Since 1 September 2026, every company operating in France has to be able to receive electronic invoices, whatever its size. If you run a French company from London, New York, Dubai or Singapore, that obligation already applies to you, even if you have no office, no accountant and no employee on French soil. Your suppliers now send structured invoices through approved digital platforms, and your company must be reachable on that network. Larger businesses have a second duty on top of receiving: they must also issue all their invoices in electronic format and transmit transaction data to the tax authority. Smaller companies get one extra year, until 1 September 2027, before issuing becomes compulsory for them too. The French Ministry of the Economy confirmed that the reform entered into force on 1 September 2026, that it concerns more than ten million economic actors, and that the administration is starting with an approach of support and tolerance toward businesses facing difficulties. Tolerance is not an exemption, and the Tax Code already provides for fines per missing invoice. This article explains, for a foreign founder or director living abroad, what the reform changes in practice: who must do what and by when, how to choose an approved platform from another country, how to keep invoices that will survive a tax audit, and what penalties apply if your company stays on paper or PDF.

I. What the 1 September 2026 reform requires of your French company

A. Every company, whatever its size, must now be able to receive electronic invoices

The starting point is simple and it surprises many foreign directors: the obligation to receive electronic invoices applies to all taxable businesses from 1 September 2026, with no threshold, no exemption for small companies and no exemption for companies managed from abroad. The Ministry of the Economy states it plainly: all businesses, whatever their size, must be in a position to receive electronic invoices. Your one-person SAS (société par actions simplifiée, the flexible joint-stock company most foreign founders choose) registered in Paris is concerned exactly like a large industrial group. So is your SARL (société à responsabilité limitée, the limited liability company with stricter statutory rules), your branch (succursale) and your subsidiary, from the day they make taxable transactions between VAT-registered businesses.

This receiving obligation is the first stage of a reform built by two founding texts: Ordonnance n° 2021-1190 du 15 septembre 2021 relative à la généralisation de la facturation électronique dans les transactions entre assujettis à la taxe sur la valeur ajoutée et à la transmission des données de transaction and Décret n° 2022-1299 du 7 octobre 2022 relatif à la généralisation de la facturation électronique dans les transactions entre assujettis à la taxe sur la valeur ajoutée et à la transmission des données de transaction. Together they extended electronic invoicing, until then reserved for dealings with the public sector, to all domestic business-to-business transactions between persons liable for VAT (assujettis). In the Tax Code, the general duty to invoice has long existed: article 289 of the Code général des impôts (CGI, the French Tax Code) provides that “Tout assujetti est tenu de s’assurer qu’une facture est émise, par lui-même, ou en son nom et pour son compte, par son client ou par un tiers”. What the reform adds is the channel: these invoices must now travel as structured electronic data through the new network, and every business must be able to catch them. The same article already recognised electronic invoices in its paragraph VI: article 289, VI, of the CGI states that “Les factures électroniques sont émises et reçues sous une forme électronique quelle qu’elle soit. Elles tiennent lieu de factures d’origine pour l’application de l’article 286 et du présent article. Leur transmission et mise à disposition sont soumises à l’acceptation du destinataire.” Under the reform, that acceptance logic is replaced for domestic transactions by a general connection duty: you designate an approved platform that receives on your behalf, and the administration can check that you did.

For a director living abroad, the practical consequence is immediate. Your French suppliers will stop sending simple PDFs by email and will route their invoices to your company’s approved platform. If your company has no platform, invoices wait in limbo: you do not see them, payment deadlines still run, and late payment penalties accrue while you believe nothing arrived. The knowledge gap is the real danger, because commercial law makes the buyer responsible for claiming invoices: article L. 441-9 of the Code de commerce (French Commercial Code) provides that “Tout achat de produits ou toute prestation de service pour une activité professionnelle fait l’objet d’une facturation”, and adds “L’acheteur est tenu de la réclamer.” A director who discovers six months of unseen invoices on a platform he never opened cannot argue he received nothing: the invoice was delivered to his company’s designated address, and the thirty-day payment clock described below was already ticking.

Enforcement of the receiving duty follows a graduated path, which is good news and a trap at the same time. Article 1737, IV bis, of the CGI provides that “Lorsque l’administration constate une omission ou un manquement par l’assujetti à l’obligation de recourir à une plateforme agréée pour la réception de factures électroniques prévue au I de l’article 289 bis du présent code, elle le met en demeure de s’y conformer dans un délai de trois mois.” If the breach persists after that formal notice, fines of 500 euros, then 1,000 euros, then 1,000 euros per additional three-month period apply. This escalation means a first omission triggers a warning rather than an instant fine, and the Ministry confirms a benevolent approach during the launch phase. But the formal notice procedure also means the administration keeps a written record of your non-compliance, and repeated 1,000-euro fines accumulate quickly for a company whose director ignored the first letter sent to the registered office. Founders living abroad should therefore treat any letter from the DGFiP (Direction générale des Finances publiques, the French tax authority) about electronic invoicing as urgent, arrange mail forwarding from the registered office, and mandate someone to act within the three-month window.

One more receiving point matters for foreign-run structures: the duty covers the company, not the person. If you hold several French entities, each SIREN number (the unique nine-digit identifier assigned at registration, appearing on the Kbis, the official company identity certificate issued by the greffe, the clerk of the commercial court) must be connected. A holding company that is connected does not shelter its subsidiaries, and a branch registered in France needs its own connection even if the foreign head office already invoices electronically under another country’s system. Map every French SIREN you control before choosing platforms, because each one is a separate receiving address in the eyes of the administration.

B. Issuing electronic invoices and reporting data: large companies now, small ones on 1 September 2027

Receiving is for everyone; issuing follows a calendar based on company size. Since 1 September 2026, large companies (grandes entreprises) and mid-sized companies (entreprises de taille intermédiaire, ETI) must issue all their invoices in electronic format and transmit their transaction and payment data to the administration, a second duty known as e-reporting. Small, micro and medium-sized businesses only have to receive for now; they must be able to issue electronically and to transmit e-reporting data from 1 September 2027. The Ministry’s calendar page confirms both dates and both perimeters, and it is the single reference your accountant will check first.

Foreign founders often ask which category their French company falls into. The calendar uses the standard French size definitions, and the decisive question is the size of the French company itself assessed under those definitions, not the size of your foreign group as a whole. A French subsidiary with a handful of employees and modest turnover will normally follow the 2027 issuing timetable even if its American or Emirati parent is a giant; conversely, a French company that already exceeds the large-company or ETI thresholds must issue electronically now, even if its shareholder is an individual living abroad with no other business. Ask your French accountant (expert-comptable) to confirm your category in writing before assuming you have until 2027, because issuing on paper in 2026 when you were already in the first wave is precisely the breach fined at 50 euros per invoice. If you are creating your company now, the formation steps themselves have not changed: opening a French corporate bank account, obtaining the Kbis and registering for VAT remain the entry gates, and electronic invoicing becomes one more system to connect once the Kbis is issued.

E-reporting deserves a clear explanation because it has no equivalent in many foreign systems. Beyond the invoice itself, the company must transmit to the tax authority data on transactions that do not pass through electronic invoices: sales to private individuals, sales to foreign customers, and payment data such as amounts collected. The logic is that the administration reconstructs your real activity from two streams, invoices plus reported data, and cross-checks them against your VAT returns (déclarations de TVA, the CA3 periodic return for most companies). A company that issues perfect electronic invoices but never transmits its e-reporting data still breaches the reform, and a company whose reported data contradicts its VAT returns invites an audit. From abroad, the practical lesson is to make sure your platform or your accountant handles both streams, not just the visible invoices, and to reconcile the three figures every quarter: invoices issued, data reported, VAT declared.

The content of each invoice does not change in principle, but the electronic format makes omissions easier to detect automatically. Commercial law lists the mandatory mentions, and article L. 441-9 of the Commercial Code requires the names and addresses of the parties, the date of the sale or service, quantities, precise description, unit prices excluding VAT, and price reductions acquired at the date of the transaction. The tax annexes add the VAT rate, the amount of tax, the customer VAT number for intra-Community supplies, and references to self-billing mandates where applicable. In a structured invoice, each of these mentions is a tagged data field, which is exactly why the Ministry promises better compliance through standardisation: as its guidance explains, the electronic invoice contains structured data, meaning every software reads the same tag as the same information. For your company, the consequence is that a missing VAT number or a wrong rate is no longer a typo a human might forgive; it is a structured anomaly the administration’s systems can flag across millions of invoices. Review your invoice templates when migrating to the platform, especially if you invoice in a foreign language or in foreign currency, and remember that the tax authority may demand a French translation of foreign-language invoices for control purposes.

Deadlines to issue remain governed by the classic rule recalled in the Commercial Code: the seller must deliver the invoice upon completion of the delivery or service, with specific timing for intra-Community supplies and periodic invoices. Electronic transmission does not extend these deadlines; if anything, it shortens the practical tolerance, because the platform timestamps every invoice and the administration sees the real issue date. Companies managed from abroad, where the director approves invoices in batches every few weeks, should reorganise the internal circuit now: give your French accountant or your platform operator a mandate to issue on time, and stop treating invoicing as paperwork you handle during your next trip to Paris.

II. How to comply from abroad without breaking your invoicing chain

A. Choose an approved platform and keep invoices that survive a tax audit

Compliance passes through one concrete decision: designating the approved platform (plateforme agréée, PA) that will send and receive your company’s electronic invoices. These are private operators registered with the administration after meeting technical and security requirements, and the tax authority publishes their official list on the impots.gouv.fr website, where a dedicated page invites every business to consult the list of administration-approved platforms. Your choice is not a mere software subscription; the platform becomes your company’s digital domicile for invoicing, the address where suppliers deliver and where the administration checks your presence. A foreign director can sign up entirely online, but three checks must come before the signature: the platform must cover both e-invoicing and e-reporting if your company is already in the issuing wave; it must offer an English-language interface or a correspondent your team understands, because invoice statuses, rejections and correction requests will arrive in French by default; and it must allow multi-user access with separate rights, so that your accountant in France sees everything while a local employee only sees purchasing.

Interoperability is the second point to verify, and it matters more for cross-border groups than for purely domestic businesses. Approved platforms must be able to exchange invoices with each other, so your supplier’s platform and your platform do not need to be the same operator. In practice, confirm with your chosen operator that it is connected to the central directory and that invoices addressed to your SIREN actually arrive in your inbox, with a test invoice before the migration. Also clarify what happens to invoices from foreign suppliers outside the French system: a German or American supplier will generally keep sending PDFs or paper, and your platform should offer a deposit or scanning function so these incoming documents join the same archive as your electronic invoices. Without that bridge, your accounting splits into two worlds and your VAT recovery file becomes fragile.

Once invoices flow through the platform, the law imposes a durability duty that many digital-first founders underestimate. Article 289, V, of the CGI requires that “L’authenticité de l’origine, l’intégrité du contenu et la lisibilité de la facture doivent être assurées à compter de son émission et jusqu’à la fin de sa période de conservation.” Authenticity of origin means you can prove who really issued the invoice; integrity means nobody altered it afterwards; legibility means you can still read it years later despite software changes. The platform handles the technical layer through timestamps, status tracking and qualified signatures or seals, and the Ministry highlights exactly these benefits: invoice statuses visible in real time and tamper-evident timestamping at each stage of transmission. But the legal responsibility stays with your company, not with the operator: if the platform loses data or goes bankrupt, the administration will ask you, not the operator, to produce the invoices.

That is why the retention period deserves your full attention. Article L. 123-22 of the Commercial Code provides that “Les documents comptables sont établis en euros et en langue française. Les documents comptables et les pièces justificatives sont conservés pendant dix ans.” Ten years is longer than most platform contracts and longer than many startups’ lives, so plan the exit from day one: negotiate a data reversibility clause, export your archives in a readable structured format at least once a year, and store a copy outside the platform, with your accountant or on your own servers. Tax law reinforces the same duty: article 286 of the CGI requires every VAT-registered person to keep the books and supporting documents, including purchase invoices, which “doivent être conservés selon les modalités prévues aux I et I bis de l’article L. 102 B du livre des procédures fiscales”. During a VAT audit (contrôle fiscal), the auditor will ask for electronic invoices in their original structured form, not screenshots; a company that only kept PDFs printed from the platform interface fails the integrity test. Finally, remember that accounting documents must be drawn up in euros and in French: invoices in dollars or pounds must still show the VAT payable converted into euros, and foreign-language invoices must be translatable on demand, two details that foreign-run companies trip over regularly.

B. What non-compliance costs, and why late payment rules still bite

The reform’s penalty scale is deliberately progressive: warnings first, then per-invoice fines, then heavier sanctions for persistent refusal. For issuing, article 1737, III, of the CGI provides that “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 €.” Fifty euros per invoice with a 15,000-euro annual cap means a company issuing three hundred paper invoices in 2026 already hits the ceiling, while a company issuing twenty late invoices pays 1,000 euros. The cap protects high-volume businesses, but it resets every calendar year, so a structural refusal to migrate costs 15,000 euros annually until fixed. For receiving, the formal-notice escalation described above applies: three months to comply after the first notice, then 500 euros, then 1,000 euros per quarter of continued breach. Platforms themselves face 50 euros per invoice and up to 45,000 euros per year if they fail their data transmission duties, which gives you a contractual lever: if your operator’s failure exposes you, its own fines prove the breach is taken seriously.

Two mitigating details complete the picture and both favour quick correction. First, article 1737, V, of the CGI provides that “Les amendes mentionnées au 3 du I et aux II, III et IV du présent article ne sont pas applicables en cas de première infraction commise au cours de l’année civile en cours et des trois années précédentes lorsque l’infraction a été réparée spontanément ou dans les trente jours suivant une première demande de l’administration.” A first, promptly repaired breach therefore escapes the fine, which is the legal translation of the administration’s benevolent launch phase. Second, the classic invoicing fines remain fully applicable alongside the new ones: article 1737, I, of the CGI punishes with a fine of 50 percent of the amount “De la transaction, le fait de ne pas délivrer une facture ou la note prévue à l’article 290 quinquies et de ne pas comptabiliser la transaction”, adding that “Le client professionnel est solidairement tenu au paiement de cette amende, qui ne peut excéder 375 000 € par exercice.” Failing to invoice at all was already expensive before the reform; invoicing on the wrong channel now adds the new per-invoice layer on top.

Electronic invoicing also sharpens a risk foreign directors chronically underestimate: French late payment discipline. Because every invoice is now timestamped on arrival, the administration, your suppliers and the courts can establish exactly when the payment clock started. Article L. 441-10 of the Commercial Code sets the default rule that, absent contrary agreement, “le délai de règlement des sommes dues ne peut dépasser trente jours après la date de réception des marchandises ou d’exécution de la prestation demandée”, with negotiated terms capped at sixty days from the invoice date, or forty-five days end of month under strict conditions, without prejudice to the sectoral agreements organised by article L. 441-11 of the Commercial Code. A director who discovers invoices late because he never opened the platform does not move the starting point: receipt by the platform counts, and penalties for late payment plus the fixed recovery indemnity accrue automatically. The DGCCRF (Direction générale de la concurrence, de la consommation et de la répression des fraudes, the competition and consumer protection authority) enforces these deadlines with administrative fines: article L. 441-16 of the Commercial Code punishes breaches with a fine that “ne peut excéder 75 000 € pour une personne physique et deux millions d’euros pour une personne morale”, doubled in case of repetition within two years, expressly targeting the failure to “Ne pas respecter les délais de paiement prévus au I de l’article L. 441-10”. Connect invoice receipt to your payment process from day one: notifications from the platform should reach whoever pays, not just the accountant who archives.

The last building block is contractual. Your general terms of sale (conditions générales de vente, CGV) are the foundation of price negotiation under French law: article L. 441-1 of the Commercial Code states that “Les conditions générales de vente comprennent notamment les conditions de règlement”. Update them to mention electronic invoicing: designate your approved platform as the valid receiving address, require your business customers to send structured invoices there, state that PDF-by-email no longer counts as delivery, and recall the payment deadlines and late penalties. This single update prevents the most common dispute of the transition years, the customer who claims he paid late because he sent a PDF to your personal email while your CGV required platform delivery. For companies with consumer customers, remember that e-reporting covers those sales even though consumers receive no electronic invoice; your systems must feed that data to the administration separately.

Conclusion

The 1 September 2026 reform does not ask your French company to do more business; it asks it to do business through a new channel, measurably and on time. Every company you control in France must already be reachable for electronic invoices through an approved platform, whatever its size and wherever you live. Large and mid-sized companies must also issue electronically and transmit their reporting data now; smaller ones have until 1 September 2027 to be ready to issue. The fines are real but graduated: formal notice before sanction for receiving, 50 euros per invoice capped at 15,000 euros per year for issuing, first promptly repaired breach excused, and the old heavy sanctions for missing invoices fully maintained. The timestamped invoice also makes late payment deadlines and DGCCRF fines harder to escape, so connect the platform to whoever actually pays your suppliers. Work through the checklist in order: map every French SIREN, confirm each company’s size category with your accountant, choose an approved platform from the official impots.gouv.fr list, run a test invoice, update your general terms of sale, organise mail forwarding from the registered office, and archive outside the platform for the full ten-year retention period. A company run from abroad can comply entirely online; what it cannot do is ignore the network and hope paper habits survive unnoticed.