Mandatory electronic invoicing in France: who and when | Comparatif-Pro

The mandatory electronic invoicing requirement comes into force in France from 1 September 2026 for the reception of inter-business invoices and for issuance by large entities, then from 1 September 2027 for the remaining categories. The reform, introduced by ordinance no. 2021-1190 and decree no. 2022-1299, fundamentally reshapes the way invoicing data flows between professionals subject to VAT.

Every business established in France and liable for VAT is concerned, whether commercial companies, liberal professions, craftsmen, traders or self-employed individuals. The reform draws a clear line between two distinct yet complementary mechanisms: the digitisation of invoices for flows between French professionals, and e-reporting for the other VAT-related operations.

Key points:

1. Every VAT-liable business established in France falls within the scope for domestic B2B flows, with no turnover threshold.
2. The transition unfolds in two stages: reception and issuance for large groups and mid-cap companies on 1 September 2026, issuance for SMEs and very small businesses on 1 September 2027.
3. B2C and international operations do not move to digitised invoicing but feed the e-reporting channel.
4. Penalties reach 15 euros per non-compliant invoice, capped at 15,000 euros per year and per business (article 1737 of the French Tax Code).

What the reform requires from French businesses

The mandatory e-invoicing framework rests on three structural principles set out in the ordinance of 15 September 2021 and its implementing decree of 7 October 2022.

First principle: every invoice exchanged between two VAT-liable parties established in France must transit through a digitisation platform. Direct transmission by email, by post or by sharing an unstructured PDF is no longer accepted. The invoice must follow a standardised form, machine-readable for the issuer, the recipient and the tax authority.

Second principle: the ecosystem relies on two types of platforms. On one side, the Public Invoicing Portal (PPF), operated by the AIFE and built on the Chorus Pro infrastructure, which acts as the central directory and tax data hub. On the other side, partner digitisation platforms, certified by the DGFiP, which deliver extended services to businesses. The detailed mechanics of the ecosystem and the tax administration’s role in electronic invoicing are covered in the dedicated article.

Third principle: invoicing data is collected by the tax authority, which enables the pre-filling of VAT returns and strengthens the fight against VAT fraud. France thus joins the so-called continuous transaction control model, already in force in Italy, Spain and Mexico.

“Electronic invoicing between taxable persons will be rolled out progressively, with the goals of modernisation, simplification and stronger competitiveness for businesses.” – French Directorate General of Public Finance, impots.gouv.fr, 2024

Who falls within the scope

The reform applies to every VAT-liable business established in France, regardless of turnover threshold. The scope is defined by article 289 bis of the French Tax Code, which transposes European rules on invoicing.

The businesses concerned cover a very broad spectrum:

• Commercial companies (SARL, SAS, SA, SASU, EURL and their variants)
• VAT-liable liberal professions (lawyers, architects, consultants, agencies)
• Craftsmen and traders registered in the national business registry
• Associations carrying out an economic activity subject to VAT
• Self-employed individuals exceeding the basic franchise thresholds
• Sole proprietorships under personal or corporate income tax with B2B sales

Structures that are not VAT-liable (associations without commercial activity, self-employed individuals under the franchise regime for their B2C flows) are not subject to the issuance obligation, but may receive digitised invoices and must therefore be ready to receive them. The specific situation of micro-entrepreneurs is detailed in the article dedicated to the reform and self-employed individuals.

A clarification: digitisation applies only to domestic B2B flows, i.e. between two French companies subject to French VAT. Exports, intra-Community acquisitions and B2C transactions follow a different track, that of e-reporting.

The distinction between issuance and reception

Drawing a line between issuance and reception obligations is central to understanding the reform’s timeline. The two notions follow different operational logics.

The reception obligation means a business must be able to receive an invoice transmitted in the standardised format, either through the PPF or through a partner platform. In practice, this requires being identified in the central administrative directory and having a reception channel in place. This obligation enters into force simultaneously for every business on 1 September 2026.

The issuance obligation requires that outgoing invoices be produced in the standardised format and transmitted through a certified platform, with the extraction of tax data. This obligation is staggered by company size to limit the adaptation shock, particularly for the smallest entities that must upgrade their management tools.

In practice, an SME that receives its supplier invoices in digitised form from September 2026 onwards but continues to issue its own invoices on paper or as PDFs until September 2027 remains compliant with the rules, provided that its large or mid-cap suppliers do transmit standardised invoices to it.

Rollout calendar by company size

The classification thresholds rely on decree no. 2008-1354 (headcount, turnover, balance sheet total). The regulatory grid is as follows:

For the full list of reform deadlines and the internal milestones to anticipate, the dedicated calendar article structures a month-by-month compliance plan. The specific circumstances of SMEs in compliance mode and those of very small businesses are also covered in operational guides.

The above schedule stems from the 2024 Finance Act article 91, which postponed the original timeline. The BOFIP (BOI-TVA-DECLA-30) consolidates administrative comments on the progressive application of the framework.

E-reporting: the counterpart for non-invoiced flows

E-reporting is a distinct yet simultaneous mechanism that covers VAT-related operations falling outside the scope of digitised invoicing. It mainly targets three categories of transactions.

B2C sales represent the largest volume concerned. A bakery selling a croissant to a private individual, an online retailer delivering to a consumer, a craftsman performing a service for a household are not concerned by digitised invoicing, but must transmit transaction data (amounts, VAT rates, dates) to the administration via a certified platform.

International B2B operations form the second category: sales to a professional client established outside France (other EU countries or third countries), intra-Community acquisitions, imports. Invoices may remain in PDF or paper form in some configurations, but tax data must be reported to the DGFiP through e-reporting.

Payment data for service provisions form the third category. For services subject to VAT on cash receipts, the business must report the date and amount of payments received, in addition to the original invoice.

The e-reporting timeline mirrors that of digitised invoice issuance: 1 September 2026 for large companies and mid-cap groups, 1 September 2027 for SMEs and very small businesses. The transmission frequency depends on company size (monthly or quarterly) and on the VAT regime.

Exceptions and special cases

Several situations fall fully or partly outside the framework. A precise mapping is needed to identify excluded flows.

VAT-exempt operations stay outside digitisation: medical services, banking and insurance operations, education services, residential furnished rentals. These transactions do not trigger an electronic invoicing obligation, nor an e-reporting obligation, except in specific cases.

Intra-group transactions follow a particular regime when a VAT group is formed: invoicing between group members does not give rise to VAT and is not subject to digitisation, although it remains subject to internal accounting obligations.

The public sector retains its existing transmission channel. Chorus Pro, already in use since 2017 for invoices sent to public bodies (B2G), continues to fulfil that role and is integrated into the PPF ecosystem. Suppliers to local authorities and to the State are already familiar with the Factur-X format.

Businesses not established in France but carrying out VAT-liable operations in France follow a lighter regime through their fiscal representative, unless they have a permanent establishment (in which case they are treated as French businesses).

Penalties for non-compliance

Failure to comply with the digitisation and e-reporting obligations is sanctioned under article 1737 of the French Tax Code, as amended by the 2024 Finance Act.

For digitised invoices, the fine is set at 15 euros per invoice not issued or received under the regulatory conditions (incorrect format, transmission outside a certified platform, missing data). The annual cap stands at 15,000 euros per business and per calendar year. The fine does not apply if the business demonstrates that obligations were met despite a technical failure of a certified platform.

For e-reporting, the fine is 250 euros per missed transmission, also capped at 15,000 euros annually. A transmission corresponds to one declarative cycle (monthly or quarterly depending on company size), not to a single transaction.

Beyond financial penalties, non-compliance increases the risk of a tax audit. Pre-filling of VAT returns through incoming invoicing data makes it easier to detect inconsistencies between collected VAT and deductible VAT. A business that fails to issue digitised invoices correctly is exposed to a VAT reassessment in case of mismatch between its returns and those of its clients.

The DGFiP has announced a tolerance period at the start of the reform, during which fines will not be applied for the first months following each milestone, allowing businesses and software publishers to finalise their compliance work. The exact length of this tolerance will be specified by administrative instruction at the BOFIP.

Compliance checklist

Preparing for the September 2026 deadline mobilises several parallel work streams. A step-by-step compliance framework helps structure the project, regardless of company size.

Step 1: map the invoicing flows. Identify every issuance and reception channel currently in place (accounting software, ERP, manual invoicing, business applications). List monthly volumes by channel. Identify domestic B2B, B2C and international flows to anticipate the split between digitised invoicing and e-reporting.

Step 2: choose a transmission platform. Two options coexist. The PPF is free of charge for basic features. A partner platform is paid but offers extended services (probative archiving, ERP integration, dunning management). Choosing the partner digitisation platform (PDP) is the most structuring decision of the project.

Step 3: check the compatibility of the invoicing software. The main publishers (Sage, Cegid, EBP, Pennylane, Indy, Tiime, Henrri, Axonaut, Yooz, Esker) are developing dedicated modules. To identify the most suitable solution for a given context, the comparison of e-invoicing software details the selection criteria by company size and by industry.

Step 4: complete the mandatory tax data. The standardised format requires extended fields: SIREN number, unique transaction identifier, VAT category code, customs data for cross-border operations. A prior audit of the customer and supplier file allows identifying the missing data to recover.

Step 5: train accounting and procurement teams. The shift to digitised invoicing transforms validation, allocation and archiving processes. Training of administrative and finance teams is essential, alongside an update of internal procedures.

Step 6: plan testing. A test cycle with a few pilot suppliers and clients, several months ahead of the deadline, helps detect interfacing and format issues before generalisation. Targeted scenarios should cover credit notes, multi-rate VAT cases, foreign-currency invoices, advance payments and partial deliveries, since these situations frequently expose mapping gaps between an internal accounting system and a certified platform.

Step 7: secure archiving and traceability. The probative value of a digitised invoice rests on a strict archiving chain: receipt acknowledgement, life-cycle status (deposited, validated, rejected, paid), retention period set to ten years under article L.123-22 of the Commercial Code, and integrity controls. Each business must define where the original electronic invoice is stored, how it can be retrieved during a tax audit, and which retention service is engaged when the partner platform contract ends. Failure to retrieve an invoice during an audit can lead to its disqualification and to a VAT reassessment, even if the original transmission was compliant.

Step 8: monitor regulatory updates. The implementing texts will continue to evolve until the rollout dates and beyond. The DGFiP regularly publishes clarifications, the AIFE updates its technical specifications, and the European Commission is also moving forward on a directive on VAT in the digital age (ViDA), which will harmonise European rules over the coming years. Assigning the regulatory watch to a single internal stakeholder, supported by professional bodies (CPA association, employer federations), avoids fragmented reading of the texts.

“Preparing for electronic invoicing mobilises finance departments, IT departments and legal departments. It is a company-wide project that goes far beyond a simple software update.” – French national council of certified public accountants, statement 2024

A pragmatic governance framework brings together finance, IT, procurement, sales and legal under the same project committee, with monthly review of progress and explicit budget lines for licence fees, integration work and team training. Smaller structures can streamline this governance into a single project lead supported by their certified public accountant.

To follow the regulatory updates and clarifications month by month, the official sources to monitor remain the dedicated page on impots.gouv.fr, the portailpro.gouv.fr website operated by the AIFE, and the administrative comments published in the BOFIP under reference BOI-TVA-DECLA-30. The complete electronic invoicing guide covers the full framework, from origins to operational rollout.

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