As part of our article on e-invoicing in France, and after covering the legal framework — that is, the laws, decrees, and obligations defining the timeline and responsibilities of businesses — it is now time to focus on another essential pillar of the reform: the normative framework.
While the law defines the what (the obligations), it is the standards that define the how (the technical and organizational requirements to comply with). These standards—whether European, international, or French—each have their own history and specific role: ensuring invoice interoperability, guaranteeing integrity, governing archiving, and securing transmission.
In this article, we will review the main standards that structure e-invoicing and e-reporting, explaining for each of them where it comes from and what its key principles are.
The Structure of the Electronic Invoice
Before it can be transmitted, archived, or audited, an electronic invoice must first be structured in a standardized way. This structure ensures that an invoice issued by a company can be understood, read, and automatically processed by the recipient’s system—whether it is another company, a dematerialization platform, or the tax administration.
To address this interoperability challenge, several standards and formats have emerged in Europe and in France. Some are purely European (EN 16931), others are international (UBL, CII), while France and Germany jointly developed a hybrid format, Factur-X, which combines human readability with technical structuring.
In the following sections, we will explore these different standards, their history, and the principles that govern them.
EN 16931: The European Foundation of Electronic Invoicing
Published in 2017 by the European Committee for Standardization (CEN), the EN 16931 standard is the cornerstone of electronic invoicing in Europe. It responds to a clear objective set by the European Commission: to harmonize invoice formats so that companies across Member States can exchange accounting documents without technical barriers.
In practice, EN 16931 does not define a specific file or programming language, but rather a semantic model: a standardized list of information that an invoice must mandatorily or optionally contain (seller and buyer identities, invoice lines, net and VAT amounts, due dates, etc.). Thanks to this common vocabulary, a French invoice can be understood by a German, Italian, or Dutch system without manual interpretation.
The standard is also designed to be interoperable with several technical syntaxes: XML UBL, CII, or the hybrid Factur-X format. In other words, it defines the content while allowing companies to choose the container, as long as it complies with the defined semantics.
UBL: The XML Language of Electronic Invoicing
Created in the early 2000s by the international consortium OASIS, the Universal Business Language (UBL) is one of the most widely used formats for exchanging electronic invoices, particularly within the European Peppol network.
Designed as a generic XML language, UBL is not limited to invoices: it covers a wide range of business documents (purchase orders, shipping notices, catalogs…). In the field of invoicing, it provides a clear structure that incorporates the information defined by the EN 16931 standard, ensuring its compatibility with European requirements.
One of its major advantages is its international adoption: widely used in Nordic and Anglo-Saxon countries, it facilitates cross-border exchanges. In France, it is recognized as one of the authorized formats, particularly for companies already interacting with Peppol or favoring fully dematerialized exchanges.
<Invoice xmlns="urn:oasis:names:specification:ubl:schema:xsd:Invoice-2">
<cbc:ID>F2025-001</cbc:ID>
<cbc:IssueDate>2025-08-20</cbc:IssueDate>
<cbc:InvoiceTypeCode>380</cbc:InvoiceTypeCode>
<cac:AccountingSupplierParty>
<cac:Party>
<cbc:Name>Fournisseur SA</cbc:Name>
<cac:PartyIdentification>
<cbc:ID schemeID="SIRET">12345678900011</cbc:ID>
</cac:PartyIdentification>
</cac:Party>
</cac:AccountingSupplierParty>
<cac:AccountingCustomerParty>
<cac:Party>
<cbc:Name>Client SARL</cbc:Name>
<cac:PartyIdentification>
<cbc:ID schemeID="SIRET">98765432100022</cbc:ID>
</cac:PartyIdentification>
</cac:Party>
</cac:AccountingCustomerParty>
<cac:LegalMonetaryTotal>
<cbc:PayableAmount currencyID="EUR">1200.00</cbc:PayableAmount>
</cac:LegalMonetaryTotal>
</Invoice>Code language: HTML, XML (xml)Example of a UBL 2.1 invoice
CII: The United Nations International Invoice
The Cross Industry Invoice (CII) is a format developed by UN/CEFACT (United Nations Centre for Trade Facilitation and Electronic Business) and first published in 2006. Unlike UBL, which was created by a private consortium, CII is managed by an international organization under the United Nations, giving it strong legitimacy in global trade exchanges.
CII is also based on the semantic model of EN 16931, but it stands out for its extensive functional richness. It can represent complex use cases: multi-line invoices with hierarchical structures, cross-border operations, and specialized sectors (energy, transport, finance…). This level of detail makes it a format favored by large enterprises and international operators.
Its main drawback is its technical complexity: CII files are often larger and more difficult to process than UBL, which limits its adoption among smaller organizations. Nevertheless, within the French reform, it is one of the authorized syntaxes, and it is above all the foundation of the Factur-X format, which we will discuss next.
<rsm:CrossIndustryInvoice
xmlns:rsm="urn:un:unece:uncefact:data:standard:CrossIndustryInvoice:100"
xmlns:ram="urn:un:unece:uncefact:data:standard:ReusableAggregateBusinessInformationEntity:100">
<rsm:ExchangedDocument>
<ram:ID>F2025-002</ram:ID>
<ram:TypeCode>380</ram:TypeCode>
<ram:IssueDateTime>
<udt:DateTimeString format="102">20250820</udt:DateTimeString>
</ram:IssueDateTime>
</rsm:ExchangedDocument>
<rsm:SupplyChainTradeTransaction>
<ram:ApplicableHeaderTradeAgreement>
<ram:SellerTradeParty>
<ram:Name>Fournisseur SA</ram:Name>
<ram:ID schemeID="SIRET">12345678900011</ram:ID>
</ram:SellerTradeParty>
<ram:BuyerTradeParty>
<ram:Name>Client SARL</ram:Name>
<ram:ID schemeID="SIRET">98765432100022</ram:ID>
</ram:BuyerTradeParty>
</ram:ApplicableHeaderTradeAgreement>
<ram:ApplicableHeaderTradeSettlement>
<ram:GrandTotalAmount currencyID="EUR">1200.00</ram:GrandTotalAmount>
</ram:ApplicableHeaderTradeSettlement>
</rsm:SupplyChainTradeTransaction>
</rsm:CrossIndustryInvoice>Code language: HTML, XML (xml)Example of a CII invoice
Factur-X: The Alliance of PDF and XML
Developed jointly by France and Germany and officially released in 2017, Factur-X is a hybrid format designed to reconcile two often opposing needs: human readability and automated processing.
Concrètement, Factur-X est un PDF/A-3 (format d’archivage lisible par tous) dans lequel est embarqué un fichier XML conforme au CII, lui-même aligné sur le modèle sémantique de l’EN 16931. Résultat : une seule facture qui peut à la fois être lue visuellement par un comptable et traitée automatiquement par un logiciel.
In practice, Factur-X is a PDF/A-3 (an archivable format readable by anyone) that embeds an XML file compliant with CII, itself aligned with the semantic model of EN 16931. The result is a single invoice that can be both visually read by an accountant and automatically processed by software.
In France, Factur-X is considered the reference format because it combines ease of use with regulatory compliance. It is also expected to be the most frequently used in the first years of the reform, particularly to meet the needs of companies that must issue electronic invoices while retaining a visually usable document.
National Regulatory Standards
While European standards define the structure and content of electronic invoices, France has deemed it necessary to add its own reference framework. The objective is twofold: to adapt the reform to the French context and to ensure the compliance of the platforms that act as intermediaries between businesses and the tax administration.
Two key pillars stand out: the experimental XP Z12-012-014 standard and the DGFiP reference framework, which details the flows and the complete lifecycle of invoices.
XP Z12 (012 – 013 – 014): The French Standard for PDPs and ODs
Published by AFNOR in 2022, XP Z12-012-014 is an experimental standard specifically designed for the implementation of electronic invoicing in France. Unlike European standards, which establish a common framework for all Member States, it directly targets French stakeholders: Partner Dematerialization Platforms (PDPs) and Dematerialization Operators (ODs).
Its key principles:
- Define compliance requirements for these actors (security, traceability, interoperability).
- Regulate the transmission of invoices and e-reporting data to Chorus Pro.eropérabilité).
- Ensure a high level of control, auditability, and reliable archiving.
This standard is therefore the French technical and organizational foundation, complementing the European framework.
The DGFiP Reference Framework: Regulatory Flows
In parallel, the DGFiP has published an operational reference framework describing the 14 regulatory flows of electronic invoicing and e-reporting. This document outlines the complete lifecycle of an invoice: issuance, transmission, reception, rejections, intermediate statuses, and archiving.
These specifications are essential for PDPs and ODs, but also for invoicing and ERP software providers, who must align their solutions with these flows to ensure full interoperability.
Security and Trust Standards
Beyond the structure of invoices and the French regulatory framework, electronic invoicing also relies on a foundation of trust. Indeed, an invoice only has value if its authenticity, integrity, and the confidentiality of its data can be guaranteed. This is why the reform is based on several international standards that govern information security and electronic signature mechanisms.
ISO 27001: Information Security
ISO 27001, first published in 2005 and regularly updated, is the international reference standard for information security management. It requires organizations that adopt it to implement a comprehensive ISMS (Information Security Management System): security policy, access control, risk management, encryption, backups, regular audits, and more.
In the context of electronic invoicing, it is an essential guarantee for PDPs and ODs, which handle millions of sensitive data every day (tax information, amounts, party identities).
eIDAS: Digital Trust in Europe
The eIDAS regulation, adopted in 2014 and implemented in 2016, governs electronic identification and trust services at the European level. It establishes the rules for electronic signatures, electronic seals, qualified timestamps, and the issuance of digital certificates.
In practice, eIDAS ensures that an electronic invoice has not been tampered with and that it truly originates from the declared issuer. Signatures and seals compliant with eIDAS give invoices evidentiary value equivalent to that of signed paper documents.
NIS2: Cybersecurity for Essential Entities
Adopted in 2022 and to be transposed into Member States by October 2024, the NIS2 (Network and Information Security 2) directive broadens the scope of cybersecurity obligations in Europe. It now applies to a wide range of actors classified as ‘essential,’ including dematerialization platforms.
Its key principles:
- Implement enhanced cybersecurity measures (incident management, penetration testing, system hardening).
- Ensure operational resilience against cyberattacks.
- Promptly report any major security incident to the competent authorities.
For PDPs and ODs, this means that electronic invoicing cannot be limited to compliance with formats: it must also be embedded within robust cybersecurity governance, under penalty of sanctions.
Standards for Reliable Archiving
The final essential component of electronic invoicing is archiving. An invoice is not only intended to be transmitted: it must also remain readable, intact, and usable throughout the legal retention period (10 years in France). This is known as reliable archiving, which is based on specific standards.
NF Z42-013: The French Reference
First published in 1999 and regularly updated (most recently in 2020), NF Z42-013 is the French standard that defines the rules of an electronic archiving system (SAE). It governs in particular:
- Traceability of operations
- Document sealing (hashing, digital fingerprints)
- Timestamping
- Access and rights management
It is considered the historical reference in reliable electronic archiving in France and has greatly inspired international standards.
ISO 14641: The International Equivalent
ISO 14641, published in 2012, is directly derived from the NF Z42-013 standard, adapted at the international level. It sets the same requirements to ensure the durability, integrity, and readability of archived digital documents.
For companies operating internationally, it provides a recognized framework beyond French territory, ensuring that their archiving systems meet the same standards across Europe and worldwide.
Conclusion
Electronic invoicing is not limited to a tax obligation or a simple change of format. It is built on a comprehensive normative ecosystem that provides both its technical robustness and its legal value.
On the one hand, structural standards (EN 16931, UBL, CII, Factur-X) ensure that each invoice can be understood and automatically processed, regardless of the country or the system used. On the other hand, the French reference frameworks (XP Z12-012-014, DGFiP specifications) define the local rules for PDPs, ODs, and all stakeholders of the reform.
In addition come the security and trust standards (ISO 27001, eIDAS, NIS2), which guarantee the integrity of flows and the protection of tax data, and finally the reliable archiving standards (NF Z42-013, ISO 14641), which ensure that electronic invoices retain their full legal value over time.
In short, the French e-invoicing reform is part of a structured, standardized, and secure framework, designed to reconcile tax requirements, the operational needs of businesses, and international harmonization.
More than a constraint, these standards represent an opportunity: they provide companies with assurance of compliance and a solid foundation to modernize their accounting and financial processes.
Glossaire
| Term | Definition |
|---|---|
| DGFiP | French Fiscal Administration |
| OD | Dematerialization Operator – Service provider that supports companies in issuing and receiving electronic invoices, but does not transmit them directly to the tax administration. |
| PDP | Partner Dematerialization Platform – Platform registered with the DGFiP, authorized to transmit invoices and e-reporting data to Chorus Pro. It plays a central role in the French reform. |
| PDF/A-3 | Standardized variant of the PDF format (ISO 19005-3) that allows XML files to be embedded as attachments. It is the standard used for the Factur-X format. |
| PEPPOL | Pan-European Public Procurement Online – European network that facilitates the electronic exchange of business documents and invoices, based in particular on the UBL syntax. |
| UNECE | United Nations Economic Commission for Europe – UN economic commission for Europe, which oversees UN/CEFACT, the body behind the CII (Cross Industry Invoice) format. |