2026, the year of E-Invoicing

Initially scheduled to take effect from July 1, 2024, the implementation of the reform making electronic invoicing mandatory has been postponed to 2026. This beginning of the year is a good opportunity to review the key points.

What are the obligations?

The reform actually covers two main aspects. First, the obligation to adopt electronic invoicing (referred to as “e-invoicing”) for sales of goods and/or provision of services carried out between VAT-registered professionals in France. Then, additionally, the obligation for electronic reporting (referred to as “e-reporting”) for transactions involving entities not subject to VAT or with operators established abroad.

Who is affected?

The obligation for electronic invoicing and e-reporting applies to all businesses, individuals, or legal entities, subject to VAT and established in France (including sole proprietors).

Clarification: Businesses carrying out certain VAT-exempt transactions (notably in the healthcare sector) will not be required to issue electronic invoices, nor to perform e-reporting, but they will need to be able to receive electronic invoices.

What is the timeline?

The timeline unfolds in two stages:
First stage: all businesses must be capable of receiving electronic invoices starting September 1, 2026.
Second stage: businesses must issue electronic invoices and perform e-reporting starting September 1, 2026 for mid-sized and large enterprises, then starting September 1, 2027 for micro-enterprises and SMEs (< 250 employees and annual turnover < €50M or total balance sheet < €43M).

How does it work?

To receive or issue an electronic invoice or to perform e-reporting, businesses must go through a certified platform (PA(1)), which they must choose. This private operator guarantees the transmission of invoices and the communication of data to the tax authorities.

Important note: an electronic invoice is not just a simple PDF! It is a structured electronic file that allows for automated analysis of its content. It must therefore be issued in a format authorized by law (UBL, CII, or a mixed format).

(1) Plate-forme Agréée (PA)