In brief
On September 1, the French electronic invoicing reform will take effect. We are now in the decisive phase.
Many companies have launched their electronic invoicing projects. However, launching such a project does not guarantee operational compliance by the deadline.
Based on our customer feedback, our discussions, and the feedback from the FNFE-MPE working groups, some companies will not be fully compliant across the entire regulatory scope.
In this article and the accompanying comprehensive report, you’ll find an overview of the five most common areas of concern and the specific risks faced by companies that aren’t fully prepared.
With just a few days to go before the electronic invoicing reform takes effect for VAT-registered businesses in France, the questions that arise are: Who will actually be ready? What are the potential obstacles? How can we better understand and overcome them?
Being ready doesn’t just mean having launched your project
Of course, many companies have launched significant transformation programs:certified platforms(CPs) are being selected—or are in the process of being selected—for small and micro-enterprises in the area of customer billing, billing tools are evolving, tests are scheduled or underway,finance teams aremobilized, and IT departments are accelerating integration efforts.
However, feedback from projects carried out in the field points to one key finding: launching an electronic invoicing project alone does not guarantee that operational compliance will be achieved by the regulatory deadline.
In fact, the reform goes beyond simply sending invoices in a new format. It fundamentally transforms financial and tax processes, organizational responsibilities, data flows, and governance models.
In this context, some companies may find themselves in a situation of partial compliance despite significant investments and projects that are on track.
Identifying the causes of this risk, assessing its impacts, and then implementing appropriate security measures is therefore a major challenge for the Finance, Accounting, Tax, IT, and Transformation departments.
In this article, we’ll help you identify the key considerations and requirements needed to transition from an electronic invoicing project to sustainable and well-managed operational compliance.
Electronic Invoicing 2026: Regulatory Context in France
The French reform calls for the widespread adoption of electronic invoicing (e-invoicing) and e-reporting for businesses subject to VAT in France.
Reminder of the official schedule:
Effective September 1, 2026:
- a requirement for all businesses to accept electronic invoices;
- issuance requirement for GE and ETI;
- e-reporting requirement for these same companies.
Effective September 1, 2027:
- Issuance and e-reporting requirements for SMEs, very small businesses, and microenterprises.
The reform is based, in particular, on Articles 289 bis, 290, 290 A, and 290 B of the General Tax Code, which stem from the provisions adopted underthe ordinance of September 15, 2021, and subsequent finance laws.
What It Really Means to Be Compliant
Compliance is not merely a matter of technical transmission capability.
Compliance is based on three distinct dimensions:
- Regulatory requirements: The company must be able to issue compliant invoices, submit the required data to the tax authorities, and receive electronic invoices from other VAT-registered entities in France, while ensuring the integrity and traceability of all transactions.
- Operational aspect: Processes must function end-to-end, from invoice creation to posting and management of lifecycle statuses.
- Organizational aspect: Roles, responsibilities, and operating procedures must be defined. Compliance is not just a tax or IT issue. It involves many departments: Finance, Tax, Accounting, Sales, Purchasing, IT, and Data.
Would you like to learn more?
Download our comprehensive report detailing possible causes of non-compliance, their business and IT impacts, and the roles of business analysis, all with the ViDA reform in mind.
The 5 Most Common Causes of Noncompliance
These observations are based on SQORUS’s field experience, feedback from FNFE-MPE meetings, and industry monitoring.
1. Underestimated business complexity
The reform is often viewed as a simple digitization project. In reality, it requires a comprehensive review of the Order-to-Cash and Procure-to-Pay processes, as well as data governance. Teams have sometimes been understaffed to cover the entire scope of the project.
2. Insufficient data quality
Many applications still contain data that is of insufficient quality or not standardized. However, data quality remains a prerequisite for compliance.
3. A heavy reliance on ERP systems and existing applications
Depending on the complexity of a company’s IT architecture (multiple ERP systems, on-premises applications, data repositories, successive acquisitions), integration with business applications constitutes a transformation program in its own right.
4. Incomplete project governance
The reform brings together stakeholders with sometimes differing objectives: Finance seeks compliance, IT seeks technical stability, Procurement aims for operational efficiency, and Tax seeks to manage risk. Without cross-functional governance, blind spots quickly emerge.
5. Delayed Contractualization
For many companies, the decision to choose an accredited platform came late in the process. The large number of accredited providers led to significant delays in benchmarking: should they choose a single accredited provider or several? Should they outsource e-reporting or not? Should they use a proprietary format or a standard format?
As a result, many stakeholders are registered inthe electronic billing directory late or even after the deadline.
Although France is the leading nation represented on the Peppol network (J. Nicolas —AIFE Project Manager), we are still far from reaching the expected number of registrants in the directory. As of early August, we had more than 3 million registrants (S. Eustacle, Director of FE Program Director – AIFE) out of approximately 4.5 million VAT-registered businesses, with more than 10 million entries expected in the long term if the SIREN/SIRET variations are taken into account.
Specific Short-Term Risks
Companies that are only partially compliant face three categories of immediate risks.
- Regulatory risks: The DGFIP has announced a lenient approach and will not impose penalties indiscriminately. However, this does not constitute a suspension of the obligation.
- Business-specific operational risks: rejected invoices, routing errors, payment hold-ups, or disruptions in the Procure-to-Pay workflow may occur.
- Risks Related to Available Cash: An error in sending or receiving funds can lengthen processing times, delay payments, and make it difficult to track incoming payments.
- All of these short-term risks ultimately translate into organizational risks: an excessive workload for teams, and the need to perform non-automated tasks and checks, which are sources of errors.
Companies also face medium- and long-term risks, as well as impacts on the various business lines discussed in our comprehensive report, which is available for download.
The European ViDA Convergence
The French reform is part of a broader European initiative: ViDA (VAT in the Digital Age), adopted by the Council of the European Union on March 11, 2025, and published in the Official Journal of the EU on March 25, 2025. The various stages of this major convergence initiative are projected to continue through 2035.
Failing to comply now means running the risk of being unable to approach upcoming regulatory deadlines with confidence and of missing out on the expected productivity gains for our companies.
Report: Electronic Invoicing—Are You Really Compliant?
Implementing a certified platform is not enough. This report outlines the obstacles, the risks, and the difference between launching a project and achieving true operational compliance.
