The electronic invoicing calendar: what can you expect?

Introduction to the reform of electronic invoicing in France

France is undertaking a major transformation of its invoicing processes with the gradual implementation of mandatory electronic invoicing. This reform, led by the tax administration and the DGFiP, represents a fundamental change in the accounting practices of French companies. The final deployment schedule has been set and finally provides clarity on this major digital transition.

Why this reform of electronic invoicing?

Before discussing the precise timetable, let us recall that this reform has several objectives:

• Simplifying billing processes and invoice processing
• Fighting tax evasion more effectively
• Modernizing the relationship between the State and businesses
• Ensuring better traceability of commercial exchanges
• Achieve significant savings by dematerializing invoices

This transformation concerns all companies established in France, whether they are small businesses, SMEs, ETI or large companies.

The schedule for deploying electronic invoicing

The reform is based on two distinct obligations:

• E-invoicing: the obligation to issue and receive invoices in electronic form
• E-reporting: the obligation to transmit transaction data to the tax authorities

First step: receiving electronic invoices

Starting on September 1, 2026 : All businesses, regardless of size, will need to be able to receive electronic invoices. This acceptance obligation concerns all companies established in France without distinction.

Second step: the gradual issuance of electronic invoices

The obligation to issue electronic invoices will spread over time depending on the size of the companies:

Starting on September 1, 2026 : Large companies (with more than 5,000 employees) and medium-sized companies (ETI) will have to issue electronic invoices. This first level also concerns the e-reporting obligation for these same companies.

As of January 1, 2027 : Small and medium-sized enterprises (SMEs) will also be subject to the obligation to issue electronic invoices and e-reporting.

Starting in July 2027 : Very small businesses (VSEs) and micro-enterprises will in turn have to comply with these obligations.

The technical modalities of electronic invoicing

The choice of the dematerialization platform

To ensure the exchange and transmission of invoices, businesses will have two options:

1. The Public Invoicing Portal (PPF) : Developed by the State, this portal succeeds Chorus Pro and will allow businesses to manage their electronic invoices.
2. A Partner Dematerialization Platform (PDP) : Businesses may also choose to use a certified private service provider for the management and transmission of electronic invoices.

Accepted formats for electronic invoicing

The reform provides several formats to ensure the readability of the invoice and the exploitation of invoice data:

• Structured XML format
• The PDF format with embedded structured data
• Other formats will also be accepted under certain conditions

What businesses need to do to prepare

In order to respect this electronic invoicing schedule, French companies must allow sufficient preparation time:

1. Audit of the existing : Evaluate the current billing system and identify the necessary changes.
2. Choice of the solution : Decide between PPF or PDP according to the specific needs of the company.
3. Adapting the tools : Update or acquire billing software compatible with the requirements of the reform.
4. Team training : Train accounting staff in the new procedures.
5. Information for business partners : Alert customers and suppliers of these changes to facilitate the transition.

The specific obligations of e-reporting

In addition to e-invoicing, e-reporting is a complementary obligation that concerns:

• B2C (Business to Consumer) transactions
• Transactions with foreign companies not established in France
• Payment data for invoices issued

This information must be sent to the tax authorities according to the same schedule as that for the issuance of electronic invoices.

Special cases and exemptions

The reform provides for a few specific cases:

• Invoices subject to the billing rules of foreign countries
• Transactions benefiting from the VAT franchise
• Some transactions exempt from VAT

These specific situations are the subject of specific provisions that should be studied on a case-by-case basis.

The impact of delaying the reform

It is important to note that this timetable is the result of a delay in the reform originally planned for 2024-2025. This additional time should be seen as an opportunity for businesses to better prepare for this major transition.

The deferral was decided to allow:

• Better technical preparation of the Public Invoicing Portal
• Longer adjustment times for businesses, especially smaller ones
• Increased awareness of the challenges of dematerializing invoices

Penalties in case of non-compliance

The tax administration has not yet specified the regime of sanctions applicable in the event of non-compliance with electronic invoicing obligations. However, it can be expected that penalties will gradually be put in place once the adjustment periods have elapsed.

Conclusion: anticipate in order to succeed in the transition

The electronic invoicing calendar is now clearly established, with an initial deadline set for September 1, 2026. This reform represents a significant change in the management practices of French companies.

To succeed in this transition, foresight is the key word. Businesses, regardless of size, have every reason to start learning and adapting their billing processes now. Paper invoices are destined to gradually disappear in favor of a fully dematerialized system that promises, despite the initial investment, gains in efficiency and productivity in the medium term.

Electronic invoicing is not only a future legal obligation, it is also an opportunity to modernize and optimize accounting processes that can constitute a real competitive advantage for companies that will be able to adapt quickly.

To stay informed of the possible changes in this calendar and the practical methods of implementation, it is recommended to regularly consult the communications of the DGFiP and to contact accounting experts familiar with this major reform of the French tax system.

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