{"id":2150909,"date":"2026-10-18T01:00:27","date_gmt":"2026-10-17T23:00:27","guid":{"rendered":"https:\/\/kohenavocats.fr\/2026\/10\/18\/foreign-company-france-e-invoicing-deadline-platform-fines-abroad\/"},"modified":"2026-10-18T01:00:27","modified_gmt":"2026-10-17T23:00:27","slug":"foreign-company-france-e-invoicing-deadline-platform-fines-abroad","status":"publish","type":"post","link":"https:\/\/kohenavocats.fr\/en\/2026\/10\/18\/foreign-company-france-e-invoicing-deadline-platform-fines-abroad\/","title":{"rendered":"Your French Company Must Switch to E-Invoicing While You Live Abroad: 1 September 2026 Deadline, Approved Platforms and Fines"},"content":{"rendered":"

You run a French company from London, New York, Dubai or Singapore. Your accountant sends PDF invoices by email, your clients pay them, and everything seems to work. That routine ended on 1 September 2026. Since that date, every company registered in France must be able to receive<\/strong> electronic invoices through a state-approved platform, and large and mid-sized companies must also issue<\/strong> all their domestic business-to-business invoices in electronic form. Smaller companies follow on 1 September 2027. A PDF attached to an email is no longer a compliant invoice for these transactions, and each non-compliant invoice can cost 50 euros in tax fines, capped at 15,000 euros per year. For a founder who lives abroad, the reform raises very practical questions: which of your invoices are covered, what happens to the bills you exchange with your foreign parent company, how you choose a platform from another country, and what a wrong invoice costs you in value-added tax (VAT) and late-payment penalties. This guide answers each of them with the statutes, the official calendar and two recent court decisions, so you can put your French subsidiary in order without flying to Paris.<\/p>\n

I. What France now requires from your company: e-invoicing, e-reporting and the 2026-2027 calendar<\/h2>\n

A. Which of your invoices must go electronic, and by when<\/h3>\n

The obligation sits in Article 289 bis of the French Tax Code (Code g\u00e9n\u00e9ral des imp\u00f4ts<\/em>, CGI), the statute book that contains all French tax rules. Its first paragraph states the rule in one sentence: “l’\u00e9mission, la transmission et la r\u00e9ception des factures relatives aux op\u00e9rations mentionn\u00e9es aux a et d du 1 du I dudit article 289 ainsi qu’aux acomptes s’y rapportant s’op\u00e8rent sous une forme \u00e9lectronique, selon des normes de facturation \u00e9lectronique d\u00e9finies par arr\u00eat\u00e9 du ministre charg\u00e9 du budget, lorsque l’\u00e9metteur de la facture et son destinataire sont des assujettis qui sont \u00e9tablis ou ont leur domicile ou leur r\u00e9sidence habituelle en France.”<\/a> In plain English: invoicing, sending and receiving must be electronic, in a format set by ministerial order, whenever the supplier and the customer are both VAT-taxable persons (assujettis<\/em>, meaning persons carrying out an economic activity for VAT purposes) established in France. The same paragraph adds the key operational sentence: “L’\u00e9mission, la transmission et la r\u00e9ception des factures \u00e9lectroniques s’effectuent en recourant \u00e0 une plateforme agr\u00e9\u00e9e.”<\/a> Issuing, sending and receiving electronic invoices must go through an approved platform. A final sentence of the paragraph refers the details to secondary legislation: “Les conditions et modalit\u00e9s d’application du pr\u00e9sent I sont fix\u00e9es par d\u00e9cret en Conseil d’Etat.”<\/a> The conditions and implementation details are set by decree reviewed by the Conseil d’Etat<\/em>, France’s highest administrative court acting here as adviser to the government.<\/p>\n

Three consequences follow for your company. First, only domestic business-to-business transactions<\/strong> are e-invoices: sales of goods and services between two French VAT-taxable persons, plus advances (acomptes<\/em>, deposits paid before the supply) relating to them, as listed in Article 289 of the Tax Code. That article<\/a> requires every taxable person to make sure an invoice is issued for supplies to another taxable person or to a non-taxable legal entity, and sets the basic invoicing discipline your company already knows. Sales to private consumers, exports outside France and intra-European Union supplies are outside e-invoicing; their data is reported through a parallel channel called e-reporting, described below. Second, invoices between your French company and its foreign parent are cross-border transactions<\/strong>, not domestic ones, because the parent is not established in France: they stay outside e-invoicing and fall into e-reporting instead. This matters enormously for groups whose French subsidiary bills management fees to, or receives recharges from, a holding company in the United States, the United Kingdom, the Emirates or Asia. Third, the statute carves out transactions subject to a defence classification measure, a narrow exception for military secrecy that ordinary companies never meet.<\/p>\n

The calendar is set by the Ministry of the Economy and published on its official portal: from 1 September 2026, all companies regardless of size must be able to receive electronic invoices<\/strong>, and large companies and mid-sized companies<\/strong> (entreprises de taille interm\u00e9diaire<\/em>, usually called ETI, the official category between small businesses and large groups) must issue all their invoices electronically and transmit their e-reporting data<\/strong>. From 1 September 2027, small and medium-sized companies and micro-enterprises must in turn issue electronically and transmit their e-reporting data<\/strong>. The official timetable<\/a> states it plainly: reception for everyone in September 2026, issuance in 2026 for the largest, issuance in 2027 for small businesses and micro-enterprises. Note the asymmetry that traps many foreign founders: even if your French subsidiary is tiny and only issues paper or PDF invoices until 2027, it must already be equipped to receive<\/em> electronic invoices from September 2026, which means registering with an approved platform now, not next year. If you created your company recently through the standard formation steps described in our guide to setting up a company in France as a foreign founder<\/a>, add platform registration to that same checklist: bank account, Kbis<\/em> (the official identity card of a French company, issued by the greffe<\/em>, the registry office of the commercial court), VAT number and now e-invoicing capability.<\/p>\n

B. How an invoice travels now: approved platform, directory and formats, and why your PDF fails<\/h3>\n

Under the reform, an invoice is no longer a document you send; it is data that transits through supervised intermediaries. Your company must issue, send and receive through a plateforme agr\u00e9\u00e9e<\/strong>, a private platform registered with the tax administration after proving it meets security, interoperability and data-protection requirements. The platform checks the mandatory fields, timestamps each step so both parties can follow the invoice status in real time, routes the invoice to the customer’s own platform, and forwards the tax data to the administration. Article 289 E of the Tax Code organises that last leg: “Les donn\u00e9es des factures \u00e9lectroniques \u00e9mises en application du I de l’article 289 bis sont transmises \u00e0 l’administration par la plateforme agr\u00e9\u00e9e choisie par l’assujetti.”<\/a> The data from electronic invoices issued under Article 289 bis is transmitted to the tax authority by the approved platform chosen by the taxable person, electronically, on a schedule and under conditions set by decree. In practice the platform does the tax reporting for you each time you invoice, which is why choosing a reliable operator matters more than comparing subscription prices.<\/p>\n

To route invoices, the statute created a central directory called the annuaire<\/strong>. Article 289 bis provides that the State places a central directory at the disposal of approved platforms, built and updated from information sent by those platforms, listing what is needed to address electronic invoices to each recipient’s platform. Your company is therefore identified in the directory by its SIREN number (the unique 9-digit identifier given to every French business at registration, which appears on the Kbis<\/em>), and your platform keeps your routing information current. When you change platform, the decree sets a switching procedure with minimum continuity services from the former platform, so invoices are not lost in transit. For a founder abroad, the practical lesson is to treat the choice of platform like the choice of a bank: check that it supports English-language interfaces, remote identity verification for a non-resident director, and the billing software you already use, because migrating mid-year complicates your audit trail.<\/p>\n

The format itself must be structured data, defined by ministerial order, and not a picture of an invoice. The administration’s guidance is explicit: an ordinary PDF, a scanned paper invoice or a document sent by simple email no longer satisfies the regulation for covered transactions. Your invoices must carry the mandatory fields in dedicated data fields and travel through the approved platform. Businesses that sell to French public bodies already know a cousin of this system: Chorus Pro<\/strong>, the public portal through which suppliers send electronic invoices to government entities, remains the channel for public procurement, alongside the new private platforms for business-to-business flows. Keep the two apart in your procedures: Chorus Pro for your public-sector customers, your approved platform for everything else.<\/p>\n

Finally, transactions that escape e-invoicing do not escape the administration. Sales to private individuals, exports, intra-Union supplies and services, and dealings with non-established partners fall under e-reporting<\/strong>: instead of a full electronic invoice, your company transmits the transaction data to the tax authority through its platform. That is how the administration reconstructs your VAT position even where no e-invoice exists. A French subsidiary that only bills its American parent and French consumers, for example, may issue no e-invoice at all yet still owe complete e-reporting. The calendar is the same as for issuance: large and mid-sized companies from September 2026, smaller ones from September 2027. Founders who assumed that a holding structure with no domestic customers meant no obligations should revise that assumption now: the data still flows to the direction g\u00e9n\u00e9rale des finances publiques<\/em> (DGFiP, the French tax authority), only through a different pipe. The official list of registered platforms is published by the tax administration and can be consulted at the impots.gouv.fr platform directory<\/a>; choose from that list and from nowhere else, because only a registered operator gives your invoices legal effect and forwards your data correctly.<\/p>\n

II. What mistakes cost and how to run compliant invoicing from abroad<\/h2>\n

A. Fines, refused VAT deduction and late-payment penalties: the price of a wrong invoice<\/h3>\n

The reform punishes three different failures, and the amounts are written into Article 1737 of the Tax Code. First, issuing a paper or simple-PDF invoice where an electronic one was due: “Le non-respect par l’assujetti de l’obligation d’\u00e9mission d’une facture sous une forme \u00e9lectronique dans les conditions pr\u00e9vues \u00e0 l’article 289 bis donne lieu \u00e0 l’application d’une amende de 50 \u20ac par facture, sans que le total des amendes appliqu\u00e9es au titre d’une m\u00eame ann\u00e9e civile puisse \u00eatre sup\u00e9rieur \u00e0 15 000 \u20ac.”<\/a> Failure to issue an invoice electronically as Article 289 bis requires draws a 50-euro fine per invoice, capped at 15,000 euros per calendar year. Second, platforms themselves face 50 euros per invoice, capped at 45,000 euros per year, if they fail to forward the data Article 289 E requires. Third, a company that refuses to equip itself to receive<\/em> electronic invoices through a platform is formally ordered to comply within three months; persistence after that order costs 500 euros, then 1,000 euros after a second three-month order, then 1,000 euros for each further three-month period of persistent breach. The statute phrases the mechanism as follows: after finding the breach, “elle le met en demeure de s’y conformer dans un d\u00e9lai de trois mois”<\/a> (the administration orders the company to comply within three months), and “La persistance de la m\u00e9connaissance par l’assujetti de l’obligation mentionn\u00e9e au premier alin\u00e9a du pr\u00e9sent IV bis \u00e0 l’expiration du d\u00e9lai pr\u00e9vu au m\u00eame premier alin\u00e9a donne lieu \u00e0 l’application d’une amende de 500 \u20ac.”<\/a> Persisting in breach when the deadline expires draws the 500-euro fine. One mitigating paragraph deserves attention: the fines for missing electronic invoices, defective invoices and platform breaches do not apply to a first offence committed during the current calendar year and the three preceding years where the breach was corrected spontaneously or within thirty days of a first request from the administration. Early correction therefore neutralises the penalty, which rewards companies that monitor their platform dashboards and fix anomalies immediately.<\/p>\n

Separate from the new fines, the classic sanction for defective invoices survives: any omission or inaccuracy in an invoice draws 15 euros per invoice, with the total per invoice capped at one quarter of the invoiced amount. And the Commercial Code adds a much heavier layer for missing mandatory information. Article L.441-9 of the Commercial Code requires every business purchase to be invoiced, the seller to deliver the invoice when the supply is performed, the buyer to claim it, and the invoice to show the parties’ names and addresses, the date, quantities, precise description, unit prices excluding tax, price reductions, payment date, discount terms, the late-penalty rate, the fixed recovery fee and the order number. Its penalty paragraph provides: “Tout manquement au I est passible d’une amende administrative dont le montant ne peut exc\u00e9der 75 000 \u20ac pour une personne physique et 375 000 \u20ac pour une personne morale.”<\/a> Any breach is punishable by an administrative fine of up to 75,000 euros for an individual and 375,000 euros for a company, doubled on repeat offending within two years of the first sanction becoming final. An e-invoice that transits correctly through your platform but omits mandatory commercial information still exposes the company to this fine, so the platform’s automatic checks never replace a review of what your invoices actually say.<\/p>\n

A wrong invoice also destroys VAT recovery. Article 283 of the Tax Code states a rule every founder should memorise: “Toute personne qui mentionne la taxe sur la valeur ajout\u00e9e sur une facture est redevable de la taxe du seul fait de sa facturation.”<\/a> Anyone who mentions VAT on an invoice owes that tax by the mere fact of invoicing it. The supplier who overstates VAT pays it to the Treasury; the customer who pays an incorrect invoice cannot deduct the wrong amount. Only a corrective invoice (facture rectificative<\/em> or avoir<\/em>) sent to the customer regularises the position. A decision of the Toulouse Court of Appeal of 9 December 2025 (RG 23\/04457, EURL Bureau de vente de fruits et l\u00e9gumes v. SAS Kuehne + Nagel Road) illustrates the mechanism with unusual clarity. The supplier had mixed euro and South African rand amounts, producing an invoice charging 6,222 euros of VAT instead of 2,219 euros, then refused to issue a corrective invoice and demanded full payment. The court recalled that legally formed contracts bind their parties<\/a> and must be performed in good faith, then recalled Article 1353 of the Civil Code: “Celui qui r\u00e9clame l’ex\u00e9cution d’une obligation doit la prouver.”<\/a> Whoever claims performance of an obligation must prove it, so the supplier, unable to prove any duty for the customer to pay an admittedly wrong invoice, could not demand the erroneous amount. The court added that paying a wrong invoice without a corrective invoice cannot let the customer recover the overpayment, reduced the 8,126.78-euro invoice to 4,123.78 euros, ordered the supplier to issue a compliant new invoice because a customer ordered to pay without fresh invoicing cannot declare the VAT actually paid, and dismissed the supplier’s claims for interest, late penalties and the fixed recovery fee, since the payment delay was the supplier’s own fault. For your company the lessons are direct: never pay a supplier’s invoice you know to be wrong without demanding correction first, always issue corrective invoices promptly when you err, and a customer who withholds payment because your invoice is defective may also defeat your late-penalty claim.<\/p>\n

Late-payment penalties themselves run automatically and generously for the creditor. Article L.441-10 of the Commercial Code sets the payment periods: “le d\u00e9lai de r\u00e8glement des sommes dues ne peut d\u00e9passer trente jours apr\u00e8s la date de r\u00e9ception des marchandises ou d’ex\u00e9cution de la prestation demand\u00e9e.”<\/a> Failing agreed terms, payment cannot exceed thirty days after receipt of the goods or performance of the service. Agreed periods cannot exceed sixty days from the invoice date, or forty-five days end of month where the contract expressly provides and the term is not manifestly abusive to the creditor. The penalty rate defaults to the European Central Bank refinancing rate plus ten percentage points, never below three times the legal interest rate, and “Les p\u00e9nalit\u00e9s de retard sont exigibles sans qu’un rappel soit n\u00e9cessaire.”<\/a> Late penalties are due without any reminder being needed. Every late-paying business is also automatically liable for a fixed recovery fee set by decree, plus proven additional recovery costs. Missing these deadlines exposes the debtor company to administrative fines of up to 75,000 euros for an individual and 2,000,000 euros for a company under Article L.441-16, doubled on repeat offending within two years. The payment-period rules<\/a> and their sanctions<\/a> apply regardless of e-invoicing, but the reform makes delays more visible: timestamps on the platform prove exactly when each invoice was received and processed. The Agen Court of Appeal confirmed the bite of these rules on 12 March 2025 (RG 24\/00104, SCEA de Guyenne v. Eurofirms ETT SL): upholding a judgment that ordered a French agricultural company to pay outstanding invoices to a Spanish temporary-work agency with late interest under Article L.441-10 of the Commercial Code and annual capitalisation of that interest, while rejecting only the separate 15,000-euro moral-damages award. Cross-border suppliers use these provisions routinely, so a French subsidiary that pays its foreign contractors late faces the same automatic penalties as with domestic ones. Our companion guide on recovering unpaid invoices as a foreign-owned French company<\/a> details how creditors enforce these rights, including the fast-track injunction procedure.<\/p>\n

B. Your compliance checklist from abroad: platform, directory data, e-reporting and records<\/h3>\n

Start with the platform, because everything else depends on it. Choose an operator from the tax administration’s official list, sign the service contract, and complete the enrolment of your company with its SIREN number so the central directory routes your incoming invoices to the right place. Verify three points before signing: that the platform authenticates a non-resident director remotely, that its interface and support work in English, and that it connects with the accounting software your French accountant (expert-comptable<\/em>, the chartered accountant who keeps your books and files your returns) already uses. If your group runs a shared-services centre abroad that issues invoices centrally, confirm who holds the mandate to invoice in the French company’s name and on its behalf, because Article 289 of the Tax Code allows invoices to be physically issued by the customer or a third party only where the taxable person has mandated them. A foreign shared-services centre invoicing without a proper mandate creates defective invoices even if every figure is right. Give the platform mandate in writing, keep a copy with your corporate records, and review the directory data once a year or whenever you change providers, since misrouting means you legally never receive invoices your suppliers validly sent.<\/p>\n

Map every revenue and expense flow to its correct channel before the deadline catches you. Domestic business-to-business sales and purchases go through e-invoicing on the platform. Sales to French consumers, exports of goods, intra-Union supplies and services, and all invoices exchanged with your non-French parent or sister companies go through e-reporting: the transaction data is transmitted to the administration without a full electronic invoice. Review your VAT position in the same exercise, because e-reporting gives the tax authority a near-complete picture of your activity and inconsistencies invite audits; our guide on French VAT registration, reverse charge and invoicing from abroad<\/a> explains how cross-border VAT attaches to each flow. Update your general terms of sale (conditions g\u00e9n\u00e9rales de vente<\/em>, the standard terms attached to quotes and orders) to state the agreed payment period within the legal ceilings, the applicable late-penalty rate, and the fixed recovery fee, since Article L.441-9 requires these statements on every invoice and punishes their absence. Align purchase orders, delivery notes and contracts so the invoice amounts always match the supporting documents; the Toulouse decision shows that a mismatch as banal as mixed currencies costs the supplier its penalties, its interest and part of its principal.<\/p>\n

Build the corrective reflex into your procedures. The day your team spots a wrong VAT amount, a wrong customer identifier or a wrong total, it issues a corrective invoice through the platform the same week, because only that document regularises the supplier’s liability and lets the customer deduct correctly. Never ask a customer to simply pay the wrong invoice on the promise of a later credit; the courts treat the uncorrected invoice as the binding document. Keep every invoice, corrective invoice and transmission receipt for the full statutory retention period in a format the administration can audit remotely, and make sure your platform contract guarantees access to archives even if you switch operators, as the decree on switching imposes minimum continuity services for exactly this reason. Train the people who actually click the buttons: your office manager in Paris, your accountant, and yourself as director, since fines attach to the company but a tax reassessment or a commercial fine lands on the director’s desk with questions from the board abroad.<\/p>\n

When something goes wrong, act in the order the statutes reward. A first-time breach corrected spontaneously or within thirty days of the administration’s first request escapes the e-invoicing fines, so acknowledge anomalies from your platform dashboard immediately and document the correction. A formal order to equip yourself for reception triggers a three-month clock, so diary it the day it arrives and complete enrolment well inside the period rather than testing the 500-euro and 1,000-euro steps. A reassessment that denies your VAT deduction for lack of a compliant invoice is answered with the corrective invoice and the transmission proofs, not with arguments about good faith, because Article 283 makes the invoiced tax due by the mere fact of invoicing. A supplier who sues you for late penalties on an invoice you refused as defective is answered with the Toulouse reasoning: no proof of an obligation to pay a wrong amount, no penalties where the delay is the supplier’s fault. And a penalty imposed by the commercial-fraud authority (DGCCRF, the consumer and competition enforcement directorate) for missing invoice information or excessive payment periods is challenged on the facts of each invoice and each contractual term, with the doubling rules for repeat offending in mind. None of these steps requires your physical presence in France: mandates, platforms, accountants and counsel operate remotely, but they require you to decide quickly, because every clock in this reform runs in days and months, not years.<\/p>\n

Conclusion<\/h2>\n

Electronic invoicing is not a software upgrade; it is the new legal form of the invoice itself for domestic business in France. Your company must receive through an approved platform since September 2026, issue electronically if it is large or mid-sized and from September 2027 in all other cases, report its other transactions through e-reporting, and keep every mandatory statement exact, because fines, lost VAT deductions and automatic late penalties attach to each defective document. The two court decisions of 2025 confirm that judges enforce these documents literally: the supplier who invoices wrongly pays the tax it wrongly stated, recovers only the corrected amount, and loses its penalties, while the debtor who simply pays late owes interest that capitalises year after year. Run the checklist from abroad now \u2014 registered platform, correct directory data, mapped flows, updated terms of sale, corrective reflex and archived proofs \u2014 and the reform becomes what it was designed to be: faster payment, fewer disputes and a VAT position the administration can verify without visiting your office.<\/p>\n","protected":false},"excerpt":{"rendered":"

From 1 September 2026 your French company must receive electronic invoices via an approved platform, and large firms must issue them too. 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