Schedule 1 to the Terms of Sale — Specific conditions for the Factur-X tool

1. Purpose of the schedule

This schedule supplements the Terms of Sale and the Terms of Use as regards the Factur-X validation tool (the “Factur-X Tool”).

It prevails over the Terms of Use and the Terms of Sale for everything concerning this Tool. Given the regulated field in which it operates, the Customer is invited to read it with particular attention.

2. Scope of the Tool

2.1 What the Tool does

The Factur-X Tool is a technical validation component. From a document submitted to it, it extracts the structured representation it contains and checks its conformity against a set of declared rules.

2.2 What the Tool is not

The Publisher is not an Approved Platform, nor a dematerialisation operator, nor a trusted third party within the meaning of the regulations on electronic invoicing.

The Tool performs none of the following functions:

• transport, issuance, receipt or filing of invoices to a recipient, a platform or an administration;
• connection to a public platform or a directory;
• e-reporting or transmission of transaction data to the administration;
• generation of documents or of their structured content;
• checking the format of the document container (in particular conformity with the PDF/A-3 format);
• handling of formats other than those expressly listed in the documentation.

The Customer retains full responsibility for the choice of its issuance platform and of its invoicing chain.

2.3 Identifier checks

The company identifiers present in the document are checked as to their form only (expected structure and length). The Tool verifies neither their check digit, nor their actual existence in an official register, nor their attachment to the designated entity. A syntactically valid but non-existent or erroneous identifier will not be flagged.

3. Nature of the result

3.1 Graded result

The result is never a binary conformity answer. It takes one of the following forms:

• certain rejection: at least one blocking anomaly has been detected;
• conforming on the evaluated scope: no anomaly detected among the rules actually evaluated, with all applicable rules having been evaluable;
• conforming subject to reservation: no anomaly detected, but all or part of the applicable rules could not be evaluated.

Each result is accompanied by the count of evaluated rules relative to the applicable rules. This count is not a probability of conformity: it is a measure of coverage. Rules that were not evaluated are declared, never passed over in silence.

3.2 Asymmetry of certainty

The Customer expressly acknowledges having understood and accepted the following principle, which governs the whole of this schedule:

An invoice for which the Tool detected no anomaly may nonetheless be rejected by an Approved Platform, by a business partner, by a third-party information system or by the administration, for a reason outside the evaluated scope.

3.3 Reservation carried by the result

Any positive result issued by the Tool includes, within the body of the response itself, an explicit reservation recalling that the absence of anomaly does not guarantee acceptance of the document by a third party. The Customer undertakes not to separate this reservation from the result when it passes it on to its own users or customers.

4. Known and declared limitations

4.1 Principle

The Publisher brings to the Customer's attention the coverage limitations it is aware of. The Customer may not rely on the Tool beyond the declared scope.

4.2 Current limitations

As at the date of the latest update of this schedule:

• approximately sixteen (16) national business rules, relating mainly to the calculations of the corresponding annex of the specification, are not yet covered by the implementation; consequently, the best result that can be issued on the French flow is “conforming subject to reservation”, each positive result carrying the corresponding reservation;
• company identifiers are subject only to a form check (§2.3);
• the format of the document container is not checked (§2.2);
• the embedded specification version may predate the most recent regulatory texts (§8).

This list is kept up to date in the Tool's technical documentation, to which the Customer is invited to refer before any use in production.

5. Nature of the commitment

5.1 Best-efforts obligation

The Publisher is bound by a best-efforts obligation. Its commitment consists in making the Tool reflect the rules of the declared specification, verified by comparison with the corresponding reference implementation.

The Publisher in no case guarantees:

• acceptance of a document by an Approved Platform, a public platform, a partner or the administration;
• the absence of rejection, of a request for regularisation, of a reassessment or of a sanction;
• the conformity of the Customer's invoicing with its legal, tax or accounting obligations;
• the exhaustiveness of the evaluated rules.

5.2 Absence of advice

The Tool constitutes neither legal advice, nor tax advice, nor accounting advice. It substitutes neither for the Customer's chartered accountant, nor for its own internal controls.

5.3 Customer's responsibility

The Customer remains solely responsible:

• for the conformity of its invoicing and compliance with its reporting obligations;
• for the choice to use the Tool and the use it makes of its results;
• for the decisions, automated or not, that it bases on those results.

6. Audit log

6.1 Purpose

Each response issued by the API gives rise to the recording, in a dedicated log, of a trace of the response provided, intended to enable the Customer to establish after the fact what the Tool answered and when.

6.2 Content and non-retention of documents

Neither the submitted document nor its structured content are retained. The recorded trace comprises exclusively:

• the server timestamp of the response;
• the identifier of the account and of the key used;
• a cryptographic fingerprint of the submitted document, which does not allow its content to be reconstructed;
• the response issued, retained in encrypted form;
• the result, the detected profile, the version of the rules applied and the processing duration.

The Publisher's promise is as follows: it does not retain the Customer's invoices; it retains the timestamped and encrypted proof of the response it provided.

The Customer is informed that the response may contain, in its anomaly messages, values extracted from the submitted document. These values are encrypted at rest but travel in clear to the Customer at the time of the response.

6.3 Integrity

The traces are recorded append-only and chained together by cryptographic fingerprint. This mechanism makes it possible to detect any subsequent alteration of the log.

The Customer is informed that this chaining is not anchored with an independent third party and is not enforceable against the Publisher itself. The timestamp applied is a server timestamp, which does not constitute a qualified timestamp within the meaning of Regulation (EU) No 910/2014.

The term tamper-proof cannot be used to describe this log.

6.4 Proof receipt and best-effort nature

Each response includes a receipt corresponding to the fingerprint of the recorded trace. The Customer is invited to keep this receipt: it allows it to later verify the consistency of the trace and constitutes its own element of proof, independent of the Publisher's log.

Recording in the log is carried out to the best of the available means. A recording failure does not interrupt the response: the receipt is then absent, which signals to the Customer that no trace has been retained for that call. The Publisher does not guarantee the availability of proof for every call.

Calls made from the demonstration interface accessible without an account give rise to no recording and cannot serve as proof.

6.5 Retention period

The traces are retained for a period of ten (10) years from their recording, for the purposes of accounting proof and proof in the event of a dispute, aligned with the usual retention periods for commercial documents and supporting records.

6.6 Encryption and erasure

The traces are encrypted using a key specific to each account, itself protected by a master key kept outside the database.

Erasure of an account's traces is carried out by destroying the corresponding encryption key, which renders the traces permanently undecipherable while preserving the integrity of the chain.

Important information: this operation is not triggered automatically upon the closure of an account. It is subject to manual handling on request, under the conditions set out in the Privacy Policy.

7. Data protection

Where the Customer submits to the Tool documents containing personal data for which it is the controller, the Publisher acts as a processor within the meaning of the GDPR. The conditions of this processing are defined in [Schedule 2](/cgv/annexe-2-dpa) to the Terms of Sale.

The metadata retained in clear in the audit log, listed in §6.2, is processed by the Publisher on its own behalf, for proof and Service security purposes.

8. Evolution of the rules and regulatory monitoring

The Tool implements a determined version of a technical specification, whose reference is recalled in each result (rules version field). As at the date of the latest update of this schedule, the version applied is 2026.1, based on the Factur-X v3.2 specification (reference of 30 April 2026).

The Customer acknowledges that this version may be earlier than the most recent regulatory texts, in particular texts issued after the date of the embedded specification.

The Publisher updates the applied rules according to the specification in force, each update taking effect on an announced date. It does not guarantee the immediate integration of every normative or regulatory change, nor the availability of standards subject to a paid licence. It is for the Customer to follow the evolution of its own obligations.

9. Liability

Without prejudice to §14 of the Terms of Use, it is expressly agreed that the Publisher shall not be held liable for the consequences of a rejection, a regularisation, a reassessment, a penalty or a sanction borne by the Customer, even where the Tool detected no anomaly on the document concerned.

The Publisher's liability under this Tool is capped at the total amount of the sums actually paid by the Customer in respect of this Tool during the twelve (12) months preceding the triggering event.

Indirect damages are excluded, in particular loss of operations, loss of turnover, damage to image and tax or administrative sanctions.

10. Acceptance

Subscribing to the Factur-X Tool entails acceptance of this schedule, and in particular of the express acknowledgement set out in §3.2.