France: Compliance expectations during e-invoicing start-up phase

The French tax authority (Direction Générale des Finances Publiques (DGFiP)) on July 11, 2026, published guidance (French) for taxpayers unable to comply with the e-invoicing mandate by its effective date of September 1, 2026. The guidance emphasizes that the mandate’s effective date is not postponed or suspended but provides some relief measures for those struggling to comply from the outset.

Background

France’s e-invoicing mandate requires a broad range of taxpayers to issue and receive invoices electronically and transmit required digital reporting data. The mandate aims to modernize business processes and enhance tax authority oversight, with integration to accredited platforms as a central requirement.

Penalties for noncompliance

Penalties will not be applied automatically or immediately to taxpayers that are not compliant by September 1, 2026. The tax authority will assess each situation individually and expect credible, documented evidence of active compliance efforts from the outset. If a taxpayer has made no effort to comply or cannot provide reliable proof of genuine effort—such as not starting preparations, not issuing electronic invoices, or not transmitting required digital reporting data—penalties may be applied immediately. The tax authority distinguishes between genuine difficulties and cases of avoidance or inaction.

Three-month notice period exception

A specific exception applies to the obligation to use an accredited platform for receiving invoices. If a taxpayer is not compliant with this requirement, the tax authority will first issue a formal notice (mise en demeure), granting a three-month period to regularize compliance. Only after this period, if the taxpayer remains noncompliant, will penalties such as fines per invoice be enforced. This three-month notice mechanism is limited to the obligation to use an accredited platform for receiving invoices and should not be viewed as a general postponement or grace period applicable to other e-invoicing or e-reporting requirements. For other types of noncompliance, such as failing to start compliance preparations or not issuing electronic invoices, the three-month notice period does not automatically apply.

Requirement to regularize invoices

If technical difficulties prevented compliance and invoices were issued or received by non-electronic means (such as mail, PDF, or paper), taxpayers are expected to regularize these invoices once the difficulties are resolved. This means transmitting the invoices electronically through the accredited platform as soon as possible, ensuring the required data is reported to the tax authority. Care must be taken to avoid double payment, double accounting, or double VAT deduction during this process. In other words, the above-mentioned regularization is generally expected and strongly recommended, particularly to ensure that the relevant data is transmitted to the tax authority. Taxpayers need to document the circumstances of the incident and the corrective actions taken.

Additional information

Taxpayers must continue to pursue compliance, regularize any noncompliant invoices or data as soon as possible, and respond promptly to any inquiries from the tax authority. The guidance is intended to distinguish between genuine difficulties and cases of avoidance or inaction, supporting those who are actively working toward compliance while ensuring the mandate’s effective date is respected.

For more information, contact a KPMG professional:

Laurent Chetcuti | laurentchetcuti@kpmgavocats.fr

Armelle Courtois-Finaz | acourtois-finaz@kpmgavocats.fr

Philippe Stephanny | philippestephanny@kpmg.com

Ramon Frias | ramonfrias@kpmg.com