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

Current sanctions under the invoicing and data transmission reform

In the event of non-compliance with the obligations regarding electronic invoicing and e-reporting, the French General Tax Code provides for several financial penalties:

• Absence of electronic invoice or non-compliant invoice
  In accordance with Article 1737 III of the General Tax Code, a company that does not issue its invoices in an electronic format compliant with the required standards is subject to a fine of €15 per invoice. This sanction particularly targets companies that continue to use paper invoices or simple PDFs instead of the mandatory standardized formats (Factur-X, UBL, CII). The fine is capped at €15,000 per calendar year.
• Failure to transmit transaction data (e-reporting)
  Article 1788 D of the General Tax Code provides for a fine of €250 per missed transmission, up to a limit of €15,000 per year, for companies that fail to transmit their transaction data.

Proposed sanctions under the invoicing and data transmission reform

The 2026 Finance Bill proposes changes to the existing sanctions and introduces a new penalty for companies regarding the electronic invoicing and data transmission reform:

• The fine for failure to transmit invoices in electronic format or for non-compliant invoices increases from €15 to €50 per invoice (amendment to Article 1737 III of the General Tax Code). The annual cap of €15,000 remains unchanged.
• The fine for non-transmission of transaction data (e-reporting, Article 1788 D of the General Tax Code) increases from €250 to €500 per transmission. The annual cap of €15,000 remains unchanged.
• A new fine of €500 is introduced for failure to designate an approved platform within three months after formal notice, rising to €1,000 per quarter as long as the situation is not regularized (Article 1737 IV bis of the General Tax Code).

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.

Discover our services

VAT Solutions offers a range of services to assist you with your VAT-related challenges in France and internationally:

• Diagnostic of your VAT organization, your flows, and the methods for preserving proof of exempt operations, as well as assessing the impact of new VAT rules;
• Confirmation of the VAT treatment of your flows;
• Coaching/training;
• Management of VAT obligations in Luxembourg and abroad: assistance, preparation, and submission of VAT identification requests and VAT returns.