| France is preparing for a major reform that, from 1 September 2026, will require all companies to exchange their invoices electronically (e-invoicing) and to transmit to the authorities the tax data of their transactions (e-reporting) falling within the scope of VAT as well as payment data when the associated VAT is due upon receipt of payment. |
Check out our infographics to understand the basics of the reform.
The legislative framework for this e-invoicing requirement is established by the Amending Finance Act for 2022 (Act No. 2022-1157 of 16 August 2022, Art. 26), modified by article 91 of the Finance Act for 2024, which will come into force for all companies on 1 September 2026.
SMEs and VSEs will only be required to issue invoices electronically from 1 September 2027.
To satisfy these new requirements, companies will have to choose, until 1 September 2026, a registered private platform (PDP) to issue and receive their invoices (press release of the French Minister for the Budget and Public Accounts, published on 15 october 2024). The PDP will transmit the main invoicing data to the tax authorities, the data relating to transactions for which the e-voicing is not required (e-reporting), as well as the data concerning the partial or the full receipt of payment.
The legal provisions and regulations specifying the application of the reform (currently, the decrees no. 2022-1299 of 7 october 2022; no. 2024-266 of 25 March 2024 and the decree of 7 October 2022) will need to be amended following the Minister's announcements on 15 october 2024.
The external specification file, which details the practical procedures related to e-invoicing, has already been subject to a first revision (link to the documents).
Companies have now access to enough information to prepare themselves.
A first group of PDPs has been registered: find the list here.
From the first stage of implementation on 1 September 2026, all businesses will have to accept invoices in electronic form. The obligation to issue electronic invoices and to transmit transaction and payment data will apply from 1 September 2026 to large enterprises and intermediate-sized enterprises (ETIs), but only from 1 September 2027 for SMEs and VSEs.
The period between now and the coming into force of the reform should enable companies of all sizes to make the significant adjustments to their information systems as required by the reform, choose the service provider(s) (PDP) to meet the new obligations relating to electronic invoicing and the transmission of transaction data, and, potentially, singing up to take part in a test phase due to start at the beginning of 2026 (the PDPs, however, should be able to access the directory in 2025).
Click here to find out more about this reform.
Finally, according to the latest estimates, the tax administration's official guidance (BOFiP) should be available shortly.
Our support
| The scope of the reform means that we need to prepare for the changes to be made to information systems, while taking into account the specific characteristics of each company: applications used to issue invoices and incorporation of new mandatory statements on invoices; procedures and formats for issuing, transmitting and receiving invoices; cash register software; collection of data relating to transactions subject to e-reporting ; updating of the documentation constituting the reliable audit trail; preservation and storage of invoice files. Assessing your needs is an essential step for choosing the appropriate PDP. |
Our VAT lawyers and our dedicated tax IT team will assist you at every stage of your preparations for this reform:
- Identifying the extent of the adjustments required and the difficulties to be anticipated
| We can offer you an assessment of the adjustments you need to consider based on your specific situation (i.e. what business you are in, the type of transactions you perform, your current practices in invoicing and registering transactions, and any other changes you may have already anticipated (such as the creation of a VAT group in 2023) |
We can help you identify the criteria best suited to your company’s situation for choosing one or several PDPs and identify the points to pay particular attention to when upgrading your information systems.
- Overseeing your preparations
| Our VAT specialists and tax IT team work with you to ensure that your new system is suited to your business and will satisfy the legal and technical requirements of the reform. |
Our teams have been actively involved in shaping this reform, contributing extensively during the consultation phase. This puts us in an ideal position to clarify any remaining uncertainties and give you an insight into what to expect looking ahead, such as pre-filled VAT returns or alignment of the French reform with the European Union’s, likely to become binding on all Member States in the very near future in the context of the directive VAT in the digital age (ViDA). All CMS Francis Lefebvre teams work together to offer specialist support covering all the various legal and tax consequences of this reform, looking at how it will affect your business relations and payment periods, ensuring your updated systems are GDPR-compliant, keeping your confidential information safe, and so on.
E-invoicing and e-reporting video (1/2)
E-invoicing and e-reporting video (2/2)
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