Mandatory electronic invoicing: not ready by September 1, 2026? Penalties, grace periods, and solutions
The electronic invoicing mandate has been in effect since September 1, 2026, for transactions between businesses established in France. Many companies are approaching this requirement feeling unprepared and are asking: has there been a delay? What are the penalties? This article outlines the basic rules, details the rollout phase and the grace period provided by the authorities, and answers the most frequently asked questions.
I. The essentials: stakes and rules
1.1. What does the reform involve?
French law is gradually making the exchange of structured electronic invoices mandatory for VAT-registered businesses established in France (domestic B2B transactions): this is known as e-invoicing.
Furthermore, companies must transmit certain transaction and payment data to the tax authorities: this is known ase-reporting.
Key rule: a standard PDF or a paper invoice is not an electronic invoice. Electronic invoices must be issued, transmitted, and received via an approved platform in one of the following three structured formats: Factur-X, UBL, or CII.
(French General Tax Code, Art. 289 bis; AFNOR XP Z12-012 standard)
1.2 What are the two components to distinguish?
- E-invoicing: electronic invoicing applies to your sales and purchases of goods and services between companies established in France.
- E-reporting: the transmission of data for transactions not covered by domestic B2B electronic invoicing—primarily sales to individuals (B2C) and international transactions—as well as payment data.
(Ordinance No. 2021-1190 of September 15, 2021; Finance Act for 2024, Art. 91; French General Tax Code, Art. 289 bis and 290)
The regulatory framework for the reform was finalized this summer, notably establishing the term "certified platform" and refocusing the public invoicing portal on the central directory and data collection.
(Decree No. 2026-677 and Order of July 27, 2026)
1.3 Why this reform?
The stated objectives are primarily to combat VAT fraud, simplify reporting obligations (eventually leading to pre-filled VAT returns), improve real-time insight into economic activity, and reduce invoice processing costs and turnaround times.
1.4 When does my business need to be ready?
The timeline depends on the size of the company and distinguishes between the obligation to receive electronic invoices and the obligation to issue them.
- As of September 1, 2026 / Receiving electronic invoices: ALL businesses, including micro-businesses, small businesses, and SMEs
- As of September 1, 2026 / Issuing electronic invoices + e-reporting: Large companies and mid-sized enterprises (ETIs)
- September 1, 2027 / Issuing electronic invoices + e-reporting: SMEs, small businesses, and micro-businesses
Key takeaway for small businesses, SMEs, and micro-businesses: as of September 1, 2026, you must be able to RECEIVE electronic invoices, even though you are not required to ISSUE them until September 1, 2027.
II. Not ready by September 1, 2026? The rollout phase
To support the launch, the administration has published a practical startup guide which establishes a structured grace period: the schedule is neither postponed nor suspended, but business continuity is maintained during the ramp-up.
(Practical startup guide, DGFiP)
You are not alone in this: as of September 1, 2026, one-third of the "core target" businesses, according to the Ministry of Public Action and Accounts, had not yet selected their certified platform (66% had done so, a trend that has grown significantly since the summer), and more than 4 million businesses had designated their receiving address.
(Press release no. 980 of September 1, 2026)
2.1. What happens if my business is not ready?
There is no postponement of electronic invoicing: the schedule remains in effect.
However, your business operations continue. The reform changes the invoice transmission channel, not the underlying rules: the existence of the transaction, commercial debt, payment, accounting, and the right to deduct VAT remain unchanged.
(Practical startup guide, DGFiP; CGI, art. 271)
2.2. Am I required to stop sending and receiving all PDF or paper invoices?
No, the reform came into effect on September 1st 2026, but all flows not subject to the reform by this date (for example, because the supplier is not yet required to issue electronic invoices, or because the transactions do not fall under the e-invoicing mandate) must continue to be issued in the traditional format.
2.3. What about flows that are supposed to be subject to the electronic invoicing mandate: can I continue to send or receive them in PDF or paper format?
A simple PDF is no longer a compliant format, but, on a transitional basis, yes: to avoid disrupting business, an invoice received via email, PDF, or paper should not be rejected as long as it corresponds to a real transaction and contains the necessary information.
However, this channel is not the target: when you are subject to the issuance mandate, it is best practice to regularize the same invoice through the electronic system as soon as possible, particularly to allow for the transmission of data to the tax authorities.
(Practical Start-up Guide, DGFiP)
2.4. Will I be penalized from the very first day?
No: no automatic fines are applied at the start of electronic invoicing. During this phase, the administration will not impose sanctions on companies that encounter genuine difficulties but are committed to a serious path toward compliance.
The Minister of Public Action and Accounts confirmed this in a press release on September 1, 2026: "no sanctions will be applied in 2026," with the launch being presented as "a kick-off, not a cutoff date."
However, this announcement is a communication commitment rather than a standard: penalty provisions remain in effect, and maintaining a compliance file is still essential, particularly for audits that will later cover this period.
(Press release no. 980 of September 1, 2026)
The timeline remains applicable; only inertia, avoidance, or the continued long-term use of parallel systems without regularization remain subject to standard legal penalties.
(Practical Startup Guide, DGFiP; CGI, art. 1737 and 1788 D)
2.5. How can I demonstrate my good faith?
By documenting your compliance journey: selection or contracting of an approved platform, correspondence with your software provider or accountant, connection and deployment schedule, tests performed, incident tickets, interim measures adopted, and any regularizations made.
(Practical Startup Guide, DGFiP)
Furthermore, it is important to keep in mind that the requirement to document a reliable audit trail remains in effect despite the introduction of mandatory electronic invoicing: this documentation must be available for presentation at any time, as the tax authorities may conduct unannounced audits of the controls establishing the reliable audit trail. The transition period must therefore be duly documented to prepare for tax audits that will take place in the coming years.
(LPF, art. L. 13 D and L. 13 E)
2.6. What should I do in the event of a technical issue?
Do not interrupt operations or block payments; identify and document the issue; contact the software provider, service provider, or platform; use traceable interim procedures if necessary, then regularize the situation.
It is important to distinguish between issues within your own ecosystem (software provider, application, platform) and those affecting tools provided by the government (directories, hubs, exchange systems).
(Getting Started Guide, DGFiP)
III. Miscellaneous Frequently Asked Questions
3.1 Scope: who and what?
Does this apply to me if I am VAT-exempt or a micro-entrepreneur?
Yes. Even if you are not liable for VAT, you must be able to receive electronic invoices starting September 1, 2026, and issue them starting September 1, 2027, for your B2B transactions.
Your invoices must include the statement " VAT not applicable, Article 293 B of the French General Tax Code », which becomes « VAT not applicable, Article L. 223-3 of the CIBS » effective January 1, 2027; however, references to the General Tax Code remain permitted until June 30, 2028.
(CGI, art. 293 B; CIBS, art. L. 223-3; Ordinance No. 2026-671 of July 27, 2026)
Are foreign companies affected?
The electronic invoicing mandate applies to VAT-taxable entities established in France. A non-established foreign company does not issue or receive electronic invoices under this system, but may be required to perform e-reporting of transactions and, where applicable, payments for operations deemed to take place in France for which it is liable.
(CGI, art. 289 bis and 290)
Am I affected if I mainly sell to individuals?
Sales to individuals (B2C) and transactions with foreign companies are not covered by domestic B2B electronic invoicing, but their data must be transmitted via e-reporting (retail, catering, e-commerce, consultants with foreign clients, etc.) on a periodic basis depending on your VAT scheme.
(CGI, art. 290)
Which operations are excluded from the system?
Certain VAT-exempt transactions are not subject to electronic invoicing requirements (notably in healthcare, education, and certain banking, financial, and real estate operations). In these cases, there is no obligation for electronic invoicing or reporting.
(CGI, art. 261 et seq.)
Are invoices for the public sector (B2G) included?
Invoices sent to government agencies (B2G) are already digitized via the Chorus Pro portal. The reform focuses on business-to-business (B2B) transactions and integrates with the existing public system.
(DGFiP)
Are all types of invoices covered (down payments, credit notes, self-billing)?
Yes: as long as they are invoices, all types (down payments, credit notes, self-billing, etc.) fall within the scope and must follow the electronic process.
(CGI, art. 289 bis)
3.2 Electronic invoicing: format and content
Will a simple PDF sent by email suffice?
No. The invoice must be issued, transmitted, and received in a structured format that can be processed automatically.
Three formats are accepted: Factur-X (a human-readable PDF enriched with XML data), UBL, and CII. Factur-X is often the most suitable for small businesses because it remains readable by the human eye.
(AFNOR standard XP Z12-012)
What new information must appear on my invoices?
As of September 1, 2026, the following must be added: the client's SIREN number; the category of the transaction (delivery of goods, provision of services, or mixed operation); the mention of the option for VAT payment based on debits, if applicable; and the delivery address of the goods if it differs from the billing address.
(CGI, Annex II, art. 242 nonies A)
What are the invoice "statuses" I will need to track?
An electronic invoice has a lifecycle marked by statuses transmitted by the platforms; some are mandatory (submitted, rejected, refused, paid).
This tracking provides visibility into the progress and payment of invoices.
(AFNOR standards XP Z12-012 and XP Z12-014)
3.3 Certified platforms: selection and contracting
What is a certified platform?
Using a certified platform is mandatory for issuing and receiving your electronic invoices. These are private platforms registered with the DGFiP, responsible for converting your invoices into the correct format, routing them, and transmitting the required data to the tax authorities.
(CGI, art. 289 bis; DGFiP)
Is the Public Billing Portal (PPF) a free option?
No: the free billing service offered by the PPF has been discontinued. The PPF is no longer an exchange platform; it now serves as a central directory (for identifying recipients) and a data hub. Every business will therefore need to choose a certified platform, which will generally be a paid service.
(DGFiP; 2026 Finance Act)
What should I look for when choosing my platform?
Its official registration as a certified platform; its compatibility with your billing or accounting software; its support for various formats (Factur-X, UBL, CII) and e-reporting; and the cost, support, and guidance provided (including archiving terms and conditions).
How will my company be identified to receive invoices?
Routing is based on a central directory using your business identifiers (SIREN/SIRET): it is essential to ensure this data is accurate and kept up to date on your platform.
3.4 E-reporting and payment data
Do I also need to transmit my payment data?
For service-based transactions, payment data (receipts) must be transmitted as it determines when VAT becomes due; this data flow, separate from the invoice, is also managed by your platform.
(CGI, art. 290; CGI, art. 269)
3.5 Compliance, retention, and penalties
What should I do if I still receive a paper invoice or a PDF after the deadline?
For VAT-registered businesses based in France, paper invoices or unstructured PDFs will no longer be compliant once the mandate is in effect; you should invite your suppliers to switch to the electronic system via an accredited platform.
(CGI, art. 289 bis; Practical Start-up Guide, DGFiP)
How long do I need to keep my electronic invoices?
Invoices must be kept for 10 years; archiving must ensure the authenticity of the origin, the integrity of the content, and the readability of the document.
Law No. 2026-534 of June 25, 2026 (art. 36) increased the tax retention period from six to ten years as provided for in Article L. 102 B of the LPF, aligning it with the ten-year commercial requirement. This applies to documents whose retention period expires after January 1, 2027. Failure to retain or premature destruction of these documents is punishable by a €10,000 fine.
(Commercial Code, art. L. 123-22; LPF, art. L. 102 B; Law No. 2026-534 of June 25, 2026, art. 36; CGI, art. 1734)
The procedures for storing invoices must be verified with your accredited platform.
What are the penalties for non-compliance?
Fines for non-compliance with electronic invoicing were increased by the 2026 Finance Act: €50 per invoice not issued in electronic format and €500 per missing e-reporting transmission, each subject to an annual cap of €15,000. Failure to use an accredited platform for receiving invoices is penalized after a formal notice remains unheeded for three months: a €500 fine, increasing to €1,000 per three-month period if the failure persists, with no identified cap. (Law No. 2026-103 of February 19, 2026, art. 123; CGI, art. 1737 and 1788 D)
(2026 Finance Act; CGI, art. 1737 and 1788 D)
3.6 Cybersecurity and archiving
Is the security of certified platforms monitored?
Yes. Certified platforms are subject to what are considered the highest cybersecurity requirements in Europe, as reiterated by the Minister of Public Action and Accounts during a meeting at Bercy on August 26, 2026: submission of a progress report to the administration by the end of September 2026, immediate reporting of any incidents, and the rollout of penetration testing starting in the fall.
Any platform that fails to continuously demonstrate its security level will have its operations suspended. In practice, include cybersecurity (certifications, data localization, incident notification) and reversibility among your selection criteria and within your platform contract.
(Press release no. 980 of September 1, 2026)
Who is responsible for archiving my electronic invoices?
You are. Using a certified platform does not transfer the archiving obligation: the company remains responsible for retaining its invoices for ten years, under conditions that guarantee the authenticity of their origin, the integrity of their content, and their legibility.
Check whether your platform offers evidentiary archiving, what exactly the contract covers (invoices issued and received, lifecycle statuses), and the conditions for data retrieval at the end of the contract.
During the startup phase, archiving must cover both electronic invoice flows and invoices received through transitional channels (in PDF or paper format) and their adjustments, in order to maintain a reliable and complete audit trail.
(CGI, art. 289, VII; LPF, art. L. 102 B)
IV. Action plan for latecomers
- Choose an approved platform as soon as possible for (i) incoming and (ii) outgoing invoices if you are subject to the issuance requirement starting September 1st , 2026.
- Check your billing tool for compliance as soon as possible: is it compatible with electronic formats and capable of connecting to an approved platform?
- Ensure your customer and supplier data is reliable: keep SIREN numbers, addresses, and contact details up to date.
- Train your teams (accounting, sales administration) on the new processes.
- Document this transition period to prepare for a future tax audit.
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