{"id":2139446,"date":"2026-10-05T19:57:26","date_gmt":"2026-10-05T17:57:26","guid":{"rendered":"https:\/\/kohenavocats.fr\/2026\/10\/05\/foreign-company-france-e-invoicing-obligation-receive-issue-penalty-abroad\/"},"modified":"2026-10-05T19:57:26","modified_gmt":"2026-10-05T17:57:26","slug":"foreign-company-france-e-invoicing-obligation-receive-issue-penalty-abroad","status":"publish","type":"post","link":"https:\/\/kohenavocats.fr\/en\/2026\/10\/05\/foreign-company-france-e-invoicing-obligation-receive-issue-penalty-abroad\/","title":{"rendered":"Your French Company Must Receive E-Invoices Since September 2026: How to Comply From Abroad, Issue by 2027, and Challenge a Penalty"},"content":{"rendered":"

If you run a French company from London, New York, Dubai or Singapore, 1 September 2026 changed your daily operations even if nobody told you. Since that date, every business established in France must be able to receive electronic invoices, while large companies and mid-sized companies must also issue their invoices electronically and transmit transaction data to the tax administration. Your small French subsidiary is not yet required to issue electronic invoices, but it must already be equipped to receive them, and its own issuing obligation starts on 1 September 2027. A supplier who simply emails you a PDF no longer meets the standard, and a customer who cannot receive your structured invoice through an approved channel may delay or refuse payment. This article explains, in plain English and for a business reader, what the French e-invoicing reform requires of a foreign-owned company, what each French acronym means, how to comply in practice when the managers live abroad, and how to react if an invoice is rejected, a fine is notified or a VAT reassessment follows. Every decisive statement below is anchored in an official text, and every remedy described is one you can actually operate from outside France. If you are still hesitating about the vehicle itself, read first our guide on choosing between a SAS, a SARL, a branch and a subsidiary when investing in France from abroad<\/a>, then come back here for the invoicing layer that applies to whichever vehicle you chose.<\/p>\n

I. What France requires of your company since 1 September 2026<\/h2>\n

The reform is often presented as an IT project. For a foreign shareholder it is better understood as a new layer of tax and commercial compliance, built on the VAT invoicing rules of the French Tax Code (Code g\u00e9n\u00e9ral des imp\u00f4ts, abbreviated CGI), on the Commercial Code (Code de commerce) for payment terms and invoice content, and on a network of approved digital platforms supervised by the administration. The official timetable is public and confirmed on the English pages of the French public service for businesses and on the Ministry of the Economy hub dedicated to the reform: generalised electronic invoicing is being rolled out gradually, with reception for everyone from 1 September 2026 and issuing obligations phased by company size between 2026 and 2027. Understanding which side of each deadline your company sits on is the first step, and understanding what counts as a compliant electronic invoice is the second.<\/p>\n

A. Who must receive, who must already issue, and who gets until 2027<\/h3>\n

The starting point is simple and applies to your company whatever its size: since 1 September 2026, all businesses established in France must be able to receive electronic invoices. There is no exemption for small companies, no exemption for companies owned by foreigners, and no exemption for companies whose directors live abroad. If your French SAS (soci\u00e9t\u00e9 par actions simplifi\u00e9e, the flexible joint-stock company most foreign investors choose) or your SARL (soci\u00e9t\u00e9 \u00e0 responsabilit\u00e9 limit\u00e9e, the limited liability company with stricter statutory rules) has only two invoices a month, it must still have a reception channel capable of receiving structured electronic invoices. Concretely, this means registering on an approved platform and appearing in the national directory (annuaire) so that your suppliers can route their invoices to you. A company that ignores this reception obligation does not merely miss a technical upgrade: its suppliers, once subject to the issuing obligation themselves, can no longer send it a valid invoice by ordinary email, and the whole payment chain slows down.<\/p>\n

The issuing obligation, by contrast, depends on the size of the company. Since 1 September 2026, large companies and mid-sized companies, known in French as ETI (entreprises de taille interm\u00e9diaire), must issue their invoices electronically and meet the associated e-reporting duties. Small and medium-sized companies (SME, or PME in French: petites et moyennes entreprises) and micro-companies keep one more year: they must start issuing electronic invoices and meeting e-reporting duties on 1 September 2027. Most French subsidiaries of foreign groups, holding companies and first operating companies fall into the SME or micro category and therefore issue under the 2027 deadline, but two traps await foreign founders. First, size is assessed at the level of the French company and, depending on the criterion, sometimes with reference to the group: a subsidiary that looks small locally but belongs to a large international group should verify its category with its accountant rather than assume it has until 2027. Second, even a company that only receives in 2026 must prepare its issuing process during that year, because the new mandatory invoice particulars, the platform contracts and the internal approval workflow cannot be improvised in August 2027.<\/p>\n

Alongside invoicing itself, the reform imposes e-reporting: the electronic transmission to the tax administration of data on transactions that are not covered by e-invoicing, typically sales to private consumers or to foreign customers, and of payment data. The calendar mirrors the issuing calendar, with large companies and ETIs concerned from 1 September 2026 and SMEs and micro-companies from 1 September 2027. For a foreign-owned French company selling both to French businesses and to consumers or export clients, e-invoicing and e-reporting together mean that nearly all turnover data flows to the administration in near real time. This changes the VAT control environment durably, as explained in our companion piece on VAT registration, fiscal representatives, OSS returns and VAT control for foreign-owned French companies<\/a>: discrepancies between reported data and VAT returns will be detected faster, and corrections should be made before the administration asks.<\/p>\n

One reassuring point, confirmed by the administration at the launch of the roll-out, is that the initial phase follows an approach of support and tolerance rather than immediate punishment: guidance published on the Ministry of the Economy hub states that the start-up phase of the generalised reform proceeds in a spirit of benevolence and tolerance by the administration. Tolerance is not an exemption, and it does not suspend the obligation, but it does mean that a company which can show real steps toward compliance, platform registration, updated templates and staff training, is in a far better position than a company which ignored the reform entirely. Document every step from now, because that file will be your evidence if a controller, a fine or a dispute arrives later.<\/p>\n

B. What counts as a compliant electronic invoice: platforms, directory, data and new mentions<\/h3>\n

A compliant electronic invoice under the reform is not a PDF attached to an email. It is a structured invoice, meaning an invoice whose data is organised in a computer-readable format, transmitted through an approved channel, and tracked through processing statuses visible to both parties. Three actors organise this circulation, and each has a French name worth learning. The PPF (portail public de facturation, the public invoicing portal) is the free public portal operated by the administration, historically known as Chorus Pro, which concentrates the directory of recipients, offers basic issuing and receiving functions, and collects the data transmitted for e-reporting. The PDP (plateformes de d\u00e9mat\u00e9rialisation partenaires, partner dematerialisation platforms) are private platforms registered with the administration that provide issuing, receiving, conversion and archiving services, often integrated with accounting software. The annuaire is the national directory in which every established business must be referenced with its delivery address so that any issuer can route invoices to it. Your company must therefore make two decisions: a reception address in the directory, and a channel, either the public portal directly or a partner platform, through which invoices flow in both directions.<\/p>\n

The legal backbone of this system remains article 289 of the CGI, which governs VAT invoicing in France. Its core principles survive the reform untouched: every taxable person must ensure that an invoice is issued for its supplies of goods and services to another taxable person, invoices must be stored in duplicate form, and documents that amend an initial invoice are treated as invoices themselves. The electronic layer is added by the same article, which provides that “Les factures \u00e9lectroniques sont \u00e9mises et re\u00e7ues sous une forme \u00e9lectronique quelle qu’elle soit.” That sentence matters for foreign managers because it confirms that the electronic form is now the ordinary channel between businesses, and that acceptance by the recipient, historically required for electronic transmission, is organised through the platform system rather than through a case-by-case email agreement. Read the full text of article 289 of the CGI on VAT invoicing<\/a> with your accountant before signing any platform contract, and check the version in force at the date you read it, since the article has been amended repeatedly to carry the reform.<\/p>\n

The same article also states the guarantee that the administration will control: The article requires the authenticity of origin, the integrity of content and the readability of each invoice to be guaranteed from the moment of issue until the end of its retention period. Authenticity of origin means the recipient can be sure the invoice really comes from the stated supplier; integrity of content means nobody altered the amounts, the VAT or the parties after issue; readability means a human and the administration can still read the invoice years later. Under the reform, the approved platforms provide this guarantee through structured formats, timestamps and lifecycle statuses: when a supplier invoice arrives on your platform, the statuses let you know in real time, through timestamping of the electronic invoice, at which processing stage it stands, from deposit to approval, payment and archiving. For a director living abroad, these statuses replace the old habit of asking the Paris office whether an invoice arrived: the platform is the single source of truth, accessible from anywhere.<\/p>\n

Content is the second half of compliance. Even a perfectly routed invoice fails if its mandatory particulars are missing. French commercial law starts from a blunt rule, stated in article L. 441-9 of the Commercial Code<\/a>: “Tout achat de produits ou toute prestation de service pour une activit\u00e9 professionnelle fait l’objet d’une facturation.” The seller must deliver the invoice upon completion of the supply or service, the buyer must claim it, and each party keeps a copy. The article then lists the particulars the invoice must carry: names and addresses of the parties and billing address where different, date of sale or service, quantity, precise description, unit price excluding VAT, price reductions, payment date, discount conditions, the rate of late penalties, the fixed recovery indemnity due on late payment, and the purchase order number where the buyer issued one. The reform adds new particulars from the same phased calendar, including the customer SIREN number (SIREN, syst\u00e8me d’identification du r\u00e9pertoire des entreprises: the nine-digit identifier of every French business, whose fourteen-digit establishment version is called SIRET), the distinction between delivery and billing addresses, and data needed for the administration to process the invoice automatically. The detailed list is set by decree under article 289 of the CGI, so verify the current decree with your accountant rather than copying an old template: an invoice template from 2023 almost certainly lacks the new fields.<\/p>\n

Two related duties complete the picture. First, accounting law requires that “Les documents comptables sont \u00e9tablis en euros et en langue fran\u00e7aise. Les documents comptables et les pi\u00e8ces justificatives sont conserv\u00e9s pendant dix ans.”, as stated in article L. 123-22 of the Commercial Code<\/a>. Ten years of storage, in euros and in French, means your platform archiving contract must guarantee long-term integrity, and that invoices drafted in English for the comfort of the foreign parent must exist in a French version that the tax auditor can read. Second, VAT registration duties apply from the very start of activity: article 286 of the CGI<\/a> provides that “Toute personne assujettie \u00e0 la taxe sur la valeur ajout\u00e9e doit : 1\u00b0 Dans les quinze jours du commencement de ses op\u00e9rations, souscrire au bureau d\u00e9sign\u00e9 par un arr\u00eat\u00e9 une d\u00e9claration conforme au mod\u00e8le fourni par l’administration.” A foreign founder who creates the company, obtains the Kbis (the official company identity extract issued by the commercial court registry, called greffe) and then forgets the VAT steps starts the e-invoicing story on the wrong foot, because the VAT identification number is the key that links the company to the directory, the platforms and e-reporting. Our guide to the annual legal calendar of a French company run from abroad<\/a> puts these recurrent duties in their yearly order.<\/p>\n

II. How to comply from abroad, and how to answer a fine or a reassessment<\/h2>\n

Distance changes nothing in the obligation and almost nothing in the method: every step below can be completed from outside France, provided the company gives its foreign manager the right digital accesses and its French accountant a clear mandate. The companies that suffer under the reform share one trait: the Paris accountant waits for instructions from the shareholder abroad, while the shareholder assumes the accountant handles everything. Break that deadlock with a written allocation of tasks, and work through the five steps in order.<\/p>\n

A. Five practical steps for a company managed from outside France<\/h3>\n

First, confirm your size category and your exact deadline in writing. Ask your French accountant for a short note stating whether the company is a micro-company, an SME, an ETI or a large company for the purposes of the reform calendar, and therefore whether the issuing and e-reporting duties start in 2026 or 2027. Keep that note with the company records. If the group later injects capital, hires heavily or exceeds thresholds, the category can change, so renew the question every year at the accounts meeting. Groups should also map intra-group flows now: invoices between the French company and its foreign parent are generally outside domestic e-invoicing, but the French side of those flows feeds e-reporting, and the VAT treatment may involve reverse charge. Article 283 of the CGI<\/a> allocates VAT in cross-border situations, providing for supplies by a taxable person not established in France that “la taxe est acquitt\u00e9e par l’acqu\u00e9reur, le destinataire ou le preneur qui agit en tant qu’assujetti et qui dispose d’un num\u00e9ro d’identification \u00e0 la taxe sur la valeur ajout\u00e9e en France”. In plain terms, when the foreign parent supplies the French subsidiary, the French subsidiary often accounts for the VAT itself, and that VAT must be consistent with the data transmitted through e-reporting. Misalignments here are the single most frequent trigger of questions from the VAT office.<\/p>\n

Second, choose and activate the platform channel before you need it. A company that only receives in 2026 still needs a live reception route: registration of the company in the directory, designation of the users allowed to approve invoices, and a rule that no supplier invoice is paid outside the platform. Managers in Paris and the Paris region (Ile-de-France) face exactly the same national rules as everywhere else in France; there is no Paris exemption and no Paris-specific portal, so a company with offices in Paris simply registers like any other, with the practical note that Paris-based accountants and approved platforms are numerous and that competition on fees is real. Ask for a demonstration of the full lifecycle in English if your team works in English, verify that the platform produces the new mandatory particulars automatically, and sign an archiving clause covering the full ten-year retention period. Then inform your regular suppliers of your directory address in writing, and ask them to confirm they can route to it: the first rejected invoice usually reveals a wrong directory entry, and it is far cheaper to discover it in a test than on a 80,000 euro invoice due in ten days.<\/p>\n

Third, rebuild the invoice templates and the general terms of sale. The reform is the right moment to audit every template the company uses: domestic sales invoices, intra-group recharge invoices, credit notes, periodic invoices and advance payment invoices. Each must carry the full list of particulars required by article L. 441-9 of the Commercial Code plus the new reform fields, in French, in euros for the tax amount, with the payment deadline, the late penalty rate and the fixed recovery indemnity. Remember that periodic invoicing, where several distinct supplies to the same customer in one calendar month are grouped on one invoice, remains possible under article 289 of the CGI but obeys its own issuing deadline at the end of that month, and that any document amending an initial invoice must reference it specifically and carry the full particulars. Update the general terms of sale (CGV, conditions g\u00e9n\u00e9rales de vente<\/a>) at the same time, because payment deadlines, discount terms and penalty rates stated on the invoice must mirror the contract. A mismatch between the contract and the invoice is exactly what a DGCCRF (Direction g\u00e9n\u00e9rale de la concurrence, de la consommation et de la r\u00e9pression des fraudes: the competition and consumer enforcement authority) inspector looks for during an invoice audit.<\/p>\n

Fourth, organise proof and archiving for ten years. Commercial disputes in France are often won or lost on invoices: commercial law allows flexible proof, since article L. 110-3 of the Commercial Code<\/a> states that “A l’\u00e9gard des commer\u00e7ants, les actes de commerce peuvent se prouver par tous moyens \u00e0 moins qu’il n’en soit autrement dispos\u00e9 par la loi.” An invoice accepted without protest has real probative weight before the commercial courts, but only if you can produce it, show where it came from, and prove it was not altered. The reform strengthens this logic: structured invoices with timestamps and statuses are harder to contest than PDFs in an inbox, and civil law gives full probative value to reliable copies, since article 1379 of the Civil Code<\/a> provides that “La copie fiable a la m\u00eame force probante que l’original.” Concretely, keep the platform archive plus an independent backup, keep the directory registration history, keep the written instructions sent to suppliers, and keep the approval logs showing who validated each invoice. A foreign director who can download this file in ten minutes answers a tax auditor or a commercial court far more convincingly than one who asks the former Paris bookkeeper to search old emails.<\/p>\n

B. Fines, refused invoices and VAT reassessments: how to react and how to challenge<\/h3>\n

The first painful experience under the reform is usually commercial, not administrative: a customer refuses your invoice, or your own accounts team cannot pay a supplier. When a customer says your invoice is not compliant, ask for the exact missing element in writing, referencing the platform rejection code where one exists, then correct and reissue within days. Never let an unpaid invoice drift because its form is disputed: French law caps payment deadlines strictly, and article L. 441-10 of the Commercial Code<\/a> provides that “Le d\u00e9lai convenu entre les parties pour r\u00e9gler les sommes dues ne peut d\u00e9passer soixante jours apr\u00e8s la date d’\u00e9mission de la facture.” The agreed period cannot exceed sixty days from the invoice date, with a contractually stipulated forty-five days end-of-month alternative, and late penalties run by right from the day after the due date shown on the invoice, without any reminder being needed. A customer who invokes a formal defect to pay late still owes the penalties and the fixed recovery indemnity once a compliant invoice is issued, so reissue fast, record the new due date, and claim the penalties in writing. If the customer persists, the fast-track order-to-pay procedure (injonction de payer<\/a>) before the commercial court remains available to foreign-owned companies on the same terms as to any other creditor, and the platform trail makes the claim easier to prove than before.<\/p>\n

The second risk is the administrative fine for invoicing breaches. Commercial inspectors can sanction missing or incomplete invoices on the basis of article L. 441-9 of the Commercial Code, which states that Any breach of these invoicing duties exposes the offender to an administrative fine of up to 75,000 euros for an individual and 375,000 euros for a legal entity. The ceiling doubles on a repeated breach within two years of the first sanction becoming final. These amounts punish the legal entity itself, so the foreign parent does not pay them directly, but they strike the French subsidiary balance sheet and the consolidated accounts. If a statement of objections (proc\u00e8s-verbal) is drawn up, do not ignore it and do not pay reflexively: request the full file, check which invoices and which missing particulars are actually targeted, verify whether the new reform particulars applied at the date of those invoices given the company size calendar, and submit written observations within the stated deadline, showing the platform registration, the corrected templates and the training steps. Inspectors and settlement procedures take documented remediation into account, particularly during a reform whose launch the administration itself placed under a tolerance approach. Where the fine is finally imposed, it can be challenged before the administrative court, and the challenge suspends neither the reflection nor the need for a lawyer admitted in France, so instruct counsel early rather than after the deadline expires.<\/p>\n

The third risk is tax: a VAT reassessment fed by the new data flows. E-reporting gives the VAT office a continuous view of your turnover, and inconsistencies between reported data, VAT returns (CA3) and the annual accounts draw automated questions. A question is not a reassessment: answer it within the deadline, reconcile the figures line by line with your accountant, and file corrective returns spontaneously where an error is confirmed, because spontaneous correction before any audit notice usually limits penalties and late interest. If a formal reassessment proposal arrives, check the procedure as carefully as the substance: the limitation periods, the burden of proof on each adjustment, the possibility of requesting the opinion of the departmental tax commission on factual matters, and the hierarchical appeal to the superior of the auditor. Most reassessments concerning foreign-owned SMEs are settled at this pre-litigation stage when the file is clean and the answers are precise. If litigation becomes necessary, the claim goes to the administrative court within two months of the rejection of the administrative complaint, and the judge decides on both the tax and the penalties. Throughout, keep the e-invoicing platform data consistent with the accounting: nothing weakens a taxpayer position faster than platform turnover figures that contradict the returns, and nothing strengthens it more than a documented correction trail.<\/p>\n

Finally, organise the company so that distance never becomes an excuse the administration can use against you. Give the French accountant a written engagement letter covering platform supervision, e-reporting filings and archiving; keep the platform administrator rights with at least two people, one of whom can act from abroad; calendar the 2027 issuing deadline now, with a mid-2027 dry run of outbound structured invoices to your main customers; and add the reform to the agenda of every annual accounts meeting. The English-language official pages of the public service for businesses and the Ministry of the Economy hub, respectively at the official English timetable for electronic invoicing<\/a> and the official guide to electronic invoicing for businesses<\/a>, are the two bookmarks every foreign director should keep, ahead of any private vendor brochure. Private platforms sell useful services, but only the official texts set the obligation, and only the official calendar sets your deadline.<\/p>\n

Conclusion<\/h2>\n

Since 1 September 2026, your French company must receive electronic invoices through the approved system, and it will have to issue them by 1 September 2027 at the latest if it is an SME or a micro-company, or already since 2026 if it qualifies as an ETI or a large company. The compliant invoice of this new era is a structured, timestamped, platform-routed document carrying the full Commercial Code particulars plus the new reform fields, stored in French for ten years and consistent with the VAT data transmitted through e-reporting. For a company managed from abroad, compliance is a matter of organisation rather than presence: confirm the size category in writing, activate the directory and platform channel, rebuild templates and terms of sale, and archive proof so that any invoice can be produced and explained from anywhere in the world. Refused invoices should trigger immediate written correction, not silent waiting; administrative fines should trigger a documented adversarial response, not reflexive payment; VAT questions should trigger fast reconciliation, not silence. The reform rewards companies whose files are orderly and punishes those whose invoicing drifts. Put your company in the first group now, while the administration tolerance phase still leaves room to correct the starting errors, and the 2027 deadline will arrive as a routine upgrade rather than a crisis.<\/p>\n","protected":false},"excerpt":{"rendered":"

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