France: The First Weeks of the E-Invoicing Mandate Show That Choosing a Platform Is Not the Same as Being Compliant
COUNTRY UPDATE — FRANCE
September 25, 2026 | Richard Cornelisse, KGT
France’s B2B e-invoicing and e-reporting reform went live on September 1, 2026, as confirmed by the Directorate General of Public Finances (DGFiP) and the Ministry for the Economy. Early operating figures, reported by VATCalc in September 2026, show high platform take-up but also a large share of non-compliant data flows. On one day, September 10, 2026, the rejection rate reached 43.5%.
For large and mid-sized enterprises that are now issuing e-invoices, the focus has shifted from being ready to go live to making sure the data they send is correct.
Background
After several postponements, France started the first phase of its reform on September 1, 2026. Since that date, all VAT-registered businesses established in France must be able to receive e-invoices. Large enterprises and intermediate-sized enterprises (ETIs) must also issue structured e-invoices through an approved platform (plateforme agréée) and transmit e-reporting data for B2C, cross-border and payment transactions.
Small and medium-sized enterprises and micro-enterprises will start issuing on September 1, 2027. The DGFiP confirmed in July 2026 that it would apply a tolerant approach to penalties during the first phase for businesses that act in good faith.
The Legislative Change
No new legislation was needed: the go-live took place under the existing legal framework, completed in the summer of 2026 by Decree No. 2026-677 and the Order of July 27, 2026, which KGT covered in August. What is new is the first evidence of how the system works in practice. As reported by VATCalc:
- By September 14, 2026, around 4.81 million entities had designated an approved platform in the national directory (Annuaire).
- 14.4% of the invoice data flows (Flux 1) transmitted to the administration were non-compliant.
- The rejection rate reached 43.5% on September 10, 2026.
The DGFiP continues to update its list of approved platforms, most recently on September 22, 2026.
Scope
The figures concern invoices issued since September 1, 2026 by large enterprises and ETIs, as well as the related data flows to the administration. All businesses that receive invoices are affected indirectly, because a rejected invoice does not reach the buyer’s platform as a valid e-invoice.
Timeline
- September 1, 2026: receiving obligation for all businesses; issuing and e-reporting obligation for large enterprises and ETIs.
- September 2026: first operating figures published; ongoing updates to the approved platform register.
- At least until January 2027: tolerant penalty approach for businesses acting in good faith, as reported.
- September 1, 2027: issuing and e-reporting obligation for SMEs and micro-enterprises.
Businesses Affected
Large enterprises and ETIs issuing invoices in France are most directly affected, particularly multinational groups that issue invoices from ERP systems outside France or from shared service centers. Buyers of all sizes are also affected, as rejected or incomplete invoices delay accounts payable processing and input VAT recovery.
Required Actions
- Monitor rejection and lifecycle status messages from your approved platform daily, and analyze the root cause of each rejection code.
- Check customer master data: SIREN/SIRET numbers, routing codes and entries in the national directory.
- Validate that mandatory invoice fields, VAT category codes and exemption reasons are populated correctly from the ERP system.
- Reconcile the e-reporting data (transactions and payments) with the VAT return and the general ledger.
- Test interoperability end to end, from the ERP system through your platform to your customers’ platforms, rather than relying on your platform’s certification alone.
- Document remediation efforts, since evidence of good faith is central to the DGFiP’s tolerant penalty approach.
Practical Implications
The early figures confirm what many practitioners expected: connecting to an approved platform is necessary but not sufficient. Most rejections come from data, not technology – missing identifiers, inconsistent VAT treatment and incomplete mandatory fields generated upstream in the ERP system. For SAP users in particular, the quality of tax codes, customer master data and billing document output determines whether invoices pass validation.
The tolerant penalty approach will not last indefinitely. Businesses that use the coming months to reduce rejection rates will be in a much stronger position once enforcement normalizes, and once SMEs join the system in September 2027 and invoice volumes rise sharply.
Expected Next Steps
The DGFiP is expected to continue publishing operating figures and updating the approved platform register, and further guidance on common rejection causes is likely. Businesses should also prepare for the second phase in September 2027, when their SME suppliers will begin issuing e-invoices and the volume of inbound structured invoices will increase.
How Can KGT Support You?
KGT helps multinationals meet e-invoicing, e-reporting and SAF-T obligations directly from SAP. Our SAP-integrated e-invoicing add-ons cover outbound and inbound flows, a data extractor and a monitoring cockpit, and can be deployed quickly for new mandates without waiting for a wider S/4HANA transformation. For organizations that have standardized on SAP Document and Reporting Compliance (DRC), KGT provides implementation, country roll-out and managed-service support, including master data readiness, tax determination review, and testing against the authorities’ validation rules.
KGT is an SAP partner for PE services and an SAP Build partner, and to become an SAP partner, strict due diligence requirements must be met, including having certified SAP consultants. You can find us at https://partnerfinder.sap.com/profile/0001925409
This update is provided for general information only and does not constitute tax advice.
