France is replacing a large part of its paper and PDF invoicing process with structured electronic invoicing and transaction reporting. For a foreign founder, the difficult question is rarely whether the group uses an international accounting platform. The real question is which French legal entity or foreign company is responsible for which flow, at which date, through which accredited platform, and with what evidence. A French subsidiary and a French branch are not treated in exactly the same way as a foreign company with no French establishment. A domestic business-to-business invoice is not the same flow as a sale to a private consumer or an invoice to a customer outside France. The answer also changes according to the size of the French taxpayer and whether French value added tax (VAT) is collected by the supplier or accounted for by the customer under reverse charge. This guide gives foreign-owned companies a working legal map for the 1 September 2026 milestone. It explains the difference between e-invoicing and e-reporting, the role of a plateforme agréée (PA, an accredited private platform), the data and contracts to prepare, and the evidence to preserve if a customer, platform or tax authority disputes a transaction.

I. Does French e-invoicing apply to a foreign-owned business?

A. When must a French subsidiary or branch receive and issue e-invoices?

Ownership does not decide the scope of the reform. A French subsidiary owned by a United States, United Kingdom, Swiss, UAE or other foreign parent remains a French-established taxable person when the subsidiary is established, domiciled or resident in France for the relevant VAT rules. The same practical question arises for a branch that has a French establishment and carries on transactions through it. The starting point is therefore the establishment and the transaction, not the nationality of the shareholders or directors.

The central rule is in Article 289 bis of the French General Tax Code (Code général des impôts, or CGI). It governs the electronic transmission of invoices between taxable persons established in France and requires the exchange to use an accredited platform. In practical language, a French subsidiary that invoices another French VAT-registered business for a transaction within the domestic business-to-business scope must be able to receive and, when its issue date arrives, send a compliant structured invoice. A PDF attached to an email can remain a useful visual copy, but it is not the same thing as the structured electronic flow required by the reform.

The calendar has two separate obligations. All businesses in scope must be able to receive electronic invoices from 1 September 2026. For the obligation to issue domestic business-to-business electronic invoices, large companies and companies in the intermediate-size category enter the first wave on 1 September 2026. Small and medium-sized companies and micro-enterprises enter the issue obligation on 1 September 2027 for the relevant domestic flows. A foreign-owned French company should not read “2027” as permission to postpone the project. A small subsidiary still needs a receiving capability in 2026, and its international or consumer flows may create separate e-reporting obligations.

The official preparation guidance from Service-Public.fr separates the receiving date from the issuing date and explains that the answer depends on company size and transaction type. The French tax authority’s business guidance uses the same practical questions: the size of the company, the type of customer, and whether the activity is subject to French VAT. A group should record the legal entity, its French VAT number, its size category and its flow classification in one compliance table. That table is more reliable than asking an overseas software provider whether it is “ready for France”.

For this purpose, “domestic business-to-business” means a transaction that falls within the French electronic invoicing rules and is between taxable persons identified for French VAT purposes. The invoice may still be denominated in dollars, pounds or another currency. The currency does not remove the French obligation. The invoice must also carry the mandatory information required by the tax rules. Article 242 nonies A of Annex II to the CGI sets out the mandatory invoice information, while Article 41 septies D of Annex IV to the CGI specifies important data fields for electronic invoices from the first phase.

Some French words appearing in onboarding requests are not decorative. A Kbis is the official extract showing the registration of a commercial company in the French trade and companies register; the greffe is the court registry office that administers the relevant commercial register formalities. The SIREN is the nine-digit national identifier of a French legal entity, while the SIRET identifies a particular establishment. A PA or plateforme agréée is a private platform approved by the French administration to route invoices and transmit the required data. It is the new official term for what was commonly called a plateforme de dématérialisation partenaire (PDP). An ordinary accounting application or an operator of dematerialisation may connect to a PA, but it does not automatically become the legally responsible PA.

The establishment analysis also matters where the French company is part of a cross-border group. An invoice from the French subsidiary to its foreign parent is not automatically a domestic French e-invoice merely because both companies belong to the same group. The place of supply, the VAT treatment and the customer’s identification must be recorded. Conversely, an invoice from the foreign parent to the French subsidiary may be an international transaction whose French VAT is accounted for by the recipient. The group should not force every intercompany invoice into the domestic e-invoice route without first classifying the transaction. The safer design is to document why each flow is domestic e-invoicing, international e-reporting, consumer reporting, reverse charge or outside the French VAT scope.

A French branch also needs a sharper review than a subsidiary. The branch may have a French establishment, a French VAT registration and operational staff while the legal counterparty remains the foreign company. The billing identity, SIREN or foreign identifier, VAT number, bank details and authority to issue a credit note must all line up. The accounting system may use the parent’s global customer master, but the French PA will need data that identifies the transaction under French rules. A mismatch between the legal seller, the French establishment and the invoice sender can create a rejected message, a reconciliation failure or a dispute over who owes the VAT.

Foreign directors should also separate the invoicing reform from other registrations. A company may have a Kbis but still need to confirm its VAT status, its establishment details and its PA connection. A registration with INPI’s French one-stop shop for business formalities is not itself a substitute for a VAT or invoicing analysis. Likewise, an employer’s registration with URSSAF, the French network collecting social-security contributions, does not decide whether an invoice is an e-invoice. The documents belong to the same corporate file, but they prove different things.

B. When must a foreign company without a French establishment use e-reporting?

A foreign company that has no French establishment is not simply placed in the same box as a French subsidiary. The French tax authority’s English guidance for foreign companies without a permanent establishment in France explains the distinction: e-invoicing generally concerns transactions between taxable persons established in France, while e-reporting can apply to transactions carried out in France by a foreign business. The French page on e-reporting for foreign companies without a French establishment is the operational reference for the cross-border cases.

The phrase “without a permanent establishment” must not be treated as a shortcut. A tax permanent establishment, a VAT fixed establishment, a warehouse, a local agent and a branch can produce different consequences. The company should establish facts: who contracts with the customer, where goods are dispatched, where services are performed, who holds stock, who has authority to bind the business, which French VAT number is used and whether the customer has a French VAT number. A company that merely sells remotely into France may be in a different position from a company operating through a staffed French office. The corporate group should obtain a written classification rather than rely on a sales team’s description of the arrangement.

The relevant statutory framework includes Article 290 of the CGI, which covers the electronic transmission of transaction data for certain transactions located in France carried out by persons not established in France, and Article 290 A of the CGI, which covers payment data for operations where the VAT becomes due when payment is collected. These provisions are why “we do not have a French company” does not always mean “we have no French digital reporting obligation”. A foreign seller can have to report data about a French transaction even where the formal invoice is sent under the foreign company’s name.

The French tax authority’s guidance identifies several recurring patterns:

Flow	Typical French question	Possible digital obligation
French subsidiary or French establishment to a French business	Is the transaction within the domestic VAT invoicing scope?	Receive or issue an e-invoice according to the company-size calendar.
Foreign company with no French establishment to a French business	Who accounts for French VAT, and does the customer have a French VAT number?	E-reporting may be due; the French recipient may report a reverse-charge transaction.
Foreign company to a French private consumer	Is French VAT due and is the transaction a consumer sale?	Transaction and, where relevant, payment e-reporting may apply.
French company to a customer outside France	Is the operation international rather than domestic B2B?	It is normally analysed as e-reporting rather than a domestic e-invoice.

This table is a starting point, not a substitute for the place-of-supply rules. In particular, the foreign seller’s responsibility can depend on whether the French customer is identified for VAT. The tax authority explains that where the foreign seller is liable for French VAT because the customer is not identified in France, the foreign seller may have a reporting responsibility. Where the French customer is identified and accounts for VAT under reverse charge, the customer may carry the relevant reporting responsibility. That allocation must be reflected in the tax code, the invoice wording and the PA configuration.

Payment reporting adds another layer. It can concern transactions for which VAT is due on collection rather than on the invoice date. A foreign-owned group should therefore map the payment event, not merely the invoice event. The data owner may sit in a treasury system outside France, while the French tax obligation sits with the French entity or the relevant foreign seller. A monthly spreadsheet sent to the French finance team is not an adequate control if it cannot preserve the source, the date, the payment status and the link to the original invoice.

Do not confuse e-reporting with sending every invoice as a French e-invoice. E-reporting is the transmission of prescribed transaction or payment data to the French administration through the PA route. A foreign invoice may remain in the company’s ordinary commercial format for the customer while the required data is reported in a structured form. That distinction should be explained to the parent company’s ERP team. Otherwise, the team may either over-engineer the foreign sales process or fail to report a French VAT transaction because no French-format PDF was required.

The timing should be confirmed against the company’s size and the date category applicable to its operation. The official Service-Public guidance states that foreign or international transactions and transactions with private consumers are routed through the e-reporting framework, and that the first and second waves differ according to the business category. A foreign company should select and validate its PA before the relevant 2026 or 2027 date, even if the legal conclusion is that it will transmit data rather than issue domestic e-invoices. Early PA selection is also useful because a PA needs time to test identifiers, exchange formats, tax codes, error messages and the division of duties between the parent and the French team.

Finally, remember that the French company register creates public corporate information. The BODACC, the French Official Bulletin of Civil and Commercial Announcements, can publish certain corporate and insolvency notices. BODACC visibility does not create an e-reporting duty, just as the presence of a Kbis does not prove that every VAT flow is domestic. These terms matter because a foreign legal department often receives a single “French registration” pack containing corporate, tax, employment and invoicing documents. Each document should be tied to the obligation it actually proves.

II. How should a foreign-owned company become compliant by the deadline?

A. Which platform, data and contracts must be prepared?

The first decision is not “which software has the best dashboard?” It is “which legal entity and which transaction stream will use which route?” Build a flow register for at least one complete VAT period. For every invoice or payment, record the seller, customer, establishment, customer status, country, VAT number, transaction category, tax rate, reverse-charge treatment, payment date and expected reporting route. Include credit notes, deposits, advances, self-billing, marketplace sales, intercompany charges, reimbursements and invoices issued by a foreign shared-service centre. The register should also name the system of record and the person responsible for correcting a rejected message.

Next, choose the accredited platform. The French tax authority explains the role of approved platforms: a PA is the official intermediary that can receive and transmit electronic invoices and the required data. A general accounting package may connect through an operator, but the company must identify the PA that appears in its compliance design. Ask each provider for its French accreditation status, the supported structured formats, the treatment of foreign VAT numbers, the handling of multilingual invoices, the correction process, the retention period, the location of backups, service levels, exit assistance and the audit export.

Do not assume that the French public invoicing portal, often called the PPF (portail public de facturation), is still the default route for every private company. The official framework has moved toward accredited private platforms for the operational exchange and reporting functions. A provider that describes itself only as an “OD”, meaning an opérateur de dématérialisation or dematerialisation operator, may be a useful technical connector but is not necessarily the PA. The contract must say who receives the invoice, who validates the syntax, who transmits data, who reports a technical failure and who supplies evidence of transmission.

The technical data model must be reviewed with the tax and legal teams. Article 289 E of the CGI addresses transmission of invoice data by the chosen platform. Article 242 nonies L of Annex II to the CGI provides for the transmission of invoice data within the prescribed time after the invoice is deposited, including the first-phase effective dates. The group should test at least the following fields:

• the legal name, address, SIREN or permitted foreign identifier, and VAT identification number of each party;
• the French establishment and delivery information where the flow depends on a branch or fixed establishment;
• the unique invoice number, issue date, due date, currency, taxable amount, VAT amount and total amount;
• the category of transaction, including goods, services, mixed supplies, export, intra-Community supply, import or reverse charge;
• the payment terms, collection date where relevant, deposits, instalments, credit notes and cancellation links;
• the customer’s status as business or consumer and the country of the transaction;
• the identifier of the originating system, the PA receipt reference, rejection code, correction history and delivery evidence.

Article 41 septies D is especially important for implementation testing. The data fields include information such as the SIREN, VAT identifiers, countries, transaction category, date, unique number, taxable amount, VAT and currency. The exact fields evolve between the first and later stages of the reform. A foreign parent should ask the PA to demonstrate how a foreign company without a SIREN is represented, how a French branch is linked to the foreign legal entity, and how a reverse-charge line is transmitted. A screen showing a PDF is not a sufficient test result. Request the structured payload, the acknowledgement, the rejection logic and a machine-readable audit extract.

The contract with the PA should also address business continuity. Identify what happens if the PA is unavailable on the invoice date, if a receiving customer rejects the file, if a tax code is mapped incorrectly, or if a French entity changes its registered office. Require notification deadlines, access to logs, a right to obtain the company’s data in a usable format, support for regulatory changes and an orderly transfer procedure. The contract should not leave the parent company unable to prove a submission because the PA’s portal shows only a green status icon.

Prepare the corporate identity pack at the same time. The French subsidiary should keep its current Kbis, RNE registration information, VAT certificate, bank details and authorised signatory matrix. A foreign branch should retain its foreign incorporation document, French registration evidence, power of attorney and branch identifiers. The Kbis is a registry extract, not a tax ruling, and the RNE is the national business register information administered through the formalities system. Where documents are supplied by a foreign parent, agree which version is authoritative and how translations are approved. This prevents a legal-name mismatch from becoming a platform rejection.

Connect the invoicing project to the company’s other calendars. The French legal calendar may include VAT returns, corporate tax payments, annual accounts, beneficial-owner updates and social-security filings. A company that is already tracking its filing dates in a French company legal calendar should add PA onboarding, access reviews, test invoices and rejection monitoring rather than maintain a separate unowned spreadsheet. The first French employee may also trigger payroll and URSSAF tasks, but those employment reports should not be confused with e-reporting for VAT transactions.

Foreign founders should also coordinate the invoicing and VAT workstreams. A French VAT registration question can determine which flow is reported, who is liable for the tax and which identifier appears in the message. The VAT number should be validated for the relevant entity and transaction, not copied from the parent company’s global master data. If a fiscal representative is required for a non-EU business in a particular situation, the representative’s role and authority must be documented separately from the PA’s technical role.

For a practical deadline plan, complete four exercises:

1. classify every material flow by entity, establishment, customer and VAT treatment;
2. select the PA and sign the data-processing, service-level and evidence provisions;
3. test receiving, issuing, credit notes, reverse charge, foreign identifiers, payment data and corrections;
4. approve a written operating procedure naming the person who monitors errors and the person who can correct a tax classification.

Run the tests with real-looking but controlled data. Include an English-language invoice, a euro invoice issued by a foreign system, a French business customer, a foreign business customer, a French consumer sale, a credit note and an invoice paid after several instalments. Check that the French accounting ledger, the PA message, the VAT return and the group consolidation record describe the same event. If the parent’s system cannot preserve the French structured data, make the PA or a controlled French system the retention point rather than relying on screenshots.

B. What proof, sanctions and remedies apply when an invoice fails?

Electronic transmission does not eliminate the need to prove the underlying transaction. The company must be able to show what was sold, to whom, when, at what price, under which VAT treatment, and whether the goods or services were delivered. This is particularly important for a foreign group where the commercial contract, order, delivery record, invoice and payment may sit in different countries.

The general burden of proof is stated in Article 1353 of the French Civil Code: Celui qui réclame l’exécution d’une obligation doit la prouver. Réciproquement, celui qui se prétend libéré doit justifier le paiement ou le fait qui a produit l’extinction de son obligation. In English, the party demanding performance must prove the obligation, and the party claiming release must prove payment or the event that extinguished the obligation. A PA acknowledgement proves a transmission event; it does not by itself prove delivery of consulting work or receipt of goods.

Article 1366 of the Civil Code recognises electronic writing when the author can be identified and the document is created and retained in conditions that preserve its integrity. The official wording states: L’écrit électronique a la même force probante que l’écrit sur support papier, sous réserve que puisse être dûment identifiée la personne dont il émane et qu’il soit établi et conservé dans des conditions de nature à en garantir l’intégrité. This supports a properly controlled digital record, but it also tells the foreign parent what to test: identity, integrity, retention, access rights and the link between the original message and any corrected version.

The commercial payment rules should be connected to the invoice design. Article L. 441-10 of the French Commercial Code regulates payment deadlines, late-payment penalties and the fixed recovery indemnity. It is not enough to display an invoice due date in the ERP if the structured message, the commercial contract and the customer portal display different dates. The PA and ERP should preserve the due-date calculation and any agreed payment terms, especially for cross-border customers who apply a group procurement template.

Accounting records and supporting documents must also survive the corporate group’s normal retention cycle. Article L. 123-22 of the Commercial Code requires commercial documents and supporting records to be retained for ten years and contains rules concerning the language and currency of accounting documents. A foreign parent may keep its master records in English and another currency, but the French entity must be able to produce the required French accounting evidence. Agree a retention architecture before the PA contract is signed. Exporting a PDF after a dispute has begun is much weaker than preserving the structured invoice, the platform acknowledgement, the delivery evidence and the correction log from the start.

French case law illustrates the distinction between an invoice and proof of the underlying claim. In Cass. com., 25 October 2023, no. 22-18.859, the Cour de cassation stated: la preuve de la livraison de la chose vendue incombe au vendeur. The decision is a warning for a foreign seller using automated invoicing: the seller should preserve delivery notes, transport records, acceptance evidence or service completion documents, not merely the electronic invoice.

In Cass. com., 4 June 2013, no. 12-14.792, the court rejected the idea that a company can establish a claim only with documents it created itself. The decision says that commercial acts can be proved by all means, but that les seules factures ou les documents dressés par la société Thema trade ne sauraient suffire à établir l’existence de sa créance. For a foreign group, independent evidence may include the signed order, customer correspondence, work product, delivery scan, timesheet, transport record, acceptance record and bank payment.

The same logic appears in Cass. com., 31 May 2016, no. 15-10.270, where the court wrote: si l’existence même de la créance est contestée, c’est à celui qui l’invoque de la prouver. An e-invoice is a valuable timestamped record, but it does not move the entire burden of proof to the customer. The company’s operating procedure should therefore require the finance team to link each material invoice to the commercial evidence before a payment dispute arises.

A further decision, Cass. com., 25 September 2019, no. 18-12.367, confirms that the court assesses the evidence of the commercial relationship as a whole. The lesson is practical: a foreign legal department should avoid a process where the PA log is stored in one country, the purchase order in a second, the delivery proof in a third and the bank record in a fourth with no stable identifier. Use one invoice number and one transaction key across the systems.

The sanctions are not theoretical. Article 1737 of the CGI provides, for the relevant failures, a penalty of 50 euros per invoice for failure to issue an electronic invoice, subject to an annual cap of 15,000 euros, and a separate capped regime for certain platform failures. The provision also addresses failure to receive through the required platform and contains a first-infraction correction mechanism under its conditions. The company should read the current version rather than copy an old presentation of the reform because the effective dates and caps have changed during the transition.

A platform rejection is not automatically a tax breach, but ignoring it can become one. Create an incident procedure with four levels: first, determine whether the error is technical or legal; second, correct the source data or invoice; third, retransmit through the PA and preserve the old and new references; fourth, assess whether the VAT return, customer statement, payment report or contractual invoice must also be corrected. A credit note should not be issued simply to hide a rejected message. The correction must reflect the underlying transaction and the legal reason for the change.

When a customer refuses a message, ask for the rejection code and retain the response. When the PA is unavailable, activate the documented continuity route and record the outage, attempted submission, eventual transmission and any customer notification. When the foreign parent changes ERP, export a complete archive before the migration and test that a French auditor can retrieve the invoice and its evidence without administrator access to the parent’s entire system. The evidence file should include the legal entity, customer, VAT status, invoice, structured payload, PA receipt, rejection or acceptance code, delivery or service proof, payment status and correction history.

Foreign founders should also distinguish a tax correction from a commercial collection dispute. If the customer says the service was not delivered, the issue is evidence and contract performance. If the customer says the VAT treatment is wrong, the issue is tax classification and possibly a corrected invoice. If the customer says the PA message never arrived, the issue is technical transmission and proof. The response team should include finance, tax, legal and the PA contact, with one person authorised to decide whether to issue a corrected document.

Before the 1 September 2026 milestone, ask the company’s management to sign off a short compliance file containing:

• the entity and establishment map, including French VAT numbers and foreign identifiers;
• the classification of domestic B2B, international B2B, B2C, reverse-charge and payment-reporting flows;
• the size category and applicable receiving and issuing dates;
• the selected PA, signed contract, service levels and continuity contact;
• the tested structured fields, error codes, credit notes and payment events;
• the retention and audit procedure linking the PA log to the contract, delivery and payment evidence;
• the incident procedure for rejection, outage, wrong VAT treatment and customer dispute.

This file should be updated when the group creates a new French entity, acquires a business, moves its registered office, changes its ERP, adds a marketplace or changes its VAT registration. A French company formation project should already be tracking the formation and registration steps for a foreign founder; e-invoicing should be added before the first sale, not after the first rejected invoice. The same discipline applies when a group chooses a French branch or subsidiary: the structure changes who contracts and registers, but it does not remove the need to classify each VAT flow.

Conclusion

For a foreign-owned business, French e-invoicing compliance begins with a legal map, not a software purchase. A French subsidiary or French establishment must prepare to receive electronic invoices from 1 September 2026 and must follow the applicable issuing wave. A foreign company without a French establishment may instead have e-reporting duties for French transactions, including payment data in the cases covered by the CGI. The decisive facts are the establishment, customer, place of supply, VAT liability, transaction category and company size.

The immediate work is clear: classify the flows, select an accredited PA, test foreign identifiers and reverse charge, preserve structured data and proof of delivery, and document the response to rejection or outage. A Kbis, VAT number or PA contract is only one part of the evidence. The company must be able to explain the entire transaction from contract to payment. That approach allows an overseas parent, French subsidiary, branch or remote seller to meet the French timetable without forcing every international invoice into the wrong legal route.

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For the wider legal roadmap, see our guide to doing business in France as a foreign founder.