{"id":2138607,"date":"2026-10-04T19:57:31","date_gmt":"2026-10-04T17:57:31","guid":{"rendered":"https:\/\/kohenavocats.fr\/2026\/10\/04\/foreign-company-france-e-invoicing-mandate-platform-penalties-abroad\/"},"modified":"2026-10-04T19:59:48","modified_gmt":"2026-10-04T17:59:48","slug":"foreign-company-france-e-invoicing-mandate-platform-penalties-abroad","status":"publish","type":"post","link":"https:\/\/kohenavocats.fr\/en\/2026\/10\/04\/foreign-company-france-e-invoicing-mandate-platform-penalties-abroad\/","title":{"rendered":"Your French Company and Mandatory E-Invoicing Since 1 September 2026: Platform, Deadlines and Getting Paid From Abroad"},"content":{"rendered":"

You formed a company in France, you live abroad, and until recently invoicing looked like the easy part: your accountant issued PDFs, you emailed them to clients, suppliers emailed theirs, and the VAT return followed. That world ended on 1 September 2026. France has switched business-to-business invoicing to a mandatory electronic circuit, and every French company is concerned from day one, including a small SAS (soci\u00e9t\u00e9 par actions simplifi\u00e9e, the flexible joint-stock company most foreign founders choose) owned and managed from London, New York, Dubai or Singapore. This article explains, in practical terms, what your French company must do now, which deadlines apply to it, which platform it must use, which new invoice details it must show, and how you enforce payment or defend a dispute from abroad under the same rules. The reform is described on the official economy ministry page in these terms: the business-to-business e-invoicing reform took effect on 1 September 2026 (official guidance of the Ministry of the Economy on e-invoicing<\/a>). From that date, the administration states: every business, whatever its size, must be able to receive electronic invoices Sending follows a staggered calendar depending on company size, and the ordinary PDF sent by email no longer counts: an administration notice warns that an invoice a scanned paper invoice, an ordinary PDF or a document sent by simple email will no longer comply. For a foreign shareholder, the risk is concrete: invoices rejected by the circuit, VAT deducted on invalid documents, late-payment interest running against you, and administrative fines. The good news is that the system, once set up, gives you real-time tracking of every invoice and a faster, cheaper way to recover unpaid bills through the French order-to-pay procedure, even from abroad.<\/p>\n

Two warnings before we start. First, this guide concerns companies registered in France (SAS, SARL \u2014 soci\u00e9t\u00e9 \u00e0 responsabilit\u00e9 limit\u00e9e, the limited liability company \u2014 branch or subsidiary) that invoice and receive invoices in France. If you only sell from abroad without a French establishment, different VAT rules apply. Second, acronyms are explained at first use throughout: SIREN (the nine-digit company identification number shown on the Kbis, which is the official certificate of existence issued by the greffe, the commercial court clerk), TVA (taxe sur la valeur ajout\u00e9e, the French VAT), DGFiP (Direction g\u00e9n\u00e9rale des finances publiques, the tax authority), DGCCRF (Direction g\u00e9n\u00e9rale de la concurrence, de la consommation et de la r\u00e9pression des fraudes, the competition and fraud authority), PDP (plateforme agr\u00e9\u00e9e, the accredited private e-invoicing platform) and PPF (portail public de facturation, the free public portal), URSSAF (the social security collection agency), BODACC (the official gazette of commercial announcements) and RNE (registre national des entreprises, the national company register fed through the Guichet unique, the single online filing desk).<\/p>\n

I. What the French E-Invoicing Mandate Requires of Your French Company<\/h2>\n

A. Which Deadlines Apply to Your Company: Receiving Now, Issuing by Size<\/h3>\n

The single most important point is that there is no grace period for receiving. Since 1 September 2026, every taxable business established in France must be able to receive electronic invoices through the mandated circuit, whatever its size and whatever the nationality or residence of its shareholders and directors. Your SAS with one shareholder living abroad and no employee in France is covered exactly like a large French group. In practice this means your company must have designated its receiving channel \u2014 a PDP of its choice or the free PPF \u2014 and must appear correctly in the national directory (annuaire) so that suppliers can route invoices to it. An invoice that cannot reach you through the circuit is not merely an administrative inconvenience: your supplier cannot discharge its own issuing obligation, your accounts payable stalls, and your VAT deduction calendar slips.<\/p>\n

The obligation to issue electronic invoices follows a two-step calendar based on company size. Large companies (grandes entreprises) and intermediate-sized companies (entreprises de taille interm\u00e9diaire) have had to issue all their domestic business-to-business invoices in electronic format and transmit their transaction and payment data (e-reporting) since 1 September 2026. Small and medium-sized companies, micro-businesses and every small foreign-owned SAS or SARL follow on 1 September 2027: from that date they must be able to issue electronically and transmit e-reporting data. The official presentation confirms the scale: more than ten million businesses are concerned If your French company is a small structure \u2014 and most foreign founders’ vehicles are \u2014 your issuing deadline is therefore 1 September 2027, but your receiving obligation is already in force, and large customers may already require you to route through a platform simply so their own systems accept your invoices.<\/p>\n

Do not confuse the two complementary duties. E-invoicing (e-invoicing) covers domestic transactions between VAT-registered businesses established in France: the invoice itself travels through the platform in a structured format (Factur-X, UBL or CII), with statuses tracked in real time. E-reporting (e-reporting) covers the rest \u2014 sales to private individuals, intra-EU supplies, exports and certain services \u2014 where no electronic invoice circulates but the transaction data must still be transmitted to the administration through your platform. A foreign-owned SAS selling both to French professionals and to consumers or foreign clients must therefore handle both flows. Your accountant or platform should map, client by client and flow by flow, which invoices go through e-invoicing and which sales go through e-reporting, because a sale wrongly classified is a sale wrongly declared, with VAT and penalty consequences described below.<\/p>\n

The legal backbone of invoicing has not changed, only its channel. Under the Commercial Code, invoicing between professionals remains compulsory: “Le vendeur est tenu de d\u00e9livrer la facture d\u00e8s la r\u00e9alisation de la livraison ou de la prestation de services au sens du 3 du I de l’article 289 du code g\u00e9n\u00e9ral des imp\u00f4ts” (article L441-9 of the Commercial Code<\/a>). On the tax side, the VAT rule provides that “Tout assujetti est tenu de s’assurer qu’une facture est \u00e9mise, par lui-m\u00eame, ou en son nom et pour son compte, par son client ou par un tiers” (article 289 of the General Tax Code<\/a>). Who pays the VAT remains governed by the basic rule that “La taxe sur la valeur ajout\u00e9e doit \u00eatre acquitt\u00e9e par les personnes qui r\u00e9alisent les op\u00e9rations imposables” (article 283 of the General Tax Code<\/a>), with reverse-charge exceptions where the French VAT-registered customer accounts for the tax on supplies from a supplier established outside France. The reform adds a layer \u2014 the platform, the format, the directory, the new mandatory details \u2014 but a missing invoice still means a missing right to deduct and, in the worst case, a fine for missing or fictitious invoicing, since the Tax Code punishes “le fait de ne pas d\u00e9livrer une facture ou la note pr\u00e9vue \u00e0 l’article 290 quinquies et de ne pas comptabiliser la transaction” (article 1737 of the General Tax Code<\/a>). Keep every invoice and supporting document for ten years in euros and in French, as company records require: “Les documents comptables et les pi\u00e8ces justificatives sont conserv\u00e9s pendant dix ans.” (article L123-22 of the Commercial Code<\/a>).<\/p>\n

For the foreign owner, three practical consequences follow. First, check today that your company can actually receive: ask your accountant which PDP or PPF channel is designated, test the directory entry under your SIREN, and confirm who inside or outside the company monitors incoming invoices (accountant, local manager, or you through remote access). Second, diary the 1 September 2027 issuing deadline now, but consider moving earlier if your big customers demand platform-routed invoices \u2014 commercial pressure often bites before the legal deadline. Third, align your VAT position with the invoicing circuit: if your French company files French VAT returns (the CA3 periodic return and the VAT setup explained in our companion guide on VAT returns, CA3 deadlines and refunds for foreign-owned French companies<\/a>), the data in the returns must match the data in the platform. Divergence between platform flows and filed returns is exactly what automated tax checks will flag first.<\/p>\n

B. Which Platform, Which Format and Which New Invoice Details Your Company Must Use<\/h3>\n

Your company cannot simply choose any software: invoices must travel through an accredited platform (PDP) or the free public portal (PPF), directly or through a compatible solution connected to one of them. The list of accredited platforms is published and updated by the tax authority on impots.gouv.fr, and the administration invites every business to consult it and designate its platform for issuing, receiving or reporting. For a company run from abroad, the choice is operational, not just legal: who logs in, who validates, who corrects a rejected invoice, in which language, with which notification chain? A founder in another time zone who discovers a rejected invoice three weeks later pays late-payment interest in the meantime. Set up notifications to at least two people (you and your accountant or local contact), define who may issue a credit note (avoir) and who may accept a supplier invoice, and document these powers \u2014 a platform account shared informally with no written authority is a dispute waiting to happen.<\/p>\n

The format matters because the platform validates structure, not just content. The three accepted structured formats are Factur-X (a PDF with embedded structured data, the gentlest path for small companies), UBL and CII (pure structured messages for integrated accounting systems). Your existing PDF template is not enough on its own: as noted above, a scanned paper invoice, an ordinary PDF or a document sent by email will no longer comply with the rules. Ask your software provider explicitly whether it produces one of the three compliant formats and whether it connects to your chosen PDP, or whether you will create invoices directly on the platform \u2014 the administration confirms that a business without software can create invoices directly on its accredited platform. Test the full loop before the deadline: issue, transmission, customer receipt status, correction by credit note, and e-reporting transmission for non-invoiced flows.<\/p>\n

Four new mandatory details must appear on invoices from 1 September 2026, in addition to the classic list (names, addresses, dates, quantities, prices, VAT, payment date, penalty rate, recovery indemnity, order number). The most quoted is the customer’s SIREN number; the others concern the category of the transaction (sale of goods, supply of services, or both), the delivery address of the goods where different from the billing address, and information about payment of the VAT on account (acomptes) where relevant. For a foreign-owned company, the SIREN-of-customer rule has immediate bite: you must collect and verify every French professional customer’s SIREN before invoicing, and foreign customers without a SIREN fall under different reporting flows. Update your client onboarding form now \u2014 legal name, SIREN, billing and delivery addresses, VAT number, platform routing details \u2014 and clean the existing customer file, because the platform will reject or your customer will refuse invoices with missing details, and each rejection restarts the payment clock against you if you are the supplier.<\/p>\n

Non-compliance is punished on two fronts. Commercially, breach of the invoicing rules exposes the company to an administrative fine: any breach of these invoicing duties exposes the business to an administrative fine of up to 75,000 euros for an individual and 375,000 euros for a legal entity, doubled for a repeated breach within two years (article L441-9 of the Commercial Code). Fiscally, missing, inaccurate or fictitious invoicing can trigger the 50% penalty of article 1737 of the General Tax Code and loss of the customer’s VAT deduction, which your customer will then claim back from you contractually. Added to this is the reform’s own penalty for breach of the electronic invoicing and e-reporting duties (a per-invoice fine with a cap, applied per offender and per year), which your accountant should quantify for your volumes. From abroad, you cannot plead distance: directors of a French SAS or SARL are liable for organising compliance, and the company’s money pays first. Budget the platform cost, the customer-file cleanup and a short training session for whoever issues invoices \u2014 it is a fraction of one fine.<\/p>\n

A Paris and Ile-de-France note, since many foreign founders base their French company in the capital: no regional variation applies to the mandate itself \u2014 it is national \u2014 but Paris-area practice matters. Commercial courts and counterparties in Paris (Tribunal de commerce<\/a> de Paris for disputes, Paris Centre des finances publiques for VAT) process high volumes of platform-era disputes, large Paris customers imposed platform routing earliest, and Paris accountants moved first to PDP partnerships. If your registered office (si\u00e8ge social) is domiciled in Paris while you live abroad, make sure your domiciliation agent forwards platform notifications and tax mail without delay, and that your Greffe (registry) and RNE details \u2014 legal name, address, directors \u2014 are current, because directory routing and invoice details draw on them. A company whose address changed without an RNE update invoices with a wrong address and gets rejected by careful customers.<\/p>\n

II. How You Enforce Payment and Handle Invoice Disputes From Abroad<\/h2>\n

A. How Late-Payment Interest, the 40-Euro Indemnity and Invoice Proof Work in Your Favour<\/h3>\n

French law is unusually creditor-friendly on late payment between professionals, and the platform era makes proof easier because every invoice carries a timestamp and a status history. The Commercial Code sets the default payment period at thirty days after receipt of the goods or performance of the service, allows agreed terms up to sixty days from the invoice date, and tolerates forty-five days end-of-month only if expressly stipulated and not manifestly abusive (article L441-10 of the Commercial Code<\/a>). Your general terms or the contract should therefore state the agreed period clearly; from abroad, align it with the platform reality \u2014 a customer who receives instantly through the platform cannot credibly claim it never saw the invoice. Keep the clause short, bilingual if needed, but with the French version prevailing, and mirror it on every invoice’s payment-details block.<\/p>\n

When the due date passes, three rights arise automatically, without any reminder letter. First, late-payment penalties (p\u00e9nalit\u00e9s de retard) run from the day after the due date at the rate stated in your terms or, failing that, at the European Central Bank refinancing rate plus ten points; the rate cannot be set below three times the legal interest rate. Under article L441-10, late penalties accrue automatically from the day after the due date with no reminder letter required. Second, every late-paying professional automatically owes a fixed recovery indemnity per late invoice, set by decree at 40 euros. These two sentences should be quoted in your reminder letters, because French debtors know them and foreign debtors learn quickly. Third, you may claim proven additional recovery costs above the 40 euros on justification.<\/p>\n

Two court decisions show how judges apply these rules to real invoices, and both deserve the attention of a foreign owner who will never attend the hearing in person. In a 2015 ruling of the Commercial Chamber of the Cour de cassation (the supreme court for civil and commercial matters), case number 14-17.116, a supplier’s late-payment interest printed on the back of its invoices was upheld because the customer had never disputed that mention: the Court approved the appeal judges who found that “la cour d’appel a pu retenir que ces conditions de paiement \u00e9taient entr\u00e9es dans le champ contractuel” (decision of 15 September 2015, Cour de cassation, commercial chamber, no. 14-17.116<\/a>). The lesson is direct: print your penalty rate and recovery-indemnity clause on every invoice and in your terms, and an undisputed mention becomes part of the contract. Conversely, a missing mention leaves you arguing from scratch.<\/p>\n

The second decision is a May 2026 ruling of the Paris Court of Appeal, RG 23\/10014, which reads like a manual for platform-era invoice litigation. A supplier claimed late-payment interest and the 40-euro indemnities on three invoices paid late (with 137 days of accumulated delay), after an order-to-pay (injonction de payer<\/a>) and an opposition that sent the case to the commercial court. The Court of Appeal held that the debtor owed the penalties at the rate shown on the supplier’s own invoices \u2014 three times the legal interest rate, the statutory minimum \u2014 because the supplier’s own mention derogated from the customer’s purchasing terms, and it added the now-famous line that the fixed indemnity was owed by any debtor in late payment under article L441-10 of the Commercial Code, even though the invoices had since been paid It therefore ordered 526.86 euros of interest plus 120 euros (three times 40 euros) of fixed indemnities, while rejecting the order-to-pay costs as court costs. Three lessons for a company run from abroad: claim interest even after the principal is paid, because the right survives payment; itemise per invoice with dates, since the court verified each invoice’s issue and payment dates; and do not inflate the order-to-pay costs into the claim, because judges reclassify them. The ruling is published under RG 23\/10014 before the Paris Court of Appeal, Pole 4, Chamber 5, 20 May 2026, and its reasoning on article L441-10 is worth having your counsel cite in any reminder or petition.<\/p>\n

Proof of the invoice itself is the other half of the battle, and here the platform helps but does not replace good habits. An accepted, unprotested invoice remains strong evidence of the obligation between merchants, especially when backed by the order, the delivery note (bon de livraison) or service acceptance, the contract, and consistent accounting entries. Keep the full chain for each disputed invoice: order, proof of delivery or performance, invoice with platform timestamps and statuses, reminders, and the customer’s responses or silence. Silence after receipt, combined with partial payment or a request for a payment plan, weighs heavily. From abroad, organise this file as you go \u2014 a shared folder per customer with everything dated \u2014 because the French judge decides on documents, and a complete file presented by your lawyer wins cases without your physical presence.<\/p>\n

B. How You Recover an Unpaid Invoice From Abroad: Order to Pay, Opposition and Force Majeure Limits<\/h3>\n

The fastest recovery route for a contractual claim of a determined amount is the injonction de payer, the French order-to-pay procedure: a judge grants an enforceable payment order on your paper application, without a hearing, and the debtor is served and given one month to oppose (contester). The Code of Civil Procedure opens this route where “Le recouvrement d’une cr\u00e9ance peut \u00eatre demand\u00e9 suivant la proc\u00e9dure d’injonction de payer lorsque : 1\u00b0 La cr\u00e9ance a une cause contractuelle ou r\u00e9sulte d’une obligation de caract\u00e8re statutaire et s’\u00e9l\u00e8ve \u00e0 un montant d\u00e9termin\u00e9” (article 1405 of the Code of Civil Procedure<\/a>). File before the competent court \u2014 usually the commercial court (tribunal de commerce) of the debtor’s place for business debts, or the judicial court (tribunal judiciaire) depending on the parties \u2014 through French counsel with a power of attorney, the contract, the order, the delivery proofs, the platform-stamped invoices, the statement of account and the unsuccessful demand letter. No travel is needed: your lawyer represents the company throughout, and you sign and transfer documents electronically.<\/p>\n

If the debtor does nothing within the month, you ask for enforceability (apposition de la formule ex\u00e9cutoire) and instruct a commissaire de justice (the enforcement officer, formerly huissier) to seize or obtain payment \u2014 bank attachment (saisie-attribution), attachment of receivables, or negotiated payment. If the debtor opposes, as happened in the Paris case above, the order-to-pay converts into an ordinary adversarial case before the competent court, and the procedure continues with exchanges of pleadings; opposition is not a defeat, it is the normal second round, and your documented file carries over. Diary two traps: first, limitation \u2014 five years for commercial claims in principle, so do not let a foreign customer’s silence age your file; second, the debtor’s insolvency \u2014 check the BODACC and the insolvency register before spending on enforcement, because an order against a company in liquidation (liquidation judiciaire<\/a>) joins the queue of creditors instead of producing payment. A quick solvency check by your counsel before filing is money well spent.<\/p>\n

Debtors resist with three classic defences, and the platform era weakens all of them when your file is complete. The first is it never received the invoice: platform timestamps, receipt statuses and e-reporting records answer it, backed by your email reminders. The second is the goods or services were defective or late, so it applied penalties or set off amounts owed: here the contract governs \u2014 “Les contrats l\u00e9galement form\u00e9s tiennent lieu de loi \u00e0 ceux qui les ont faits.” (article 1103 of the Civil Code<\/a>) \u2014 and a judge compares the penalty clause, the proven delay or defect, and your late-payment interest symmetrically, exactly as the Paris court did when it confirmed 31,818.16 euros of delivery-delay penalties against the supplier while awarding the supplier its own late-payment interest. The third is force majeure, and it fails more often than debtors hope. The Civil Code defines it strictly: “Il y a force majeure en mati\u00e8re contractuelle lorsqu’un \u00e9v\u00e9nement \u00e9chappant au contr\u00f4le du d\u00e9biteur, qui ne pouvait \u00eatre raisonnablement pr\u00e9vu lors de la conclusion du contrat et dont les effets ne peuvent \u00eatre \u00e9vit\u00e9s par des mesures appropri\u00e9es, emp\u00eache l’ex\u00e9cution de son obligation par le d\u00e9biteur.” (article 1218 of the Civil Code<\/a>). In the Paris case, the supplier blamed the March 2021 Suez Canal blockage for late delivery, but the court dismissed the defence because a Wikipedia extract about the 2021 Suez Canal obstruction could not prove the impact of that event on the delivery delays at issue, adding that the supplier produced no evidence of the precise impact on its own business. A famous event is not proof: your opponent must prove the concrete causal link to its own failure, and general press cuttings do not suffice. When you are the creditor facing such a defence, ask for the missing proof in your pleadings; when you are the debtor invoking it, build the file event by event, document by document.<\/p>\n

Organise the whole function so it runs without you being in France. Give your French lawyer a standing file: company Kbis, articles, delegation of powers to the person who signs demands, template demand letter citing articles L441-9 and L441-10, and the platform access needed to export invoice histories. Give your accountant a monthly closing checklist: all issued invoices transmitted, all received invoices accepted or disputed within days, e-reporting sent, VAT return reconciled with platform data, doubtful receivables flagged before they age. And set escalation thresholds in writing: reminder at due date plus seven days, formal demand (mise en demeure) with interest calculation at plus thirty days, order-to-pay petition above a defined amount or age. A foreign owner who runs this calendar from abroad, with counsel and accountant each knowing their cue, recovers faster and cheaper than an owner who discovers the unpaid pile at year-end.<\/p>\n

Conclusion<\/h2>\n

Your French company must receive electronic invoices through the mandated circuit since 1 September 2026, whatever its size, and must issue electronically from 1 September 2026 if it is large or intermediate-sized and from 1 September 2027 if it is a small or micro-business \u2014 which covers most foreign-owned SAS and SARL structures. Designate the PDP or PPF channel now, clean the customer file with SIREN numbers and addresses, add the four new mandatory details to the template, test the Factur-X, UBL or CII loop, and reconcile platform data with VAT returns every month. The sanction for neglecting the circuit is not theoretical: fines up to 375,000 euros for a legal entity on the commercial side, loss of VAT deduction and heavy tax penalties on the fiscal side, and interest running against you as a late payer. Symmetrically, the same law arms you as a creditor: penalties without reminder, 40 euros per late invoice even after payment, contract clauses that bind an undisputed debtor, and the order-to-pay procedure that a French lawyer runs for you from filing to enforcement. Run the calendar from abroad with two partners \u2014 a platform connected to a responsive accountant, and counsel holding a standing enforcement file \u2014 and the reform becomes what it promises: faster invoices, fewer disputes, and unpaid bills recovered without boarding a plane. For related VAT mechanics, keep alongside this guide our analysis of VAT returns, CA3 deadlines and refunds for foreign-owned French companies<\/a>.<\/p>\n","protected":false},"excerpt":{"rendered":"

Since 1 September 2026 every French company must receive electronic invoices through an accredited platform or the public portal, and issue them from 2026 or 2027 by size. 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