Electronic invoicing: a two-stage reform, but an immediate obligation for all

The electronic invoicing reform in France has applied since 1 September 2026. Small and medium-sized enterprises have until 2027 to issue their invoices in the new format, but all businesses must already be able to receive them, or face a fine.

The end of the PDF sent by email

Invoices between businesses established in France and subject to VAT are gradually moving to electronic invoicing (Article 289 bis of the French General Tax Code, Code général des impôts). A simple PDF sent by email is no longer sufficient. An electronic invoice is a structured file that must pass through an approved platform, meaning a private provider registered by the tax authorities. This platform checks each invoice and forwards its key data to the tax authorities.

Invoice templates must also include new information, in particular the customer’s SIREN (French nine-digit business identification number) and the nature of the transaction (sale of goods, supply of services, or both). An incomplete invoice is rejected by the platform.

A two-stage timetable

Since 1 September 2026, all businesses subject to VAT must be able to receive electronic invoices, regardless of size, including micro-entrepreneurs benefiting from the VAT exemption. Only large enterprises and intermediate-sized enterprises are required to issue them as of that date. SMEs and micro-businesses will be required to do so from 1 September 2027.

Size is assessed at the level of each company, independently of the group to which it belongs. A subsidiary qualifying as an SME therefore has the same deadline as an independent SME and is not required to issue its electronic invoices until 1 September 2027. An exception applies to companies that have opted, with other group companies, for a joint VAT return (the “single taxable person”, Article 256 C of the French General Tax Code). They are required to issue them from 2026.

Sales to individuals and international transactions: e-reporting takes over

No electronic invoice is required when the customer is an individual or a foreign business, or when the purchase is from a foreign supplier. The platform must nevertheless transmit the data on these transactions to the tax authorities, including their amount and the corresponding VAT. This is known as e-reporting, meaning electronic transaction reporting. For supplies of services, receipts must in principle also be reported. These obligations follow the same timetable as issuance.

On this point, France goes further than Germany. A French subsidiary to which its German parent company invoices management fees must report this transaction through its platform. In Germany, by contrast, all taxable persons established in Germany have been required since 1 January 2025 to accept the receipt of electronic invoices for domestic transactions between taxable persons (§ 14(2), sentence 2, no. 1 UStG). The actual obligation to issue electronic invoices will be introduced in stages: from 1 January 2027 for businesses whose turnover in the previous year exceeds 800,000 €, and from 1 January 2028 for all other businesses. Transactions involving a business established abroad remain outside the system.

Up to 15,000 € in fines per year

A business that has no receiving platform is first served with a formal notice to remedy the situation within three months. If it fails to do so, it is liable to a fine of 500 €, then 1,000 €, renewable every three months for as long as the situation continues.

Each invoice not issued electronically incurs a 50 € fine, capped at 15,000 € per year. Each omitted transmission under e-reporting incurs a 500 fine, subject to the same annual cap. For these latter two fines, a first infringement that is remedied voluntarily or within 30 days after the tax authorities’ request is not sanctioned.

Four checks to carry out without delay for the businesses concerned

  • Check that your company and each group company is linked to an approved platform listed on impots.gouv.fr
  • Update your invoice templates and your customers’ SIREN numbers
  • List your sales to individuals and your transactions with foreign countries, which fall under e-reporting
  • Review your contract with the platform, including the conditions for changing provider and the handling of rejected invoices

Sources: code général des impôts, articles 256 C, 289 bis, 290, 290 A, 1737 and 1788 D ; annexe IV au CGI, article 41 septies D ; loi n° 2022-1157 du 16 août 2022, article 26 ; loi n° 2026-103 du 19 février 2026 de finances pour 2026, article 123.