All You Need to Know About the French E-Invoicing Mandate: Expert Q&A
As France prepares to enforce its comprehensive e-invoicing and e-reporting mandate on September 1, businesses are facing the challenge of aligning their operational workflows and IT frameworks before the deadline.
On May 27, 2026, we hosted a dedicated webinar to guide companies through the new regulatory ecosystem, covering everything from the interoperability model to complex document lifecycles. Below, you will find answers to some of the most pressing questions asked during the webinar. Discover practical guidelines and specific solutions that could determine the success of your implementation.
General Mandate Scope, Timelines & Grace Period
1. How does the real-time reporting under e-invoicing differ from e-reporting?
In real-time reporting, data from domestic electronic invoices is reported to the governmental platform (PPF) by the issuer’s PA (certified provider) in parallel with the electronic invoice sent to the customer. Payment data is also reported in real time via an invoice status update. On the other hand, e-reporting is the transmission of transaction and payment data for operations outside the scope of e-invoicing (cross-border invoices and B2C transactions).
2. What are the differences in implementation timelines for large organizations and small/medium businesses? Is there a difference in e-reporting requirements?
E-Invoicing reception is mandatory for all companies from September 1, 2026. Issuing for large (GE/Grandes Entreprises) and intermediate-sized companies (ETI/Entreprises de tailles intermédiaires) will start from September 1, 2026. For all other companies, issuing invoices begins one year later, on September 1, 2027.
E-reporting requirements apply at the same time as the e-invoicing issuance obligation begins. For companies based outside France, e-reporting will begin on September 1, 2027.
3. How does a company qualify as an SME, and what are the requirements?
Company size thresholds are as follows:
- SME (Small and Medium-sized Enterprise): Headcount <250 employees and annual turnover <€50M or a balance sheet total <€43M.
- Mid-cap company (ETI): A company that does not belong to the SME category, with a headcount <5,000 employees and an annual turnover <€1,500M or a balance sheet total <€2,000M;
- Large enterprise: A company that cannot be classified in the previous categories. Companies with a headcount of more than 5,000 employees, or if the headcount is under 5,000 employees, with a turnover of more than €1,500M and a balance sheet total of more than €2,000M.
4. Are the SME thresholds based just on the French entity or on the group as a whole if part of a multinational enterprise?
The thresholds are based on the French entity identified with its SIREN number.
5. Is there any grace period for non-compliance, or will penalties apply immediately after September 1, 2026?
No penalties will be issued during the pilot phase. After September 1, 2026, the government will manage non-compliant companies case by case to understand the reason for their non-compliance. If companies are able to prove their willingness and pathway to become compliant, the government will have tolerance. Otherwise, penalties will apply.
6. We are an SME business. What should we do if a French supplier sends us an invoice in PDF after September? Should we reject it?
It is not your responsibility if your supplier is not compliant. If you receive an invoice in PDF, you should process it. There will be tolerance for companies as long as they show good faith and willingness to comply.
7. What is the cut-off date for accepting pdf?
There is no cut-off date, as you might receive PDF invoices from other countries as well. We can assume some companies will not be ready in time, so you can also add a buffer period.
8. How should invoices that were issued before September 1, but not received until September 1 (or after), be treated? Can we still accept those (or copies) in their original format (probably PDF), or do we need to request a new electronic invoice?
You can process them as you are currently doing. There’s no need to request a new, electronic invoice.
Foreign Companies & Cross-Border Transactions
9. How does French law apply to companies outside of France?
Some companies are not based in France but have operations that are deemed to be subject to VAT in France. You can find more information about this on the French government’s slide deck with examples of such operations on slide 17.
10. What do foreign companies need to e-report? Would an Irish company paying a French company have an obligation in France?
E-reporting data required by the government is the same for French and foreign companies. It includes transaction data (all invoice data for B2B and daily revenue for B2C) and payment data (per invoice for B2B and per day for B2C).
Some companies are not based in France but have operations deemed subject to VAT in France. You can find more information on this slide deck from the French government, with examples of such operations on slide 17.
11. Is payment data needed for reverse charge invoices from a French company?
Payment data must be reported by the company receiving the payment. If you receive an invoice from a French company, then they will be the ones for whom this requirement will apply. In the case of a reverse charge invoice, they are out of the scope of payment reporting.
12. We are a healthcare business based in the NL with UK and BV entities, charging VAT on our invoices. We already submit B2G invoices to French hospitals, but we also trade B2B. Do we need to do anything for the September deadline?
If you are based outside of France, it is highly likely that you are not subject to e-invoicing obligations. Still, you might be subject to e-reporting in September 2027. Some exemptions also apply to the health industry. In any case, we encourage you to consult your tax advisor regarding this matter.
13. Does e-reporting for foreign companies from September 2026 apply only to local sales with VAT?
E-reporting for foreign companies is limited to some operations where VAT is due in France. You can find more information on this slide deck from the government, with examples of such operations on slide 17. In any case, we encourage you to consult your tax advisor regarding this matter.
Platforms, Onboarding & Infrastructure
14. Is it possible to use the PPF directly for inbound invoices for a limited period, i.e., manually download invoices from PPF and process them in the local system without a PA integration?
In a press release issued in October 2024, the government announced that the PPF will no longer allow the possibility of sending and receiving invoices using it. They let the responsibility fall on the PA (PDP at the time) to manage the exchange between themselves and the PPF.
15. What is the onboarding/registration process? What are the timelines in general to complete this process?
Regarding registration in the directory, first, you need to sign an opt-in form to confirm that your PA is assigned to a specific electronic address or range of addresses. Then you need to tell your PA which electronic address you want to register in the directory. Finally, it's the PA's role to do the registration. You will then be able to receive electronic invoices. In terms of timeline, we can assume between 3 and 10 days, depending on the PA workload and opt-in form signature.
16. Do you need to be able to store all four e-addresses, or will there just be one e-address per customer?
The default electronic address will be the SIREN. But a company can choose to have multiple addresses. Depending on the customer you are exchanging with and the invoicing flow you are using, you might need to store multiple addresses.
17. Can you see which PA a company is registered with? Or whether a company is small or large?
Currently, there is no public directory to freely check a specific company's PA. You need to ask the company directly. Regarding company size, this is also a bit difficult to check. Generally, you should contact your biggest/strategic suppliers and the ones who send you the most invoices to know how they are planning their convergence towards e-invoicing.
18. Will there be a way to determine whether our supplier will be sending an e-invoice as of September 1?
No, there is no automated way to check this; you will need to ask them directly. For example, you can focus on your largest/strategic suppliers or the ones you exchange the most invoices with. But anyway, you should be ready to receive electronic invoices, whether the supplier is a large company or not.
Technical Requirements, Formats & Document Lifecycles
19. How does the Comarch solution work? Can Comarch connect to the ERP and pull/push the info directly? If yes, does it work with NetSuite
Comarch's solution is ERP agnostic. It can connect to any ERP using different communication channels such as SFTP or API.
20. Can the automotive industry continue using EDIFACT to send invoices directly between supplier and customer, as long as the report is also sent to PPF?
Yes, it is possible to exchange formats other than the mandatory ones (UBL, CII Factur-X). In the technical specifications, this is referred to as Flow 3 (Flux 3). The EDIFACT’s INVOIC message can be used under the following conditions:
- Both parties consent to use this format.
- PAs (certified providers) from both parties support the format.
- The format used allows the extraction of data required for the real-time reporting sent to the French government.
You can get in touch with GS1, which is editing specifications about INVOIC (the latest version is available here), or GALIA, which is an association dedicated to document exchange in the automotive industry.
21. Is self-billing allowed, and does it require sequential numbering?
Yes, self-billing is allowed in the e-invoicing framework in France. Of course, you will need a mandate between the customer and the supplier that allows the customer to issue invoices on behalf of the supplier. It is described in detail as a use case (n°19b) in the XP Z12-014 norm (available under “free consultation”/consult in English/telechargement des annexes, here).
Sequential numbering is also required, but you can have your own numbering.
22. Is sequential numbering required for e-invoicing in France, and are breaks in numbering acceptable to the tax authorities?
The e-invoicing reform doesn't change the need to provide the invoice number when issuing an invoice. This number should be unique and allow chronological ordering without breaks.
23. Are all lifecycle statuses required to send to PPF?
All statuses defined as mandatory are shared with the PPF. Mandatory statuses include submitted, rejected, refused, and payment received (déposée, rejetée, refusée, encaissée). Only 'refused' and 'payment received' are mandatory statuses for which the companies are responsible.
24. Does the “refused” status mean that invoices can still be canceled (no corrective invoice is needed)?
If an invoice is “refused”, the issuer will create an internal credit note to cancel the invoice in their books. Then they will have to create a new invoice to send to the customer.
25. If accounts payable systems aren't ready in time, can an agent download invoices and provide them to the business for manual entry into the accounting system, or is it mandatory to electronically upload the bills to the business’s accounting system?
There is no obligation regarding how invoices should be integrated into your systems, so you can do it manually or ask your PA what services they can offer to make it easier to integrate automatically.
26. In case the internal systems are not ready in time, what are your recommendations for a workaround to meet the minimum mandatory requirements in time?
Our recommendation would be to start as soon as possible to be ready as early as possible. The first step would be to identify the compliance gap or pain points. Then you can define what is needed from an operational and technical perspective and try to find a PA (or multiple PAs) to make it easier for you. Also, there will be some tolerance from the government at the start for companies that make the effort of getting compliant.
27. When a PA sends an e-invoice, they send it first to the customer and later to PPF, or is it done simultaneously?
There is no specific order. The invoice should first be validated by the PA to make sure that it is compliant. Then it can be sent in parallel to the receiving PA and the PPF.
28. What is the difference between ‘VAT on debit’ and ‘VAT on collection,’ and how will it impact the way we need to treat the reporting and sending lifecycle status? Do we need to register with one of the above options while registering for e-invoicing?
In France, you can choose to report VAT when you receive the payment or part of the payment (on collection) or when you issue the invoice (on debit). Companies can choose between the two options.
29. PDP can demand supplementary validation data. The invoice will be rejected if this supplementary data is missing. But will it also not be sent to the PPF then? Do we need to check all supplementary requested data for each PDP?
In general, the PAs need to have the same validation that checks whether the invoices exchanged are compliant. If an invoice is “rejected” by a PA (the one issuing or receiving the invoice), then the status is also shared with the PPF, so the data related to the invoice will not be taken into account by the tax administration. So if your invoices pass through the checks from your PA, they should be accepted by others with no problem.
30. Do companies also send detailed info to PA and let PA aggregate it, or a mix of inbound and outbound for e-reporting?
In standard, companies must send the data required for e-reporting already aggregated. Some PAs can propose the aggregation service, but it's not mandatory for them to offer it to their users.
31. Are partial payments considered a mandatory status to report on, as in payment received? Or is it only when the invoice is cleared?
If you receive partial payments, you should also report them. On the government side, they will aggregate all the data and should find the total amount in the end.
Useful Information on E-Invoicing in France
For looking up public information and registry services, you can use the official portal.
For international companies executing operations inside France or subject to French non-resident tax protocols, direct contacts for specialized desks are available below:
- DINR / AFNR (for companies not based in France)
- Phone: +33 (0)1 72 95 20 31
- Email Contact: afnr.dinr@dgfip.finances.gouv.fr
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