In my April 22 article, I announced Odoo's final approval as an Approved Platform (Plateforme Agréée): the move from "provisional" registration to fully operational status after validation of interoperability tests with the Public Invoicing Portal. It removed the last uncertainty for companies that hesitated to rely on Odoo as the pivot of their compliance.
Since that publication, I keep getting the same question by email, in customer meetings, and during my talks at BNI or Réseau Colbert:
"OK, Odoo is a PA. Great. But concretely, what is covered, what isn't, and how do I get organized?"
This is precisely the question Odoo France answered on May 18 by sending its integrator partners a comprehensive status update on the solution: technical architecture, supported versions, timeline, and — the big news — the precise list of the State's 42 use cases with the coverage status of each. It is this operational material that I consolidate here.
For the thousands of French companies running Odoo — and for the integrators who support them — this is a relief and excellent news. The scenario of a mandatory connection to a third-party PDP, with its subscription costs and integration complexities, will not happen. Odoo handles everything, natively, within its own ecosystem.
2. What to take away from the official announcement
Here are the key points communicated by Odoo, reproduced faithfully:
Certification and infrastructure
- PA certification confirmed by the French administration.
- Secure servers in France, exclusively.
- Private PA: the Odoo platform will not accept connections from other vendors. It is reserved for the Odoo ecosystem.
- Pilot phase registration validated: testing will be possible as soon as the official module is released.
Scope of the solution
- B2B (invoices between French companies): Odoo acts as the access point. Invoices are issued in the right format to the customer's system via the approved platform, transiting through the Peppol network between PAs. In parallel, each invoice is transmitted to the State portal.
- B2C, international B2B, and payment flows: transmission of transaction data (E-reporting) before each deadline.
- All current Odoo features are maintained: optical document recognition (OCR), manual entry, payment management, partial payments, etc.
Supported Odoo versions
- V19: current version, supported by design.
- V18: priority target version on which Odoo develops the requirements. All fixes arrive there first.
- V17: backporting now confirmed by Odoo (a point that was still under discussion in my April article). Expect a lag of a few weeks on fixes.
- V16 and earlier: no support planned.
Availability by hosting mode
- Odoo Online
- Odoo.sh
- Private hosting (on-premise)
- Odoo Community ← excellent news for advocates of free software and digital sovereignty.
Timeline
- September 2026: full coverage of all mandatory requirements set by the State.
- June 4, 2026: Odoo Insider live (Q&A session reserved for Odoo integrator partners). ANOR will attend and publish a report.
3. ⚠️ The trap to avoid at all costs: the "e-invoicing" module already present in your databases
This is the point I want to hammer home in this article, because it is already causing errors at customer sites.
If you look at your Odoo database today, you will find a module named "Electronic invoicing". Many managers think it is the official module for the reform and activate it, sometimes registering in the Peppol directories.
This module is NOT the future PA module. It is a generic Peppol connector, useful in certain European contexts, but it has no connection with the Approved Platform solution that Odoo will publish.
What to do:
- Do not activate this module if you haven't already.
- Do not register in the directories through this module.
- Wait for the official publication of the Odoo PA module. Odoo will explicitly communicate the date.
Early registration can create technical conflicts when the real PA module is deployed. Be patient.
4. The State's 42 use cases: what Odoo covers, what it doesn't
The French administration has published a list of 42 use cases that PAs and PDPs can handle. Odoo has chosen to cover everything its standard solution handles natively, and to leave out of scope the cases that go beyond standard functionality.
Here is the full analysis, organized by coverage status.
4.1. Cases covered as standard by Odoo PA (21 cases)
These situations will be handled automatically, with no specific intervention.
| N° | Use case | Functional summary |
|---|---|---|
| 1 | Multi-order / Multi-delivery | A single invoice grouping several orders or deliveries, with line-by-line linking. |
| 2 | Invoice already paid at issuance | Cash purchase, net amount payable zero, "Collected" status transmitted. |
| 5 | Expenses paid by employees, invoice in the company's name | Expense reports with an invoice made out to the employer. |
| 6 | Expenses paid by employees without a company invoice | Small purchases in B2C E-reporting, convertible after the fact into a B2B invoice. |
| 7 | Purchase paid with a ghost card (purchasing card) | Travel or trips paid through a centralized solution. |
| 17a | Payment via an intermediary (marketplace) | Funds transiting through a payment platform. |
| 18 | Debit notes | Clear distinction between a debit note and an official invoice. |
| 19b | Self-billing | The buyer creates the invoice on behalf of its seller. |
| 20 | Down payment invoice | Prior payment that must be invoiced. |
| 21 | Final invoice after down payment | Settlement with deduction of the down payments received. |
| 22a | Discount with VAT on receipts (services) | VAT adjustment on the amount actually collected. |
| 22b | Discount with VAT on debits (goods) | Issuance of a credit note to adjust the VAT collected. |
| 23 | Self-billing individual / professional | Typical case of solar panels resold to a supplier. |
| 27 | Toll tickets sold to a taxable person | B2C E-reporting tolerance. |
| 28 | Restaurant bills issued in France | Exemption from customer identification below €150. |
| 29 | Single taxable person (art. 256 C of the CGI) | VAT group with a single SIREN. |
| 30 | VAT already collected (B2C → B2B after the fact) | B2B invoice after a sale already declared at the till. |
| 31 | Mixed invoices (principal + ancillary) | VAT regime of the principal transaction applied to the whole. |
| 32 | Monthly payments | Installment schedule + annual settlement. |
| 34 | Partial payment and cancellation | Handling of reconciliation errors through statuses. |
| 38 | Sub-lines and line groupings | Detail of gift baskets, kits, etc. |
If your business relies on these flows, you are fine. The vast majority of French SMEs and mid-sized companies (trading, services, retail, professional services) fall into this category.
4.2. Conditional cases: covered if market demand is sufficient (7 cases)
A small point of vocabulary to understand well. Odoo's "If demand" status does not mean these cases will be handled as soon as you express the need. It means that Odoo will add these cases to the standard roadmap if a sufficient volume of customers raise them. It is a logical publisher approach: adapt the solution to the most widely shared market needs.
Concrete implication for a manager: if one of these cases concerns your business, two scenarios are possible. Either Odoo decides to support the case as standard and you benefit natively. Or the case stays out of scope, and it joins the same partner-extensibility question as that raised for the uncovered cases (see section 4.3). This question is being clarified with Odoo France.
| N° | Use case | When it applies to you |
|---|---|---|
| 3 | Third-party payer known at invoicing | Group company, centralizing body. |
| 4 | Partial coverage by a third party | Subsidy, insurance (health insurer, etc.). |
| 9 | Third party managing payment + supply chain | Advanced variant of factoring. |
| 14 | B2B co-contracting | Consortium of companies with an agent. |
| 15 | Order placed by a third party for the buyer | Media agency, purchasing broker. |
| 16 | Disbursement invoice | Reimbursements outside VAT (tax stamps, etc.). |
| 25 | Gift vouchers and gift cards | Single-use / multi-use distinction. |
4.3. Cases not covered by Odoo PA (14 cases)
On these situations, Odoo has made the deliberate choice not to carry the developments in its standard solution. It is a scope logic: Odoo natively covers what its solution already handles functionally, and concentrates its certified effort on that base.
For customers whose business depends on one of these 14 cases (construction with subcontracting and direct payment, travel agencies under the margin scheme, mid-sized companies using factoring, etc.), a precise architectural question arises: will the Odoo PA implement, in its official module, all the structured fields needed for the French EXT-FR-FE- extensions (PAYER, ADDRESSED TO, factor BENEFICIARY, etc.), or only those strictly necessary for the 21 cases covered as standard?*
This question, and this question alone, determines the technical path for these 14 cases. Two possible scenarios:
- Scenario 1 — The PA implements all Factur-X / EXT-FR-FE-* fields. In this case, partner integrators such as ANOR can extend the Odoo modules upstream (through standard Odoo inheritance) to use these already available fields and address the uncovered cases. Your customers' compliance is then achievable through partner development, with no dependence on Odoo's roadmap.
- Scenario 2 — The PA only implements the fields for the 21 standard cases. In this case, it is not possible for an extension module to generate the missing fields for the other 14 cases in the XML. The compliance path then depends entirely on Odoo's decision to evolve its PA to include these fields.
On the technical side, the Factur-X EXTENDED-CTC-FR profile standard defined by FNFE-MPE exists precisely to carry all the necessary fields. The AFNOR XP Z12-013 standard published in May 2025 also standardizes the exchange APIs between enterprise systems and approved platforms.
I put this question directly to the Odoo team. I will give you the precise answer the day after the June 4 Odoo Insider, in a dedicated report on this blog. This point must be settled before I can guarantee a clear compliance path if your business falls in the non-standard zone.
| N° | Use case | Why you need to anticipate it |
|---|---|---|
| 8 | Designated third-party payer (factoring, centralized treasury) | Very common in mid-sized companies. |
| 10 | Factor unknown at creation (subrogation) | Assignment of receivable during the invoice's life. |
| 11 | Third-party recipient on behalf of the buyer | Property manager, building administrator. |
| 12 | Transparent intermediary for the buyer | Delegated professional buyer. |
| 13 | Subcontracting with direct payment | Very frequent in construction. |
| 17b | Payment intermediary + invoicing mandate | Advanced marketplaces. |
| 19a | Invoicing third party with mandate | Full outsourcing of invoicing. |
| 24 | Deposits (arrhes) | Outside VAT scope, outside the reform. |
| 26 | Contractual reservation clauses | Retention money in construction. |
| 33 | Profit margin scheme | Second-hand goods, travel agencies. |
| 35 | Author's statements | Publishers, copyright. |
| 36 | Professional secrecy | Lawyers, regulated professions. |
| 37 | Joint ventures (sociétés en participation) | Structures without legal personality. |
| 39 | Multi-seller invoices | Platforms grouping several sellers. |
| 40 | Grouped payments / netting / offsetting | Cross purchases-sales. |
| 41 | Barter companies | Exchanges of goods and services. |
| 42 | Tax refund (détaxe) | VAT refund at customs crossing. |
Note: the list evolves regularly. Odoo maintains an up-to-date grid of its coverage.
4.4. Visual summary
| Status | Number of cases | Share |
|---|---|---|
| Covered as standard | 21 | 50 % |
| Covered on demand | 7 | 17 % |
| Not covered | 14 | 33 % |
| Total | 42 | 100 % |
Quick read:
- Green zone (50%): if your business fits the standard flows of trading, retail, services or classic industry, you are natively covered by Odoo. No additional action required.
- Orange zone (17%): if you fall into a conditional case, your coverage will be provided either by Odoo (if the market pushes in that direction) or by partner development. A compliance path exists in both scenarios.
- Red zone (33%): if you operate in construction, advanced marketplaces, regulated professions or with complex financial arrangements (factoring, profit margin, etc.), your path depends on the answer Odoo will give on the extensibility of its PA module by partners. This is exactly the question I put to Odoo France and for which we await the answer at the June 4 Odoo Insider.
The message to remember: for 67% of companies (green and orange zones), compliance is technically clarified. For the 33% in the red zone, the path will be settled in the coming weeks.
5. My integrator's analysis: why I advise migrating directly to V19
Odoo officially recommends migrating to V18. My advice for ANOR differs on one specific point.
Starting a V17 → V18 migration today only to have to redo the V18 → V19 project in a few months makes no economic sense. An Odoo migration costs in analysis, testing, training and operating risk. Doubling that cost for intermediate-version reasons is an avoidable expense.
My decision is simple:
- If you are on V16 or earlier: migrate directly to V19. You will benefit from the PA as soon as it is backported (and V19 will be covered before V17, by design).
- If you are on V17: plan the move to V19 in the coming months. You will have the PA module on V17, but you will systematically be one notch behind on fixes and enhancements.
- If you are on V18: stay where you are, but start scoping your move to V19. You will be on Odoo's target version, so well served for PA fixes, but V19 will give you an edge on new business functionality.
- If you are already on V19: well done, you are in the best place. Get ready to welcome the PA module as soon as it is published.
A single migration, on the current version, is healthier and more sustainable. It is also the position I have held at ANOR from the start: no intermediate migration when you can do the right one the first time.
6. Recommended action plan for an SME or mid-sized company leader
Here, in actionable form, are the six steps to start right now to be ready in September.
Step 1 — Map your flows
List your invoice types: B2B France, international B2B, B2C, marketplace sales, subcontracting, factoring, debit notes, down payments. Check this list against the 42 use cases. Identify your critical cases.
Step 2 — Audit your third-party master data
E-invoicing relies entirely on reliable identification of partners. Check:
- SIREN and SIRET of all your business customers
- Intra-community VAT numbers for your European customers
- Standardized postal addresses
- Invoicing contact details separate from delivery details where needed
A wrong or missing third-party data point = an invoice rejected by the public portal.
Step 3 — Decide on the target Odoo version
Launch the migration analysis to V19 with your integrator. The earlier you start, the more you spread the cost and the risk.
Step 4 — Identify your specific cases and prepare the decision
For each case outside standard coverage that concerns your business, map out precisely the usage and volumes. This analysis gives you two things: the action priority (a marginal case is not a structuring case), and the exact scope of the specification to carry once Odoo's position on partner extensibility is known.
This mapping work can start right now, regardless of Odoo's final decision. The sooner you have the precise, quantified list of your at-risk use cases, the faster you will be able to decide between the options that will arise: native extension by a partner module in Odoo, switching these flows to a specialized third-party PDP, or a procedural adjustment to fit into a covered case.
Step 5 — Prepare your teams
E-invoicing changes the user experience in accounting, sales administration and purchasing. Plan the training ahead. A deployment that succeeds technically but is poorly supported on the human side is a failed deployment.
Step 6 — Receive our report on the June 4 Odoo Insider
On June 4, Odoo is holding an "Insider" session reserved for its integrator partners, hosted by Laureline Zizi (PA lead at Odoo France). Two hours of live Q&A on PA and e-invoicing topics. As an Odoo partner, ANOR will attend.
We will publish a detailed report of the information shared right afterwards: clarifications on supported versions, release schedule of the official module, changes to the functional scope, answers to sensitive technical questions. To receive this report directly, subscribe to our newsletter or follow us on LinkedIn.
7. How ANOR supports you
ANOR is an Odoo consulting and integration firm dedicated to French SMEs and mid-sized companies in trading, retail, services and industry. We operate under the Auguria commercial brand, a member of the ANOR group.
On e-invoicing, we offer three levels of intervention:
E-Invoicing Compliance Audit (fixed price)
A scoping engagement of 5 to 10 days depending on the size of your business, delivering:
- A mapping of your flows against the 42 use cases
- An audit of your third-party master data
- The recommended migration plan (target version, timeline, budget)
- The list of necessary custom developments, with estimates
Odoo V19 migration with integrated PA preparation
For customers on V16, V17 or V18, we offer a single migration to V19, including preparation for the PA module. You save effort: a single operation, a single cost, a single risk period.
Support for deploying the PA module
As soon as Odoo publishes the official module, we take charge of deployment, configuration, testing, registration in the directories and training of your teams.
8. In conclusion
E-invoicing is a structuring reform that goes beyond a mere administrative obligation. It reconfigures information flows between companies and the administration, it accelerates the modernization of information systems, and it raises digital sovereignty questions that I have been defending for years.
The fact that Odoo is certified as an Approved Platform, and that it offers this solution even on Odoo Community, is excellent news for the technological sovereignty of French SMEs and mid-sized companies. Free software becomes a player in regulatory compliance, and it demonstrates that the open source ecosystem is now mature enough to carry the most critical stakes of the economic fabric. Let us also acknowledge the quality of the work accomplished by the Odoo France teams to obtain this certification on time and with an ambitious functional scope.
For the majority of SMEs and mid-sized companies (trading, retail, services, classic industry), the Odoo PA foundation will directly cover their needs. For businesses that fall into the cases not covered as standard, the question of extensibility by integrator partners remains to be clarified with the publisher. I have put it to Odoo formally and I commit to publishing the answer the day after the June 4 Odoo Insider.
For your company, the window for action is clear: between now and September. All the workstreams independent of this decision (migration, third-party audit, flow mapping) must be launched as soon as possible to approach the deadline calmly. Mapping your use cases in particular is work you can start right now: it will give you the material to decide quickly, whatever technical path emerges.
If you want to open a dialogue on your specific situation, let's schedule a meeting. The first conversation is free, with no commitment, and decision-oriented.