E-invoicing in France — and what’s coming in Spain, Germany and Belgium

France: what changes

The reform doesn’t change VAT rules. It changes how invoices travel between businesses and what data the tax authority receives.

An e-invoice is not a PDF sent by email or a scanned paper invoice. It is an invoice issued, sent and received in a structured format that software can read, and it must go through a platform approved by the tax authority (French “plateforme agréée”). The issuer’s platform sends it to the platform chosen by the client, and passes certain data to the tax authority along the way.

The reform has three parts, depending on the client and the transaction:

• E-invoicing: sales and services between VAT-registered businesses established in France.
• Transaction data reporting (e-reporting): sales to consumers or non-taxable persons, and transactions with clients or suppliers established abroad.
• Payment data reporting: payments received for transactions where VAT is due on receipt of payment, usually services.

France: who, and when

The timeline depends on company size, assessed at the level of the legal entity (the SIREN number), as of 1 January 2025, based on the last financial year closed before that date.

E-reporting follows the same timeline as issuing e-invoices.

• 1 September 2026: every business, whatever its size or legal form, must be able to receive e-invoices through an approved platform.
• 1 September 2026: large and mid-sized companies must issue their invoices electronically and send their e-reporting data.
• 1 September 2027 at the latest: SMEs, small businesses and micro-enterprises must issue their invoices electronically and send their e-reporting data.
• Before their deadline, SMEs and small businesses may issue e-invoices voluntarily. This doesn’t oblige them to start e-reporting earlier.

France: who is concerned, and the exceptions

Every business subject to VAT and established in France is concerned, whatever its turnover, legal form or tax regime. That includes freelancers, liberal professions and micro-entrepreneurs.

Businesses under the French VAT exemption scheme for small businesses (“franchise en base”, article 293 B of the French General Tax Code) don’t charge VAT but remain subject to it. So the reform applies to them, for receiving and issuing.

The obligation to issue e-invoices covers transactions between two taxable persons established in France, within the scope of French VAT and subject to French invoicing rules. Not concerned, or only in part:

• Transactions outside the scope of VAT: no e-invoice, no e-reporting.
• Persons not subject to VAT, such as a non-taxable non-profit association or a holding company that only holds shares: they don’t issue or receive e-invoices.
• VAT-exempt transactions exempted from invoicing (articles 261 to 261 E of the French General Tax Code), such as medical care: no e-invoice for those transactions, but e-invoices for the business’s other transactions, and supplier e-invoices must be received since 1 September 2026.
• Sales to consumers and transactions with businesses abroad: no mandatory e-invoice, but data reporting (e-reporting).
• Businesses not established in France: not concerned by e-invoicing, but they may be by e-reporting.
• Invoices to public bodies (central government, local authorities, public institutions) still go through Chorus Pro. Since 1 September 2026, you can send them through your approved platform connected to Chorus Pro, or keep using Chorus Pro directly until 1 September 2027 at the latest.

France: approved platform or compatible solution

An approved platform (formerly “PDP”) is a private company registered by the French tax authority (DGFiP). It issues, sends and receives e-invoices and passes data to the tax authority. It must meet audited security requirements (ISO 27001 certification, data hosted in the EU). The official list is published on impots.gouv.fr.

A compatible solution is software (invoicing, point of sale, accounting) that isn’t registered. To be compatible, it must offer features that meet the reform’s requirements (formats, data) and be connected to at least one approved platform. It never sends anything directly to the tax authority: it always goes through its approved platform.

You are free to choose your platform. You can use several, for example one for issuing and another for receiving, and change at any time. There is nothing to declare to the tax authority: your platform records your choice in the directory itself.

The French state has not created a free public invoicing platform. The public portal (PPF) has been refocused on two roles: the directory, which shows which platform receives each company’s invoices, and the concentrator, which collects data for the tax authority.

France: mandatory invoice details, old and new

The details already required by the French Commercial Code and General Tax Code stay the same. As a reminder, a B2B invoice in France must include, among other things:

• the issue date and a unique invoice number;
• the identity of the seller and the client, and the seller’s VAT number;
• the date of the sale or service, and the purchase order number if there is one;
• the description and detailed breakdown of goods or services, amounts excl. and incl. VAT, the VAT and any discounts;
• the payment date, the late payment interest rate and the €40 fixed compensation for recovery costs;
• for a business under the VAT exemption scheme: the statement “TVA non applicable, article 293 B du CGI”.
• New: the client’s SIREN number.
• New: the type of transaction: supply of goods, services, or both.
• New: the statement “Option pour le paiement de la taxe d’après les débits” (written in French, word for word), if you chose to pay VAT on invoicing.
• New: the delivery address of the goods, if it differs from the billing address.

France: Factur-X, UBL and CII

An e-invoice must use one of the three “base” formats that every approved platform can handle. All three follow the European standard EN 16931.

A supplier can’t impose a format on you: you choose your receiving platform based on the formats that suit you, and the common base guarantees platforms understand each other.

Invoice data must be structured, each item in its own field. According to the DGFiP FAQ, the number of mandatory structured data items increases gradually: 26 in 2026, then 34 from 2027.

• UBL: a structured data file (XML), with no image of the invoice.
• CII: another structured data format (XML), also with no image.
• Factur-X: a hybrid format. A readable PDF (PDF/A-3) that contains the structured data in CII format. Often the simplest for a small business, as the invoice stays readable on screen.

France: invoice lifecycle and statuses

Each e-invoice follows a path, and each step is marked by a time-stamped “status” visible to the supplier and the client on their platforms. There are about ten optional statuses, and four that every approved platform must offer:

• Submitted: you have submitted the invoice to your platform, directly or through your compatible solution.
• Rejected: your platform refuses the invoice for a technical reason (format, missing or inconsistent data, recipient not found). It isn’t sent to the client: correct it and send it again.
• Refused: the invoice was delivered, but the client refuses it. The refusal must give a reason and is final. For a simple disagreement (price, quantity, delivery), temporary dispute statuses exist. If you reissue an invoice after a refusal, it needs a new number.
• Paid: the invoice has been paid. The supplier sets this status. It is mandatory where VAT is due on receipt of payment, as it is used to send payment data to the tax authority.

France: e-reporting of transactions and payments

E-reporting covers what doesn’t go through an e-invoice between French businesses. It is also done through your approved platform. You can keep sending the invoice to your consumer or foreign client by any channel you like.

How often you send depends on your VAT regime. A business under the VAT exemption scheme sends its data every two months. A business on the standard monthly regime sends transaction data three times a month and payment data once a month.

• Sales to consumers or non-taxable persons: the total amount of transactions per day, over the period.
• Sales to businesses established abroad, and purchases from abroad (intra-EU acquisitions, for example): invoice-by-invoice data.
• Payment data: only for transactions where VAT is due on receipt of payment, in practice services. Nothing to send if you opted to pay VAT on invoicing or if the client self-assesses the VAT (reverse charge).
• If the service was covered by an e-invoice, the payment is reported by setting the “Paid” status, with the date and the amount received per VAT rate.

France: penalties

The French General Tax Code sets several fines. For the business, the amounts in force on 11 October 2026 are:

For the start-up phase, the tax authority has said it will not penalise businesses in difficulty that are on a “serious path to compliance”. This doesn’t postpone the obligation: you must be able to show concrete, dated steps (choosing a platform, exchanges with your software provider, tests, incident tickets).

• Invoice not issued electronically when it should have been: €50 per invoice, capped at €15,000 per calendar year (article 1737 of the CGI).
• No approved platform for receiving: formal notice to comply within three months, then a €500 fine, then €1,000 for each further three-month period without compliance (article 1737, IV bis of the CGI).
• E-reporting data not sent: €500 per transmission, capped at €15,000 per calendar year (article 1788 D of the CGI).
• No fine for a first offence (in the current year and the three previous years) if it is corrected spontaneously or within 30 days of the tax authority’s first request.
• The usual rules still apply: for example, €15 per missing or incorrect detail on an invoice, capped at a quarter of the invoiced amount.

France: small businesses and micro-enterprises

Under the reform, a micro-enterprise has fewer than 10 people and turnover or a balance sheet total of €2 million at most. An SME has fewer than 250 people. The French micro-enterprise tax regime changes nothing: you are concerned as soon as you are subject to VAT, even under the exemption scheme.

Since 1 September 2026, you must already be able to receive your suppliers’ e-invoices (energy, phone, internet, equipment). So you need an approved platform for receiving now, even if you don’t issue anything electronically yet.

Until 1 September 2027, you can keep invoicing as you do today. A client can’t require e-invoices from you under the reform before that date, or refuse to pay an invoice just because it isn’t electronic. You can also start earlier, voluntarily.

Spain: B2B e-invoicing and Verifactu

Spain has two separate obligations that add up. B2B e-invoicing (Ley 18/2022 “Crea y Crece”, implemented by Real Decreto 238/2026) requires businesses established in Spain to issue and receive e-invoices between themselves — there is no “receive first” phase as in France. Verifactu (Real Decreto 1007/2023) targets the software that issues all invoices, B2B and B2C, even on paper or as PDFs.

Under Real Decreto 238/2026, accepted formats follow EN 16931 (UBL, UN/CEFACT CII, EDIFACT, Facturae). Invoices travel through a private platform or the free public solution of the Spanish tax agency (AEAT). The recipient reports acceptance or rejection and full payment within four working days.

On 5 October 2026, the Ministry of Finance announced a plan to postpone the Verifactu obligations to October 2028, to align them with B2B e-invoicing for smaller businesses. When we last checked, this postponement had not been published in the BOE (Spain’s official gazette): until it is, 1 January 2027 and 1 July 2027 remain the legal dates.

Companies in Spain can create a Le Frac account to manage their receivables, but Le Frac does not issue invoices in Spain yet and is not Verifactu-compliant today.

• 6 October 2027: B2B e-invoicing mandatory for businesses with a volume of operations above €8 million.
• 6 October 2028: B2B e-invoicing mandatory for all other businesses (SMEs, small businesses, self-employed).
• Verifactu, legal dates: 1 January 2027 for corporate tax payers (SL, SA…), 1 July 2027 for others.
• Businesses under the foral tax regimes of the Basque Country and Navarre are outside Verifactu.
• Our guide for Spain, in Spanish: www.lefrac.fr/es/facturacion-electronica

Germany: the E-Rechnung

Germany’s obligation (§ 14 UStG, rewritten by the Wachstumschancengesetz) covers domestic B2B only: both supplier and client must be established in Germany. Sales to consumers and cross-border transactions are not concerned.

Any format compliant with EN 16931 is accepted, including XRechnung and ZUGFeRD from version 2.0.1 (except the MINIMUM and BASIC-WL profiles). There is no mandatory platform or channel: format and channel are agreed between the parties. Germany has no real-time reporting yet; the Federal Ministry of Finance says the necessary laws have not yet been proposed.

Companies in Germany can create a Le Frac account: our guide for Germany says what is available there.

• Since 1 January 2025: every business established in Germany must be able to receive e-invoices (an email inbox is enough).
• 1 January 2027: issuing e-invoices becomes mandatory for businesses whose total turnover in the previous year exceeded €800,000.
• 1 January 2028: mandatory for everyone, with permanent exceptions such as invoices up to €250 incl. VAT and invoices from small businesses under the § 19 UStG exemption (which must still receive e-invoices).
• Our guide for Germany, in German: www.lefrac.fr/de/e-rechnung

Belgium: Peppol since 1 January 2026

Since 1 January 2026, invoices between VAT-registered businesses established in Belgium must be structured e-invoices (law of 6 February 2024). They are issued in the Peppol BIS format (UBL version) through the Peppol network, unless the parties agree on another EN 16931-compliant format and channel (royal decree of 8 July 2025).

Businesses under the Belgian small business VAT exemption scheme are, in principle, concerned too, as the Belgian tax authority recalled on 7 April 2026. The general tolerance period ended on 31 March 2026: fines now apply. Lacking the technical means to issue and receive structured e-invoices costs €1,500 for a first offence, €3,000 for a second and €5,000 for each further one.

In 2026, no invoice data is reported to the Belgian tax authority. Near-real-time e-reporting is planned but still has to be written into Belgian law.

Companies in Belgium can create a Le Frac account: our guide for Belgium says what is available there.

• Our guide for Belgium, in French: www.lefrac.fr/be/fr/facturation-electronique
• Our guide for Belgium, in Dutch: www.lefrac.fr/be/nl/e-facturatie

France: getting compliant in 7 steps

1. 01

   Take stock of your situation

   Note your size (headcount, turnover), your VAT regime (exemption scheme, standard, VAT on invoicing) and your types of clients: businesses in France, consumers, abroad, public bodies. The questionnaire on impots.gouv.fr gives you your obligations in four questions.

2. 02

   Choose your approved platform for receiving

   Mandatory since 1 September 2026. Choose a platform from the official list on impots.gouv.fr, directly or through your software, bank or accountant. The platform registers you in the directory: you have nothing to declare yourself.

3. 03

   Check your invoicing software

   Ask your provider whether it is an approved platform or a compatible solution, and which platform it is connected to. Without software, you can enter invoices on an approved platform, or use a compatible solution such as Le Frac, connected to an approved platform.

4. 04

   Complete client records and invoice templates

   Collect each business client’s SIREN number and the delivery address when it differs, and state for each invoice whether it covers goods, services or both. Add the VAT-on-invoicing statement if you chose that option.

5. 05

   Test issuing before September 2027

   Send a few real e-invoices to willing clients. Check they reach the “Submitted” status without rejection, and fix the data at fault if they are rejected. Starting early leaves time to solve problems without pressure.

6. 06

   Prepare e-reporting

   Identify your sales to consumers, your transactions with businesses abroad and your payments received for services. Check with your platform or software how this data will be collected and how often it will be sent (every two months under the exemption scheme).

7. 07

   Follow statuses and keep records

   Check your invoices’ statuses, set the “Paid” status when you are paid (if your VAT is due on payment) and send reminders based on this information, for example with Le Frac. Keep your exchanges, tests and incidents: they prove your compliance efforts.

France: the checklist

• I’ve checked that my company is subject to VAT in France (including under the exemption scheme).
• I’ve chosen at least one approved platform from the official list on impots.gouv.fr.
• My platform has registered me in the directory to receive my invoices.
• I know where to see my suppliers’ e-invoices.
• My software is an approved platform or a compatible solution connected to one.
• I have the SIREN number of all my business clients.
• My invoices state the type of transaction (goods, services or both).
• My invoices show the delivery address if it differs, and the VAT-on-invoicing option if I chose it.
• I can issue Factur-X, UBL or CII through my platform, and I’ve tested it.
• I’ve identified my transactions subject to e-reporting (consumers, abroad, payments for services).
• I know how to set the “Paid” status, and I follow rejections and refusals.
• I keep records of my steps (contract, tests, exchanges, incidents).

Frequently asked questions

Sources

1. impots.gouv.fr — Discovering e-invoicing (French tax authority)
2. DGFiP (French tax authority) — FAQ “Je découvre la facturation électronique” (“Getting started with e-invoicing”, in French), 1 Sept 2026
3. DGFiP (French tax authority) — FAQ “J’approfondis la facturation électronique” (“E-invoicing in depth”, in French), 1 Sept 2026
4. DGFiP — Practical guide to e-invoicing at 1 September 2026 (July 2026)
5. DGFiP — Sheet 2: Will my company have to e-invoice? (October 2026)
6. DGFiP — Sheet 6: How does my company receive e-invoices? (statuses)
7. DGFiP — Sheet 10: Invoicing public bodies
8. DGFiP — Leaflet “E-invoicing for micro-enterprises” (May 2026)
9. impots.gouv.fr — List of approved platforms
10. impots.gouv.fr — External specifications of e-invoicing (formats)
11. AIFE — B2B e-invoicing (role of the public portal: directory and concentrator)
12. Légifrance — Article 1737 of the French General Tax Code (CGI)
13. Légifrance — Article 1788 D of the CGI (version at 1 Jan 2027)
14. Service-public.fr — Mandatory details on an invoice
15. AEAT — Public e-invoicing solution and B2B timeline (7 Oct 2026)
16. BOE — Real Decreto 238/2026 (B2B e-invoicing)
17. BOE — Real Decreto 1007/2023 (Verifactu), consolidated text
18. AEAT — Verifactu invoicing software systems
19. Ministerio de Hacienda — Information note on Verifactu (5 Oct 2026)
20. gesetze-im-internet.de — § 14 UStG (invoices)
21. gesetze-im-internet.de — § 27 UStG (transitional rules, para. 38)
22. Federal Ministry of Finance (BMF) — FAQ on e-invoicing
23. BMF — Letter of 15 Oct 2025 on mandatory e-invoicing
24. Belgian Official Gazette — Law of 6 February 2024 (structured e-invoices)
25. Belgian Official Gazette — Royal Decree of 8 July 2025 (Peppol format and fines)
26. einvoice.belgium.be — Who must use e-invoicing?
27. einvoice.belgium.be — End of the tolerance period (7 Apr 2026)
28. einvoice.belgium.be — FAQ on e-reporting

This guide summarises official texts to help you get organised. It is not legal or tax advice and doesn’t replace personalised advice from your accountant.