Last update February 2, 2026
INDEPTH ANALYSIS
1. Scope of the Mandate
France’s upcoming e-invoicing and e-reporting mandate applies broadly to all VAT-applicable transactions involving at least one French-established taxpayer. In particular: [impots.gouv.fr], [cleartax.com]
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Domestic B2B (business-to-business): Mandatory e-invoicing will be required for all B2B supplies of goods or services where both supplier and buyer are established (VAT-registered or domiciled) in France. This covers essentially all domestic B2B invoices subject to French VAT, including within corporate groups and involving branches in France. The e-invoice (in a standardized digital format) must be issued and transmitted through certified platforms at or around the time of issuance, with a copy (or key data from it) delivered automatically to the tax authority in real time. [impots.gouv.fr], [sovos.com] [sovos.com] [ey.com], [sovos.com]
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Domestic B2C (business-to-consumer): Consumer invoices will generally not be subject to mandatory e-invoicing, as private individuals are outside the e-invoicing scope. However, B2C transactions must be reported to the tax authorities electronically via “e-reporting”. Businesses must transmit specified sales data for their domestic B2C transactions to the tax administration on a periodic basis (see section 5). In practice, companies can continue to issue paper or PDF invoices/receipts to consumers, but they must send summary information (e.g. daily or periodic totals by VAT rate) through the e-reporting system. [cleartax.com] [impots.gouv.fr] [cleartax.com], [cleartax.com] [cleartax.com], [kpmg.com]
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Domestic B2G (business-to-government): **Electronic invoicing for B2G transactions has been mandatory since 2020 via the state’s Chorus Pro system. All invoices to French public authorities must already be issued through the central “Portail Public de Facturation (PPF)” (originally known as Chorus Pro). This existing B2G e-invoicing requirement remains in effect and is complementary to the new B2B mandate. In fact, the same public platform (PPF) and processes are being extended to B2B e-invoicing under a new architecture (see section 5). [impots.gouv.fr] [impots.gouv.fr], [marosavat.com]
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Intra‑EU B2B (cross-border supplies and acquisitions within the EU): Cross-border B2B transactions involving a French VAT-registered company will fall under e-reporting obligations, not domestic e-invoicing. Invoices between a French company and an EU business customer/supplier must still be issued in whatever format is required by the parties and EU law (for example, a French supplier may issue a PDF or paper invoice to an EU buyer as today), but the key details of these transactions must be electronically reported to the French tax portal in lieu of real-time e-invoicing. Intra-EU supplies (sales from France to another EU country) are typically zero-rated for French VAT; they will be captured via e-reporting rather than exchanged via the French e-invoicing system. Likewise, intra-EU acquisitions (purchases by a French company from a supplier in another EU member state) must be reported by the French buyer via e-reporting in order to give the tax authorities visibility of those inbound transactions (especially since the foreign supplier is outside the French e-invoicing network). [impots.gouv.fr], [cleartax.com] [cleartax.com] [kpmg.com], [cleartax.com]
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Imports and Exports (extra-EU): Imports into France (purchases from non-EU suppliers) and exports from France (sales to non-EU customers) are in scope of e-reporting. As with intra-EU trade, French companies will generally continue to issue/receive invoices for these transactions outside the domestic e-invoicing system (using traditional means), but they must transmit the transactional data to the tax authority via the e-reporting channel. This includes import of services where French VAT is due under the reverse-charge mechanism – these, too, need to be reported by the French buyer via the new system. The customs VAT on imported goods will continue to be handled via customs declarations, but any additional invoice information required for tax control may fall under e-reporting as well. [cleartax.com] [kpmg.com]
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Cross-border B2B transactions (EU or non-EU): All B2B supplies involving a French VAT-registered party and a foreign party must be reported (e-reporting) rather than exchanged as e-invoices. In practice this means French outbound sales to customers abroad and inbound purchases from foreign suppliers (which are outside the domestic B2B scope) will require the French party to submit key invoice data (buyer/seller details, invoice date/amount, VAT amount or tax nature, etc.) to the tax authority’s portal shortly after the transaction. [impots.gouv.fr] [impots.gouv.fr], [cleartax.com]
In summary, only B2B transactions where both parties are established in France require e-invoicing. **Other types of transactions – B2C sales, sales to or purchases from foreign counterparties, as well as certain special cases – do not trigger a full French e-invoice, but must be reported to the tax authorities electronically (this is the “e-reporting” obligation). The overall aim is to ensure that all French VAT sales and purchase data (B2B, B2C, and cross-border) are digitally transmitted to the tax administration, either via an actual e-invoice or via an e-report, so that tax can be assessed and verified efficiently. [impots.gouv.fr], [cleartax.com] [ey.com], [cleartax.com]
Special inclusions and scenarios: The mandate’s scope is extensive. It explicitly covers scenarios such as self-billing, triangulation, and various VAT regimes:
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Self-billing (client-issued invoices, “autofacturation”): Self-billed invoices are treated as electronic invoices and thus must flow through the mandated platforms. France’s framework allows self-billing (with prior agreement between the parties, per existing VAT rules) and the new system will accommodate it. In practice, the customer (buyer) will issue the invoice via a certified platform, which will deliver it to the supplier through the e-invoicing system and to the tax authorities just as with any other B2B invoice. The supplier’s platform (or the public portal) will relay the invoice to the supplier for acknowledgment. The invoice must meet all the usual French requirements (including indicating it’s self-billed and referencing the self-billing agreement) and will be subject to the same data and reporting standards. The buyer is responsible for transmitting the invoice in the platform; the seller must ensure the invoice is valid (and typically must have granted advance consent for self-billing). In short, a self-billed invoice still counts as an e-invoice and must be handled via the e-invoicing platform, with appropriate acceptance workflows between buyer and seller to verify its accuracy. [bdo.global]
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Triangulation and chain transactions: France’s system does not exempt triangulation arrangements or multi-party chain transactions. The treatment depends on the nature of each invoice and the location of the parties: any invoice between French-established businesses in a supply chain must be e-invoiced via the platform (even if part of a larger intra-EU triangulation). If an intermediate transaction in a chain is a cross-border sale (e.g. a French company selling to an EU customer as part of a triangulation), that invoice is treated as an export/intra-Community supply and thus requires e-reporting rather than domestic e-invoicing. The key point is that every link of a multi-party transaction must be digitally tracked: domestic links via e-invoice, and cross-border links via e-reporting. Businesses involved in complex chain transactions will need to classify each invoice appropriately (domestic vs cross-border) and comply with the corresponding e-invoicing or e-reporting requirement. [impots.gouv.fr], [impots.gouv.fr] [impots.gouv.fr]
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Special VAT regimes (e.g. margin schemes, travel agencies, etc.): These transactions are included in the mandate, but the government has introduced some simplifications. For instance, supplies under the second-hand goods margin scheme or the travel agent regime (which are often B2C and involve VAT calculated on a profit margin) will not require detailed line-by-line reporting of every underlying sale in real time. Businesses can use simplified or aggregated reporting methods for such transactions, such as reporting the total margin or an average margin rate over a period, and then making any necessary adjustments in the VAT return. These measures are intended to ease compliance for special cases while still providing the tax authority with essential information. Other exemptions or special schemes (e.g. agriculture flat-rate regime) remain subject to the e-invoicing/e-reporting rules whenever an invoice is issued. Notably, VAT-exempt or zero-rated transactions are not excluded from the mandate: if an invoice is issued for a zero-rated or exempt supply (for example, an export sale or a domestic exempt transaction), it must still be transmitted as an e-invoice or e-report, with the appropriate VAT status coded (such as “exempt” or “0%”) so the authorities receive the data. [kpmg.com], [kpmg.com] [kpmg.com] [cleartax.com], [bdo.global]
2. Taxable Persons in Scope
The mandate applies to nearly all “taxable persons” (VAT-registered businesses) in France, with very few exceptions. Key points: [cleartax.com], [impots.gouv.fr]
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Established businesses in France: All legal entities established in France and subject to French VAT are in scope, regardless of size or legal form. This includes companies of all sizes (large, mid-tier, SME, micro-entrepreneurs) and even those under the VAT franchise/exemption regime (i.e. very small businesses below the VAT threshold). In effect, if a business has a French VAT number or is required to charge VAT in France, it must comply with e‑invoicing (for domestic B2B sales) and/or e‑reporting (for other transactions) requirements. There are no sector-based exemptions: the law applies across all industries – finance, healthcare, etc. – although entities not engaged in any B2B transactions (e.g. exclusively B2C businesses) will primarily have e-reporting rather than e-invoicing obligations. [cleartax.com] [impots.gouv.fr]
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French branches of foreign companies: If a foreign company is registered in France through a local branch or fixed establishment, that branch is considered an established French taxable person. Such branches will be subject to the mandate just like any French company, for invoices they issue to French customers. [sovos.com]
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Non-established businesses with a French VAT registration: Foreign or non-resident companies that have a French VAT number (but no fixed establishment in France) are also within scope, but their obligations are somewhat narrower and deferred. Since these companies are not “established” in France, they will generally not be required to issue e-invoices (because the e-invoicing requirement applies only to invoices between two French-established entities). However, VAT-registered non-established companies will have to fulfill e-reporting duties for certain transactions – notably their sales into France (e.g. domestic B2C sales) and any other operations for which they are liable for French VAT, such as domestic reverse-charge purchases or intra-EU acquisitions. In recognition that this is a new requirement, France has postponed the e-reporting go-live for non-established taxpayers to 1 September 2027 (regardless of size). In other words, a foreign company without a French establishment gets an extra year to prepare, and only from 2027 will need to start reporting transactions like local French purchases subject to reverse charge and intra-EU acquisitions. [kpmg.com], [kpmg.com] [sovos.com]
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Foreign businesses without any French VAT registration: Truly foreign companies that do not have a French VAT number and are not “taxable or identified persons” in France are outside the scope of these obligations. For example, a foreign company selling goods to French consumers under distance selling/OSS (without a FR VAT number) would not have French e-reporting duties. However, French buyers dealing with such foreign suppliers may themselves have to report the purchase (as an import or reverse-charge transaction) in some cases, so that these flows are ultimately captured. [impots.gouv.fr] [kpmg.com]
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Exclusions and special cases: The mandate’s coverage is designed to be comprehensive. There are few exemptions – for instance, businesses that are entirely outside the VAT system (e.g. non-profits or very small enterprises with no VAT number) would not participate. Likewise, certain transactions that do not involve invoicing at all (like some retail sales to consumers under certain thresholds where no invoice is legally required unless the customer requests one) are not forced into e-invoicing – though their aggregate turnovers still get reported via e-reporting. France’s tax authority has indicated no blanket carve-outs by sector; even traditionally exempt or sensitive sectors (finance, insurance, medical, etc.) must comply for their taxable transactions, albeit using the appropriate “exempt” reporting codes when no VAT is charged. That said, the government is providing accommodations and a longer lead time to small businesses (see section 3) and non-established companies (as noted above) to ease the transition. Voluntary early adoption is encouraged: beginning from 2024–2025, companies of any size can opt to start using the e-invoicing system (via registered platforms) before the mandatory dates, to gain experience ahead of the deadline. In 2025 a controlled pilot program will be in place, allowing firms to exchange e-invoices and reports on a voluntary basis through the central portal and partner platforms. [cleartax.com] [bdo.global] [ey.com]
3. Implementation Timeline
The French e-invoicing and e-reporting mandate has undergone several schedule changes. As of the Finance Act 2024, the official timeline is: [sovos.com], [sovos.com]
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July 2024 – Original start date (ABANDONED). The reform was originally slated to begin in 2024, but in July 2023 the French government announced a postponement to give businesses and the administration more time to prepare. (Notably, an EU derogation is required for a domestic e-invoicing mandate; France’s existing EU approval expires end of 2026, so the timeline was adjusted accordingly.) [assemblee-…tionale.fr] [ey.com]
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Q1–Q2 2025 – Pilot Phase: A voluntary pilot is expected to launch by early/mid-2025. The government aims to have the central Public Portal functional by late 2024 to enable a pilot in the first half of 2025, where companies (likely volunteers, software providers, and possibly large firms) can begin exchanging e-invoices and test the system via the PPF and partner platforms. This “sandbox” period will help iron out technical issues before the mandate goes live. (Precise dates are to be confirmed by the authorities.) [ey.com]
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September 1, 2026 – First Mandatory Phase: All companies (of any size) **must be able to receive e‑invoices by this date. In addition, issuance of e-invoices (and associated e-reporting) becomes mandatory for large enterprises and mid-sized companies (ETI) from this date. “Large” enterprises generally mean >5,000 employees or ≥€1.5 billion turnover; ETIs (entreprises de taille intermédiaire) roughly 250–5,000 employees or €50M–€1.5B turnover. These categories are assessed at the legal entity level, based on 2024 financials (size status fixed as of 1 Jan 2025). Starting Sep 2026, all such large/medium companies must issue invoices electronically via a certified platform, and must transmit e-reporting data for non-B2B flows. All French VAT-registered businesses – including SMEs – must at least receive e-invoices from their suppliers as of this date. (Sep 2026 is also the initial start of all e-reporting obligations – see below.) Note that the law allows a possible grace delay of up to 3 months via decree – i.e. implementation could be shifted to December 1, 2026 latest, if necessary. [sovos.com] [sovos.com], [sovos.com] [cleartax.com] [ey.com] [sovos.com], [cleartax.com]
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September 1, 2027 – Second Mandatory Phase: Small and medium-sized enterprises (SMEs) and micro-enterprises must begin issuing e-invoices and submitting e-reporting from this date. This assumes any business not classified as large/ETI – i.e. roughly under 250 employees and ≤€50 million turnover (SME), or under 10 employees ≤€2M turnover (micro). In effect, smaller businesses get an extra 12 months beyond the largest companies to comply. As with the first phase, the date could be postponed to Dec 1, 2027 by decree if needed. [sovos.com], [sovos.com] [cleartax.com] [sovos.com]
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Future adjustments: The Finance Law 2024 (Article 91) that set these dates requires France to obtain a renewed EU Commission authorization for mandatory e-invoicing, since the prior derogation expires end of 2026. If the EU authorization is delayed, it’s possible the dates shift slightly. Barring that, no further delays have been announced as of early 2026 (a proposal to delay to 2027 for large companies was not accepted in late 2025). Authorities are, however, empowered to grant a short deferral by decree if critical systems are not ready in time (the quarter adjustments noted above). [ey.com] [marosavat.com] [sovos.com]
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Grace period and leniency: To support a smooth transition, French authorities have indicated a degree of “soft landing” in enforcement for the initial stage. For example, for a short period after go-live, first-time offenders who promptly correct non-compliance (within 30 days of notification) may have penalties waived. Additionally, recent guidance suggests no penalties will apply to certain cases in the beginning, such as transactions involving foreign recipients lacking a French SIREN ID in the central directory. These tolerance measures aim to avoid penalizing companies for technical difficulties in the early days of the mandate. Nonetheless, companies are expected to make genuine efforts to comply by the deadlines, as the overall schedule is now set in law after extensive consultation and a one-time postponement. [cleartax.com] [kpmg.com], [kpmg.com] [assemblee-…tionale.fr]
(Different timelines by sector or transaction type: The phased implementation is primarily by company size, not by industry. All sectors follow the same dates above. One exception is that non-established firms registered for VAT have until 2027, aligning with the SME phase-in. Also, some public-sector specific workflows (e.g. certain government invoices) will continue on slightly different timelines or processes, but these do not affect most taxpayers.) [kpmg.com] [bdo.global], [bdo.global]
4. Technical & Functional Requirements
Invoice format and content: French e-invoices must be in a structured electronic format, not just PDF images. **France has specified three primary acceptable syntaxes: the UN/CEFACT CII format (Cross-Industry Invoice XML), the UBL 2.1 format (ISO-approved XML standard), or Factur‑X (the hybrid PDF with embedded XML data meeting the EN16931 standard). These cover France’s “minimum core” invoice schema; certified platforms must support at least these formats for interoperability. (Other structured standards, like EDIFACT or PEPPOL BIS 3.0 format, may also be used via conversion as long as all required data is captured, but the system revolves around the core 3 formats). Every e-invoice must contain all mandatory fields defined in French law (as per the Code Général des Impôts and commercial law) in the structured data – including traditional invoice details and new tax-specific fields introduced for this reform. These include, for example, the seller’s and buyer’s VAT/SIREN identification numbers, invoice date and number, line-item details (description, quantity, price, VAT rate, etc.), the type of transaction (goods, service, or mixed) and whether VAT is due on payment (for services under the “option sur les débits”). (The requirement to add the buyer’s SIREN and certain nature-of-transaction codes is new – French invoices will need these details from 2026 onward to facilitate the e-invoicing system.) In short, the data model for e-invoices aligns with the European standard EN 16931 (as implemented by CII/UBL/Factur-X), plus some additional French-specific data points to enhance tax controls. [impots.gouv.fr], [marosavat.com] [sovos.com], [marosavat.com] [sovos.com], [sovos.com] [sovos.com], [bdo.global] [bdo.global]
E-reporting data and format: E-reporting involves sending specified data points about transactions to the tax authority, rather than the full invoice file. **For e-reporting, any structured data format that the platform and portal accept can be used (often XML/JSON messages as defined by the tax authority’s schema) – the “External Specifications” published by DGFiP detail the data fields and format for these transmissions. In general, the required data elements for e-reporting include: identification of the seller and buyer, date and value of the transaction, VAT amount or reason for no VAT (e.g. intra-EU supply, export, B2C sale), and relevant payment information for services. E-reports for B2C and cross-border transactions are typically summary-level (not line-item invoices) – for example, a company might report the total daily amount of B2C sales at each VAT rate, rather than every consumer invoice, and for incoming cross-border purchases the requirement for line-by-line detail has been removed to simplify compliance. The authorities have committed to freezing the scope of required data fields to the current set, to give companies certainty and avoid continuous updates to IT systems. [ey.com] [impots.gouv.fr], [cleartax.com] [kpmg.com], [kpmg.com] [kpmg.com], [bdo.global]
Validation rules: All e-invoices will be subject to automated validation checks by the platforms before they are accepted into the system. Each certified platform (“Plateforme Approvée”) must perform a pre-validation of the invoice data upon submission. This includes verifying that the invoice is compliant with the required format and that all mandatory fields are present (for example, that the invoice has a valid SIREN/SIRET for both supplier and customer, a correct invoice number and date, proper tax amounts, etc.). If an invoice fails validation (e.g. due to missing data or format errors), it will be rejected and not considered issued in the eyes of the law until corrected and resubmitted. Likewise, the central portal (PPF) will perform its own checks on data received from platforms, and any e-reporting files with errors or inconsistencies may be rejected – however, the government has signaled it will not penalize mistakes immediately as companies learn the new system (see section 9). Businesses should prepare to update their ERP/invoicing software to produce invoices with all required fields and to handle any error feedback from their chosen platform. [marosavat.com] [sovos.com], [bdo.global] [cleartax.com], [kpmg.com]
Mandatory data elements: By law, electronic invoices in France must contain all information required of paper invoices (per Article 289 of the CGI and French Commercial Code) plus some new details introduced by the 2022 decree. Key fields include: supplier’s and customer’s full identification (names, addresses, and VAT/SIREN numbers), invoice date and number, product/service description, quantity, unit price, taxable amount, applicable VAT rates and amounts per rate, total amount without and with VAT, etc., as well as new fields identifying the nature of the transaction (goods/services), any option for cash-accounting of VAT on services (“VAT on collection”), and payment due date. The e-invoice data model also accommodates references like purchase order numbers, contract references, and payment details/status, which are important for the “e-reporting” of payments (see below). If any mandatory field is omitted or inaccurate, it can trigger penalties (e.g. €15 fine per missing detail). [bdo.global]
Digital signatures and integrity: Electronic signatures are not mandated on French e-invoices provided they are transmitted through the approved platforms, because the controlled platform environment itself ensures authenticity and integrity of origin. France’s legal framework for e-invoicing recognizes the platform’s role in guaranteeing that the invoice data isn’t altered and that the transacting parties are accurately identified. Thus, qualified electronic signatures or seals are optional – a company may apply a digital signature to its invoices, but in practice the vast majority of taxpayers will rely on the platform’s security measures instead of individual signing of each invoice. Importantly, French law continues to require each invoice’s authenticity, integrity, and legibility be guaranteed throughout its life cycle. This can be achieved either by using **trusted technologies (like EDI exchanges or qualified e-signatures) or by implementing reliable business controls (a “piste d’audit fiable” or audit trail) that link each invoice to the underlying transaction documents. Under the new system, the platforms will effectively provide this assurance by tracking and timestamping invoices and statuses. If a company chooses not to use a qualified e-seal/signature on the invoice, they must ensure a robust audit trail is in place as an internal control measure. [assemblee-…tionale.fr], [assemblee-…tionale.fr] [pennylane.com] [pennylane.com], [pennylane.com] [assemblee-…tionale.fr], [pennylane.com]
Real-time and periodic elements: The mandate introduces a form of continuous transaction control (CTC). For in-scope B2B invoices, data will be transmitted in real time or near-real time – essentially as invoices are issued, they are delivered to the customer and tax authorities almost immediately via the platform network. There is no legal grace period for sending e-invoices once the system is live; an invoice must be sent through a platform as it is created (any delay would mean the invoice isn’t considered duly issued). For e-reporting (B2C and cross-border flows), the system is slightly less than real-time – data are transmitted periodically, with frequency depending on the company’s VAT filing cycle. For example, a business filing monthly VAT returns must e-report transaction data in three submissions per month (by the 10th, 20th, and end of month) covering all transactions in each ten-day period. Businesses on quarterly VAT filing will likely report monthly, and those under the very small enterprise regime may be allowed to report bimonthly or with their less frequent filing cycle. In all cases, payment data for services (where VAT becomes due only upon payment) must be reported by the 10th of the month following the payment. (The “e-reporting” of payment data is a separate component of the reform – it requires companies to report when they receive payment for certain transactions, particularly services taxed on a cash basis. This is meant to let the tax authority know when VAT on a given invoice has become payable.) [ey.com], [cleartax.com] [sovos.com], [impots.gouv.fr] [impots.gouv.fr] [impots.gouv.fr], [impots.gouv.fr]
5. Transmission & Workflow
France has adopted a “Y‑shaped” clearance model for this reform, involving a central public platform and multiple private service providers. The key components and flow are: [impots.gouv.fr], [marosavat.com]
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Portail Public de Facturation (PPF) – the central state e-invoicing & e-reporting portal operated by the tax authority (built on the existing Chorus Pro system). The PPF serves as a data hub and directory under the new model. Its main functions are to maintain a centralized directory of recipients (all French taxable businesses and their chosen service provider or “mailbox” for invoices) and to receive all invoice/report data for the tax administration. The PPF will not generally act as a free invoicing tool for taxpayers (unlike initial plans). Instead, businesses must use a certified private platform to send and receive invoices, and those platforms will then transmit the data to the PPF. (The only exception may be very small businesses or certain public-sector specific cases, where simplified uses of the PPF are being considered – but in general, every company needs to access the system via a registered private solution.) [economie.gouv.fr], [economie.gouv.fr] [economie.gouv.fr]
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Plateformes de Dématérialisation Partenaires (PDP), now called “Plateformes Agréées” (PA) or simply “Approved Partner Platforms” – these are certified private e-invoicing service providers authorized by the French government. As of late 2025, over 100 such platforms have been preliminarily registered. Companies will contract with one or more of these providers (or use a compatible in-house software solution that connects to a certified platform) to handle their e-invoice issuance, reception, and data reporting. Each Approved Platform (AP) must be able to perform key functions: convert invoices into the standard formats, forward invoices to the appropriate recipient (via the central directory), perform validation and security checks, and transmit the required data to the PPF in the prescribed format. APs also must handle the return of invoice statuses (e.g. delivered, rejected, etc.) and any error messages back to the sender. Businesses may choose any AP that suits their needs – the buyer and seller do not have to use the same provider, as all certified APs are required to interoperate with each other through the central system. [sovos.com], [kpmg.com] [marosavat.com] [economie.gouv.fr], [sovos.com] [impots.gouv.fr]
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Interoperability via APIs and PEPPOL: To enable broad interoperability, France is leveraging both API integrations and the EU PEPPOL network. The French tax authority (DGFiP) became the official PEPPOL Authority for France in 2025, which means French e-invoice platforms can use the PEPPOL network and standards (e.g. PEPPOL BIS 3.0 format over AS4/PEPPOL API) to exchange invoices. This complements the national channel: APs can either exchange invoices through the PPF’s routing system or via direct connections using standardized APIs or PEPPOL gateways – but either way, the invoice data will still be reported to the tax portal for every transaction. The creation of a French PEPPOL Authority ensures that international and cross-platform invoice exchanges meet French requirements and that foreign businesses integrated in the PEPPOL network can exchange invoices with French recipients in compliance with the mandate. [marosavat.com] [marosavat.com], [bdo.global] [bdo.global]
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Deadlines for transmission: Under the new system, invoices must be sent to the customer’s platform essentially immediately upon issuance. The platform’s validation and forwarding process is typically instantaneous or within minutes. Thus, “real-time” exchange and reporting of B2B invoice data will become the norm. For e-reporting of non-B2B invoices (B2C, cross-border), the law provides short deadlines measured in days rather than in real-time: e.g. transaction data generally must be reported within 2 days to 10 days (depending on the taxpayer’s filing status and the timing of the transaction). For instance, a company on a standard monthly VAT regime will batch-submit e-reporting for all invoices issued in the first 10 days of a month by the 20th of that month, and so on. Some data, like payment status updates for certain invoices, are reported on a slightly longer timeline (monthly). There is no periodic “summary” report needed for domestic B2B invoices – since those are individually transmitted as e-invoices – but for B2C and cross-border, monthly summary reports or listings are effectively replaced by the required e-reporting submissions. The system thus collects data on a continuous or near-continuous basis, giving the tax authority timely information on all invoicing flows. [ey.com] [sovos.com], [impots.gouv.fr] [impots.gouv.fr]
6. Self-Billing
Self-billing (“autofacturation”) is permitted under the French e-invoicing regime, with the same digital requirements. In a self-billing arrangement, the buyer (customer) issues the invoice on the supplier’s behalf – under the mandate, this self-generated invoice must be transmitted via an Approved Platform just like a normal invoice. The buyer’s platform will send the invoice (in the standard format) to the seller’s platform, which delivers it to the seller for acknowledgment, while also reporting the data to the PPF (tax authorities) in real-time. The e-invoice must include all standard mandatory fields (including both parties’ SIREN/VAT IDs, etc.), and it should indicate that it is self-billed. French VAT law already requires a written agreement between the parties for self-billing, and this remains necessary – typically the buyer and supplier must have an arrangement in place authorizing self-billed invoices. The supplier’s acceptance of self-billed invoices is generally required (explicitly or implicitly), so the platforms will support functionality for the seller to approve or reject a self-billed invoice sent by the buyer. In practice, the buyer’s platform may flag the invoice as “self-billing” so that the seller’s platform can prompt for confirmation. Once accepted by the seller (or if no rejection occurs within a set time), the self-billed invoice is considered a legal e-invoice for VAT purposes, and the VAT it contains is deductible by the buyer and collectible by the seller as usual. The self-billing process will thus be seamlessly integrated into the overall e-invoicing workflow – aside from the inversion of the issuer, all the same data and transmission rules apply. [bdo.global]
7. Triangulation & Special Scenarios
The French framework has been designed to handle complex transaction scenarios to ensure complete VAT reporting:
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Triangulation and chain transactions: These typically involve multiple parties and may span across borders. If a transaction in a chain involves two parties established in France, their invoice must be e-invoiced via the French platform system, even if it’s part of a larger international deal. For example, in a typical EU “triangulation” (A sells to B, who onward sells to C, with goods moving from A to C), a French company (B) might be an intermediate purchaser and seller. B’s purchase from A (a foreign supplier) would be an intra-EU acquisition (subject to e-reporting by B as the French buyer), and B’s sale to C abroad would be an intra-Community supply (subject to e-reporting by B as the seller). Only if B were selling to a French buyer would that particular invoice be domestic and require e-invoicing. In summary, multi-party and cross-border deals do not escape the mandate – each leg of the transaction involving a French taxpayer will be either e-invoiced (if domestic) or e-reported (if one side is foreign) so that the tax authority receives data on the entire chain. Companies engaged in complex supply chains will need to diligently classify and report each transaction according to its nature (domestic vs cross-border, sale vs purchase) so that the appropriate electronic process is applied. [impots.gouv.fr]
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Cross-border reverse-charge scenarios: Special situations where a French business is liable for VAT on a purchase (for instance, importing services from outside France, or buying goods in France from a foreign company that isn’t VAT-registered locally) are addressed by the e-reporting obligation. In these cases, the French buyer must report the details of the transaction via the platform, since there won’t be a French e-invoice from the (foreign) supplier. This ensures that acquisitions on which French VAT is due (via self-assessment) are visible to the tax authorities. [kpmg.com]
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Zero-rated and exempt supplies: Even if a particular sale is zero-rated or VAT-exempt, French companies must still comply with the e-invoice/e-reporting regime. For example, exports and intra-EU sales (which are zero-rated for VAT) are not invoiced through the domestic system but must be reported through the e-reporting channel. Conversely, a domestic supply that is exempt from VAT (e.g. certain medical or financial services, or small businesses under the franchise regime) still requires an e-invoice if an invoice is issued – the only difference is that the invoice will show no VAT (and the corresponding code for exemption). The platform and the tax authority will thus receive the invoice data, including the indicator that the transaction was exempt or out of scope of VAT. [cleartax.com]
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Margin schemes & travel agents: Transactions under special VAT regimes (like second-hand goods margin schemes or the travel agency/TOMS regime, where VAT is calculated on a margin or profit) are also covered by the mandate. However, French authorities have introduced simplified reporting methods for such cases – e.g. allowing aggregate reporting of margin scheme transactions rather than individual invoice reports, using an average margin or total period margin for B2C sales subject to these regimes. Businesses can then reconcile or adjust the VAT in their periodic return. This reduces the compliance burden for industries like used car dealers or travel package sellers. Other unique scenarios (consignment sales, commissions, self-invoiced rebates, etc.) are likewise addressed in the technical guidelines (France’s standardization body AFNOR has published use-case standards covering 36 scenarios, including subcontracting, self-invoicing, consignment, etc.). In short, the system is intended to handle special cases, with some data fields or process adjustments as needed, but no category of taxable transaction is wholly exempt from the requirement to report or e-invoice. [kpmg.com] [bdo.global]
8. Archiving & Retention
Retention period: France’s laws on retention of invoices require that invoices (whether paper or electronic) be kept for 6 years for tax purposes and 10 years for commercial/accounting purposes. These periods run from the end of the financial year or tax year of the invoice’s issuance. In practice, companies usually align with the longer 10-year requirement for all invoices to satisfy both the tax code (Livre des Procédures Fiscales, Art. L102B, 6-year rule) and the Commercial Code (10-year rule for books and records). The new e-invoicing mandate does not change the retention periods, so e-invoices and e-reports must be stored accordingly. [pennylane.com], [pennylane.com]
Format and storage: Electronic invoices must be archived in their original electronic form in a way that guarantees their legality and legibility for the full retention period. Common practice is to store the invoice’s structured data (XML/JSON) along with a human-readable version (such as the PDF in a Factur-X file) to ensure readability for auditors. France’s regulations require that the archived invoices maintain their authenticity of origin, integrity of content, and readability throughout the storage period. This is often achieved by using certified digital archiving systems or trusted third-party archivers that implement access controls, timestamping, and encryption to prevent any alteration of the data. Many Certified Platforms (APs) will offer compliant e-archiving services (typically ensuring 10-year storage) as part of their solutions, but companies remain responsible for meeting retention obligations even if they change providers. [pennylane.com] [pennylane.com], [pennylane.com]
Location of archives: French law permits electronic archiving in France or abroad (including on cloud servers), as long as the invoices can be made available without delay to the French tax authorities upon request. In other words, companies can use foreign or cloud storage solutions, provided the data remains accessible for inspection. If servers are located outside the EU, additional safeguards or notifications to the tax authority may be required (to ensure France can exercise its audit rights – e.g. via specific bilateral agreements). Many French businesses choose to store e-invoices within France or the EU to simplify compliance. [pennylane.com]
Audit access and integrity: During the retention period, businesses must be able to reproduce invoices in their original format, with certifiable integrity (e.g. providing the original XML and a readable rendering) to tax auditors. In case of an audit, inability to produce the required e-invoices or related records for the last 6 years can lead to penalties – for instance, a fine up to €10,000 for missing archives has been stipulated. To comply with audit requirements, archived e-invoices should be indexed and searchable, and any “audit trail” documentation (e.g. purchase orders, delivery receipts, payment proof linked to an invoice) should be retained as well to provide context if needed. The bottom line: companies must implement archiving solutions that secure e-invoices for 6–10 years, ensure their integrity (no undetected modifications), keep them legible, and allow efficient retrieval to meet legal and tax obligations. [pennylane.com]
9. Penalties & Enforcement
Non-compliance with the e-invoicing/e-reporting obligations can lead to financial penalties and other enforcement actions. French authorities have outlined a range of sanctions in the tax code (notably in the 2022 and 2023 Finance Laws) to encourage compliance. Key penalties include: [e-invoicin…asware.com], [bdo.global]
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Failure to issue an e-invoice for a domestic B2B transaction: This is treated similarly to failing to issue a required invoice under existing VAT law. It can trigger a penalty of up to 50% of the transaction’s amount (a severe sanction reflecting the seriousness of not issuing an invoice). If the sale was properly recorded in accounts and the omission was not an attempt to evade tax, a reduced fine of 5% of the transaction value may apply. (Example: A French company that sells to another French company but does not issue any invoice, electronic or otherwise, could face a penalty of half the value of that sale, unless it was an honest mistake that was later corrected). [bdo.global]
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Failure to transmit an invoice via a platform: If an invoice was issued but not routed through the e-invoicing system (e.g. a business sent a paper or PDF invoice directly to its customer, bypassing the platform), the penalty is €15 per invoice not transmitted electronically, capped at €15,000 per year. This effectively penalizes companies for circumventing the mandate’s channels. (Authorities have indicated they may waive this fine once if the issue is promptly fixed within 30 days – see grace period above.) [e-invoicin…asware.com], [bdo.global] [cleartax.com]
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Failure to submit e-reporting data: For transactions requiring e-reporting (like B2C or cross-border sales), neglecting to send the required data will incur a fine of €250 per missing transmission, capped at €15,000 per year. “Transmission” in this context generally means a periodic report or batch of reports; missing an entire batch or not reporting transactions at all is thus subject to the fine. (By contrast, if the data is reported but contains errors, see the next item.) [e-invoicin…asware.com]
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Errors in e-invoice data or reported data: Transmitting incorrect or incomplete data (such as wrong taxable amounts, VAT amounts, dates, or other required details in an e-invoice or e-report) carries a penalty of €250 per erroneous invoice or report, capped at €10,000 per year. This would apply, for example, if a company submits an e-report with the wrong VAT rate or fails to include required information in an invoice’s data fields. Minor mistakes can be corrected within a short window (30 days) to avoid the fine, as noted earlier. [bdo.global] [cleartax.com]
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Archiving and retention failures: Not specifically introduced by the new law but still relevant, failing to meet France’s invoice retention requirements can lead to penalties. In particular, if a business cannot present all required invoices for the last 6 years during a tax audit, they may be fined up to €10,000 for insufficient record-keeping. Additionally, general tax law provides for penalties (and potential accounting rejection) if books and records are not properly kept for the 6- or 10-year retention periods. Businesses should therefore ensure their archiving solutions for e-invoices meet legal standards (see section 8) to avoid these sanctions. [pennylane.com]
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Platform (AP) non-compliance: Certified platforms themselves are subject to oversight. If an Approved Platform fails to fulfill its obligations to transmit data to the tax authority or to ensure invoice integrity, the platform can face fines of €15 per invoice and €750 per incomplete transmission, with penalties capped at €45,000 per year. Moreover, the authorities may revoke a platform’s certification in cases of serious non-compliance (after due notice), which would bar it from operating in the e-invoicing network. [e-invoicin…asware.com] [bdo.global]
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Intentional fraud: In cases of proven fraud (such as deliberate omission of invoices or falsification of data to evade VAT), harsher penalties and criminal charges can apply under France’s general tax fraud laws. For instance, deliberate VAT fraud can lead to significant fines (up to €500,000 or more) and even imprisonment under French law. The e-invoicing system gives tax authorities more immediate visibility into transaction-level data, making it easier to detect discrepancies and trigger audits. French tax auditors are expected to use the e-invoice/e-report data to cross-check VAT declarations, so deliberate non-compliance carries a high risk of enforcement action. [e-invoicin…asware.com]
10. Pre-Filled VAT Returns
One long-term goal of the French e-invoicing and e-reporting reform is to facilitate the pre-filling of VAT returns for businesses. As of early 2026, pre-filled VAT returns are not yet a reality in France, but the government has explicitly planned for them. The continuous flow of detailed invoice data to the tax administration is expected to enable the authorities, in the future, to draft VAT declaration proposals for taxpayers (similar to how individual income tax returns are pre-filled). The 2024 Finance Law and official communications highlight “the development of a new service: pre-filling VAT returns” as a key objective of the reform. [impots.gouv.fr], [bdo.global]
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Current status: Pre-populated VAT returns do not exist yet under French law, and the implementation will depend on the successful roll-out of e-invoicing/e-reporting. The government has indicated that once the system is fully operational and validated with a couple of years of data, it will consider providing businesses with draft VAT returns (especially for the CA3 periodic VAT declaration) that leverage the invoice data collected. This could occur after 2027, once all phases of the mandate are live and the majority of transactions are being reported in real time. [impots.gouv.fr]
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Relation to e-invoicing data: The envisioned pré-remplissage (pre-filling) of VAT forms will be based on the data gathered via e-invoices and e-reports. Because the tax authorities will receive information on each sale and certain purchases, they could aggregate the total taxable sales, VAT collected, etc., for each business and propose those figures in the VAT return. Indeed, a core aim of requiring e-reporting for B2C and cross-border sales is to eventually allow VAT to be calculated and pre-declared by the tax system itself, reducing the administrative burden on companies. [impots.gouv.fr] [bdo.global]
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Scope of pre-filled data: It’s expected that pre-filled VAT returns would include the main figures such as total output VAT and total input VAT (or at least the data for sales and purchases that the tax office can reliably determine from the invoices). However, certain fields would likely remain for the taxpayer to complete or verify – for example, adjustments, VAT exempt transactions (which might not all be derivable from the invoice data alone), or other specific regimes. In any case, businesses will need to verify any pre-filled returns and remain responsible for their accuracy. The reform’s intent is to streamline VAT compliance, but not to remove the taxpayer’s accountability.
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Preparatory steps: In anticipation of eventual pre-filling, from 2024 the French authorities introduced new invoice content requirements (notably the transaction type, payment status, and other tax details on invoices) to capture data necessary for future VAT return calculations. A decision on when pre-filled returns will be offered is expected after the system’s full implementation. Until then, companies must continue filing VAT returns as usual (the mandate does not change filing frequencies or deadlines), but over time they should see more data pre-populated by the tax authority, reducing manual effort. [bdo.global]
11. Impact on SMEs and Startups
The e-invoicing mandate will impact small and startup businesses significantly, despite the phased timeline and support measures. Here’s an analysis of the implications and accommodations for SMEs:
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Phased rollout & exemptions: As noted, smaller firms (SMEs and micro-entreprises) benefit from a deferred implementation date – September 2027 – giving them an extra year to comply. This staged approach was designed to give SMEs more time to adapt, recognizing that they have fewer resources. Importantly, no permanent turnover threshold exempts businesses from compliance – even micro-entrepreneurs are required to eventually use e-invoicing (for any B2B bills) and e-reporting. The government’s surveys in 2023 showed that SME awareness and preparedness for e-invoicing was relatively low – only about 57% of businesses felt they would be ready by 2024, with smaller companies being less prepared on average than large firms. This was a key reason for postponing the mandate. The extra time is intended to raise readiness to near 100%. There are no special exclusions for startups or new businesses: any company starting after the mandate will need to comply, though they will be in the same position as other businesses of similar size. [sovos.com] [impots.gouv.fr] [assemblee-…tionale.fr]
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Simplified regimes & support: France has introduced simplification measures to ease SME compliance. For instance, the e-reporting frequency for very small companies under the franchise or regime simplifié may be reduced (bimonthly instead of decadal) to align with their simpler tax filing periods. The government has also pledged support for SMEs through various programs. This includes technical guidance (webinars, documentation, a dedicated support portal on impots.gouv.fr), as well as financial support in some cases. In 2024–2025, state-backed initiatives like France Num and Bpifrance are offering assistance to small businesses for digital transition, including subsidized loans or grants to upgrade accounting systems and join a compatible platform (e.g., Bpifrance introduced a “Prêt Facturation Électronique” low-interest loan for SMEs to finance e-invoice software investments). Additionally, the tax authority has built a “PPF portal” that, while not intended as a full invoicing solution, may provide basic reporting tools for the smallest businesses if needed. These efforts aim to ensure that costs and IT complexity are not barriers for SMEs. [impots.gouv.fr] [economie.gouv.fr], [economie.gouv.fr]
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Cost of compliance: For many SMEs and startups, the mandate will entail upfront costs — upgrading or replacing invoicing and ERP software to handle e-invoices, subscribing to an Approved Platform service, and possibly training staff or re-engineering billing processes. There may also be ongoing costs (subscription fees to a platform, integration maintenance, etc.). The government is trying to mitigate this: the large number of certified providers encourages competition (as of late 2025, 100+ APs have been provisionally registered, including many catering to SMEs), and some low-cost or even free solutions may be available for small users. Nonetheless, SMEs will need to budget for compliance – surveys indicate this as a concern, especially for micro-businesses with very tight budgets. In the long run, however, the shift to e-invoicing could reduce certain costs (paper, printing, postal mailing, manual processing), so there may be efficiency gains once the initial investments are made. [marosavat.com]
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Operational impact: SMEs and startups should prepare for changes in their day-to-day operations: invoicing, accounts payable/receivable, and tax compliance processes will all become more automated and digital. In the short term, this means implementing new software or services (or updating existing ones) to issue invoices in structured format and to receive invoices electronically. Staff may need training on the new tools or workflows – for example, handling invoice errors/rejections, or using dashboards to retrieve incoming e-invoices. There’s a potential learning curve that could temporarily increase administrative workload. Over time, however, the automation of invoice processing can reduce administrative burden, especially for small firms that currently rely on paper. Routine tasks like data entry of supplier invoices into accounting systems will be minimized (since e-invoices can be automatically imported), freeing up time. Moreover, the mandate could improve cash flow management for SMEs: e-invoices are delivered instantly, which may lead to faster approval and payment cycles between businesses. The government also touts improved invoice tracking and fewer payment disputes as advantages that will benefit SMEs’ cash flow. Additionally, by catching errors early (through automated validation and cross-checks), businesses might avoid VAT underpayments/overpayments and subsequent corrections or audits, thus reducing compliance risk and possibly speeding up VAT credit refunds. [marosavat.com] [bdo.global], [bdo.global]
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Administrative burden vs. simplification: There is an inherent trade-off for smaller enterprises. In the initial phase, administrative burden will increase – SMEs must adapt to new invoicing methods, ensure internet connectivity and digital storage, and possibly manage multiple platform relationships if clients use different providers. There may be a need to hire or consult IT/tax specialists to achieve compliance. However, once the system is in place, many traditional tasks will be simplified or automated. For example, preparing VAT returns should become easier with pre-filled data (no need to compile sales and purchase totals manually), and storing and searching invoices will be more efficient with digital archives. According to French officials, the e-invoicing mandate is expected to save businesses money in the long run through reduced processing costs and fewer errors – estimates suggest a paper invoice costs ~€10–15 to process versus ~€3 for an e-invoice. [marosavat.com]
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Market impact and interoperability issues: The mandate is accelerating the digitalization of business processes in France, potentially giving an edge to early adopters and software providers. SMEs that adapt quickly may gain a competitive advantage, as they can integrate more easily with large customers’ systems (many large companies are pushing their supply chains to use e-invoices) and benefit sooner from process efficiencies. There is also a broader market opportunity: new fintech and software startups have emerged to serve the e-invoicing needs of small businesses, which could drive innovation. On the other hand, interoperability challenges remain a concern. Not all SMEs have modern IT systems – many still issue invoices via Word/Excel or PDF. These businesses may need to find suitable “bridging solutions” (like simple invoicing portals or converters) to connect to the e-invoicing network. The government’s decision to not offer the PPF as a free invoicing tool has been controversial, but it has spurred a wave of private sector solutions targeting small businesses. Ensuring that all these solutions can talk to each other (through standard APIs and formats) is critical; France’s adoption of PEPPOL standards and publication of API specs (the XP Z12-013 standard) is aimed at addressing this issue. [economie.gouv.fr] [marosavat.com], [marosavat.com]
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SME readiness and assessments: Both the French government and the EU have been monitoring SME readiness. The French tax authority (DGFiP) conducted surveys and industry consultations – as noted, by mid-2023 a significant number of SMEs were still unprepared, prompting authorities to delay the mandate. Since then, outreach has increased. The government has been providing information through webinars, guidelines, and pilot programs to bring SMEs up to speed. The EU’s proposed “VAT in the Digital Age” (ViDA) reforms are set to make e-invoicing more prevalent across Europe by 2028, so France’s efforts align with an EU-wide push for digital VAT compliance. French SMEs, with the extra time and support given, are expected to be significantly more prepared by 2026–2027. The message for startups and small firms is to treat this as both a compliance requirement and an opportunity to modernize – firms that integrate e-invoicing into their operations early can streamline their billing, reduce errors, and potentially get paid faster, whereas laggards may struggle or even face cash-flow issues if they cannot invoice larger customers in the required format by the deadline. [assemblee-…tionale.fr] [economie.gouv.fr], [economie.gouv.fr]
12. Official References
France’s e-invoicing initiative is supported by numerous official publications and expert analyses. Key up-to-date references include:
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Government & Tax Authority Resources:
- DGFiP Official Portal – “Je comprends la facturation électronique” (Nov 2025) – A concise official FAQ in English explaining the French e-invoicing and e-reporting reform. (French Tax Authority – impots.gouv.fr) [impots.gouv.fr], [impots.gouv.fr]
- French Ministry of Economy – “Tout savoir sur la facturation électronique” (Oct 2024) – Government press release confirming the revised 2026/2027 timeline, legal basis (Finance Law 2024, Article 91) and the state’s support measures for businesses during the rollout. (economie.gouv.fr) [economie.gouv.fr], [economie.gouv.fr]
- Official Legal Text: Article 26 of Loi n° 2022-1157 (16 Aug 2022) and Article 91 of Loi n° 2023-1322 (Finance Law 2024) – These legislative provisions establish the e-invoicing/e-reporting requirements and the implementation schedule. The 2022 law and its October 2022 decrees detail the mandate’s scope and initial deadlines, while the 2024 law formalizes the 2026–27 rollout dates and includes the new phased approach and penalty framework. (Accessible via the Legifrance official portal.) [assemblee-…tionale.fr], [assemblee-…tionale.fr] [assemblee-…tionale.fr], [bdo.global]
- Council Implementing Decision (EU) 2022/133 (Jan 2022) – The EU authorization allowing France to derogate from the VAT Directive (Articles 218 and 232) to impose mandatory e-invoicing. This decision currently permits France’s e-invoicing requirement until Dec 31 2026; France will seek an extension for dates beyond that. [impots.gouv.fr] [ey.com]
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Technical Specifications:
- External Technical Specifications, Version 2.3 (English, 2023) – Detailed schema and instructions published by the French tax administration for implementing e-invoicing and e-reporting, including data formats, API details, and validation rules. (Available on impots.gouv.fr – “Documentation Technique externe”) [ey.com]
- AFNOR Standards XP Z12-012/013/014 (2025) – French national e-invoicing standards developed by the AFNOR committee, covering invoice data formats & life-cycle messages (012), standardized API protocols for platform interconnection (013), and a catalog of 36 specific invoicing scenarios (014) such as self-billing, discounts, invoice corrections, etc.. These technical standards provide the framework ensuring all platforms and software can interoperate under the mandate’s requirements. [bdo.global], [bdo.global]
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Tax & Legal Advisory Publications (Big 4 / Law Firms):
- EY Tax Alert (Oct 2023) – “France revises schedule for adopting e‑invoicing reform” – outlines the delay to 2026/27, the joint e-invoice/e-report obligations, and the need for a new EU derogation. [ey.com], [ey.com]
- KPMG TaxNewsFlash (Sep 2025) – details the French government’s simplification and tolerance measures (e.g. relaxed reporting requirements for B2C and foreign transactions, and deferred obligations for non-established businesses). [kpmg.com], [kpmg.com]
- BDO France Indirect Tax News (Oct 2025) – “Mandatory E‑invoicing in 2026: Updates on Preparations” – provides an in-depth overview of the French mandate, including its scope, objectives, updated timeline, new mandatory invoice content, penalties, and technical considerations. [bdo.global], [bdo.global]
- Deloitte France (various articles, 2023–25) – has published insights on the strategic and IT impact of EU e-invoicing compliance, including comparisons of France’s system with other countries’ (see “E-Invoicing and Real-Time Reporting in EU – Deloitte,” Jan 2023 for a broad overview).
- Sovos France e-Invoicing Guide (Oct 2023) – a technology provider’s summary of the mandate, including requirements, examples of how e-invoicing and e-reporting will work, and a high-level timeline. Sovos also reported on the updated Finance Law amendment with the new dates. [sovos.com], [sovos.com] [sovos.com]
- Marosa “E-Invoicing in France – Complete Guide” (2025) – a comprehensive guide covering the mandate’s scope, the Y-model architecture, simplification measures, and compliance recommendations for businesses of all sizes. [marosavat.com], [marosavat.com]
- French Government FAQ and Blog Resources: French authorities and industry groups have released numerous explanatory materials (in French and English) on official sites like impots.gouv.fr, economie.gouv.fr, and portal sites (e.g. entreprendre.service-public.fr, Bercy Infos). These cover common questions, detailed use-case examples, and step-by-step guidance for companies preparing for e-invoicing. [economie.gouv.fr], [economie.gouv.fr]
(All links above are to publicly accessible sources – official government websites or reputable tax/technology advisories – providing the latest information as of 2025–2026.)
13. Summary
In summary, France is implementing a phased mandatory B2B e-invoicing and associated e-reporting regime starting 2026, with the dual goals of modernizing business processes and closing the VAT gap. The mandate’s scope is comprehensive: all companies established in France will be required to issue and receive electronic invoices for domestic B2B transactions, and to electronically report data on other transactions (B2C and cross-border) to the tax authorities. The timeline has been finalized after a postponement: large and medium firms must comply by September 1, 2026, and small/micro firms by September 1, 2027, with all businesses able to receive e-invoices by 2026. Key obligations include using a certified platform to transmit e-invoices in one of the accepted formats (UBL, CII, or Factur-X), capturing all required invoice data fields, and adhering to the new digital reporting schedule (real-time invoicing and periodic reporting for other transactions). [bdo.global], [bdo.global] [cleartax.com], [impots.gouv.fr] [sovos.com], [sovos.com] [sovos.com]
The French system uses a continuous transaction control model: invoices will be cleared through a network of approved platforms and a central “Public Portal,” giving the tax authority near real-time visibility of sales and tax data. Main risks for businesses include potential fines for non-compliance (e.g. €15 per invoice not e-filed, €250 per missing/incorrect report), operational disruptions if they cannot adapt in time, and increased scrutiny of their tax data (since errors or fraud will be more easily spotted). However, the reform also brings opportunities: pre-filled VAT returns are planned to simplify compliance, and businesses stand to gain in efficiency, faster invoice processing, and better record-keeping. [sovos.com] [e-invoicin…asware.com], [bdo.global] [bdo.global], [marosavat.com]
For SMEs and startups, the government has built in a delayed rollout and is providing support, recognizing their resource constraints. Smaller firms should use the extra time to choose a suitable e-invoicing solution and update their invoicing practices. In the end, the move to e-invoicing is expected to become a net positive for French businesses – reducing fraud, enabling automation, and even improving competitiveness by streamlining payment cycles and VAT compliance. The critical next steps for businesses are to assess their readiness, engage with a certified platform or provider, and adapt their internal systems well ahead of the 2026/2027 deadlines to ensure a smooth transition to France’s new digital invoicing era. [bdo.global], [marosavat.com] [assemblee-…tionale.fr], [bdo.global]
- See also
- Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
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