One month has passed since 1 September 2026, when France’s e-invoicing obligation for large companies and mid-size enterprises (ETI) came into force. In the absence of consolidated DGFiP statistics — the first aggregated data release is expected during October 2026 — this review draws on field feedback from industry associations, certified platforms (PA), accounting firms, and ERP vendors that have publicly shared their early production results.
What Came into Force on 1 September 2026
Mandatory receipt for all VAT-registered businesses
Since 1 September 2026, every French VAT-registered business must be capable of receiving supplier invoices in a structured electronic format via a government-certified platform (Plateforme Agréée, or PA). This obligation applies even to SMEs, micro-enterprises, and sole traders — who are not yet required to issue e-invoices, but who must have an operational PA for receiving them.
Mandatory issuance for large companies and ETI
Large companies (more than 250 employees or revenue above €50 million) and mid-size enterprises (ETI, 50–250 employees) were also required to issue invoices in structured format from the same date. A decree dated 27 July 2026 confirmed the calendar would hold despite the political uncertainty of late summer.
What comes next: 2027 for SMEs, 2027–2028 for micro-enterprises
1 September 2027 is the next key milestone: SMEs, micro-enterprises, and sole traders will have to activate their issuance obligation. Reception was already mandatory from September 2026. This distinction is critical — many SME directors still interpret “2027 deadline” as “nothing to do yet,” which has been incorrect since the start of the academic year.
Accepted formats and scope
Three structured formats are accepted by registered PAs: Factur-X (a hybrid format combining a human-readable PDF with embedded XML data), UBL 2.1 BIS 3.0 (the pan-European PEPPOL standard), and CII (Cross Industry Invoice). Factur-X remains the de facto format for domestic French B2B invoicing: it retains human readability via the PDF layer, which eases adoption in finance teams unfamiliar with pure XML. These flows cover the domestic B2B scope only — international invoices fall under e-reporting rules, not e-invoicing.
Five Friction Points Identified in the First Month
1. SIREN/SIRET identifiers: the most frequent error source
The national directory of the Public Billing Portal (PPF — Portail Public de Facturation) routes invoices via SIREN and SIRET identifiers. A missing, malformed, or mismatched identifier — for example, one pointing to a company headquarters instead of the correct establishment — triggers an automatic rejection: the invoice never arrives, and the supplier goes unpaid. Finance teams at large companies discovered that their customer master data, sometimes last updated before 2020, contained incorrect SIRET numbers or directory addresses that had never been configured on the recipient side.
This is not a purely technical problem: it reveals a gap in third-party reference data maintenance that few companies had included in their e-invoicing project scope. The fix is manual, record by record, and takes several weeks at scale.
2. PA processing delays: acknowledgements arriving late
During the first weeks, several certified platforms experienced unusual delays due to the sudden surge in volumes. Acknowledgements of receipt — mandatory under the legal e-invoicing cycle — could run hours or even a full day late, muddying payment tracking on the supplier side. Communication quality varied sharply between vendors: platforms with real-time status portals absorbed the wave with far less friction than those relying on error emails containing raw XML error codes.
3. Credit notes and corrective invoices: an underestimated flow
The original invoice had captured most of the attention during e-invoicing projects. Credit notes and corrective invoices — which require differentiated handling depending on the platform — were far less thoroughly tested in advance. Several teams discovered that their PA did not natively link an invoice to its corrective credit note, generating orphaned flows and questions about VAT deductibility during the reconciliation process.
4. VAT e-reporting: scope and frequency widely misunderstood
VAT e-reporting — the transmission to DGFiP of data on transactions outside the e-invoicing scope (B2C sales, foreign non-VAT-registered customers) — emerged as the least visible but most widespread stumbling block, according to professional association feedback. Two misunderstandings recurred consistently: the belief that e-reporting only applies to large companies (it applies to all companies with out-of-scope transactions), and confusion between its specific periodicity — every ten days for transaction data, monthly for payment data — and the standard VAT calendar.
5. Legacy ERP non-compliance: the underlying structural problem
One month in, a significant share of companies running older ERP systems found that their platforms did not generate compliant files. The warning signs of a non-compliant legacy ERP are well documented: invoice export limited to PDF with no structured XML layer, no SIREN field in the customer master, ISO-8859-1 encoding instead of UTF-8 (causing character corruption in XML flows), no e-reporting module in the current licence. For these businesses, the answer is not a patch — it is either a major ERP version upgrade (if the vendor has released a compliant version) or the insertion of a third-party connector between the ERP and the PA.
What Went Well
Large companies that prepared 12 to 18 months in advance
Companies that launched their e-invoicing project before January 2026 — with pilot environment testing, finance team training, and customer master data audits — made the transition without major incident. Their platform logs show high success rates from the first weeks, with minor corrections resolved within days.
Mature PAs: flows processed without major incident
Platforms that had reached operational maturity through years of deployment on public-sector invoicing, or those built by ERP vendors who developed their e-invoicing solutions ahead of schedule, broadly held up under load. Their clients benefit from a production track record, support teams trained on complex edge cases, and complete documentation of rejection codes. Platforms that had published clear compliance roadmaps since 2024 were less exposed to last-minute integration failures.
The national SIREN directory: adopted faster than expected
The PPF, in its role as national directory, proved more useful than anticipated: project teams quickly adopted the habit of checking a customer’s registration status before sending the first invoices. This “pre-issuance verification” practice has become an operational reflex in large finance departments, helping avoid “unknown recipient” rejections before they turn into payment disputes.
The Specific Situation for SMEs and Micro-Enterprises
Exempt from issuance until 2027 — but the receipt obligation is real
Technically exempt from issuance until 1 September 2027, a portion of SMEs chose to get ahead of the mandate, particularly those whose large-company and ETI customers had made supplier compliance a condition of ongoing orders. This voluntary early adoption delivered two benefits: a better grasp of the subject before deadline pressure builds, and the ability to work through early technical issues without regulatory urgency.
For SMEs that have not yet subscribed to a PA, a concrete situation arose as early as September: their large-company and ETI customers, now under the mandatory issuance obligation, attempted to route structured invoices to them. Without a PA address registered in the national directory, these invoices land in an error status (NON_TRANSMISE) — and the issuing customer is legally considered to have fulfilled its issuance obligation regardless.
Risks of late preparation
SMEs that had not yet started their e-invoicing journey by early October 2026 are facing an increasingly tight timeline. A standard e-invoicing project involves: selecting and contracting a PA (two to four weeks), configuring the ERP-to-PA connection (two to eight weeks depending on the solution), running a pilot batch of tests (one to three weeks), and training the team. Cumulatively: two to four months minimum. To meet the September 2027 deadline, industry associations advise launching the project before end of 2026.
Recommended next steps for SMEs that have not yet started
Three concrete actions to initiate immediately:
- Audit your ERP: check whether your vendor has published a compliant version, or whether an e-invoicing/e-reporting module is available in your current licence.
- Select a PA and sign up: consult the list of registered PAs on the DGFiP website and compare two or three offerings on the criteria of volume capacity, ERP integration, and support quality.
- Register in the PPF directory: registration is separate from subscribing to a PA — it enables issuers to find you and correctly route incoming invoices without a
DEST_INCerror.
Regulatory Adjustments and DGFiP Clarifications
Clarification points published by DGFiP
DGFiP published several updates to its technical documentation in the weeks following the launch. The most frequently requested clarifications covered: handling mixed invoices containing both B2C and B2B line items on a single document, managing deposits and advance payments in the e-invoice flow, and processing recurring service contracts. These clarifications allowed several sectors — real estate, professional services, construction — to unblock configurations on their platforms.
Temporary tolerance for good-faith businesses
DGFiP maintained the tolerance posture announced before launch: no automatic sanctions in 2026 for businesses demonstrating a documented compliance trajectory in good faith. This tolerance is conditional, not unconditional: the company must be able to produce a compliance dossier (signed PA contracts, support tickets, active deployment schedule). A wait-and-see stance — doing nothing and hoping tolerance extends indefinitely — does not meet the criteria published by the tax authority.
What to Do if Your ERP is Not Yet Compliant
5-point checklist to assess your situation quickly
- Does your ERP generate Factur-X, UBL, or CII? If not, contact your vendor to find out when a compliant version will be available.
- Is your vendor itself a registered PA, or does it offer a certified connector to a third-party PA? Both approaches are valid.
- Does your customer master contain full SIREN numbers (9 digits) and establishment SIRET numbers (14 digits) for each customer? Run a database audit now, not in reaction to the first rejection.
- Have you activated the e-reporting module separately from the e-invoicing module in your PA configuration? The two obligations are technically independent in most platform settings.
- Do your finance teams know the rejection codes defined under the AFNOR XP Z12-012 standard? A half-day training session covers the most common cases and prevents support queues from becoming saturated.
Vendor update or specialist integrator: how to choose?
A vendor update is the most direct path if your vendor has released a compliant version and your infrastructure can absorb the version upgrade. It becomes insufficient if your ERP predates 2019 with no native e-invoicing module, if it has been heavily customised, or if you handle significant volumes requiring batch error management.
A specialist integrator adds value in these configurations: mapping complex flows (credit notes, multi-establishment, regularisation invoices), testing on the target PA environment, and training teams on rejection-handling procedures. The cost of an integrator is typically recovered within three to six months through the reduction of rejection incidents and the elimination of manual correction workflows.
Conclusion: A Controlled Start, with Ongoing Challenges
One month after 1 September 2026, the picture is one of a controlled launch for well-prepared businesses, and a de facto grace period granted to the rest by DGFiP’s tolerance stance. Large companies and ETI that invested in their e-invoicing project 12 to 18 months in advance have validated their approach. Others are working through an adaptation period whose length depends on how quickly they respond.
For SMEs, October 2026 is a concrete signal: the September 2027 deadline is eleven months away. The first lessons from large-company production — SIREN/SIRET data cleansing, e-reporting as a separate obligation from e-invoicing, training on rejection codes, pre-issuance directory verification — are now available. Getting ahead of the problem, rather than scrambling in summer 2027, is the difference between a controlled project and a painful last-minute compliance push.
Further reading: our complete compliance guide to PDP/PPF for French e-invoicing, our article on the 1 September 2026 mandate entering into force, and our France e-invoicing roadmap 2026–2027: PA, directory, and e-reporting.
