Lightly edited for clarity and continuity.
Brian: E-invoicing. Does France still have a September 30 deadline?
Adam: September 1st.
Brian: September 1st! And that deadline's still on?
Adam: It is. And it's somewhat remarkable for anybody who's worked in Europe that the whole continent goes on vacation for the whole month of August, and boom, you come back and there's a September 1st e-invoicing deadline waiting for you. In the country where the month-long vacation was invented.
Brian: But it's not every invoice everywhere all the time. It's a subset for September 1st, right? Phase one.
Adam: Right. On September 1, if you're doing business in France, you must be able to receive a structured invoice. No exceptions. But only large enterprises and ETIs have to start issuing and reporting this September. Everybody smaller gets another year.
At Opal Creek, most of the clients we’re working on this with are companies that have a branch or subsidiary in France that mostly behaves like a cost center. They don't do a whole heck of a lot of invoicing out to customers. So the primary focus for September 1st is, can I receive my local vendor bills through the standard and keep the authorities off my back? In the clients we work with there's at least a 10:1 ratio of vendor bills coming in to customer invoices going out, if not 10:0. So even next year, they’re not going to have much to do.
Brian: What about the transfer pricing invoices these companies are issuing to their US and UK parent companies? Are those invoices going to have to comply?
Adam: It doesn’t seem like they’re going to have to comply with the e-invoicing mandate, since our understanding is that’s only for intra-France transactions. They will have some level of reporting, but we’re still looking into exactly what that entails.
Brian: I’ve been thinking about this as an “onus on the vendor” situation. Is that the right framing?
Adam: It’s really a shared onus. Everyone will need to be able to receive e-invoices come September, but only the larger entities have to send them for now.
Brian: I know how hard our team has been working on this, so I know our clients will be ready and compliant unless there are unexpected technology hiccups with our partners at Zone, which we don’t expect. How’s it going to go more generally? Is this going to be a really disruptive change?
Adam: Well, I think there’s some practical leeway. What does September 1st really mean? If I need an AP invoice from a local vendor and I'm not ready by the first, maybe I get it on the 7th. Or we have them resend. The law is categorical: the functionality needs to be there by the first. But if you're not ready, can you get those vendor bills added later in the month? A lot of people are banking on that.
Brian: So some vendors will be sending invoices later than usual next month.
Adam: And that would be mutually beneficial for all participants.
Brian: Except for the cash flow part.
Adam: Indeed. Though one has to argue cash flow can't be that important if you've just come back from a month off!
Brian: To any French readers: we love you, and we're speaking mostly from jealousy.
For those of us at the back of the class, what is e-invoicing? What is getting sent? XML? A blob? A PDF?
Adam: The information that would be on an invoice, in a markup language. I resist getting specific because my focus has been the pipes rather than what passes through them. But imagine something universally recognized that carries the item, the quantity, the rate, quantity times rate, the amount, the tax.
Brian: Some kind of structured payload. Not a document. You don't send them a PDF of your invoice and have that count as e-invoicing.
Adam: Correct. It’s not e-invoicing just because you sent it electronically.
Brian: And the tax authority gets a log of every transaction that goes down? What about my kebab frites with extra harissa and sauce blanche? Is that getting e-invoiced?
Adam: No. This is only business to business. Consumer sales get reported rather than invoiced.
Brian: So my contractor will have to invoice me electronically. My tobacconist won’t. Got it.
Adam: The spirit of it is getting complete data sets between parties and making sure companies are compliant on their VAT reporting. I had some statistics in our last discussion on the VAT gap — a lot of people are collecting VAT and not all of them are remitting it, and they want to close that. VAT is a consumption tax paid by the final consumer, and each business in the supply chain has to remit its appropriate amount based on the value it adds.
Further reading
Timeline. France's business-to-business e-invoicing mandate takes effect 1 September 2026. From that date, all businesses established in France must be able to receive structured electronic invoices, and large enterprises and intermediate-size enterprises must issue them and submit e-reporting data. Small and medium enterprises and micro-enterprises begin issuing and reporting 1 September 2027.
| Category | Receive | Issue and Report |
|---|---|---|
| Large enterprise, ETI | 1 Sep 2026 | 1 Sep 2026 |
| PME, TPE | 1 Sep 2026 | 1 Sep 2027 |
| French VAT registration, no fixed establishment | not applicable | e-reporting only, by size |
Marosa VAT · Dynatos · Nymus · VATupdate
Scope. The mandate covers domestic transactions where both supplier and customer are taxable persons established in France. Cross-border business-to-business transactions, consumer sales, and exports fall outside it and are covered by e-reporting, under which transaction data is transmitted to the tax authority rather than an invoice delivered to the buyer. A French branch or fixed establishment of a foreign company is treated as established for the operations attached to it. Companies with a French VAT registration but no fixed establishment are outside the e-invoicing mandate and subject to e-reporting only. vatcalc · Avalara · Facturwise · VATupdate
Company size. Size is assessed at the level of the legal entity, identified by its SIREN number. Intermediate-size enterprises have 250 to 5,000 employees or turnover between €50 million and €1.5 billion. Small and medium enterprises have 10 to 249 employees or turnover between €2 million and €50 million. Micro-enterprises have fewer than 10 employees and turnover below €2 million. For companies without a fixed establishment in France, the turnover test uses worldwide turnover. impots.gouv.fr · Comarch · Facturwise
Formats and network. Three syntaxes are authorized: UBL 2.1, UN/CEFACT CII, and Factur-X. Peppol BIS Billing 3.0 is a profile of UBL 2.1 rather than a separate authorized format, and EDIFACT is not authorized. Invoices are exchanged through accredited platforms rather than directly between trading partners. France became a Peppol authority on 8 July 2025. ClearTax · TrueCommerce · Fonoa · Peppol Validator
NetSuite. Zone & Co markets ZoneCapture e-invoicing to NetSuite users for the French mandate, connecting approved-platform infrastructure to invoice workflows inside NetSuite. NetSuite's Electronic Invoicing SuiteApp includes Peppol templates and Peppol ID fields on customer, vendor, and subsidiary preference records. Zone & Co · Oracle NetSuite
VAT gap. The European Commission estimated the European Union's VAT compliance gap at €128 billion for 2023, or 9.5 percent of total VAT liability, an increase from €101 billion the previous year. France is among six member states accounting for roughly three quarters of the total. 1stopVAT · NRD Companies
