France e-Invoicing Guide

France switched on mandatory B2B e-invoicing on 1 September 2026. Since that date every business registered for VAT and established in France must be able to receive structured electronic invoices, and large and intermediate-sized enterprises must also issue them and report transaction data to the tax administration. Small and medium enterprises, small businesses and micro enterprises get one more year before the issuing obligation reaches them, on 1 September 2027. The legal framework was finished well before the start: Article 123 of the Finance Act for 2026 rewrote the operative provisions of the tax code in February, and Décret n° 2026-677 with its accompanying arrêté, both dated 27 July 2026, closed the regulatory layer five weeks before go-live. On the opening day the ministry reported more than 4 million businesses with a declared reception address and 66 per cent of the core target signed up to a platform, and said no penalty would be applied to any business in 2026.

The architecture is a network of private platforms, not a government portal. An approved platform (plateforme agréée) is an operator registered by the DGFiP for a renewable three-year term after passing interoperability tests, and it is the only channel through which an in-scope invoice may legally travel. The State walked away from running a free exchange service in October 2024, when the Ministry of the Economy announced it would keep only two roles: a directory of recipients that tells each platform where to send an invoice, and a concentrator that receives the data destined for the tax administration. Anyone still planning around a free public invoicing portal for B2B exchange is working from a 2023 design.

One distinction causes more confusion than any other, and the DGFiP publishes a document specifically to settle it. Alongside the approved platform label there is a second label, solution compatible, covering accounting software, billing tools, cash registers and banking apps that can produce compliant invoices and data. A compatible solution is not registered by the administration. In the DGFiP's words it can therefore neither transmit invoices directly to the tax authority nor act as official intermediary for transaction or payment data, and it must be connected to an approved platform to carry the label at all. Keeping your existing software is fine. Keeping it instead of contracting with an approved platform is not.

The public sector went first, and long ago. Ordonnance n° 2014-697 of 26 June 2014 staged the B2G obligation by supplier size, starting with large enterprises on 1 January 2017 and finishing with micro enterprises on 1 January 2020, all routed through Chorus Pro. B2B was supposed to follow in 2024. Article 26 of the amending Finance Act for 2022 set that calendar, then Article 91 of the Finance Act for 2024 pushed it back to 2026 and 2027 after the scale of the build became clear. The October 2024 decision to abandon the free public portal reshaped the model again, moving invoice exchange entirely onto private platforms.

The final year moved quickly. The DGFiP and the AIFE opened the directory for consultation on 18 September 2025 with nearly 80 platforms connected and more than 120,000 companies already registered as able to exchange invoices. The first official register of approved platforms appeared on 16 January 2026 with 101 names on it, and has been refreshed repeatedly since as more operators clear the interoperability tests. The Finance Act followed in February and the decree and order in July. One caveat used to belong on every France timeline: Article 26 III A of the amending Finance Act for 2022 lets a decree set a later date, capped at 1 December 2026 for the first phase and 1 December 2027 for the second. No decree was issued for the first phase, which began on 1 September 2026 as planned, after the Minister for Public Action and Public Accounts confirmed the calendar on 11 July 2026. The mechanism stays available for the second phase, so anyone planning around September 2027 should keep it in view.

Scope follows VAT registration and establishment. Every business, sole trader and liberal profession registered for VAT and established in France is covered, whatever its size, turnover, legal form or tax regime. The receiving obligation is universal and landed on everyone at once on 1 September 2026, because it is the mirror image of somebody else's duty to issue. The issuing obligation is staged: large and intermediate-sized enterprises from 1 September 2026, then small and medium enterprises, small businesses and micro enterprises from 1 September 2027. Which wave you fall into turns on the statistical categories in Article 3 of Décret n° 2008-1354, and the test is easy to get wrong: a business is an SME only if it employs fewer than 250 people and either its turnover is EUR 50 million or less or its balance sheet total is EUR 43 million or less. Fail that and you are an intermediate-sized or large enterprise in the first wave, even with a headcount under 250. A business in the second wave may enter early and voluntarily, and the DGFiP guide confirms the reform gives a customer no power to impose electronic issuing before 1 September 2027, though the two parties remain free to agree dematerialised exchange commercially.

Foreign businesses without a permanent establishment sit in a different regime, and this is routinely reported wrongly. The DGFiP states that the e-invoicing leg of the reform, meaning both issuing and receiving, does not concern them at all. What they owe is transaction reporting, and where relevant payment reporting, on operations deemed to take place in France for which they are liable for French VAT. That reporting is itself staged: as seller, large and intermediate-sized enterprises from 1 September 2026 and micro, small and medium enterprises from 1 September 2027; as buyer under the reverse charge, every business from 1 September 2027. Such businesses must still appoint an approved platform, by whichever of those two dates applies to them.

B2C and B2G run on separate tracks. Sales to consumers carry no e-invoicing obligation but do fall within transaction data reporting under Article 290 of the tax code, on the same size-based calendar as issuing. Public sector invoicing continues through Chorus Pro, now described in Article L2192-5 of the Code de la commande publique as the shared portal for that purpose. Practically, preparation comes down to three steps: choose an approved platform, make sure your routing information is published in the central directory so suppliers can find you, and confirm that whatever software you already use is connected to that platform.

The exchange model has no clearance step. A supplier passes an invoice to its approved platform, which looks up the buyer in the central directory, routes the invoice to the buyer's platform, and separately extracts the data the tax administration needs and sends it on. Nothing waits for government approval before an invoice is valid, which is what separates France from clearance countries such as Brazil or Poland. What the administration gets is a continuous data feed rather than a gate, which is why France is classed as a real-time reporting model. Emailing a PDF is the practice that stopped working: for an invoice within the issuing obligation, an ordinary email attachment has not been a compliant channel since 31 August 2026.

The arrêté of 27 July 2026 fixes the accepted syntaxes precisely. There are five: the EN 16931 profile and a French extension called EXTENDED-CTC-FR, each implemented in UN/CEFACT Cross Industry Invoice and in Universal Business Language, plus a mixed format pairing a structured XML file in CII with a PDF/A-3 rendering of the same invoice. All of them must conform to AFNOR standard XP Z12-012. Worth noting for anyone matching vendor marketing against the legal text: the arrêté never uses the name Factur-X, and XP Z12-012 is not titled Factur-X either, so the hybrid format is defined by what it contains rather than by its trade name. DGFiP guidance for businesses stays deliberately plainer, describing the options as UBL, CII or a mixed format combining structured data with an image.

E-reporting has its own cadence, set by decree rather than left to the platform. Under Article 242 nonies O of Annexe II, amended by the July 2026 decree, transaction data goes out three times a month for businesses on the monthly normal VAT regime, once a month on the quarterly normal and simplified regimes, and once every two calendar months for those under the small business franchise or the flat-rate reimbursement schemes, with no transmission required in a period with nothing to report. Payment data, covered by Article 242 nonies P, is due only for operations on which VAT falls due on collection, monthly or bimonthly depending on regime. Retention runs on two clocks: six years for tax purposes under Article L102 B of the Livre des procédures fiscales, which requires records drawn up or received electronically to be kept in that form throughout, and ten years for accounting documents under Article L123-22 of the Code de commerce. On the supply side, the July decree requires platforms to be certified by accredited bodies, adds a surveillance audit, and introduces formal portability arrangements so a business can change platform without being locked in. Supervision does not stop at registration: after meeting the approved platforms on 26 August 2026 the ministry set out continuing cybersecurity duties, a status report before the end of September 2026, immediate reporting of any cyber incident and generalised intrusion testing from autumn 2026, with suspension for a platform that cannot show it holds the required security level.

The amounts rose sharply in the Finance Act for 2026 and now sit at two levels, one for taxpayers and a higher one for platforms. Failing to issue an invoice electronically where Article 289 bis of the tax code requires it costs EUR 50 per invoice under Article 1737, capped at EUR 15,000 per calendar year, up from EUR 15 before the Finance Act for 2026; the same EUR 50 applies to an approved platform that fails its transmission duties, capped at EUR 45,000. The receiving obligation is policed differently and is easy to miss: under Article 1737 IV bis the administration first serves a formal notice giving three months to comply, then EUR 500 if the breach persists, a second three-month notice, EUR 1,000, and a further EUR 1,000 after each later three-month period that ends unresolved. Missing an e-reporting transmission costs EUR 500 under Article 1788 D, capped at EUR 15,000 a year, rising to EUR 750 per transmission and EUR 100,000 a year for a platform. Both articles carry the same relief: no fine for a first breach in the current calendar year and the three preceding years if it is put right spontaneously or within thirty days of the administration's first request. A separate EUR 7,500 per system applies under Article 1770 duodecies where a business cannot produce a certificate or attestation for its cash register software, which belongs to the caisse regime rather than to this reform.

Alongside the statute there is a start-up tolerance, and its limits matter as much as its existence. On the opening day the ministry went further than the guide had, stating that no penalty would be applied to any business in 2026 and calling 1 September a starting point and not a cut-off date. The DGFiP practical start-up guide, published in July 2026, states that penalties will not be applied during the start-up phase to businesses meeting real, documented difficulties while pursuing a serious compliance path, and that the administration will distinguish those cases from inertia, avoidance or lasting refusal to enter the system. The same document says in terms that this is neither a postponement nor a suspension of the obligation, and the legal calendar of 1 September 2026 continues to apply. Nothing in the Finance Act grants a grace period; what exists is a stated approach to enforcement, which is a weaker thing to rely on and turns on being able to show the trajectory. The guide is worth reading in full for the operational answers it gives, including whether an invoice that arrives outside the electronic channel can still be paid, booked and deducted.