Electronic invoicing in France: A pragmatic approach during the launch phase

France’s electronic invoicing reform officially entered into force on 1 September 2026. The French tax authorities have announced a pragmatic and proportionate approach for businesses that encounter technical or organisational difficulties despite making genuine efforts to comply.

The statutory timetable remains unchanged

The announced tolerance does not constitute a postponement or suspension of the reform. The following obligations have applied since 1 September 2026:

• All businesses within the scope of the reform must be able to receive electronic invoices through an approved platform.
• Large companies and intermediate-sized enterprises, known in France as entreprises de taille intermédiaire (ETIs), must issue electronic invoices and transmit the required transaction and payment data.
• Small and medium-sized businesses, micro-enterprises and sole traders will become subject to the electronic issuance and e-reporting obligations on 1 September 2027.

 

What does the tolerance policy mean in practice?

Businesses acting in good faith should not automatically be penalised during the launch phase if they encounter difficulties in implementing the new requirements.

To benefit from this approach, a business must be actively addressing the problem and following a credible path towards compliance. The French tax authorities intend to consider the actual circumstances, the steps taken by the business and the principle of proportionality.

The authorities will distinguish between:

• genuine and documented implementation difficulties,
• corrective measures that are already under way, and
• inactivity, deliberate avoidance or a lasting refusal to enter the new system.

 

The policy therefore does not provide a general exemption from the electronic invoicing requirements.

 

What happens if technical problems occur?

The approach notably covers temporary technical incidents such as:

• an approved platform being temporarily unavailable,
• invoice transmission or routing errors,
• problems involving accounting or invoicing software, and
• incidents caused by a software provider or another service provider.

 

According to the practical guidance published by the French tax authorities, business operations should continue during such incidents. An invoice sent temporarily by email, as a PDF or on paper does not become invalid solely because it has not followed the required electronic channel.

Provided that the invoice relates to a genuine transaction and contains the information required for processing, it may generally still be processed, recorded and paid. The right to deduct input VAT is not automatically lost and continues to be assessed under the ordinary substantive and formal requirements.

Where the supplier is already subject to mandatory electronic issuance, the invoice should subsequently be transmitted or regularised through the appropriate electronic channel where necessary. Businesses must take care to avoid duplicate payments, duplicate accounting entries and duplicate VAT deductions.

 

What should businesses do now?

Businesses should not interpret the tolerance policy as a reason to delay implementation. Recommended actions include:

1. Selecting an approved platform or verifying the existing connection.
2. Recording technical incidents, error messages and rejected transmissions.
3. Retaining correspondence with platforms, software providers and other service providers.
4. Moving all operationally ready invoice flows into the electronic system.
5. Restricting temporary alternative procedures to the transactions genuinely affected.
6. Correcting errors and irregular transmissions as soon as possible.
7. Preventing duplicate payments or accounting entries when an invoice is retransmitted.

 

The key consideration is whether the business can demonstrate active and continuous progress towards compliance.

 

How Fradeco can assist

The practical impact of the reform depends on factors such as the size of the business, its transactions, its existing systems and the approved platform it uses.

If you have questions about how the French electronic invoicing reform applies to your business, or if you are experiencing difficulties with its implementation, please contact us. Fradeco can help you review your situation, identify any remaining action points and determine the appropriate next steps.