In brief
Large companies and mid-sized businesses have begun their transition to electronic invoicing. While the major milestones have been reached, there are still areas that require attention.
Platform connected, teams mobilized, rollout underway—for large corporations and mid-sized companies, the groundwork is generally in place.
As the go-live date approaches, however, several challenges could still jeopardize the project’s success: e-reporting, business-specific requirements that were not sufficiently anticipated, or the validation of use cases under real-world conditions.
This article reviews these areas of concern and offers practical tips for addressing them.
Status Report on Companies’ Regulatory Preparedness
At the 2026 Electronic Invoicing Conference, the DGFiP reiterated that another postponement would only add to the stress and delay the system’s rollout. The timeline has been confirmed and will remain in place.
On July 10, 2026, the Minister of Public Action and Accounts stated that a lenient approach would be taken toward businesses acting in good faith. There will be no immediate penalties for companies facing difficulties, provided they begin and document their efforts to comply. The DGFiP has published a practical guide on impots.gouv.fr to support this transition.
As of September 1, 2026, three prerequisites must be met for the go-live:
- A certified, connected platform: designated and operational for sending and receiving invoices in a structured format (Factur-X, UBL, or CII). A PDF sent by email is no longer sufficient.
- An active listing in the directory: Without an address registered with the PPF (Public Invoicing Portal), no valid invoices can be received. As of May 5, 2026, 1 million businesses already had a billing address listed in the central directory, representing approximately 12% of the entities concerned.
- Compliant e-reporting: The submission of transaction and payment data to the tax authorities follows the same schedule as the issuance of such data for large companies and mid-sized companies.
The new mandatory information on invoices also takes effect as of this date: the customer’s SIREN number, the transaction category, any applicable VAT option on debits, and the shipping address if it differs from the billing address.
The Remaining Challenges
Fabrice QUÉRÉ
Manager Finance & Business Transformation
Our clients are not all at the same stage of progress; some are on schedule, but many know that they will still have major milestones to reach after September 1—such as global deployment, e-reporting, and very specific cases…
E-reporting, which is often not prioritized.
In virtually all projects, teams naturally focus on e-invoicingandthe B2B invoicing workflow, andput e-reporting on the back burner. This is where issues start to pile up as the launch approaches. The figures from the PPF pilot show that, as of mid-July 2026, the e-reporting data flows received by the PPF remained well below expected volumes.
Most companies and platforms have treated e-reporting as a secondary priority. However, it covers a wide range of often complex use cases:B2C transactions, international operations, and payment data forservices rendered.
Inadequate configuration or incomplete testing of these data flows can lead to reporting anomalies as early as the first few weeks of operation.
Practical Tips: Start by identifying all the processes not covered by e-invoicing. Then, verify that each one is properly supported by your platform and validate their functionality through tests conducted before go-live.
Business-specific requirements that were not adequately anticipated
The reform does not apply uniformly to all billing flows. Certain sectors involve complex use cases. These require specific handling, which is often not adequately anticipated during the initial project scoping phase.
Retention of guarantee, reverse VAT charging for subcontracting, joint contracting, joint venture companies (SEP): these cases require precise configuration that generic guides do not always cover, otherwise the transaction may be rejected by the recipient’s approved platform.
Practical Tips: List your specific use cases. For each one, verify that a test invoice has been issued and received without being rejected. A case that hasn’t been tested is a case that will fail in production.
Validation of Use Cases
Beyond these advances, one question remains: Have all scenarios actually been tested under real-world conditions?
A connected system is not a tested system. This is something we consistently see in the PPF pilot: companies that thought they were ready but discovered during production that their subcontracting scenario or B2C workflow had not been configured correctly.
Practical Tips: Don’t limit yourself to integration tests. Simulate real-world scenarios using your business workflows. This is the stage at which any discrepancies and necessary adjustments are identified, well before go-live.
How does SQORUS get involved in the final phase of your project?
SQORUS does not step in to take over your project. Your teams are familiar with your information system, your processes, and your context. Our role is different: we provide targeted expertise and assistance on issues that are causing bottlenecks or delays, on a time-and-materials basis, without reorganizing your operations.
The goal is to help you finalize your compliance on time or, if the September deadline cannot be met in certain areas, to approach the next steps with confidence using a documented plan, recognized by the DGFiP as a good-faith effort.
SQORUS for Your E-Invoicing Project
Take advantage of a 30-minute consultation to assess your level of preparation and identify any potential obstacles.
The Next Regulatory Step: ViDA
The French reform is part of a broader European framework. The ViDA (VAT in the Digital Age) package was adopted by the Council of the EU on March 11, 2025. It stipulates that, as of July 1, 2030, structured electronic invoicing will become mandatory for all intra-EU B2B transactions, along with a system for digital reporting of VAT data in near real time.
National electronic invoicing and e-reporting systems mustbe interoperable with the European standard by January 2035 at the latest, which will require a gradual harmonization of local systems.
For companies with business operations in Germany, Belgium, or Spain, it won’t be a matter of starting from scratch in 2030, but rather of aligning existing solutions with the future European standard. The infrastructure put in place today (approved platform, directory, e-reporting) forms the foundation upon which ViDA compliance will be built.
SQORUS is already positioning itself as a partner for this upcoming initiative. We are securing your current deliverables for the French reform and laying the groundwork for your ViDA compliance by 2030–2035.
A project? A request? Any questions?
FAQ
Who is affected by electronic invoicing?
All VAT-registered businesses established in France will be required to accept electronic invoices starting September 1, 2026, regardless of their size. As of that same date, the requirement to issue electronic invoices and submit e-reporting data will apply only to large companies and mid-sized companies. SMEs, very small businesses, and micro-enterprises will be granted an additional grace period until September 1, 2027, to comply with these requirements.
What are the penalties for noncompliance as of September 1, 2026?
The 2026 Finance Act (Section 123) has tightened the penalty regime. Three distinct fines apply:
- 50 € per invoice not issued in a compliant electronic format, capped at 15,000 € per year (Article 1737-III of the CGI)
- 500 € per missing e-reporting submission, capped at 15,000 € per year (Article 1788 D of the CGI)
- €500, then €1,000 per quarter for any company that has not designated an approved receiving platform after receiving a formal notice
The DGFiP has, however, confirmed a lenient approach toward companies acting in good faith that are able to document the steps they have taken to achieve compliance, although this does not constitute a formal grace period.
How Can You Ensure a Smooth Go-Live for E-Reporting and Specific Business Cases?
The go-live must be preceded by testing that covers all workflows, including those often addressed last—such as e-reporting (B2C, international transactions) and complex business cases (retention of title, reverse charge, co-contracting, SEP). A connected system is not a tested system; only a simulation under real-world conditions can identify discrepancies before launch.
