On this page · 13 sections
- The French calendar on 7 November 2026
- Who counts as an SME or micro-enterprise
- What 1 September 2027 changes for an SME
- Choosing a plateforme agréée
- Formats: UBL, CII and Factur-X
- E-reporting: what to send and how often
- Fines and the start-up tolerance
- ERP and invoicing-software readiness
- How France compares with Germany
- A ten-month plan to 1 September 2027
- Notes for Indian groups and foreign suppliers
- How eCorpIT can help
- References
Summary. France's e-invoicing reform started on 1 September 2026. Since then every VAT-registered business established in France must be able to receive e-invoices through a plateforme agréée (approved platform), and large companies and mid-caps (ETI) must also issue them and report transaction and payment data. On 1 September 2027 the issuing and e-reporting duties extend to SMEs, very small firms and micro-enterprises, micro-entrepreneurs under the VAT franchise included. Size is judged per legal entity (SIREN), on the last financial year closed before 1 January 2025. The DGFiP's platform list, updated on 3 November 2026, names 158 operators. A valid e-invoice uses UBL, CII or a mixed format such as Factur-X and carries 34 structured data items, four of them new. The 2026 finance law set fines of €50 per invoice not issued electronically and €500 per missed e-reporting transmission, each capped at €15,000 a year. The government has said no company will be sanctioned before the end of 2026. For ERP owners, the work is master data, lifecycle statuses, payment feeds and B2C aggregation.
About this article. For owners, finance and IT leads at French SMEs and micro-firms, and at foreign groups with French entities or French VAT sales. On 7 November 2026 we checked dates, thresholds, fines and the platform list against impots.gouv.fr (reform pages, DGFiP FAQs, the July 2026 start-up guide, the list of 3 November 2026), ministry press releases, a Senate bill and the legal texts: article 123 of Loi 2026-103 as published on 20 February 2026, CGI articles 1737 and 1788 D in the versions in force from 21 February 2026 and due from 1 January 2027, and Décret 2008-1354 as in force on 24 January 2025. Légifrance refused automated requests, so we used DILA's official open data and archived copies. This is not tax or legal advice; confirm your category with your expert-comptable. No vendor paid for inclusion. Researched with AI assistance and reviewed by our editorial team.
The French calendar on 7 November 2026
The DGFiP's calendar Q&A (updated 16 January 2026) and the ministry both confirm the two steps.
| Date | Who | What happens |
|---|---|---|
| 1 September 2026 | Every VAT-registered business established in France | Must receive e-invoices through a plateforme agréée |
| 1 September 2026 | Large companies and ETI | Issue e-invoices; send transaction and payment e-reporting |
| To 31 December 2026 | All businesses | Government says no sanctions for any company this year |
| 1 January 2027 | All businesses | VAT rules, including the e-invoicing articles, move from the CGI into the CIBS |
| 1 September 2027 | SMEs (PME), very small firms (TPE) and micro-enterprises | Issue e-invoices; send transaction and payment e-reporting |
The no-sanctions pledge comes from ministry press releases of 1 September and 9 October 2026. An ordinance of 27 July 2026 postponed the move of VAT law into the Code des impositions sur les biens et services (CIBS) to 1 January 2027; old CGI references stay usable until 30 June 2028. Expect CIBS article numbers in platform and adviser documents from January.
Before 1 September 2027 an SME may e-invoice voluntarily, for some or all invoices, and fall back to its usual method if that fails. A customer cannot use the reform to force earlier e-invoicing, nor refuse payment because an invoice is not electronic.
Who counts as an SME or micro-enterprise
The reform uses the company categories of article 51 of the 2008 economic modernisation law and Décret 2008-1354.
| Category | Headcount | Financial test | Issuing date |
|---|---|---|---|
| Micro-enterprise | Fewer than 10 people | Turnover or balance sheet total up to €2 million | 1 September 2027 |
| SME (PME) | Fewer than 250 people | Turnover up to €50 million or balance sheet up to €43 million | 1 September 2027 |
| Mid-cap (ETI) | Fewer than 5,000 people, not an SME | Turnover up to €1,500 million or balance sheet up to €2,000 million | 1 September 2026 |
| Large company | Everyone else | Not applicable | 1 September 2026 |
For this reform the DGFiP applies the tests to each legal unit (SIREN), not to the group, and fixes size at 1 January 2025 on the last financial year closed before that date. A firm moves up once it exceeds the headcount limit or, below it, only if both turnover and balance sheet exceed the thresholds. A 20-person French subsidiary of a large group therefore normally has until 1 September 2027.
Micro-entrepreneurs are in scope, and even a business that issues no invoices must be able to receive them.
What 1 September 2027 changes for an SME
From that date, an SME runs three flows, all through a plateforme agréée.
- E-invoicing. B2B sales between VAT-registered businesses established in France, where French VAT applies, travel as structured e-invoices through platforms, which pass the required data to the administration. A scanned invoice, ordinary PDF or emailed invoice no longer complies.
- E-reporting of transactions. Sales to non-taxable customers, such as consumers or non-profit associations, are reported as daily totals by VAT rate. Transactions with businesses not established in France (exports, intra-EU supplies and acquisitions) are reported with the same data as an e-invoice, using the VAT or foreign ID instead of a SIREN.
- E-reporting of payments. Where VAT is due on receipt (typically services, unless the business opted to pay VAT on debits or the operation is reverse-charged), the business reports the date and amount collected by VAT rate. For e-invoiced operations, this is a collected (encaissée) status added to the invoice.
VAT-exempt operations also exempt from invoicing under CGI articles 261 to 261 E, such as certain health, education, property, non-profit, banking and insurance operations, are outside both regimes.
Choosing a plateforme agréée
A plateforme agréée is a private operator registered by the State to issue, transmit and receive e-invoices, extract the data the administration needs and forward transaction and payment data. Registration requires tax compliance, security and interoperability, and becomes final only after live interoperability tests; the number lasts three years, renewable.
The DGFiP's FAQ sets the security bar: ISO 27001 for the e-invoicing scope, SecNumCloud-qualified cloud where the rules require it, EU hosting with no transfer outside the EU, and annual audits. The State runs the directory (annuaire) that routes each invoice to the recipient's platform; it does not centralise invoices.
The list updated on 3 November 2026 has 158 operators that met all conditions, 152 with a registration date and 6 still awaiting their number, plus a second list of 7 operators awaiting interoperability tests. It includes ERP and accounting vendors (SAP, Sage, Cegid, Odoo, Axonaut), fintechs (Qonto, Shine), accounting-firm tools (Pennylane, Tiime) and specialists (Basware, Esker, Generix, EDICOM, Pagero, Storecove, Sovos, Avalara, ClearTax). On 1 August 2026, more than ten of the then 150 platforms offered a free or no-extra-cost service for basic needs. By 4 October 2026, 75% of VAT-filing businesses had designated a receiving platform. You may use several platforms, and yours need not match your partners'.
| Criterion | Why it matters | What to ask the platform |
|---|---|---|
| Fit with your ERP | Re-keying defeats the purpose | Native connector, compatible solution, or the XP Z12-013 API? |
| Formats | Suppliers will send UBL, CII and Factur-X | Do you accept, deliver and convert all three? |
| E-reporting | B2C, international and payment data are separate flows | Do you aggregate B2C sales and take payment status from our bank or ERP? |
| Lifecycle statuses | Rejections, refusals and collected status drive cash and VAT | Which statuses do you expose by API and webhook? |
| Pricing | Volumes vary widely | Per invoice, subscription or free tier? |
| Registration | Only registered platforms carry the flows | Registered, or still awaiting interoperability tests? |
| Exit and portability | You may switch later | How do we export history and move our directory entry? |
On exit, the outgoing platform must keep minimum services running for at least a year. Platforms also carry their own fines: €750 per failed transmission of transaction or payment data, up to €100,000 a year per obligation.
Formats: UBL, CII and Factur-X
The DGFiP accepts three formats: UBL, CII, or a mixed format combining a structured data file with an image, of which Factur-X is the common example. Formats and profiles sit in AFNOR standard XP Z12-012, the APIs between company systems and platforms in XP Z12-013, and B2B use cases in XP Z12-014. Version 3.2 of the DGFiP's external specifications, dated 30 April 2026, covers the directory and the data flows to the administration.
| Format | What it is | Good fit | Watch-outs |
|---|---|---|---|
| UBL | XML syntax, also used by Peppol BIS 3 | ERP-to-ERP flows, Peppol users | Must follow the French profiles in XP Z12-012 |
| CII | UN/CEFACT Cross Industry Invoice XML syntax | EDI-heavy supply chains, retailers | Same profile rules; less familiar to some ERPs |
| Factur-X | PDF/A-3 with CII XML embedded | Small firms wanting a readable PDF | The XML carries the legal data; a plain PDF is not an e-invoice |
Whatever the format, mandatory mentions go in structured fields; the DGFiP counts 34 data items. Four mentions are new: the customer's SIREN, the category of operation (goods, services or both), the VAT-on-debits option where chosen, and the full delivery address if it differs from the billing address.
E-reporting: what to send and how often
The DGFiP's August 2026 table ties e-reporting frequency to your VAT regime.
| VAT regime | Transaction data | Payment data |
|---|---|---|
| Normal regime, monthly returns | Every 10 days (1st to 10th, 11th to 20th, 21st to month end), due 10 days after each period | Monthly, before the 10th of the following month |
| Normal regime, quarterly option (under €4,000 VAT a year) | Monthly, before the 10th of the following month | Monthly, before the 10th of the following month |
| Simplified regime | Monthly, by the 25th to 30th of the following month | Monthly, by the 25th to 30th of the following month |
| VAT franchise (franchise en base) | Every two calendar months, by the 25th to 30th of the month after | Every two calendar months, same deadline |
In most cases the seller sends a data file to its platform, which forwards it. Treat it as a batch job, like a period-end close: reconcile B2C sales by VAT rate, match receipts to service invoices and keep the evidence.
Fines and the start-up tolerance
Article 123 of the 2026 finance law (Loi 2026-103 of 19 February 2026) rewrote the penalty articles, applying from each obligation's start date for the company's category: 1 September 2026 for receiving, 1 September 2027 for an SME's issuing and e-reporting.
| Failure | Fine | Annual cap | CGI article |
|---|---|---|---|
| Not issuing an e-invoice when required | €50 per invoice | €15,000 | 1737 III |
| Not using a platform to receive e-invoices | Three-month formal notice; then €500 and a new notice; then €1,000 per further three months | None stated | 1737 IV bis |
| Missing transaction e-reporting | €500 per transmission | €15,000 | 1788 D I |
| Missing payment e-reporting | €500 per transmission | €15,000 | 1788 D II |
| Missing or wrong mention on an invoice | €15 per omission | A quarter of the invoice amount | 1737 II |
A first-offence exemption covers all but the receiving fine: none for a first infringement in the current year and the three before it, if it is corrected spontaneously or within 30 days of the administration's first request.
One caveat for 2027. When VAT law moves into the CIBS on 1 January 2027, articles 1737 and 1788 D are rewritten to cite the new code. In DILA's official consolidation, unchanged as of 6 November 2026, the new 1737 keeps the €50 fine, but the new 1788 D shows the older €250 per transmission and a €45,000 platform cap. We could not establish whether that is a consolidation gap or the law; recheck in January 2027.
The DGFiP's July 2026 start-up guide spares businesses with real, documented difficulties that are being corrected from automatic sanctions, while separating them from inertia or refusal; it stresses this is neither a postponement nor a suspension. An invoice received by email, PDF or paper should still be paid if it matches a real operation, and the VAT deduction right is not lost for that reason alone.
On 8 October 2026 the first monitoring committee repeated the no-sanctions pledge for 2026, promised an updated guide within two weeks and will meet again before the year ends, with 2027 on its agenda. On 7 November impots.gouv.fr still carried the July edition.
ERP and invoicing-software readiness
Start with your current tool and ask one question: is it a registered platform, a compatible solution connected to one, or neither?
- Microsoft Dynamics 365 Business Central. Microsoft's release plan, now archived, gave 3 August 2026 for general availability and says Microsoft does not act as a platform itself. Its October 2026 documentation describes an E-Reporting FR extension producing UBL 2.1 (Peppol BIS 3.0) and Factur-X invoices, sent to a platform through an E-Document connector.
- SAP, Sage, Cegid and Odoo. Each appears on the DGFiP's list as a registered operator. Check which editions and hosting options the registration covers. If your French entity still runs SAP ECC, our SAP ECC end-of-maintenance guide covers the wider upgrade decision.
- Other tools. We did not verify French coverage for every ERP used by foreign subsidiaries. Ask the vendor for its platform partner and test the full flow, including rejections.
Whatever the tool, the changes are similar:
| Change | Where it lands | Notes |
|---|---|---|
| Customer SIREN on every B2B invoice | Customer master data | Validate against the directory |
| Operation category (goods, services, both) | Item and invoice header | Drives VAT treatment and e-reporting |
| VAT-on-debits option flag | Company settings and invoice | Affects whether payment data is due |
| Delivery address when different | Sales order and invoice | New structured mention |
| Rejection, refusal and collected statuses | Accounts receivable and payable | Feed cash application and dunning |
| Daily B2C totals by VAT rate | POS and e-commerce | Batch on your regime's rhythm |
| Foreign customer VAT IDs | Customer master data | Replaces SIREN in international e-reporting |
| Directory lookup before sending | Platform integration | Unroutable invoices are rejected |
How France compares with Germany
| Item | France | Germany |
|---|---|---|
| Next date | 1 September 2027: SMEs and micro-firms issue | 1 January 2027: firms above €800,000 prior-year turnover issue |
| Exchange model | Registered platforms plus a State directory | Direct exchange, no registered platforms |
| Reporting to tax authority | Invoice data plus transaction and payment e-reporting | Not part of the domestic mandate |
| Formats | UBL, CII, Factur-X | Structured formats meeting EN 16931, such as XRechnung and ZUGFeRD |
Germany's dates come from section 27(38) of its VAT Act and its e-invoice definition from section 14. Our Germany 2027 e-invoicing checklist covers the detail; for Spain, see our Verifactu 2027 guide.
A ten-month plan to 1 September 2027
- November 2026. Confirm each French entity's category with your expert-comptable, and that a receiving platform is designated.
- December 2026. List every French invoice source: ERP, subscription billing, POS, e-commerce, manual spreadsheets.
- January 2027. Shortlist two or three platforms using the table above and check their registration status; update tax references to the CIBS.
- February 2027. Clean customer master data: SIREN, VAT IDs, delivery addresses, VAT-on-debits settings.
- March 2027. Configure your tool for the four new mentions and your chosen format.
- April 2027. Build the e-reporting jobs for B2C totals, international sales and payments.
- May 2027. Start voluntary issuing to a few friendly customers; monitor rejections.
- June 2027. Extend to all domestic B2B customers; wire statuses into receivables.
- July 2027. Run a full e-reporting cycle for your regime; reconcile against the VAT return.
- August 2027. Freeze changes, train staff and keep dated evidence of every step, which the DGFiP's guide treats as proof of a serious compliance path.
Notes for Indian groups and foreign suppliers
A business not established in France is outside e-invoicing, but may owe e-reporting on operations taxed in France for which it is liable for the VAT. Its size is judged on the whole foreign legal entity: a large or mid-sized one has owed this since 1 September 2026, a smaller one from 1 September 2027. Where the foreign business is the liable customer, the date is 1 September 2027 whatever its size. A foreign company with a French VAT fixed establishment counts as established in France.
Platforms commit to EU hosting with no transfer outside the EU, so if your accounts team works from India, ask how offshore access fits the contract. Indian SaaS vendors whose software invoices French firms need a link to a registered platform, since only those carry the flows. Teams running India's GST e-invoicing will recognise the pattern; see our GST e-invoicing integration service.
How eCorpIT can help
eCorpIT is a Gurugram-based technology organisation, founded in 2021, assessed at CMMI Level 5 and MSME certified, with senior-led engineering teams working across AWS, Microsoft and Google platforms. We map ERP and billing data to the French structured mentions, connect your system to the plateforme agréée you choose through its API, and build the e-reporting and status jobs, as part of our ERP software development work. Talk to us at /contact-us/.
Last updated: 7 November 2026.
