The reform changes how an invoice travels, not just its format.

Who must do what, and from when

The receiving obligation comes first: it applies to everyone from 2026. A subsidiary that will only issue its own invoices electronically in 2027 is therefore up a year earlier — the deadline most often discovered too late.

Electronic invoicing or “e-reporting”?

Which obligation applies depends on the business partner and the nature of the transaction. The two routes run side by side and do not overlap.

• Electronic invoicingIt covers supplies of goods and services between companies established in France and liable to French VAT, where the transaction falls under French VAT and French invoicing rules.
• “E-reporting”It covers transactions for which no electronic invoice is issued in the French B2B circuit: sales to private individuals and other non-taxable persons, certain transactions with companies established abroad, and where applicable the corresponding payment data.
• Outside the scopeCertain transactions that are VAT-exempt and also relieved of the invoicing requirement stay out — notably in healthcare, education, financial services and insurance.

“E-reporting” is not necessarily invoice by invoice: the data goes to the tax authorities through the approved platform, at the frequency applicable to the company.

Payment data

For certain services, actual receipt of payment must also be reported. That applies where VAT becomes chargeable on receipt and the company has not opted to account for VAT on invoice date, provided the transaction is not subject to the reverse charge.

The information to be reported includes the date and the amount received. Where the payment relates to an electronic invoice, this data is added through the “Encaissée” status and transmitted by the platform. The timetable follows that of “e-reporting”.

The approved platform

Issuing and receiving pass through an operator registered with the French tax authorities. The current official term is “plateforme agréée”; “plateforme de dématérialisation partenaire”, abbreviated “PDP”, was previously in common use.

• The choice is freeSupplier and customer need not use the same platform — approved platforms are interoperable. A company may also use several.
• Connection takes timeEvery company subject to the receiving obligation must be able to receive from 1 September 2026. Choice and connection are therefore decided well before the deadline.
• The software vendor has to keep upCheck with the vendor whether the invoicing solution or the ERP produces the required structured data and whether it is already connected to an approved platform.

The new mandatory particulars

The existing particulars remain. Four are added:

• the customer’s SIREN number;
• the nature of the transaction — supply of goods, supply of services, or both;
• where applicable, the reference to the option to account for VAT on invoice date;
• the full delivery address where it differs from the billing address.

The platform extracts the required data from the invoice and transmits it: in principle the issuer does not have to report the same invoice data a second time.

Rejection and refusal are two different things

The two words describe different events, and each calls for a different response.

• A rejection comes from a platformThe issuer’s or the recipient’s platform does not accept the invoice for technical or formal reasons: an inadmissible format, missing or inconsistent mandatory data, a discrepancy between net, VAT and gross amounts, a routing or identification error.
• A refusal comes from the recipientIt must be reasoned and has nothing to do with technology. As a definitive refusal it is intended above all for an invoice sent to the wrong recipient.
• A substantive dispute is neitherWhere the invoice does not match the quotation, contract, order or service delivered, the intermediate processing or dispute statuses are used. The disagreement itself is settled outside the technical circuit, under the usual contractual procedures.

After a rejection, identify the cause, correct it and transmit again electronically. Whether the invoice number can be kept or a corrective invoice with a new number is required depends on the nature of the correction: a mere transmission incident, or a change to the invoice data. A copy sent through another channel remains informational and does not replace transmission through the platform. Errors, corrections and re-transmissions should be documented traceably.

What actually decides the outcome

The technical connection is only part of the project. Five points come up again and again.

• Incomplete master dataWithout correct SIREN numbers, VAT numbers and addresses, some invoices can be neither processed nor routed.
• Incompatible softwareInvoicing software, ERP or point-of-sale systems must produce the structured data and pass it to an approved platform.
• Incorrect tax classificationCross-border transactions, reverse-charge cases, exempt transactions and sales to private individuals must be allocated correctly between electronic invoicing and “e-reporting”.
• Effect on cash flowNon-compliant invoices lead to rejections and queries, and they delay payment. The subject is therefore operational and financial as much as technical.
• Coordination within the groupWhere the ERP, a shared service centre or invoicing is centralised, the French requirements have to fit into the group’s processes.

Working together

The review in four steps.

1. 1Establish the scopeWhich companies, establishments, VAT registrations and transactions are affected? This is also where the question of a fixed establishment for VAT is settled.
2. 2Examine data and systemsAre SIREN numbers, VAT data, transaction categories, tax codes and invoice lines available and complete?
3. 3Align platform and interfacesHow will the ERP, the accounts, invoicing and the approved platform be connected?
4. 4Implement and testHow will invoice statuses, rejections, refusals, corrections, “e-reporting” and responsibilities be handled from now on?

Choosing the software and the platform is naturally yours. Where both touch the accounts and VAT, we supply what makes the decision easy: what the format has to produce, what the platform has to be able to do, and what needs to be ready before connection.

The deadline that counts first: the ability to receive, on 1 September 2026. It applies regardless of company size, and the lead times that matter are those of software vendors and platforms, not those of the tax authorities.