The question every group CFO is asking — and should answer early
This article applies exclusively to companies subject to French tax law (droit fiscal français).
Since 1 September 2026, large companies and mid-sized enterprises (ETI) have been required to issue invoices through a government-approved platform (Plateforme Agréée — PA). SMEs will follow on 1 September 2027. For a single entity, choosing a platform is already a significant decision. For a group with multiple subsidiaries, multiple ERPs and varying entity sizes, the question becomes a genuine governance project.
The good news: the regulation imposes no specific organisational model. It imposes an outcome — every B2B invoice must pass through a DGFiP-registered PA, and every taxable entity must be declared in the DGFiP directory (annuaire) with its own legal identifier. How to achieve this is left to the group's discretion. That is precisely what makes the choice complex.
What the reform actually requires from a group
Before making any decision, the regulatory foundations must be clear. Each subsidiary is a distinct legal entity, identified by its own SIREN number. It has its own e-invoicing obligations, regardless of its group membership. A subsidiary classified as an ETI was already required to emit invoices electronically from 1 September 2026. A PME subsidiary will be required to do so from 1 September 2027.
The approved platform (PA) plays two roles: it routes invoices to recipients, and it transmits regulatory data to the tax authorities (e-reporting). It is not a simple technical tool — it is the mandatory gateway between your information system and the fiscal network.
The DGFiP directory (annuaire) is the central element of the system. Each group entity must be registered there, specifying which PA has been chosen for receiving invoices. This declaration enables the routing of flows between all actors in the ecosystem.
The three organisational models
The centralised model: one PA for the entire group
In this configuration, the group selects a single approved platform capable of managing multiple entities. Each subsidiary is declared in the DGFiP directory with its own identifiers (SIREN/SIRET), but all converge onto a single management interface. This is the most readable model from the CFO's perspective: consolidated visibility over all flows, a centralised third-party repository, and homogeneous reporting.
This model is entirely feasible. Nothing prevents a parent company from centralising the emission and reception of invoices for all its subsidiaries on a single PA, provided that access rights are correctly configured per entity. Some platforms offer a multi-entity architecture, with a group-level account and separate subsidiary workspaces.
The main challenge is technical: each ERP must be connected to the shared PA. If subsidiaries run on SAP S/4, Oracle, Sage X3 or MS Dynamics — sometimes simultaneously within the same group — the complexity of connectors is real. It is manageable, but it requires a structured IT project with timelines that must not be underestimated.
The decentralised model: one PA per subsidiary
Here, each subsidiary selects its own approved platform and retains its existing tools. The approach maximises operational agility: each entity can opt for the PA best integrated with its ERP, its invoice volume, and its specific needs.
The downside for the CFO is immediate: no natural consolidated view, multiple contracts to manage, and internal control processes that must be adapted to each scope. As soon as a group has more than three or four active entities, the management overhead becomes significant.
That said, this model can be the right choice for groups whose subsidiaries have highly heterogeneous activities, ERPs with no common connector, and a strong culture of autonomy. It is not a failure — it is a deliberate choice, and it must be accompanied by appropriate oversight governance.
The hybrid model: group rules, subsidiary autonomy
This is the most common model among mid-sized groups. The group defines the rules — mandatory formats, compliance principles, monitoring indicators, an internal list of approved PAs — while subsidiaries retain operational autonomy within that framework. The PA becomes a point of convergence for flows, even when ERPs remain heterogeneous.
The appeal of this model is its flexibility in the face of on-the-ground reality: it is rare for a group to be ready to migrate all its ERPs before the deadline. It allows progress in waves, starting with the most mature entities, without blocking others.
The decision framework: how to choose
Four criteria structure the choice.
The first is the group's legal structure. Subsidiaries with separate SIREN numbers each have their own obligations. Secondary establishments of a single company (one SIREN, multiple SIRETs) can often make do with a single PA without added complexity. This is the first filter to apply.
The second is the homogeneity of the information system. If all subsidiaries run on the same ERP — or on a single multi-company ERP already in place — centralisation on a single PA is natural and low-risk. If the group has inherited multiple ERPs from successive acquisitions, the question is not to standardise everything before the deadline (that would be unrealistic), but to define a point of convergence towards the PA, using connectors or intermediate integration layers.
The third is the timeline of obligations. An ETI subsidiary has already been subject to the emission requirement since 1 September 2026. A PME subsidiary will only be subject to it in September 2027. In a mixed group, it is possible to deploy first on ETI entities, then integrate PMEs in a second wave — provided the chosen architecture allows for this from the outset.
The fourth is the finance team's capacity to oversee operations. A single PA gives the CFO a real-time consolidated view: invoice statuses, rejection rates, processing times, e-reporting data. This is a significant lever for internal control and treasury management — one that multi-PA groups can only replicate through manual aggregation or additional tooling.
What the field has revealed since September 2026
The first weeks after launch highlighted several difficulties specific to multi-ERP environments. The quality review of reference data — customer and supplier databases, product catalogues, directory registrations — proved more time-consuming than anticipated in groups where data had historically been managed in silos by subsidiary. Missing SIREN numbers, unregistered reception addresses in the annuaire, duplicates between entities of the same group: these reference data errors generated cascading rejections in the early weeks.
The second lesson relates to e-reporting. In a multi-subsidiary group, the reporting perimeters do not always align with the usual accounting perimeters. Teams that had not mapped their B2C flows and their transactions with parties outside the scope of e-invoicing discovered blind spots.
What Trevys recommends
The e-invoicing reform is a full-scale IT project — not a simple parametric update. In a multi-ERP environment, it requires a serious scoping phase: mapping entities and their obligations, auditing existing ERPs and their connectivity capabilities, choosing an organisational model, then deploying in waves.
Our recommendation: do not start from the platform — start from the IT master plan. Choosing an approved platform before mapping your flows and IT constraints is a risk — you may end up having to switch, or making costly adaptations down the line. The PA is the end of the chain, not the starting point.
For groups whose PME subsidiaries have not yet begun their compliance journey, the window between now and September 2027 is short. ERP-PA integration projects typically take four to six months in a standard environment. In a multi-ERP environment, plan for more.
Would you like to map your group's architecture before selecting your PA? Our consulting teams support finance functions at every stage, from flow mapping to go-live.
This article applies exclusively to companies subject to French tax law. Information is current at the time of publication — DGFiP e-reporting doctrine may evolve. For any significant decision, personalised advice is recommended.