W System / Blog / France e-invoicing 2027 for invoicing software

France e-invoicing: what invoicing software must fix before SMEs start issuing on 1 September 2027

By Zifeng Wei, W System · Published · All articles

In short: France's B2B e-invoicing reform went live on 1 September 2026. Every VAT-registered business must now be able to receive e-invoices through an approved platform (plateforme agréée), and large companies and mid-caps must issue them. By 4 October, 75% of businesses filing VAT had chosen a receiving platform and more than 20 million invoices worth over EUR 70 billion had been exchanged. The next step is 1 September 2027, when SMEs and micro-enterprises must issue too and e-reporting ramps up. The official guide says what goes wrong in practice: rejected files, wrong recipients, missing mandatory data, duplicates. This page turns that into a checklist for invoicing and ERP builders, with the four new mandatory mentions, the penalties and a live check of the client's SIREN.

Where France stands after the first month

The first follow-up committee met on 8 October 2026. The government's figures as of 4 October: 75% of businesses filing VAT had designated a receiving platform, more than 20 million invoices had been exchanged, worth more than EUR 70 billion. Business organisations raised the readability and cost of platform offers, choosing or changing platform, adapting invoicing software and processes, and the needs of the smallest businesses. Large companies pointed to interoperability problems between some solutions and to lifecycle statuses not being passed on correctly, which breaks automated processing. The committee agreed to update the starting guide within two weeks, and the minister confirmed that no business will be fined before the end of 2026. The committee meets again before the end of the year (communiqué of 9 October 2026, economie.gouv.fr).

Timeline

DateWhat happens
1 Sep 2026All VAT-registered businesses in France must be able to receive e-invoices through an approved platform. Large companies and ETI must issue e-invoices and transmit e-reporting data. Supplier and client SIREN, operation category and invoice totals are part of the data transmitted to the administration.
Until 31 Dec 2026No fines for any business (minister, 8 October 2026). The obligation itself is not postponed.
1 Sep 2027SMEs (PME), very small businesses and micro-enterprises must issue e-invoices; e-reporting ramps up. Line-level data (description, quantity, unit price excluding VAT) joins the data transmitted to the administration.

What a French e-invoice has to be

Rejected, refused, unreachable: how the official guide says to handle them

The practical starting guide (guide pratique de démarrage) separates problems your software must handle differently:

SituationWhat it meansWhat to do in softwareSource
Rejected by a platform (rejet)A transmission or control problem: format error, mandatory data missing or inconsistent, a party identified wrongly, routing problem, blocking anomaly.Treat it as an incident to fix, not a reason to stop invoicing. Correct the file and send it again through the electronic circuit. Keep the file, the status or rejection message, the cause and the correction.Guide Q11
Refused by the buyer (refusée)A lifecycle status, not a technical error. It must give a reason and may only be used for the reasons the standard allows (regulatory non-compliance the receiving platform did not catch, wrong addressee, contractual conditions that block processing). Not for a commercial dispute.Read the reason. If you re-issue, use a new invoice number so it isn't confused with the refused one or rejected as a duplicate number.Guide Q12
Recipient can't be found in the directory (annuaire)Check the SIREN, SIRET, receiving establishment and name you used, then ask your platform whether it is wrong data, a missing update or a routing problem; then confirm with the client.Store SIREN (and SIRET where the client uses one) per customer and re-check before the first invoice. A copy by e-mail is a continuity measure, not a new invoice.Guide Q10
Same invoice sent twice (duplicates)Re-sending or regularising must not cause double payment, double booking or double VAT deduction. A copy should be clearly linked to the original (e.g. marked duplicata or copie).Drive re-sends from the lifecycle statuses you receive; only send a copy by another channel when the status shows the invoice did not reach the client.Guide Q15

Penalties (2026 finance law)

FailureFine
Invoice not issued electronicallyEUR 50 per invoice, at most EUR 15,000 per calendar year (CGI art. 1737)
E-reporting transmission missingEUR 500 per transmission, at most EUR 15,000 per year and per type (transaction or payment data) (CGI art. 1788 D)
No approved platform chosen for receivingFormal notice first; EUR 500 after three months, then EUR 1,000 for each further three months

A first offence repaired spontaneously or within 30 days of a first request is not fined (CGI art. 1788 D V for e-reporting). Sources: Service Public, 20 February 2026. The guide's question 29 adds that fines won't be applied automatically to a real, documented difficulty that is being corrected.

Checklist for invoicing and ERP builders before 1 September 2027

Example: catch a missing client SIREN before the platform does

Disclosure: W System, which publishes this page, makes the e-invoice API used below. W System is not an approved French platform and does not transmit invoices in France. It checks the files you create: EN 16931 rules for UBL, CII and Factur-X, plus, for French parties, whether the supplier's and client's SIREN are present as legal registration identifiers. The SIREN check is a hint: it doesn't change valid (EN 16931 itself doesn't require a buyer SIREN), and the French XP Z12-012 rules aren't run. Placeholder SIREN and VAT numbers; not tax advice.

The test invoice (created with POST /einvoice/create, then the buyer's SIREN left out):

{
 "invoice_number": "F-2026-0412",
 "issue_date": "2026-10-20",
 "currency": "EUR",
 "seller": {
  "name": "Exemple Logiciel SAS",
  "vat_id": "FR11123456782",
  "company_id": "123456782",
  "company_id_scheme": "0002",
  "street": "10 rue de Rivoli",
  "city": "Paris",
  "postal_code": "75001",
  "country": "FR"
 },
 "buyer": {
  "name": "Client Exemple SARL",
  "vat_id": "FR14987654324",
  "company_id": "987654324",
  "company_id_scheme": "0002",
  "street": "5 quai Saint-Antoine",
  "city": "Lyon",
  "postal_code": "69002",
  "country": "FR"
 },
 "lines": [
  {
   "description": "Abonnement logiciel, octobre 2026",
   "quantity": 1,
   "unit": "C62",
   "unit_price": 150,
   "vat_rate": 20
  }
 ]
}
curl -X POST https://api.wsystem.dev/einvoice/validate \
  -H 'Content-Type: application/xml' --data-binary @facture.xml

Real response from the live API on 20 October 2026 (errors, sources and timing left out):

{
 "valid": true,
 "error_count": 0,
 "warning_count": 0,
 "syntax": "ubl",
 "format_error_count": 0,
 "business_rule_error_count": 0,
 "checked": {
  "xsd": true,
  "EN16931": true,
  "XRechnung": false,
  "PeppolBIS3": false,
  "SK_national": false
 },
 "france": {
  "applies": true,
  "domestic_b2b": true,
  "seller_country": "FR",
  "buyer_country": "FR",
  "seller_siren": "123456782",
  "buyer_siren": null,
  "missing": [
   {
    "item": "buyer_siren",
    "field": "BT-47 with schemeID 0002 (SIRENE)",
    "message": "No SIREN found as the buyer's legal registration identifier. The FR VAT number suggests SIREN 987654324.",
    "suggested_value": "987654324"
   }
  ],
  "not_checked": [
   "category of operation (goods / services / both)",
   "delivery address if different",
   "option to pay VAT on debits",
   "French XP Z12-012 platform rules and lifecycle statuses"
  ],
  "explanation": "French platforms (plateformes agreees) reject invoices with missing or inconsistent mandatory data. Since 1 Sep 2026 the supplier's and the client's SIREN are among the data transmitted to the tax administration for domestic B2B. This hint checks only the SIREN items.",
  "source": "impots.gouv.fr, 'Donnees de facture a transmettre a l'administration' (art. 41 septies D annexe IV CGI): SIREN of supplier and client expected from 1 Sep 2026; see https://wsystem.dev/france-e-invoicing-2027-sme-software"
 }
}

The file passes EN 16931, but the france block flags the missing client SIREN and suggests the value from the VAT number. To look up or confirm a SIREN, GET /company?country=FR&q=… searches the official Sirene data. Try your own files in the free e-invoice validator; the API is free for 20 calls a day per IP, details on the e-invoice validation API page.

Questions and answers

Who must issue e-invoices in France, and when?

Since 1 September 2026 every VAT-registered business established in France must be able to receive e-invoices through an approved platform (plateforme agréée), and large companies and mid-caps (ETI) must issue them and transmit e-reporting data. SMEs (PME), very small businesses and micro-enterprises must issue from 1 September 2027. Until then they may issue e-invoices voluntarily.

Which formats are accepted?

UBL, UN/CEFACT CII, or a mixed format that combines structured data with a readable image (Factur-X). The common minimum set every platform must support is defined in the AFNOR standard XP Z12-012. A scanned or ordinary PDF sent by e-mail is not an e-invoice under the reform.

What are the new mandatory mentions?

Four new mentions: the client's SIREN number (when the client is a business), the delivery address if it differs from the client's address, the nature of the operations (goods, services or both), and the mention 'Option pour le paiement de la taxe d'après les débits' when the supplier opted to pay VAT on debits. They apply to large companies and ETI first and to SMEs and micro-enterprises from 1 September 2027.

What are the penalties?

Since the 2026 finance law (loi n° 2026-103 of 19 February 2026): EUR 50 per invoice not issued electronically, capped at EUR 15,000 per calendar year; EUR 500 per missing e-reporting transmission, capped at EUR 15,000 per year and type of transmission; for not using an approved platform to receive, a formal notice, then EUR 500 after three months and EUR 1,000 for each further three months. A first offence repaired spontaneously or within 30 days of the administration's request is not fined (CGI art. 1788 D V for e-reporting). The minister said on 8 October 2026 that no business will be fined before the end of 2026.

Does a software company need to become an approved platform?

No. Invoicing and ERP software can connect to one or more approved platforms (plateformes agréées) through their APIs; the AFNOR standard XP Z12-013 describes those APIs. Only the platforms are registered by the tax administration. The software still has to produce correct files and handle the statuses the platforms return.

Sources

Related

Checked against the 9 October 2026 communiqué, the impots.gouv.fr starting guide and data table, Service Public and Légifrance on 20 October 2026. The starting guide is due an update in late October 2026; re-check it before you release.

Facts checked 2026-10-20. W System is the maker of this product. Not affiliated with the European Commission. Not legal or tax advice.