If you own a French company while living abroad, your invoicing habits are about to become a compliance issue. From 1 September 2026, every company established in France must be able to receive electronic invoices, and large and intermediate-sized companies must issue all of their domestic business-to-business invoices in electronic form through an approved platform. Smaller companies follow one year later, on 1 September 2027. A PDF attached to an email will no longer count as an electronic invoice, and the fines for ignoring the new channel are written into the French Tax Code: 50 euros per missing electronic invoice, capped at 15,000 euros per calendar year, plus a separate warning-and-fine procedure if your company cannot even receive electronic invoices. This guide explains, in English and with the exact legal texts, what the reform requires from a French subsidiary or company owned from abroad, what a compliant invoice looks like, how to choose your invoicing channel without travelling to France, and what to check before the September 2026 deadline. It assumes you already have a French structure in place; if you are still choosing between a subsidiary and a branch, read our comparison of branches and subsidiaries in France first, and our foreign founder setup guide for the bank account, Kbis company registration certificate and VAT registration steps that come before invoicing.
I. What France Now Requires From Your French Company: Electronic Invoicing and Electronic Reporting
A. Which of your invoices must go electronic, and by which date?
The core obligation sits in Article 289 bis of the French Tax Code (Code général des impôts, abbreviated CGI). It provides that, and I quote the exact wording, “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” (Article 289 bis, I of the CGI). In plain English: when both your French company and its customer are VAT-registered businesses (“assujettis”, meaning persons liable for VAT) established in France, the invoice must be issued, transmitted and received electronically, in a format set by ministerial order (“arrêté”, a binding order signed by the minister). Deposits (“acomptes”, advance payments) on such transactions are covered too. Transactions with private consumers, and cross-border transactions where one party is not established in France, stay outside this electronic-invoicing channel, but they may fall into the second pillar of the reform, electronic reporting, described below.
The timetable is staggered by company size, and the French Ministry of the Economy states it publicly: on 1 September 2026, all companies regardless of size must be able to receive electronic invoices, while large companies (“grandes entreprises”) and intermediate-sized companies (ETI, “entreprises de taille intermédiaire”) must issue all of their invoices electronically and transmit their electronic reporting data; on 1 September 2027, small and medium-sized companies (PME, “petites et moyennes entreprises”) and micro-enterprises must in turn be able to issue electronically and transmit their reporting data (Ministry of the Economy, timetable of the reform, confirmed by service-public.fr, the official public service portal). Note the asymmetry that matters most for a small foreign-owned subsidiary: even if your French SAS (société par actions simplifiée, the flexible joint-stock company most foreign founders choose) or SARL (société à responsabilité limitée, the limited liability company with stricter statutory rules) is a tiny structure with one employee, it must be technically able to receive electronic invoices from 1 September 2026. Reception is not optional, not conditional on your size, and not excused by the fact that the director lives in London, New York or Dubai. If your accounting still runs on a personal mailbox where your Paris accountant forwards PDFs, that setup stops being compliant on that date for incoming supplier invoices from large French vendors, because those vendors will send them through the electronic channel only.
The second pillar, electronic reporting (“e-reporting”), covers everything the invoicing channel does not. Article 290 of the CGI lists the data that VAT-registered persons established, domiciled or habitually resident in France must transmit electronically to the tax administration (“l’administration”, here the DGFiP, Direction générale des Finances publiques, the French tax authority): business-to-consumer sales, exempt intra-EU supplies, services performed for non-established clients, distance sales, and purchases from non-established suppliers, among others (Article 290, I of the CGI). The same article states the transmission rule in one sentence worth quoting exactly: “Les données relatives aux opérations mentionnées aux I et II du présent article sont transmises à l’administration sous forme électronique par la plateforme agréée choisie par la personne assujettie” (Article 290, III of the CGI). In other words, your company pushes these data to the tax authority through the approved platform it has chosen, with the frequency and technical details left to a decree. For a foreign group this is the provision that quietly extends French tax visibility to cross-border flows: sales by your French subsidiary to French consumers, and services your foreign parent buys from the subsidiary, generate reporting data even though no electronic invoice circulates between the parties.
A foreign parent company that invoices French customers directly, without a French subsidiary, is not forgotten either. Article 290, II of the CGI requires VAT-registered persons that are not established in France, or their appointed representative where one is mandatory, to transmit electronically the data on French-situated supplies of goods and services for which they are liable for VAT (Article 290, II of the CGI). And Article 289 A of the CGI adds that a person not established in the European Union which owes French VAT or must complete French filing formalities “est tenue de faire accréditer auprès du service des impôts un représentant assujetti établi en France qui s’engage à remplir les formalités incombant à cette personne et, en cas d’opérations imposables, à acquitter la taxe à sa place” (Article 289 A, I of the CGI), meaning it must have an accredited VAT-registered representative established in France who completes its formalities and pays the tax in its place, unless its home country has a mutual tax-assistance agreement with France. If you run French operations from a non-EU country through a mere VAT registration, check that mutual-assistance condition now: without it, you need a French fiscal representative, and that representative is the person who will operate the reporting channel on your behalf. Our detailed guide to French VAT registration, returns and refunds for foreign companies explains the registration side of this setup.
B. What counts as a compliant electronic invoice in France?
Start with what no longer counts. The Ministry of the Economy warns that invoicing understood today as a scanned paper invoice, an ordinary PDF or a document sent by email “ne sera plus conforme à la réglementation”, will no longer comply with the rules (Ministry of the Economy, definition of the electronic invoice). A compliant electronic invoice must follow a standardised electronic format, carry the mandatory invoice items in dedicated structured fields, and travel to the customer through an approved platform that partners with the tax administration. The law says the same thing in its own words: “L’émission, la transmission et la réception des factures électroniques s’effectuent en recourant à une plateforme agréée” (Article 289 bis, I of the CGI). A “plateforme agréée”, usually shortened to PDP (“plateforme de dématérialisation partenaire”, partner dematerialisation platform), is a private invoicing service provider registered with the tax administration; the current list of registered platforms is published and updated on the tax authority website (impots.gouv.fr, list of registered approved platforms). Your company designates its platform for issuing and receiving invoices and for declaring its data, either directly on the platform or through compatible business software that connects to it.
The content of the invoice does not change with the channel, but the channel forces you to get the content right, because each item must sit in its own structured field. Between professionals, Article L. 441-9 of the Commercial Code (Code de commerce) opens with a sentence every foreign supplier should memorise: “Tout achat de produits ou toute prestation de service pour une activité professionnelle fait l’objet d’une facturation”, and it adds that the buyer must claim the invoice, “L’acheteur est tenu de la réclamer” (Article L. 441-9, I of the Commercial Code). The same article lists the mandatory items: the names and addresses of both parties, the billing address where different, the date of the sale or service, quantity, precise description and unit price excluding VAT, any price reduction earned at the date of sale, the payment due date, the discount terms for early payment, the late-penalty rate applicable from the day after the due date, and the fixed recovery fee (“indemnité forfaitaire pour frais de recouvrement”) owed if payment arrives late. On the tax side, Article 289 of the CGI requires the invoice to be issued when the supply takes place, provides that electronic invoices “sont émises et reçues sous une forme électronique quelle qu’elle soit”, and demands that authenticity of origin, integrity of content and legibility be preserved from issuance until the end of the retention period (Article 289, I, V and VI of the CGI). Four additional items join the mandatory list with the reform from 1 September 2026 for large companies and ETIs, and from 1 September 2027 for SMEs and micro-enterprises: the customer’s SIREN number (SIREN, Système d’Identification du Répertoire des Entreprises, the nine-digit national business identifier issued by INSEE, the French statistics institute), the category of the invoiced operation (sale of goods, supply of services, or both), any election to pay VAT on a cash-received basis where applicable, and the full delivery address of the goods where it differs from the customer’s billing address (Ministry of the Economy, new mandatory invoice items). If your current invoice template lacks the customer SIREN field, update it now: the structured format will reject or misroute invoices whose dedicated fields are empty.
Two details foreign directors often discover too late deserve emphasis. First, language. Article 289 of the CGI provides that where an invoice is written in a foreign language, the tax office may require a French translation for control purposes: “Lorsqu’elle est rédigée dans une langue étrangère, le service des impôts peut, à des fins de contrôle, exiger une traduction en français” (Article 289, IV of the CGI). Nothing forbids English-language invoices between consenting businesses, but during a VAT audit (“contrôle fiscal”) the administration can demand French versions, and a structured electronic invoice whose free-text fields are all in English while the coded fields carry the legal data is the safest combination. Second, payment deadlines, which the electronic invoice must state. Article L. 441-10 of the Commercial Code sets a default of thirty days from receipt of the goods or performance of the service, and caps any agreed term in these exact words: “Le délai convenu entre les parties pour régler les sommes dues ne peut dépasser soixante jours après la date d’émission de la facture”, with a possible forty-five days end-of-month-that-follows scheme where the contract expressly provides for it and it is not manifestly abusive toward the creditor (Article L. 441-10, I of the Commercial Code). A foreign group that imposes its standard ninety-day group payment policy on its French subsidiary’s supplier contracts is therefore writing unenforceable clauses into French-law invoices; the statutory cap overrides the group template. This point connects directly to cash collection: our guide to recovering unpaid invoices in France, with late penalties and procedures, explains how those statutory penalties and the recovery fee are actually enforced.
II. How to Comply in Practice When You Run the Company From Abroad
A. Choosing and connecting your invoicing channel: approved platform, directory and compatible software
Compliance starts with a designation: your company must choose its approved platform. The DGFiP publishes the list of registered platforms, and the market includes offerings from large accounting-software publishers, banks and specialised providers, with interfaces in English for several of them. If your company already uses billing, cash-register or accounting software, that software can carry the invoices to their recipients and the data to the administration where the publisher has made it a compatible solution (“solution compatible”, software connected to an approved platform); if the company uses no software at all, invoices can be created directly on the chosen approved platform (Ministry of the Economy, how to equip your company). For a holding structure abroad with a single French operating subsidiary, the lightest workable setup is usually one approved platform chosen by the subsidiary, connected to whatever tool issues its invoices, plus a clear rule that no one in the group sends French domestic B2B invoices from Outlook or a foreign e-billing tool that bypasses the platform. Parallel invoicing circuits are the main source of duplicate or missing invoices, and duplicates are exactly what the tax authority’s cross-checks will flag once both sides of every transaction report into the same system.
Routing between platforms relies on a central directory (“annuaire central”). Article 289 bis of the CGI provides, and I quote, that “Par dérogation à l’article L. 151-1 du code de commerce, l’Etat met un annuaire central à la disposition des plateformes agréées”, built and updated from information transmitted by those platforms, so that each invoice finds its recipient’s platform (Article 289 bis, III of the CGI). In practice this means your company must keep its directory data current with its platform: its SIREN, its chosen platform and its receiving address. A subsidiary that changes its platform without updating its routing data risks invoices piling up undelivered on the old platform while suppliers believe they have billed correctly. The same paragraph of the article adds that a decree sets the terms for changing platforms, including minimum services the former platform must keep providing for at least one year after the switch (Article 289 bis, III of the CGI), which protects you against an abrupt cutoff but does not dispense you from organising the migration. Contracts with public bodies keep their own logic: Article 289 bis expressly applies without prejudice to the public-procurement invoicing rules of Article L. 2392-1 of the Public Procurement Code (Article 289 bis, IV of the CGI), so invoices to ministries, hospitals and local authorities continue through the dedicated public-sector channel your French team already uses, in parallel with the new domestic B2B channel.
Running the company from abroad changes nothing about record-keeping, and the reform makes those records more exposed. Article 286 of the CGI requires every VAT-registered person to file its opening declaration, provide its business details and, crucially, to keep its books and supporting documents, including purchase invoices, under the conditions of Article L. 102 B of the Tax Procedures Book (Article 286, I of the CGI). Article 289 of the CGI separately requires the business to keep a copy of every invoice issued and to guarantee the authenticity, integrity and legibility of invoices from issuance to the end of retention (Article 289, I and V of the CGI). The approved platform stores and archives, but legal responsibility for completeness stays with your company: if the platform archives only what it received, and your sales team issued two invoices outside the platform, the archive is incomplete and the company is liable. Keep also the “piste d’audit fiable”, the reliable audit trail the law describes as documented and permanent controls set up by the business that link each invoice to the underlying supply of goods or services: “des contrôles documentés et permanents sont mis en place par l’entreprise et permettent d’établir une piste d’audit fiable entre la facture émise ou reçue et la livraison de biens ou prestation de services qui en est le fondement” (Article 289, VII of the CGI). Concretely, that means signed contracts or accepted quotes, delivery notes or time sheets, and the invoice, all reconcilable by number. A foreign director who approves deals over email from abroad should make sure those emails feed the French file: an invoice whose underlying supply cannot be documented is fragile in an audit, electronic channel or not. The BODACC (Bulletin officiel des annonces civiles et commerciales, the official gazette where company registrations and insolvency openings are published) and the Kbis extract from the trade register (“greffe”, the court clerk’s office holding the RCS, Registre du commerce et des sociétés, the French company register) play no direct role in invoicing, but the SIREN number those registrations give you becomes the routing key of every invoice, so a company whose registration details are outdated starts the reform with a handicap.
B. What non-compliance costs, and your checklist before 1 September 2026
The fines are specific to the reform and sit in Article 1737 of the CGI. For issuance, the wording is exact and worth reading in full: “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, III of the CGI). Fifty euros per invoice that should have travelled through the approved platform but did not, capped at 15,000 euros per calendar year. For reception, the procedure is graduated: where the administration finds that a business does not use an approved platform to receive electronic invoices as Article 289 bis requires, it formally orders compliance within three months (“elle le met en demeure de s’y conformer dans un délai de trois mois”); persistence after that period draws a 500-euro fine, then a fresh three-month order, then 1,000 euros, and a further 1,000 euros after each subsequent three-month period of persistence following an unsuccessful formal order (Article 1737, IV bis of the CGI). Platforms themselves face 50 euros per invoice mishandled, capped at 45,000 euros per year (Article 1737, IV of the CGI). One mitigating point exists: the fines for missing invoices, invoice errors, issuance failures and platform transmission failures do not apply to a first offence committed in the current calendar year and the three preceding years where the breach was repaired spontaneously or within thirty days of a first request from the administration (Article 1737, V of the CGI). That leniency rewards the company that fixes its setup at the first warning; it does not protect the company that ignores the warning.
Beyond the fines, the reform changes the audit landscape. URSSAF (Unions de recouvrement des cotisations de sécurité sociale et d’allocations familiales, the bodies collecting French social-security contributions) and the DGFiP already cross-check payroll and VAT data, and electronic reporting hands the tax authority structured, near-real-time transaction data it previously reconstructed from PDFs during audits. A French subsidiary whose reported turnover, intra-group service fees or supplier costs diverge from the data its counterparties report will surface automatically. Foreign groups should therefore treat the invoicing project as a data-consistency project: align the subsidiary’s accounting codes, its transfer-pricing documentation for management fees and royalties, and the figures the parent consolidates, before the reporting channel goes live. If your group is already facing questions from the contribution-collection side, our guide to URSSAF audits for foreign-owned French companies explains the control procedure and how to challenge assessments from abroad.
Practical checklist for a foreign owner before 1 September 2026. First, confirm your company’s size category and therefore its issuance deadline, remembering that reception by September 2026 applies in all cases. Second, choose the approved platform, sign the contract, and make sure the platform or the connected software covers both issuance and reception plus electronic reporting data, not issuance alone. Third, verify the directory data: SIREN, receiving address and platform designation current on both sides, for the company and for its main French customers and suppliers. Fourth, update the invoice template with the four new mandatory items, especially the customer SIREN field and the operation category, and align the payment-terms clause with the sixty-day statutory cap. Fifth, close the parallel circuits: forbid domestic B2B invoicing from email or foreign tools that bypass the platform, and route public-sector invoices through their dedicated channel. Sixth, organise archiving and the audit trail: platform storage plus contract, delivery and payment records reconciled by invoice number, with a French-translation procedure ready for English-language documents. Seventh, brief whoever approves and pays: the director abroad, the French accountant (“expert-comptable”, the regulated French chartered accountant) and any de facto manager, so that a change of provider or software never silently disconnects the platform. Eighth, calendar the e-reporting deadlines for business-to-consumer and cross-border flows alongside the VAT return calendar, so the finance team treats them as one filing discipline.
Conclusion
France is replacing the emailed PDF with a structured invoice that travels through an approved platform into a central directory, on a timetable that starts on 1 September 2026 with reception for every company and issuance for large companies and ETIs, then extends issuance to SMEs and micro-enterprises on 1 September 2027. The legal machinery is already in force: Article 289 bis of the CGI defines the electronic channel and the central directory, Article 290 organises electronic reporting through the chosen platform, Articles L. 441-9 and L. 441-10 of the Commercial Code frame invoice content and payment deadlines, and Article 1737 of the CGI prices non-compliance at 50 euros per invoice up to 15,000 euros a year, with a graduated warning procedure for companies unable to receive. For a company run from abroad, the risk is less the technology than the distance: an outdated SIREN record, a parallel invoicing habit in the parent’s system, or an invoice template missing the new fields will each generate fines or blocked invoices without anyone in Paris noticing immediately. Designate the platform now, connect issuance, reception and reporting in a single setup, update the template, close the side channels and reconcile the data the administration will now see on both sides of every transaction. Done before September 2026, this is an administrative project; done late, it becomes a penalty file.