Electronic invoicing in France: SME requirements 2026-2027

Electronic invoicing changes the invoice process, not just its presentation. In our assignments, we encounter missing identifiers, duplicates and disconnected invoicing tools. We recommend resolving these issues before migration: a structured file can still reach the wrong recipient or remain impossible to reconcile.

Management must identify who invoices, from which system and for which entity. We connect this mapping to purchasing, sales and receipts. The priority is a traceable process, with a team able to resolve exceptions and retrieve decision-useful data.

Electronic invoicing covers relevant transactions between businesses established in France and subject to VAT. We separate business-to-business (B2B), business-to-consumer (B2C), international and public-sector sales. Exemptions and specific cases are classified by transaction, rather than sector alone.

A micro-enterprise may be in scope even where it benefits from the French VAT exemption threshold. Being a taxable person is different from actually charging the tax. We recommend recording each entity’s regime in the flow matrix instead of inferring an exemption from its legal status alone.

Since 1 September 2026, all relevant VAT-taxable businesses must be able to receive electronic invoices from suppliers required to issue them. Large and intermediate-sized businesses (ETI) must also issue invoices and submit e-reporting data. DGFiP sets the issuing deadline for small and medium-sized enterprises (SMEs) and micro-enterprises at 1 September 2027.

For an SME, receipt is therefore already an operational matter. Check platform designation, the receiving address and access for staff handling purchases. Then prepare issuing on a representative sample: an activated subscription is not evidence of a tested process.

The integration project depends on sources, entities and VAT regime. If the business already invoices in accounting software with clean master data, the process can be simple. If an industry ERP remains the source, we test connector, data and statuses. Subscription price comes after these checks.

Identifiers and addresses must be consistent in the system producing invoices. SIREN identifies a French business using nine digits; SIRET identifies an establishment using fourteen. We distinguish these references, the invoicing entity and the routing address, instead of using a trading name as an identifier.

We correct duplicates and incomplete fields at source. A correction made only in the platform may disappear on the next import. The procedure identifies who creates a counterparty, who approves a change and how corrections propagate to other systems. We retain the anomaly list and its status.

Acceptance testing must cover actual flows, including credit notes, deposits and rejections. For each scenario, we retain source data, the expected outcome, returned status and correction evidence. An invoice accepted for one customer does not demonstrate coverage of every entity.

Indicators to track include rejection rate, supplier posting time, receipt disputes and average customer collection time. We define their scope and a baseline period. Changes also depend on sales and payment terms; they do not, alone, demonstrate a software effect.

We deliver a flow map, a test record and a rejection-handling procedure. Our work covers diagnosis, a scenario matrix, master-data preparation, Pennylane configuration where appropriate, and training. The CFO follows the controls within the agreed mandate.

Management designates the PA, signs contracts and organises daily operations. The accountant classifies VAT and specific cases; the vendor operates its platform and support. We coordinate these responsibilities around a single process linked to accounting and cash management.

The approved platform sends and receives invoices and submits regulatory data to the administration. PA is the current terminology; PDP meant plateforme de dématérialisation partenaire in earlier documents. Compatible invoicing software may use a separate PA: its trading name does not prove approval.

The public invoicing portal (PPF) provides the public directory and data-concentration functions. The directory identifies the electronic invoicing address used to route an invoice. This is not simply an email inbox: the recipient and routing rules must reflect the actual organisation.

We recommend checking a pilot entity’s address, then testing receipt with the people approving purchases. Retain evidence of the recipient, access rights and outcome. If several establishments share an accounting team, document the approval process before multiplying addresses.

Factur-X, UBL and CII are structured formats in the French baseline. Factur-X combines a readable PDF with an XML file, using extensible markup language. UBL means Universal Business Language; CII means Cross Industry Invoice. The latter two describe structured data that systems can process directly.

We check content as carefully as format: references, VAT, amounts, recipient and statuses. The vendor confirms the formats accepted by your enterprise resource planning system (ERP) and PA. File conversion does not correct a wrong identifier, transaction classification or inconsistency between credit note and invoice.

As at 6 October 2026, the French tax code (CGI) provides for €50 per invoice for failure to issue electronically, capped at €15,000 annually. Article 1788 D provides €500 per missing e-reporting submission, capped at €15,000 annually for each relevant obligation. These figures describe the law at this date, not an automatic penalty.

The legislation provides conditional relief for a first infringement corrected voluntarily or within thirty days of the initial request. Failure to designate a receiving PA follows a separate process: three months’ formal notice, then €500 and subsequently €1,000 for continued failure, repeatable under the statutory procedure.

The ministry announces an assistance and tolerance phase through the end of 2026 for businesses experiencing implementation difficulties. We recommend documenting incidents and corrective actions while continuing compliance work. Tolerance does not remove the requirement or the need to designate a platform.

The French reform does not automatically apply to a subsidiary established in Spain. We build a matrix separating issuer, establishment, recipient and transaction type. The French parent follows its French requirements; the Spanish subsidiary prepares Spanish systems within their own scope.

In Spain, the invoicing-system regulation (RRSIF) concerns software and record integrity. VERI*FACTU is one mode within it, distinct from B2B electronic invoicing under Crea y Crece. AEAT gives 1 January 2027 for relevant corporate-tax taxpayers and 1 July 2027 for other relevant taxpayers.

For Spanish B2B invoicing, Royal Decree 238/2026 sets implementation twelve months after the public-solution order enters into force for businesses whose previous-year turnover exceeds €8 million, and twenty-four months for the others. Order HAC/1028/2026 enters into force on 6 October 2026. We plan each entity using these texts without importing French dates or conflating Spain’s two projects.

An SME should first check its actual receiving capability, then prepare issuing for 2027. We recommend gathering management, finance and the software contact around one flow list. Start with actual received purchases and issued sales instead of a feature catalogue.

Teaching example: an SME sells to businesses and consumers from two tools. The first check identifies the entity issuing each invoice. The second separates domestic B2B from B2C data. The third links sales, credit notes and receipts to accounting without counting the same transaction twice.

The purchasing decision follows this inventory. You then have data to correct, scenarios to test and functions to demonstrate. We use these inputs to assess workload, organise responsibilities and build the budget. This sequence avoids choosing solely on a compliance claim.