAQ provides for the data to be reported to the FTA through a predefined endpoint. According to the same FAQ, the subsidiary's purchases from foreign suppliers, such as the parent company, do not create a UAE reporting obligation.

The software. You have three options:

  1. Two separate tools, one per country: simple, but consolidation stays manual.
  2. The head office ERP extended to the subsidiary, if it produces PINT AE and connects to a UAE ASP: check this with the vendor.
  3. A multi-company ERP connected to an approved platform in France and to an ASP in the UAE: often the most consistent route for a growing group. Odoo is one of them, as are other ERPs. Our guide to UAE e-invoicing software, our shortlist of the best ERP software in the UAE and our Odoo vs Zoho Books comparison help you decide.

For a small subsidiary that mainly issues invoices, a group-wide ERP is not required. At that size, Odoo (Invoicing and Accounting, connected to an accredited ASP), Zoho Books and Wafeq are equivalent options. Do not oversize the tool.

What should you do if you operate in both countries?

  1. Map your entities: country, VAT status, revenue for the latest financial year.
  2. Set each entity's dates: 31 March and 1 July 2027 in the UAE for an SME, 1 September 2027 in France.
  3. Do not let the UAE deadline slip: appointing the ASP, by 31 March 2027, comes before French issuing on 1 September 2027.
  4. Align your master data: SIREN numbers (the French company identifier) for French customers, TRNs for UAE customers, full addresses.
  5. Choose the software architecture before signing with the ASP and the approved platform.
  6. Have intra-group flows checked by your chartered accountant (expert-comptable) in France and by an FTA-registered tax agent in the UAE.

For the French reform in detail, with the list of approved platforms updated every month, see facturation-electronique-tpe.fr (in French). For the UAE, our UAE e-invoicing guide and our UAE e-invoicing FAQ cover the essentials, and the e-invoicing readiness check shows where your subsidiary stands in two minutes.

Odoo is a trademark of Odoo S.A.

Frequently asked questions

Does our UAE subsidiary have to use a French approved platform?

No. The French obligation to issue invoices through an approved platform applies to businesses established in France and subject to VAT. Your UAE subsidiary falls under the UAE system: it must appoint an ASP accredited by the Ministry of Finance, by 31 March 2027 if its revenue is below AED 50 million.

Can we use the same software in France and the UAE?

Yes, if the software can produce the formats of both countries and connect to an approved platform in France and to an accredited ASP in the UAE. A multi-company ERP often can. Check both official lists: being an approved platform in France does not make a provider an accredited ASP in the UAE, and the reverse is also true.

Is the Factur-X format accepted in the UAE?

No. The UAE format is PINT AE, an XML file exchanged over the Peppol network. Factur-X is one of the three formats accepted in France, alongside UBL and CII. Whatever format your French entity uses, the software of your UAE subsidiary must produce PINT AE.

Can the French reform still be postponed?

The Finance Act for 2024 allows each deadline to be moved by decree, by up to three months: no later than 1 December 2027 for SME issuing, currently set for 1 September 2027. In the UAE, the Ministry of Finance has said that no further extensions will be granted.

Does French e-reporting exist in the UAE?

Not in that form. In France, e-reporting covers, among other things, sales to individuals and transactions with foreign customers. In the UAE, B2C is excluded for now; your ASP sends the tax data from your e-invoices to the FTA, and the Ministry of Finance FAQ provides for export data to be reported through a predefined endpoint.

Are the record-keeping periods the same in France and the UAE?

No. In France, invoices are kept for 10 years under the Commercial Code and 6 years under tax law. In the UAE, the Tax Procedures Law periods apply: generally 5 years, or 7 years for real estate, with records kept within the State.

Not sure which software fits?

Free 30-minute call with Kenobiz (English or French) about your software and deadlines, whether you use Odoo, Zoho Books or another tool.

Sources

Official texts and references used for this page:

  1. economie.gouv.fr — Everything businesses need to know about e-invoicing: timetable, mandatory details, formats (in French) — 2026-07-15
  2. impots.gouv.fr — List of approved platforms (plateformes agréées) (in French) — 2026-07-16
  3. Légifrance — Finance Act for 2024 (Law No. 2023-1322 of 29 December 2023), Article 91: deadlines and postponement clause (in French) — 2026-07-16
  4. Légifrance — Finance Act for 2026 (Law No. 2026-103 of 19 February 2026), Article 123: penalties (in French) — 2026-07-15
  5. Entreprendre Service-Public — E-invoicing: the penalties are changing, 20 February 2026 (in French) — 2026-07-15
  6. Légifrance — Tax Procedures Code (Livre des procédures fiscales), Article L102 B: 6-year retention (in French) — 2026-07-16
  7. Légifrance — Commercial Code, Article L123-22: 10-year retention (in French) — 2026-07-16
  8. Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System (Ministry of Finance, PDF) — 2025
  9. Ministerial Decision No. 244 of 2025, as amended by Ministerial Decision No. 66 of 2026: UAE implementation phases (Ministry of Finance, PDF) — 2026
  10. Cabinet Decision No. 106 of 2025 — e-invoicing violations and penalties (Ministry of Finance, PDF) — 2025
  11. Ministerial Decision No. 168 of 2026 — ASP eligibility criteria and accreditation procedure (Ministry of Finance, PDF) — 2026
  12. Official list of accredited e-invoicing service providers (Ministry of Finance), consulted on 10 October 2026 — 2026-10-10
  13. UAE Electronic Invoicing Guidelines v1.1 (Ministry of Finance, 1 June 2026) — 2026-06-01
  14. Ministry of Finance FAQ on e-invoicing (exports, imports, groups) — 2026-10-10
  15. facturation-electronique-tpe.fr — guide to the French reform, in French (facts checked on 15 and 16 July 2026) — 2026-07-16

Last reviewed: By Kenobiz Solutions editorial team

General information, not tax or legal advice. For your specific case, consult an FTA-registered tax agent.

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