French e-invoicing: Navigating directories, SIRENs, and registration

Before diving into platforms, directories, and registrations, you must answer one fundamental question: Am I a taxpayer? In this context, "taxpayer" means any entity subject to value-added tax (VAT) in France and therefore required to participate in the e-invoicing mandate.

If the answer is NO (for example, certain pure associations or non-taxable entities), no further actions are required. You do not need to be in the Annuaire.

If the answer is YES, you are required to participate and must be listed in the Annuaire. Proceed to the next steps.

A widespread point of confusion arises from companies checking their status in the wrong directory.

• The legal directory: This contains all legal entities registered in France. SIREN — France's national company registration system, maintained by INSEE (Institut national de la statistique et des études économiques, France's national statistics body) — records every registered business and organisation in the country.
• The taxpayer directory (L'Annuaire DGFiP): This is the specific directory built by the French tax authority (Direction générale des Finances publiques, or DGFiP) strictly for entities subject to the e-invoicing mandate.

How they interact: The DGFiP builds the Taxpayer Annuaire using data from the Legal Annuaire. The common identifier across both is the SIREN. However, just because your SIREN exists in the legal directory does not automatically mean it is present in the Taxpayer Annuaire. A SIREN may be missing from the Taxpayer Annuaire if the entity is not recognised as a VAT taxpayer or if there are discrepancies in their tax records.

When setting up your electronic invoicing routing, you will encounter the SIREN and the "addressing line".

• SIREN: Your 9-digit unique legal identification number. This is your primary identifier in an Annuaire.
• Addressing line: This is used to route the invoice to the correct platform. In many default cases, especially for smaller companies or centralised systems, the addressing line is simply identical to the SIREN.

Many holding companies and associations experience a common frustration during onboarding. The process dictates that your chosen approved platform must handle your registration and update it in the Annuaire.

However, when these companies try to assign their platform, the approved platform states: "We cannot do anything without your SIREN being active in the Annuaire."

This creates a frustrating loop where the company cannot be registered by the approved platform because they aren't in the Annuaire, and they cannot use the approved platform until they are.

An approved platform can register addressing lines in the annuaire, but it cannot register a missing SIREN. That must be resolved directly with the DGFiP — see section 5 for how to do this.

If you have confirmed you are a taxpayer, but your approved platform cannot find your SIREN in the Taxpayer Annuaire, you must resolve this directly with the tax administration — not your approved platform.

Contact the French tax authorities (DGFiP) immediately. You can do this by messaging them using the private/secure messaging system. Your platform cannot do this on your behalf; the legal entity must initiate the correction.

Understanding these nuances is key to a smooth transition to France's e-invoicing mandate. Always verify your taxpayer status first and contact the DGFiP directly if your SIREN isn't showing up where it belongs.

The steps above give you a clear framework, but France's e-invoicing process has layers that vary by business structure, tax profile, and entity type. If you're stuck — whether at the taxpayer verification stage, navigating the two directories, or caught in the platform catch-22 — speak with Avalara today about solutions to your challenges.