You formed your French company from London, New York, Dubai or Singapore. The Kbis, the official extract that proves your company is registered with the greffe, the registry office of the commercial court, is in your inbox. The corporate bank account works. Your accountant, called expert-comptable in France, sends you an email you did not expect: from now on, your company must receive its supplier invoices in a new electronic format, and depending on its size it must already issue its own invoices through an approved platform, or be ready to do so by next September. You answer from abroad that you already send PDF invoices by email. Your accountant answers that a PDF sent by email is no longer enough. That exchange has happened in thousands of foreign-owned French companies since 1 September 2026, the day the French electronic invoicing reform between businesses entered into force.
This guide explains the reform in order, for a founder or foreign shareholder who runs a French company from abroad. It covers what changed on 1 September 2026 and what changes on 1 September 2027, the difference between electronic invoicing and electronic reporting, the approved platforms you must choose, the four new details your invoices must now show, and the fines that punish inertia. It also covers the situations foreign groups meet constantly: a French subsidiary whose customers or parent company sit outside France, a small structure with no staff in France, and an accounting function outsourced to a French firm while decisions are taken abroad. The company vehicle itself, SAS versus SARL versus branch, is covered in our companion guide on how to choose between an SAS, an SARL and a branch when you live abroad; VAT registration, returns and reverse charge are covered in our companion guide on VAT numbers, CA3 returns and reverse charge for companies run from abroad; and the yearly rhythm of meetings and filings sits in our companion guide on the annual legal calendar of a French company run from abroad. Throughout, every French acronym is explained: the SIREN is the nine-digit number that identifies your company, the DGFIP is the tax authority, the ETI is the intermediate-sized company category, the PME is the small and medium enterprise category, and URSSAF is the agency that collects social contributions.
I. Receive now, issue on your date: what the 1 September 2026 reform requires of your company
The reform does not ask every company to do the same thing on the same day. It works in two waves built on one immediate duty. Since 1 September 2026 every French business, whatever its size, must be able to receive electronic invoices from its French suppliers. The duty to issue invoices in the new format and to report transaction data to the tax authority then depends on size: large companies and intermediate-sized companies started on 1 September 2026, while small, medium and micro enterprises follow on 1 September 2027. For a foreign founder this means one question comes before all others, and it is not whether the reform applies to you, because it does, but in which wave your French company sits. The paragraphs below set out the calendar, the two duties the reform creates, and the cross-border cases that matter most to groups run from abroad.
A. The two waves, the two duties and the foreign-group cases: French clients, foreign clients and the parent company abroad
The calendar is public and confirmed by the Ministry of the Economy: the reform entered into force on 1 September 2026, and from that date all companies must be able to receive electronic invoices, while large companies and intermediate-sized companies, called entreprises de taille intermédiaire or ETI, must also issue all their invoices in electronic format and transmit their transaction and payment data to the administration, a second duty called e-reporting. Small and medium enterprises and micro-enterprises have one additional year: they must be able to issue electronically and to transmit their e-reporting data from 1 September 2027. A company that benefits from the VAT exemption for small turnovers, called franchise en base de TVA, is not exempt from the reform: the administration states expressly that such companies remain liable to VAT as taxable persons and are therefore subject to electronic invoicing, both for receiving and for issuing. Most French subsidiaries of foreign groups are small or medium enterprises, so their issuing duty starts in September 2027, but their receiving duty started in September 2026, and that receiving duty alone forces a decision now: a platform must be chosen now, not next year, because invoices from French suppliers already arrive through that channel.
The statute draws the boundary of the issuing duty precisely. It provides that the issue, transmission and receipt of invoices for the standard domestic transactions between taxable persons take place in electronic form, under invoicing standards set by order of the Minister for the Budget, where the issuer and the recipient are taxable persons established, domiciled or habitually resident in France, and it adds that the issue, transmission and receipt of electronic invoices are carried out using an approved platform, called plateforme agréée: in the words of the text, “l’émission, la transmission et la réception des factures relatives aux opérations mentionnées aux a et d du 1 du I dudit article 289 ainsi qu’aux acomptes s’y rapportant s’opèrent sous une forme électronique, selon des normes de facturation électronique définies par arrêté du ministre chargé du budget, lorsque l’émetteur de la facture et son destinataire sont des assujettis qui sont établis ou ont leur domicile ou leur résidence habituelle en France” and “L’émission, la transmission et la réception des factures électroniques s’effectuent en recourant à une plateforme agréée” (Article 289 bis of the General Tax Code). Two consequences follow for foreign founders. First, the classic PDF attached to an email, however regular it looks, is not an electronic invoice within the meaning of the reform: the invoice must travel from the issuer’s approved platform to the recipient’s approved platform. Second, the reform is domestic in its core but not blind to borders, and the border cases are handled by the second duty, electronic reporting.
Electronic reporting, called e-reporting, is the transmission to the tax authority of data on transactions that stay outside electronic invoicing. The statute requires taxable persons established, domiciled or habitually resident in France to communicate to the administration, in electronic form under transmission standards set by ministerial order, the data on a list of transactions that are not exempt, a list that expressly includes supplies of goods and services whose customer is a taxable person not established in France, services located outside France, and transactions with private individuals: in the words of the text, “Les assujettis qui sont établis ou ont leur domicile ou leur résidence habituelle en France communiquent à l’administration sous forme électronique, selon des normes de transmission définies par arrêté du ministre chargé du budget, les données relatives aux opérations suivantes lorsqu’elles ne sont pas exonérées en application des articles 261 à 261 E” (Article 290 of the General Tax Code). In plain terms, confirmed by the administration’s own guidance: where the customer is a private individual or is established abroad, the supplier sends the invoice through the usual channel and simply transmits its transaction or payment data to its approved platform, which forwards it to the administration. A French subsidiary that bills its American or British parent company for management services, or that sells to customers outside France, therefore stays inside the reform through e-reporting even though no electronic invoice travels to the foreign customer. The VAT treatment of those cross-border supplies does not change: where a supply covered by Article 259 A of the General Tax Code is made by a taxable person established outside France, Article 283 places the VAT on the buyer, recipient or customer, provided that customer acts as a taxable person and holds a French VAT identification number (Article 283 of the General Tax Code). Founders should therefore map three invoice flows separately: domestic French customers, where full electronic invoicing applies; foreign customers and the parent company abroad, where the usual invoice plus e-reporting applies; and foreign suppliers billing the French company, where reverse charge and deduction rules continue to run on the VAT return.
The oldest invoicing duties survive underneath the reform and still bite companies run from abroad. Every purchase of products or provision of services for a professional activity must be invoiced, the seller must deliver the invoice as soon as the supply or service is performed, and the buyer must claim it: the Commercial Code states that “Tout achat de produits ou toute prestation de service pour une activité professionnelle fait l’objet d’une facturation” and that “L’acheteur est tenu de la réclamer” (Article L441-9 of the Commercial Code). The tax rule behind it provides that the invoice is in principle issued as soon as the supply or service is performed, since “La facture est, en principe, émise dès la réalisation de la livraison ou de la prestation de services” (Article 289 of the General Tax Code). A founder abroad who lets invoices pile up unclaimed, or whose French team issues invoices weeks late, therefore breaches rules that predate the reform and that the reform’s traceability makes easier for the administration to detect. Practical consequence: the first compliance step is not the platform, it is the discipline of issuing and claiming every invoice on time.
B. Choose the approved platform, feed the central directory and add the four new invoice details
From 1 September 2026 every company must send its invoices through an approved platform, directly or through compatible software, and every company must designate its platform for issuing and receiving electronic invoices and for declaring its data. The list of platforms registered by the tax authority is published and regularly updated on the impots.gouv.fr website, the portal of the French tax administration. The choice is not a formality: the platform becomes the company’s single invoicing address, the place where supplier invoices are centralised instead of arriving scattered across letter boxes, email inboxes and supplier portals, and the channel through which the company’s own invoices and data reach the administration. A founder living abroad should select the platform personally or by a written instruction to the accountant, and should refuse to let the decision drift: an accountancy firm can operate the platform under a mandate, but the legal responsibility for issuing and receiving stays with the company, and a company whose accountant changes firm without transferring the platform ends up unreachable at its own invoicing address.
Behind the platforms sits a central directory, called annuaire central, the central directory, which the State places at the disposal of the approved platforms and which records the addressing data needed to route electronic invoices to each recipient’s platform. The statute builds this directory from information transmitted by the platforms themselves and provides that a decree in Council of State specifies the data to be transmitted, the procedures for collecting it from recipient taxable persons, the procedures for changing platform, and the nature and duration, which cannot be less than one year, of the minimum services the former platform must supply when such a change occurs (Article 289 bis of the General Tax Code). Three practical lessons follow. First, keep the company’s directory data accurate: a wrong address routes invoices into the void and the company still owes the underlying debt. Second, changing platform is a right, but the former platform must keep minimum services for at least a year, so plan the migration instead of cutting access overnight. Third, monitor invoice statuses on the platform, because the reform gives each electronic invoice a timestamped trail showing in real time where it stands in the transmission circuit, and a founder abroad can supervise that trail without travelling.
The reform also changes what the invoice must say. The transmission process changes but the invoicing rules stay the same, and four new mandatory details must appear on invoices from 1 September 2026: the customer’s SIREN number, the statement of the operation category covered by the invoice, meaning a sale of goods, a supply of services, or both a sale and a distinct service; the statement that the company has opted to pay VAT on receipts, called TVA sur les débits, where that option is used; and the full delivery address of the goods, but only where it differs from the customer’s billing address. Companies run from abroad fail most often on the first two: the SIREN of each French customer must be collected and stored, and mixed contracts must be split honestly between goods and services instead of being forced into one box. The remaining mandatory details do not disappear: names and addresses of the parties, date of the sale or service, quantity, precise description and unit price excluding VAT of the goods sold and services supplied, any price reduction acquired at the date of the sale and directly linked to the transaction, the date payment falls due, the discount terms for early payment, the penalty rate due from the day after the payment date shown on the invoice, and the statutory fixed compensation for recovery costs owed on late payment. A company whose invoicing software has not been updated for the four new details issues defective invoices from September 2026, and defective invoices attract their own fines, described below, on top of any electronic format failure.
II. Survive the inspection: fines, tolerance and the from-abroad compliance file
The reform carries its own fines, and they are calibrated to hurt repetitive negligence rather than a single mistake. The scale runs per invoice with yearly ceilings, plus a specific procedure for companies that refuse to receive electronically. The administration announced an approach of goodwill and tolerance for companies facing difficulties at the 1 September 2026 start, but tolerance is a phase, not an amnesty, and it protects companies that equip themselves late, not companies that do nothing. The paragraphs below set out the fines exactly as written, then give the founder abroad a concrete file: platform, software, archiving, and the paper trail that proves diligence if an inspection comes.
A. Fifty euros per invoice, yearly ceilings and the formal notice before the reception fine
The headline fine punishes issuing outside the electronic circuit. Failure by a taxable person to issue an invoice in electronic form under the conditions of Article 289 bis draws a fine of 50 euros per invoice, capped at 15,000 euros per calendar year: in the words of the text, “Le non-respect par l’assujetti de l’obligation d’émission d’une facture sous une forme électronique dans les conditions prévues à l’article 289 bis donne lieu à l’application d’une amende de 50 € par facture, sans que le total des amendes appliquées au titre d’une même année civile puisse être supérieur à 15 000 €” (Article 1737 of the General Tax Code). Platforms face their own mirror fine: any omission or failure by an approved platform in its data transmission duties draws 50 euros per invoice charged to the platform, capped at 45,000 euros per calendar year. Refusing to receive electronically follows a two-step procedure: the administration first formally orders the taxable person to comply within three months, and only continued breach after that period draws a 500 euro fine, followed by a fresh formal order. Alongside these reform-specific fines, the classic invoice-content fine survives: any omission or inaccuracy found in invoices draws 15 euros, although the total fines per invoice cannot exceed one quarter of the amount shown or that should have been shown. Heavier conduct stays under the older heavy scale: disguising the identity or address of suppliers or customers, issuing an invoice with no real supply or service behind it, or failing to issue an invoice and to record the transaction draws a fine of 50 percent of the sums or of the invoice or transaction, with the professional customer jointly liable up to 375,000 euros per financial year, reduced to 5 percent and 37,500 euros where the transaction was recorded.
Three readings matter for a company run from abroad. First, the ceilings make chronic paper invoicing expensive but bounded: a small subsidiary issuing two hundred paper invoices to French customers in 2027 faces up to 10,000 euros, while systematic failure across thousands of invoices stops at 15,000 euros per year, which never makes compliance optional but puts its cost in perspective. Second, the reception procedure gives a warned company three months to equip itself, so a formal notice must never be filed away: diary the deadline, designate the platform, and keep proof of each step, because the 500 euro fine punishes persistence after warning, not the initial gap. Third, the tolerance announced for the September 2026 start helps the company that can show purchase orders for software, a platform contract, or correspondence with its accountant about the migration; it does not help the company with an empty file. A founder in Paris or the Ile-de-France region follows the same national fines and the same platform list, with two local notes: disputes with a supplier or a platform that cut off access can be brought urgently before the Paris Commercial Court, whose interim judge hears business continuity disputes, and in-person help with the reform is available from the Paris tax offices and the national helpline the administration opened for the reform. National rules, local judges: that is the whole geography of this reform.
B. The founder-abroad file: platform mandate, updated software, six and ten year archives, and proof of diligence
Build the compliance file in this order. First, designate the approved platform now, even if the company only receives until September 2027: reception is already mandatory, and the platform centralises all supplier invoices in one place with timestamped statuses the founder can check from abroad. Sign the platform contract in the company’s name, name the administrator accounts, and give the accountant a written mandate limited to operating the platform, keeping the power to revoke it. Second, update the invoicing software or the platform’s own invoice editor so the four new details appear automatically: customer SIREN collected for every French customer, operation category chosen per invoice, VAT-on-receipts option flagged where used, and delivery address added where it differs from billing. Test the chain with a real small invoice before the first large one, and keep the test trail. Third, connect e-reporting for everything outside electronic invoicing: sales to private individuals, supplies to customers outside France, and services billed to the foreign parent company. The company’s VAT returns must reconcile with the reported data, since the administration will hold both, and any gap between reported turnover and declared turnover invites questions that are expensive to answer from another continent.
Fourth, organise archiving for two different clocks. Accounting documents and supporting papers, which include invoices issued and received, must be kept for ten years, since the Commercial Code states that “Les documents comptables et les pièces justificatives sont conservés pendant dix ans” (Article L123-22 of the Commercial Code). Tax books, registers and documents that the administration may audit must be kept for six years from the last recorded transaction or from the date the document was drawn up, and where they are drawn up or received electronically they must be kept in that form for that period: the procedural text provides that they “doivent être conservés pendant un délai de six ans à compter de la date de la dernière opération mentionnée sur les livres ou registres ou de la date à laquelle les documents ou pièces ont été établis” and that “Lorsqu’ils sont établis ou reçus sur support informatique, ces livres, registres, documents ou pièces doivent être conservés sous cette forme pendant le délai prévu” (Article L102 B of the Tax Procedures Book). The combined rule is simple: keep the electronic invoice in its electronic form for six years for the tax auditor and the accounting record for ten years for the company, and never satisfy an auditor with a printed screenshot when the electronic original exists. The general VAT accounting duties point to the same storage rule, since taxable persons must keep their books and supporting papers, including purchase invoices, under the procedures of Article L102 B (Article 286 of the General Tax Code). A founder abroad should verify personally that the platform or the accountant’s storage covers both clocks, because a platform changed in 2028 must still produce a 2026 invoice, and the one-year minimum service of the former platform after a change is a floor, not a full archive.
Fifth, keep a diligence folder that proves the company moved in time: the platform contract and designation date, the software update order, the SIREN collection file, the e-reporting activation confirmation, the accountant’s mandate, and every exchange with the administration including any formal notice and the reply within its three-month deadline. That folder is what turns the announced tolerance into actual leniency and what caps any dispute to the per-year ceilings instead of letting it drift into the heavy 50 percent scale for unrecorded transactions. Review it once a quarter from abroad: confirm that every domestic invoice travelled platform to platform, that every foreign-customer sale produced its e-reporting line, that every supplier invoice was claimed and stored, and that the VAT return matches the reported data. Companies that run this quarterly check from abroad pass inspections the same way resident companies do, because the inspector reads the platform trail and the archive, not the founder’s passport stamps.
Conclusion
Since 1 September 2026 every French company, including the smallest subsidiary run entirely from abroad, must be able to receive electronic invoices through an approved platform. Large and intermediate-sized companies must also issue electronically and report their transaction data, and small, medium and micro enterprises join them on 1 September 2027. Sales to foreign customers and to the parent company abroad travel by the usual invoice plus electronic reporting, and the four new invoice details apply to all invoices from September 2026. Paper invoicing to French customers costs 50 euros per invoice up to 15,000 euros a year, platform failures cost the platform up to 45,000 euros, and refusing to receive draws a formal order then 500 euros, while defective invoice content and unrecorded transactions keep their own older fines. The founder abroad who designates a platform now, updates the invoice template, activates e-reporting for cross-border flows, keeps electronic archives for six and ten years, and files proof of every step, runs a French company that the reform makes more transparent, not more fragile. The invoices now travel through platforms; the company’s discipline must travel with them.