Foreign founders often approach the French electronic-invoicing reform as if ownership were the decisive test. It is not. The practical questions are different: is the business established in France for VAT purposes, is it a French subsidiary or only a branch, who is the customer, where is the transaction located, and what is the size category of the issuing business? These distinctions determine whether the company must issue an electronic invoice, transmit transaction data through e-reporting, report payment data, or merely be ready to receive an electronic invoice.

The first operational date is 1 September 2026. Every VAT-taxable business must be able to receive electronic invoices through an approved platform, while large companies and enterprises of intermediate size must also issue them. Small and medium-sized enterprises and micro-businesses generally move to mandatory electronic issuance on 1 September 2027. A foreign business without a fixed establishment in France follows a different route: it is generally outside French e-invoicing, but may still have French e-reporting obligations when it is liable for French VAT.

This guide gives a foreign founder a decision path, the legal texts behind it, a platform and data checklist, and a response plan for a refusal or a missed deadline. It also separates the French subsidiary, the French branch and the foreign company selling into France. The official French terms are explained as they appear: INPI is the National Institute of Industrial Property, the Kbis is the official extract identifying a company in the Trade and Companies Register, and the greffe is the registry office that processes corporate filings.

I. What does French e-invoicing change for a foreign-owned company in France?

A. Which company and invoice are actually covered from 1 September 2026?

The starting point is not the nationality of the shareholder. It is the VAT and establishment profile of the entity issuing or receiving the invoice. A French SAS or SARL remains a French taxable business even if its parent company is incorporated in the United States, the United Kingdom, the United Arab Emirates or Singapore. The same is true of a French subsidiary owned 100% by a foreign company. A Kbis identifies the legal entity and its registration, but the VAT analysis also looks at the place where the economic activity is established and the nature of the transaction.

Article 289 of the French General Tax Code states: “Tout assujetti est tenu de s’assurer qu’une facture est émise”. In English, every taxable person must ensure that an invoice is issued for the transactions covered by the provision. That obligation does not disappear because the finance team is abroad, because the invoice is prepared in English, or because the parent company controls the accounting software.

For domestic business-to-business operations, the central rule is Article 289 bis of the French General Tax Code. It provides that “L’émission, la transmission et la réception des factures électroniques s’effectuent en recourant à une plateforme agréée.” A plateforme agréée, or PA, is an approved platform registered by the French tax administration. Older French material may call the same type of operator a PDP, meaning a partner dematerialisation platform. The terminology changed; the need to use an approved operator did not.

A PDF attached to an email is not automatically an electronic invoice under this new channel. A compliant electronic invoice contains structured data that can be processed and transmitted through the approved platform. A compatible solution may continue to generate invoices, but it must connect to an approved platform or itself hold that status. The company therefore needs to distinguish three things:

• the accounting or billing software: the tool used by the finance team to prepare the invoice;
• the compatible solution: the technical layer that connects the tool to the approved platform; and
• the approved platform: the operator responsible for receiving, transmitting and, where required, reporting data to the administration.

From 1 September 2026, all VAT-taxable businesses must be able to receive electronic invoices. The issuance timetable depends on the size of the issuer. Large companies and ETIs, meaning enterprises of intermediate size, must issue electronic invoices from 1 September 2026. PME means small or medium-sized enterprise, TPE means very small enterprise, and micro-entreprise means a micro-business. Those businesses generally have until 1 September 2027 to issue electronic invoices. The company must still be able to receive them in 2026, regardless of whether its own outgoing invoices remain outside the issuance phase until 2027.

The size test is not a label chosen by the founder. The French tax administration explains that the relevant assessment uses the last financial year closed before 1 January 2025, or the first financial year closed from that date if there is no earlier year. A foreign group must therefore identify the size of the French taxable entity and the rule applicable to the relevant issuer, then retain the calculation supporting that conclusion.

The distinction between B2B and B2C also matters. B2B means business-to-business; B2C means business-to-consumer. French e-invoicing primarily concerns transactions between VAT-taxable businesses established in France for which French invoicing rules apply. Sales to consumers, sales to foreign business customers, and other transactions outside the domestic e-invoicing perimeter may instead trigger e-reporting. The correct answer cannot be obtained by searching only for the word “foreign” in the customer file.

There is a second legal boundary. Article 289-0 of the French General Tax Code provides that French invoicing rules apply to certain transactions located in France, but also contains an exception where a business established in another Member State supplies a French customer that is liable for the tax. The provision must be read with the place-of-supply and reverse-charge rules. A foreign founder should therefore ask the accountant to document why each important invoice falls within e-invoicing, e-reporting or neither channel.

Foreign ownership can still affect the practical file. The platform may ask for the Kbis, SIREN number, SIRET number, VAT identification number, registered office evidence, beneficial-owner information and proof of authority for the person onboarding the business. SIREN is the nine-digit national company identifier; SIRET adds the five-digit establishment identifier. These are administrative identifiers, not substitutes for a VAT qualification. A French branch has a French establishment identifier but does not become a separate company. A French subsidiary has its own legal personality, accounts and VAT profile.

B. When must a French subsidiary, branch or foreign company report transactions?

The cleanest way to avoid a filing error is to classify the three common structures separately.

First, the French subsidiary. The subsidiary is a French legal entity. Its domestic B2B sales to another French VAT-taxable business normally enter the e-invoicing channel. Its sales to French consumers or foreign customers may enter e-reporting, depending on the transaction and VAT rules. Its purchases from a French supplier must be receivable through the approved platform from 1 September 2026. An English-speaking parent does not change this domestic status. The subsidiary should appoint one person in France or one authorised external adviser to own the platform account and monitor failed invoices.

Second, the French branch. A branch, or succursale, is not a new company. It is an establishment of the foreign company recorded in France. The foreign company must map which invoices are issued by the branch, which transactions are booked to the French establishment, and whether the branch is the establishment from which the supply is made. The French tax profile may pull the branch into the e-invoicing or e-reporting rules even though the legal contracting party is the overseas company. The branch should not simply use the parent company’s foreign address and foreign VAT number on every invoice without testing the French establishment data.

Third, the foreign company without a fixed establishment in France. The French tax administration states that the e-invoicing obligation for an overseas company without a fixed establishment in France does not normally cover the company’s reception and issuance of French e-invoices. That does not mean that no French reporting exists. Where the overseas company carries out transactions treated as located in France and is liable for French VAT, it may have to transmit transaction data, and in some cases payment data, through a platform approved for the French system.

Article 290 of the French General Tax Code provides that taxable persons established or habitually resident in France communicate data electronically to the administration for categories of operations that are outside ordinary domestic e-invoicing. The text covers, among other situations, certain supplies to foreign taxable customers, exports and services whose place of taxation is outside France. It is not a general permission to ignore reporting. It is a classification rule.

The 2026 reform adds a separate data channel. Under Article 289 E of the French General Tax Code, “Les données des factures électroniques émises en application du I de l’article 289 bis sont transmises à l’administration par la plateforme agréée choisie par l’assujetti.” The approved platform is therefore part of the information chain. The company must verify what the platform sends automatically, what the company must validate, and which fields are sent periodically rather than with each invoice.

Payment e-reporting is a further layer. Article 290 A of the French General Tax Code states: “Les données relatives au paiement des opérations … sont communiquées à l’administration sous forme électronique”. The rule concerns operations for which VAT becomes due when payment is collected, subject to the statutory exceptions. A service company that reports the invoice but does not transmit the required payment status can remain non-compliant. The finance team should therefore identify whether VAT is due on invoice or on collection, whether reverse charge applies, and who will update the paid or unpaid status.

The official timeline is easier to apply as a matrix:

• French subsidiary or French establishment, 1 September 2026: receive domestic electronic invoices; issue them if the issuer is a large company or ETI; report the relevant transactions according to the applicable phase;
• French subsidiary or French establishment, 1 September 2027: PME, TPE and micro-businesses must generally issue domestic electronic invoices and transmit the corresponding data;
• foreign company without a fixed establishment, 1 September 2026: a large company or ETI selling or providing services in France may enter e-reporting as an issuer when French VAT is due;
• foreign company without a fixed establishment, 1 September 2027: a PME, TPE or micro-business selling or providing services in France may enter the e-reporting phase; and
• payment data: assess separately, especially for services, collection-based VAT and transactions that are not subject to reverse charge.

This classification is particularly important after a group creates a French company. A parent may believe that every invoice can be issued from the parent because the parent owns the brand and signs the commercial contract. The French subsidiary may nevertheless be the entity selling to the French customer and collecting the price. Conversely, a parent with no French establishment may have an e-reporting obligation without being required to send a domestic electronic invoice. The commercial agreement, purchase order, delivery evidence, VAT treatment and ledger entry should tell the same story.

The recent case law reinforces the need for a factual file. In Cass. crim., 20 April 2005, no. 04-84.934, the record described that “à partir du 1er janvier 1998, la société Arand LTD s’est fait représenter fiscalement en France, en matière de TVA”. The foreign company was still examined through its French VAT activity. The Court also referred to the company’s Paris commercial activity, invoicing and records when reviewing the tax investigation. The lesson for a founder is practical: appointing a representative or outsourcing accounting does not remove the need to preserve evidence of where the activity occurred and how the VAT treatment was chosen.

In Cass. crim., 20 December 2017, no. 16-85.029, the Court examined alleged false intra-Community deliveries. The decision records that “les factures émises par CCO ne mentionnaient aucune adresse de livraison, empêchant ainsi tout contrôle de l’administration”. The case is not a decision about the 2026 platform reform, but it illustrates why a foreign group should not treat delivery data, customer location and supporting transport documents as optional fields. A badly classified cross-border invoice can create a VAT dispute long before a technical platform error appears.

II. How should a foreign founder prepare and what happens after a refusal?

A. Which platform, Kbis data and invoice fields must be ready?

The preparation should begin with an entity-and-transaction map, not with a software demonstration. List every French company, branch and foreign company that invoices or receives invoices connected with France. For each entity, record its legal form, SIREN, SIRET, Kbis date, VAT number, VAT regime, registered office, establishments, size category, customer profile and expected invoicing date. The Kbis is the official company extract; it is not the invoice and it does not prove by itself that every transaction is subject to French VAT. The INPI is the National Institute of Industrial Property, and the Guichet unique operated through the French formalities system is the online route used for many corporate filings. Neither replaces the VAT analysis.

The second step is choosing a platform. The French tax administration’s platform page explains that an approved platform handles the electronic-invoice and e-reporting functions. Use the official list rather than relying on a vendor’s marketing label. Before signing, obtain written answers to at least these questions:

• Can the platform onboard a company whose ultimate shareholder and finance team are outside France?
• Can it manage a French subsidiary, a branch of a foreign company and an entity without a French establishment under separate VAT profiles?
• Can it route invoices through the central directory using the correct SIREN, SIRET, VAT number and billing address?
• Can it transmit transaction and payment data for invoices outside domestic B2B e-invoicing?
• Does it preserve rejected messages, delivery status, corrections, credit notes and an audit trail that can be exported?
• Can the business change platform without losing access to historic routing and proof of transmission?

The approved-platform rules are not merely technical. Article 290 B of the French General Tax Code describes platforms that transmit invoices and data to the administration and receive an identification number for a renewable period. The relevant operational wording is that the approved platform is the one “qui assure la transmission des factures électroniques ainsi que la transmission à l’administration des données”. The founder should keep the platform’s approval status, contract, onboarding confirmation and change log in the corporate compliance file.

The central directory is also significant. Article 242 nonies H of Annex II to the French General Tax Code states: “Sont enregistrés dans l’annuaire central” the taxable persons subject to the electronic-invoicing rules, public entities and approved platforms. The directory uses identifiers and routing data. A foreign parent should not assume that an overseas email address is enough. The French entity’s legal name, SIREN, establishment information, line-of-business or routing code and chosen platform must match across the Kbis, tax records, accounting system and directory.

Changes must be controlled. If the company moves its registered office, changes its director, opens a new establishment or changes its VAT registration, the Kbis and the platform directory may not update at the same time. The greffe is the registry office that processes or records certain company changes; the INPI formalities system is the filing route; the approved platform handles invoice routing. These are three separate actors. A filing to the greffe does not automatically prove that the platform has corrected its routing record.

The invoice content remains important. Article 242 nonies A of Annex II to the French General Tax Code lists mandatory information, including “Le nom complet, le numéro d’identification … et l’adresse de l’assujetti et de son client”. It also covers the invoice date, a unique chronological number, the goods or services, the taxable amount and VAT rate, exemptions and the “Autoliquidation” mention where the customer is liable for the tax. The company can issue an English-language commercial invoice, but the structured data must still carry the French legal fields and the correct French VAT logic.

Article L441-9 of the French Commercial Code adds the commercial-law requirement that “Tout achat de produits ou toute prestation de service pour une activité professionnelle fait l’objet d’une facturation.” It requires parties, addresses, transaction date, quantity, description, price, payment date, late-payment terms and the recovery indemnity. The 2026 platform reform does not abolish the commercial invoice. It changes the channel and the data flows.

A foreign finance team should therefore test at least four sample invoices before going live:

• a French subsidiary invoicing a French VAT-taxable customer;
• a French subsidiary invoicing its foreign parent for a service, with the place-of-supply and reverse-charge analysis;
• a foreign company without a French establishment invoicing a French customer where French VAT is due; and
• a French company selling to a consumer or a foreign business customer, where e-reporting may replace domestic e-invoicing.

For each sample, keep the contract, order, delivery or service evidence, VAT analysis, invoice, credit note if any, platform acknowledgment and payment status. If a group uses an EDI, meaning electronic data interchange, or PEPPOL, the connection must still be mapped to the French approved-platform route. A software integration that works in the parent company’s country is not proof that the French platform obligations are satisfied.

Do not confuse invoicing with other French reporting bodies. URSSAF is the network that collects social-security contributions; it does not replace the approved invoice platform. BODACC is the Bulletin officiel des annonces civiles et commerciales, the official bulletin for certain corporate and commercial notices; it is not the central invoice directory. A foreign founder can have a valid URSSAF payroll account and a published BODACC notice while still having an incomplete e-invoicing setup.

For the broader formation file, a founder can also consult the firm’s French company formation and corporate-law page. The e-invoicing project should be connected to that formation work: the registered office, legal representative, establishment identifiers, VAT registration and bank-account documentation must remain consistent. The firm’s existing guides on VAT registration for a foreign company and the French corporate compliance calendar are useful companion steps, but they do not replace the invoice classification performed for each flow.

B. What should the company do if a platform rejects, a customer refuses, or a deadline is missed?

A failed invoice is not a reason to create a second invoice with a different number and hope that the first record disappears. The company should first identify the failure layer:

• identity failure: the legal name, SIREN, SIRET, VAT number, branch identifier or address does not match the central directory;
• routing failure: the customer has no active platform address, has changed platform, or has not completed the formal designation process;
• data failure: the invoice lacks a mandatory field, contains a wrong VAT rate, uses the wrong exemption code or omits an auto-liquidation reference;
• scope failure: the company selected e-invoicing although the transaction requires e-reporting, or selected e-reporting although the domestic B2B rules apply; and
• payment failure: the invoice is accepted but the payment status is not transmitted when collection-based VAT makes payment reporting relevant.

Preserve the technical acknowledgment, error code, timestamp, original payload, corrected payload and correspondence with the customer. This evidence matters when the finance team later needs to show that it acted quickly, that the transaction was genuine and that a credit note or replacement invoice was linked to the original. A French business should not use a new number to conceal a rejected invoice. The correction must remain traceable.

The statutory penalty provision is precise. Article 1737 of the French General Tax Code states that non-compliance with the electronic-issuance obligation may trigger “une amende de 50 € par facture”, subject to the annual cap set by the text. The same article addresses omissions or inaccuracies in invoices and continued failure to use an approved platform for reception after formal notices. The provision also contains a first-offence repair mechanism under conditions stated in the article. The company should not assume that the first problem is automatically forgiven; it should document the repair and the date on which it occurred.

Commercial sanctions remain relevant as well. Article L441-9 of the Commercial Code provides for administrative fines for failures in mandatory invoicing. The amount can be substantial for a legal person and can increase in the event of repetition. The correct response to a refusal is therefore not only technical. It may require a written request to the customer, a corrected invoice, a credit note, a review of payment terms and a decision on whether the transaction was incorrectly classified from the outset.

When the customer says that a PDF is enough, ask whether the transaction is actually within French domestic B2B e-invoicing. If it is, check whether the customer has appointed an approved platform, whether its routing data is active and whether the issue is on the sender’s or recipient’s side. If the transaction is outside the e-invoicing channel, record why it belongs to e-reporting or ordinary invoicing. A customer preference cannot override a legal classification, but a company should not force a domestic e-invoice onto a transaction that the rules exclude.

When the approved platform rejects a foreign group because the legal representative is abroad, request the exact document requirement and distinguish corporate authority from tax status. The platform may need a signed mandate, an identification document, a Kbis, an extract from the parent register, an apostille or a translation for its customer due-diligence file. That does not necessarily mean that a French director must be appointed. The company should answer with a document index and a clear chain of authority rather than sending unlabelled files.

When the company’s Kbis has changed, compare three versions of the data: the public Kbis, the tax account and the approved-platform directory. A director change filed with the INPI or the greffe may require a separate platform update. A registered-office change may change the SIRET of an establishment. A branch may need the parent company’s current certificate and a French establishment extract. If the platform cannot correct the directory, retain the support ticket, contact the tax administration’s designated channel and consider a written legal response before the first deadline expires.

When a company discovers a missed reporting deadline, it should calculate the scope of the error rather than backdating a file. Identify the invoices, customers, VAT rates, dates, payment status and platform messages. Submit the data through the proper channel as soon as possible, make a written record of the correction and ask the accountant to assess the consequences for VAT returns and accounts. A director or parent company should also verify whether the error affected several group entities. The internal review should include a sample of invoices issued by the French subsidiary, branch and foreign parent, not just the invoice that triggered the problem.

The Court of Cassation’s approach to tax evidence is a useful warning. In Cass. crim., 20 December 2017, no. 16-85.029, it held that a criminal court could rely on factual findings made by tax inspectors when those findings were accurately assessed and debated. The decision states that the judges may draw on “les constatations de fait relevées par les vérificateurs fiscaux, et contradictoirement débattus devant lui”. This is not a rule that every platform error becomes a criminal case. It is a reminder that invoices, transport proof, contracts and accounting entries must tell a coherent story that can withstand a later review.

For a foreign founder, the action list before the relevant deadline is short but concrete:

1. confirm whether the issuer is a French subsidiary, a French establishment or a foreign company without a fixed establishment;
2. classify domestic B2B, consumer, foreign-customer, export, intra-Community and reverse-charge flows;
3. record the applicable issuance and e-reporting date for each entity and size category;
4. choose an approved platform from the official administration list and obtain written onboarding confirmation;
5. reconcile Kbis, SIREN, SIRET, VAT and central-directory data;
6. test English-language invoices with French mandatory data and the correct VAT treatment;
7. test credit notes, payment status, rejection messages and platform changes;
8. appoint a person responsible for monitoring failed invoices every business day during launch;
9. preserve the legal, technical and accounting evidence; and
10. escalate a refusal or missed deadline with a documented correction plan.

The decisive question is not whether the founder lives abroad or whether the parent company has a foreign bank account. The decisive question is which entity performs which transaction, where the transaction is taxed, and whether the French system requires an electronic invoice or a data report. That answer should be written down before the platform is configured.

Conclusion

French e-invoicing is an entity-and-transaction project for a foreign-owned group. A French subsidiary must prepare to receive domestic electronic invoices from 1 September 2026 and must issue them according to its size category. A French branch needs a separate mapping of the foreign company’s French establishment and invoice flows. A foreign company without a fixed establishment is generally outside domestic e-invoicing but may still owe French e-reporting when it is liable for French VAT. Payment reporting must be assessed separately.

The safe preparation file combines the Kbis, SIREN and SIRET data, VAT analysis, customer classification, platform approval, central-directory routing and proof of transmission. It also keeps the original invoice, correction, credit note and payment evidence together. If the platform refuses a document, a customer rejects the invoice or the company misses a deadline, preserve the technical reason, correct the underlying data and create a traceable response. A foreign founder who makes these distinctions early can integrate the French compliance calendar into the group’s existing finance process without treating a French invoice as a mere translation of a foreign template.

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