On 1 September 2026, we had a meeting scheduled with the managing director of a British subsidiary based in Paris to discuss the budget. The meeting ended up being about something else: the first electronic invoice received that very morning, which nobody in the company could locate. That is how the reform entered the daily lives of our clients. Two months on, we share what we have observed and what we recommend to every SME between now and September 2027.
The essentials in three lines
Since 1 September 2026, all French companies must be able to receive electronic invoices, and large companies and mid-sized companies (ETIs) must issue them. On 1 September 2027, the obligation to issue will extend to SMEs and micro-enterprises. If your accredited platform has not yet been chosen, that is the first decision to take — and we advise taking it before the end of the year.
What we have observed among our clients
The technical side caused nobody any difficulty. The platforms work, the structured formats (Factur-X, UBL, CII) are accepted, the directory responds. The difficulties came from organisation.
An unregistered subsidiary. A services company with twelve employees and €3 million in turnover. Its landlord, a mid-sized company subject to the obligation to issue, sent it its September invoice through the platform. As the subsidiary was not registered anywhere in the directory, the invoice remained in error on the issuer’s side. Three weeks of late payment, and a rent finally settled on the basis of a PDF sent as a courtesy. Nothing serious in itself; multiplied by twenty suppliers, it is a disorganised cash position.
The platform imposed by the group. A subsidiary of an American group, whose head office had selected a global platform for all of its entities. That platform was not accredited in France on 1 September. It has since become so, but the subsidiary was outside the framework for six weeks. The head office is not at fault: the list of accredited platforms changes every month, and monitoring it is not part of its remit.
Data, the most frequent case. Missing or incorrect customer SIREN numbers, delivery addresses never filled in, on the grounds that the company “does not deliver anything”. Yet the nature of the transaction has become a mandatory mention, and invoicing software that does not know it produces non-compliant invoices. We have spent more time cleaning up customer files than configuring platforms.
The four new mandatory mentions
They apply to all invoices, electronic or not. We suggest passing this table on to the person in charge of your invoicing:
| New mention | Why it matters |
|---|---|
| The customer’s SIREN number | It is the routing key in the directory. An incorrect SIREN, and the invoice does not arrive. |
| The delivery address, if it differs from the billing address | Required for VAT control on supplies of goods |
| The nature of the transaction: goods, services, or both | It determines when VAT becomes chargeable and the scope of e-reporting of payments |
| The option to pay VAT on a debits basis, where applicable | It allows your customer to deduct VAT from the invoice date |
If your software does not handle these fields, it will have to be replaced before September 2027. It is better to know now.
What awaits SMEs on 1 September 2027
In eleven months, an SME will no longer be able to send a PDF by e-mail to a French customer. It will have to produce a structured file and submit it on its accredited platform. E-reporting — the transmission to the tax authorities of data on sales to private individuals and abroad, and of payments received on services — will start the same day.
Here is the timetable we propose to our SME clients. Those who followed it in 2026 went through September without incident:
- By December 2026: choose the accredited platform. If your group imposes one on you, check that it is accredited in France and compatible with your accounting tool. Check registration in the directory.
- First quarter of 2027: clean up the customer file — SIREN numbers, addresses, nature of transactions. Test issuing with two or three willing customers.
- Second quarter of 2027: switch sales to electronic invoicing and train teams on the invoice life cycle: submitted, rejected, refused, paid. This vocabulary is new to everyone.
- Summer 2027: deal with special cases — advance payments, credit notes, self-billing, transactions with foreign parties falling under e-reporting.
Penalties
€50 per invoice not issued electronically, capped at €15,000 per year. €500 per missing e-reporting transmission, same cap. The first offence benefits in principle from a tolerance.
No accredited platform: the tax authorities send a 3-month formal notice. If you do not regularise, the fine is €500. It then rises to €1,000 every 3 months if the problem continues.
The fine is not the main risk. The risk is the day a major customer rejects non-compliant invoices and receipts fall six weeks behind. We have already seen it.
For subsidiaries of foreign groups, three additional points
- The group’s global platform. Accreditation must be checked on the official list published by the tax authorities, not in the vendor’s documentation.
- Invoicing centralised abroad. Invoices addressed to French customers, even if produced in an ERP located outside France, must pass through an accredited platform. Integrating the flow is a project in its own right, not a simple configuration.
- Intra-group flows. A management fees invoice addressed to the foreign parent company is not a domestic invoice: it falls under e-reporting, not electronic invoicing. The distinction is simple in theory; in a poorly configured ERP, it is much less so.
What we do at Hexagone Advisory
- We check that the platform selected by your group is accredited in France and compatible with your accounting.
- We review your customer file and your invoice templates against the new mandatory mentions.
- We configure receipt, issuing and e-reporting, then we monitor the first months of flows with you. The first rejections are inevitable; what matters is dealing with them in hours, not weeks.
- We keep you informed of regulatory developments.
The questions we are asked
“We have not received any electronic invoices since September. How do we know whether we are compliant?”
The e-invoicing directory, managed by Chorus Pro, lets you check whether your company is properly registered and whether a valid electronic invoicing address exists. If you have received nothing, either you have no large company or mid-sized company suppliers, or your registration is not compliant.
“Isn’t a PDF sent by e-mail already an electronic invoice?”
Within the meaning of the reform, no. An electronic invoice is a structured file submitted on an accredited platform. A simple PDF is not an electronic invoice but a digital copy of a paper invoice.
“Our subsidiary only invoices its parent company abroad. Are we affected?”
Yes, through e-reporting: invoices addressed to a company not established in France do not pass through the platform, but their data must be transmitted. And the obligation to receive applies to your purchases in France.
Further reading : Corporate taxation in France · Contact us
