France - Sanctions related to electronic invoicing and transmission of transaction and payment data

Application sanctions under the invoicing and data transmission reform

The 2026 Finance Act has amended the existing sanctions and introduced a new penalty for companies in connection with the e-invoicing and data transmission reform:

•  The penalty for failure to transmit invoices in electronic format or for transmitting non-compliant invoices is now €50 per invoice (Article 1737 III of the French General Tax Code). The total amount of penalties imposed over a calendar year may not exceed €15,000.
• The penalty for failure to transmit transaction data, known as e-reporting (Article 1788 D of the French General Tax Code), is now €500 per transmission. The total amount of penalties imposed over a calendar year may not exceed €15,000.
• A new €500 penalty has been introduced for failure to designate an approved platform within three months following formal notice. This penalty is increased to €1,000 per quarter for as long as the situation remains unregularized (Article 1737 IV bis of the French General Tax Code).

Start-up period and tolerance

In July 2026, the French tax authorities (DGFiP) published a “Practical Guide to the Start-up of E-Invoicing” (Guide pratique de démarrage de la facturation électronique).

Question 29 of the guide asks whether “sanctions will be automatically applied in the event of a delay, technical issue or subsequent regularization after 1 September 2026.” The tax authorities state that: “Sanctions will not be applied immediately, automatically and indiscriminately solely because a company encounters difficulties when the reform is launched, provided that such difficulties are genuine, documented and followed by corrective action.”

However, the tax authorities clarify that this approach does not mean that the obligation is postponed or suspended. The reform timetable remains applicable. Companies concerned must use the process provided for under the reform whenever possible, address any difficulties encountered, and regularize invoices or data that could not immediately be processed through the required channel.

This flexibility will be assessed on a case-by-case basis and does not apply to situations where companies persistently disregard the obligation, fail to take steps towards compliance, refuse to participate in the system, deliberately maintain parallel processes without subsequent regularization, or use start-up difficulties as a pretext to block payments or delay compliance.

For further information on this start-up period and the conditions under which this flexibility may apply, please refer to the guide published by the French tax authorities (Question 29, page 33).

Reminder of the obligations related to the e-invoicing and e-reporting reform  

The entry into force of this reform introduces three new obligations for businesses. Some apply exclusively to French-established companies (e-invoicing), while others apply to any business carrying out certain operations in France. Below is a brief reminder of these three new obligations:

1.  The obligation of electronic invoicing (e-invoicing): VAT-registered companies established in France will be required to issue invoices in specific formats (UBL, CII, and Factur-X) through an approved platform for transactions carried out with VAT-registered customers also established in France.
2. The obligation of transaction e-reporting : French, EU, and non-EU companies carrying out certain operations in France that are not covered by the e-invoicing obligation will be required to transmit specific invoicing data for certain commercial transactions (net amount, VAT amount, type of transaction, etc.) through an approved platform.
3. The obligation payment e-reporting :  Payment e-reporting, which may apply to French, EU, or non-EU businesses arrying out certain operations in France, consists of transmitting data for transactions where VAT becomes chargeable upon receipt of payment, including the invoice number, the payment date, and the amounts received per tax rate.

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