Since 1 September 2026, every company in France must be able to receive electronic invoices, and large and mid-sized companies must also issue them in electronic form. If you own a French SAS or SARL from London, New York, Dubai or Singapore, this reform reaches you directly: your French company cannot keep sending PDF invoices by email as if nothing had changed. The tax administration now expects structured electronic invoices that travel through approved platforms, and it punishes companies that stay outside the circuit. This article explains, in plain English, what the reform requires from a foreign-owned French company, by which date, through which platform, with which mandatory invoice details, and what happens if you ignore it. You will find the exact legal texts, the official calendar published by the tax authorities, the fines provided by the Tax Code and the Commercial Code, one court decision that shows why the small print on your invoices matters, and a practical checklist you can follow from abroad.
I. Must My French Company Receive and Issue Electronic Invoices?
The short answer is yes for receiving, and yes for issuing, but not on the same date for every company. The distinction between the two obligations is the key to the whole reform, and foreign owners often confuse them. Receiving capacity has been mandatory for all businesses since 1 September 2026. Issuing electronic invoices is already mandatory for large companies and intermediate-sized companies, while small businesses keep a grace period until 1 September 2027. Your company size therefore decides your issuing deadline, but nothing exempts you from receiving.
A. Which French Companies Must Receive E-Invoices Since 1 September 2026?
Every business established in France that is liable for French VAT must be able to receive electronic invoices since 1 September 2026, whatever its size. The tax administration states this without ambiguity: Toutes les entreprises, quelle que soit leur taille, sont concernées par la réforme dès le 1er septembre 2026, car elles doivent toutes être en capacité de recevoir des factures électroniques à compter de cette date. The Ministry of the Economy confirms the entry into force in the same terms: La réforme de la facturation électronique entre entreprises est entrée en vigueur le 1er septembre 2026. A one-person SAS owned from abroad is concerned exactly like a large group, because the obligation attaches to the French company, not to the residence of its shareholder or director.
To understand who is concerned, you need three French acronyms. VAT is called TVA (taxe sur la valeur ajoutée) in France. A company liable for VAT is called an assujetti, which means a taxable person. The SIREN is the unique nine-digit identification number given to every business registered in France; it appears on the Kbis, which is the official company identity card issued by the greffe, the registry office of the commercial court. If your French structure holds a SIREN and falls within VAT, it must receive electronic invoices, even if it benefits from the franchise en base, the French scheme that exempts very small turnovers from charging VAT. The reform expressly covers businesses under franchise en base, which surprises many foreign founders who assumed that no VAT means no invoicing duties.
The receiving obligation covers domestic business-to-business transactions, meaning purchases and sales of goods or services between two businesses established in France and liable for French VAT. Your French SAS must therefore be technically able to accept an electronic invoice from its French electricity supplier, its telecom operator, its accountant or any French supplier that already issues in electronic format. In practice, being able to receive means having chosen a reception channel: a plateforme agréée, which is a private invoicing platform registered with the tax administration, or, during the transition, a compatible dematerialisation operator. The company must also appear correctly in the national directory (annuaire) so that suppliers can route invoices to it. A foreign director who never opens a French professional mailbox and never designates a platform will simply stop receiving supplier invoices, which leads to unpaid bills, interrupted services and late-payment penalties.
Two companion duties complete the picture for transactions that stay outside electronic invoicing. When your French company sells to private individuals in France, or to customers established outside France, there is no electronic invoice as such, but the company must transmit transaction data to the tax administration electronically. This is called e-reporting. A foreign-owned e-commerce SAS selling to French consumers, or a consulting SARL billing American clients, must therefore still set up electronic data transmission for those flows. The calendar for e-reporting follows the same timetable as issuing, described below. If your activity mixes French business clients, foreign clients and private consumers, which is the normal case for a subsidiary created by a foreign group, you must handle both circuits at once: electronic invoices for French business customers, and e-reporting for the rest.
The legal root of the invoicing duty is old. Article 289 of the French Tax Code (Code général des impôts, CGI) provides that Tout assujetti est tenu de s’assurer qu’une facture est émise for supplies of goods and services made to another taxable person. Commercial law adds a parallel duty in article L. 441-9 of the Commercial Code: Tout achat de produits ou toute prestation de service pour une activité professionnelle fait l’objet d’une facturation. The 2026 reform does not create invoicing; it changes its mandatory form for domestic business-to-business flows. That is why the tax administration could make reception universal from day one: the invoice already had to exist, only its channel is changing.
VAT registration is the foundation on which everything rests. Article 286 of the Tax Code requires every taxable person, dans les quinze jours du commencement de ses opérations, to file a declaration with the tax office, and article 283 recalls that la taxe sur la valeur ajoutée doit être acquittée par les personnes qui réalisent les opérations imposables. If you are still setting up your French presence, read our pillar guide for foreign founders on setting up a company in France: bank account, Kbis, VAT and first hire, and our detailed article on VAT number registration, invoicing and refunds for foreign-owned companies. Without a clean VAT position, your electronic invoices will carry wrong tax mentions and your e-reporting will be inconsistent with your VAT returns, which article 287 of the Tax Code requires from tout redevable de la taxe sur la valeur ajoutée within the time limit set by order. A company whose Kbis registration itself is blocked faces an even earlier problem, described in our article on Kbis blocked: INPI single window and greffe rejection.
B. When Must My Company Start Issuing Electronic Invoices: 2026 or 2027?
The issuing obligation depends on company size, and the two waves are exactly one year apart. Since 1 September 2026, large companies (grandes entreprises) and intermediate-sized companies (entreprises de taille intermédiaire, ETI) must issue all their domestic business-to-business invoices in electronic format and transmit transaction and payment data to the administration. Small and micro-businesses, including freelancers under the auto-entrepreneur scheme, have until 1 September 2027 to issue electronically. The official notice states that les petites et micro-entreprises (cela concerne les auto-entrepreneurs) auront jusqu’au 1er septembre 2027 pour émettre électroniquement leurs factures, and that data transmission follows the same calendar.
Most foreign-owned French subsidiaries are small businesses and therefore fall in the 2027 wave for issuing. That does not mean waiting is safe. First, the receiving obligation already applies to them since September 2026, as explained above. Second, their large French customers already issue electronic invoices and increasingly refuse paper or simple PDF, which means a small supplier that cannot respond in the same format looks unreliable and slows down payment. Third, setting up the platform, the directory listing, the chart of accounts mapping and the internal validation process takes several weeks, especially when the director lives abroad and signs through delegated powers. Starting in early 2027, or even at the end of 2026, is the realistic timetable for a foreign-managed small SAS.
Size is assessed under the French definitions that distinguish micro, small, intermediate and large companies by headcount, balance-sheet total and turnover. A French holding company owned from abroad that itself has few employees can still belong to a large group, and group-level thresholds may pull it into the 2026 wave depending on consolidation rules applied by its provider. When in doubt, ask your French accountant (expert-comptable) to confirm in writing which wave your company belongs to, and keep that written confirmation: in a tax audit, the good faith of the company counts, and a dated written analysis from its accountant supports it.
Three frequent misunderstandings deserve correction. A company under franchise en base must still receive electronic invoices and, from its wave date, issue them, even though it charges no VAT; its invoices simply state the legal ground for the exemption instead of a VAT amount. A French company whose customers are all outside France issues no domestic electronic invoices, but it still must receive them from French suppliers and still owes e-reporting on its foreign and consumer flows. A branch (succursale) of a foreign company registered in France is treated like a French business for these duties when it carries out taxable transactions in France. Our comparison of branch versus subsidiary in France explains which vehicle you operate and what follows for registration and tax.
Missing the issuing deadline is punished directly. Article 1737, III of the Tax Code 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 euros par facture, sans que le total des amendes appliquées au titre d’une même année civile puisse être supérieur à 15 000 euros. Fifty euros per invoice adds up fast for a company issuing hundreds of monthly invoices, and the cap is annual, not global. Refusing the reception circuit is punished separately: when the administration finds that a taxable person fails to use an approved platform for receiving, elle le met en demeure de s’y conformer dans un délai de trois mois, and persistent failure leads to fines of 500 euros then 1,000 euros. The message is clear: the administration first orders compliance, then fines.
II. How Does a Foreign Owner Put a French Company on E-Invoicing and Survive a Tax Audit?
Compliance has two faces: choosing the right technical channel before the deadline, and making every invoice legally waterproof so that it proves the debt, supports the VAT and resists challenges. Foreign owners often delegate everything to a provider and sign nothing, which is precisely how mistakes become systematic. The director remains responsible, even when living abroad, so the method below keeps you in control without requiring you to move to France.
A. Which Platform Must I Choose and What Must Each Invoice Contain?
France chose an open network rather than a single state portal for business-to-business invoices. Your company must send and receive through a plateforme agréée, a private platform immatriculated by the tax administration, or through an opérateur de dématérialisation connected to one. The former Portail Public de Facturation, the free state platform once planned as the default hub, was abandoned in that role; its functions for public procurement survive through Chorus Pro, the portal used for invoices addressed to public bodies. In practice, your French accountant or your invoicing software vendor will propose a registered platform: check its registration on the official list published by the administration, confirm that it handles both issuing and receiving, and confirm that it transmits the required data extracts to the tax authorities automatically.
The service-public.fr business portal and the impots.gouv.fr professional pages describe the calendar, the directory and the platform list in English and French, and they remain the safest practical references alongside your accountant. Keep dated screenshots or PDF exports of the official pages you relied on, because the administration updates its doctrine regularly and an auditor may ask what information you had at the time. The same discipline applies to your contracts: general conditions of sale (conditions générales de vente, CGV) are the backbone of business negotiation, since article L. 441-1 of the Commercial Code states that dès lors que les conditions générales de vente sont établies, elles constituent le socle unique de la négociation commerciale. Align your CGV, your invoice template and your platform settings before the first electronic invoice leaves your system.
The content of an invoice is governed by article 289 of the Tax Code, whose implementing decree lists the mandatory mentions: identification of both parties with names, addresses and VAT numbers, invoice number and issue date, date of the sale or service, quantity and precise description of goods or services, unit price excluding VAT, applicable VAT rate and amount, reductions, and, where relevant, the legal reference for exemption or reverse charge. Commercial law repeats and completes these mentions in article L. 441-9, which also requires the payment date, the discount terms for early payment, the late-penalty rate, the fixed recovery fee, and the purchase-order number when the buyer issued one. A structured electronic invoice (formats Factur-X, UBL or CII) carries these mentions as data, not as free text, which means your product catalogue, VAT codes and customer master data must be clean before migration. A company that bills in English to reassure its foreign shareholder must still issue the French-law mentions; nothing forbids adding an English courtesy translation, but the French legal mentions control in case of dispute.
Payment terms deserve special attention because they are the most litigated invoice mention. The default rule in article L. 441-10 of the Commercial Code is that 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 alternative when expressly agreed and not abusive toward the creditor. Late penalties run by law: les pénalités de retard sont exigibles sans qu’un rappel soit nécessaire, at no less than three times the legal interest rate, plus a fixed recovery fee set by decree, currently forty euros. A Cour de cassation decision of 15 September 2015 (pourvoi number 14-17.116) shows why the back of the invoice is not decoration: the Commercial Chamber approved an appeal court that had applied a nine percent late-penalty rate printed on the back of two invoices, holding that la cour d’appel a pu retenir que ces conditions de paiement étaient entrées dans le champ contractuel. If penalty mentions printed on invoices can bind the customer, their absence or inconsistency across your electronic templates can cost you real money when a French customer pays late. Our guide on recovering unpaid invoices in France explains how those mentions support fast-track recovery.
Retention is the second pillar of audit survival. Article L. 123-22 of the Commercial Code provides that les documents comptables et les pièces justificatives sont conservés pendant dix ans, and article 286 of the Tax Code requires taxable persons to keep invoices and supporting documents under the conditions of article L. 102 B of the Tax Procedures Book. Electronic invoices must therefore be archived in their original structured format with integrity guarantees, not merely as printed PDFs in a drawer. Your platform contract must state who archives, for how long, in which format, and how you recover everything if you change provider. A foreign owner should test the export once a year and store a copy outside the platform, because losing ten years of invoices during a provider change is an entirely preventable disaster.
B. What Fines Apply and How Do I Fix a Wrong or Missing E-Invoice From Abroad?
The sanction system combines tax fines, commercial fines and the ordinary consequences of defective invoices: lost VAT deductions for the customer, rejected evidence in court, and delayed payments. On the tax side, the scale is set by article 1737 of the Tax Code: 50 euros per invoice issued outside the electronic channel, capped at 15,000 euros per calendar year for the company, plus 50 euros per invoice charged to a faulty approved platform up to 45,000 euros, plus the formal-notice procedure and the 500 then 1,000 euro fines for refusing the reception circuit. On the commercial side, article L. 441-9 punishes any invoicing breach with an administrative fine that ne peut excéder 75 000 euros pour une personne physique et 375 000 euros pour une personne morale, doubled in case of repetition within two years. These two regimes stack: the same missing invoice can trigger both a tax fine and a commercial fine, and neither replaces the customer’s right to refuse payment of a defective invoice.
Fixing an error follows one strict rule: never quietly rewrite history. Article 289, V of the Tax Code treats any correcting document as an invoice in its own right: only a document that refers to the initial invoice specifically and unequivocally counts, and it must carry all the required mentions. In practice, you issue a corrective invoice (facture rectificative) or a credit note (avoir) that states the number and date of the initial invoice, describes exactly what is corrected, and travels through the same electronic channel. A credit note cancels all or part of the initial invoice; a corrective invoice replaces the wrong mentions. Both must be archived with the initial invoice for ten years, because the auditor reconstructs the chain. Deleting or editing an issued invoice inside your software, even in good faith, breaks that chain and looks like concealment.
A missing invoice is worse than a wrong one. Article 1737 punishes fictitious invoices and missing invoices with a fine equal to fifty percent of the sums concerned, reduced when the transaction was properly recorded. Beyond fines, a company that cannot produce its purchase invoices loses the corresponding VAT deduction, and a company that cannot produce its sales invoices cannot prove the debt in court. French commercial courts give real weight to accepted invoices: an invoice sent and never protested, supported by delivery notes and consistent accounting, regularly carries the day, while an invoice contradicted by the company’s own books fails. Keep delivery proofs, order confirmations, time sheets and bank statements aligned with your invoices; in a dispute run from abroad, those documents are your witnesses.
Companies based in Paris and the Île-de-France region face the same national rules, with two local practical points. Commercial disputes over invoices fall to the commercial courts of the Paris conurbation, now organized around the Tribunal des activités économiques de Paris for Paris cases, and enforcement moves fast in the capital because bailiffs (commissaires de justice) serve process quickly. Deadlines are therefore felt more sharply: a Paris supplier that receives no compliant invoice will escalate sooner, and a Paris customer that is billed defectively will deduct or delay payment with professional routine. If your registered office (siège social) is domiciled in Paris through a domiciliation company while you live abroad, make sure the domiciliation address actually forwards platform notifications and tax letters the same day; many foreign owners discover audits months late because mail slept at the domiciliation agent.
Here is the minimum checklist to run from abroad before the end of the year. Confirm in writing with your accountant which wave your company belongs to and which flows need e-reporting. Choose a registered platform, sign the mandate, appear in the directory, and test one full cycle: issue, receive, correct. Clean your customer and product data so VAT numbers, SIREN entries and VAT rates are exact. Align CGV, invoice template and platform parameters, including payment deadlines, penalty rate and recovery fee. Organize ten-year archiving with an annual export test. Train one person, inside or outside the company, who checks the platform weekly and forwards anything urgent to you. Record every step with dates, because an auditor judges diligence as much as results. Our article on the first corporate tax calendar, filings and penalties completes this calendar with the tax filings your invoices feed.
Conclusion
Electronic invoicing in France is no longer a project; since 1 September 2026 it is daily life for every French company, including the smallest SAS held from abroad. Reception is already mandatory for all, issuing is mandatory for large and intermediate companies now and for small businesses on 1 September 2027, and e-reporting covers everything else on the same timetable. The legal framework is demanding but readable: article 289 of the Tax Code commands invoicing, article L. 441-9 of the Commercial Code details its mentions, article L. 441-10 caps payment deadlines and arms creditors with automatic penalties, and article 1737 punishes those who stay outside the electronic circuit invoice by invoice. The courts, for their part, take invoice mentions seriously enough to enforce a penalty rate printed on the back of an invoice. A foreign owner who chooses a registered platform now, cleans invoice data, aligns general conditions and organizes ten-year archiving will cross the reform without fines and with faster-paying customers. The one who waits for 2027 to think about 2026 duties will pay to learn the difference.
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