Electronic invoicing on September 1, 2026: what you may have missed this summer

Electronic invoicing enters a new phase on September 1, 2026. Just days before this deadline, several important developments have occurred: confirmation of the timeline, an announcement of leniency from the administration, new regulations, registration of approved platforms, and publication of a practical start-up guide. Here is a summary of the key electronic invoicing news to remember before September 1, 2026.

After several years of preparation, the reform of electronic invoicing is becoming a reality for businesses.

From September 1, 2026, all affected businesses must be able to receive electronic invoices. On the same date, large companies and medium-sized enterprises (ETIs) must also issue their invoices electronically and comply with their data transmission obligations.

SMEs, micro-enterprises and micro-enterprises will have an additional year for issuance, until September 1, 2027. But they are indeed subject to the obligation to receive from September 2026.

Although this schedule is now known, the news surrounding electronic invoicing has been particularly eventful in recent weeks.

Here's what businesses may have missed over the summer.

1. Electronic invoicing September 1, 2026: the schedule is confirmed

Ultimately, there will be no further postponement.

The Government has confirmed that the electronic invoicing reform on September 1, 2026.

From this date:

• all companies concerned must be able to receive electronic invoices;
• Large companies and mid-sized companies will also have to issue their invoices electronically;
• They will have to transmit to the administration the data falling within the scope of e-reporting.

For SMEs and micro-enterprises, the obligation to issue will take effect on September 1, 2027.

This confirmation is important given the scale of the scheme: the reform affects approximately 10 million economic actors.

The Ministry of Economy reiterated this on August 28, 2026 in its presentation of the main measures coming into effect in September.

For companies, the time is therefore no longer for anticipating the schedule, but for its effective implementation.

2. Administrative tolerance at the start: be careful not to confuse it with a postponement

This is probably one of the most important pieces of information this summer.

On July 10, 2026, at the 11th meeting of the Electronic Billing Relay Community, the Minister of Public Action and Accounts confirmed the timetable while announcing an approach of "tolerance and goodwill" when starting the reform.

The minister indicated that, during this phase, the administration would favour dialogue and proportionality with regard to companies acting in good faith and engaged in a compliance process.

This announcement is reassuring, but it must be interpreted with caution.

The tolerance announced by the administration does not constitute a postponement of September 1, 2026, nor a suspension of obligations, nor a general guarantee of no sanctions.

Its implementation will necessarily depend on the administration's assessment of each company's situation.

The distinction could therefore be important between a company that encounters a difficulty despite effective preparation and one that has not undertaken any steps to achieve compliance.

It is therefore prudent to be able to document the steps taken : choice of a platform, exchanges with service providers, tests carried out, adaptation of software, training of teams or even modification of internal procedures.

This traceability could prove invaluable in case of difficulties during the start-up phase.

3. A practical guide to managing initial incidents

Alongside this announcement, the DGFiP published a practical guide dedicated to starting electronic invoicing.

Its interest is particular because it does not limit itself to recalling the principles of the reform. It addresses incidents that may occur in the daily life of companies.

What happens when an invoice doesn't immediately go through the expected electronic channel? Does it still have to be paid? Can it be recorded in the accounts? Is the right to deduct VAT preserved?

The guide also considers difficulties related to the operation of the system itself: temporary unavailability of a platform, incident affecting a service provider or temporary impossibility of transmitting certain data.

These questions perfectly illustrate the phase change we are witnessing.

For several years, the questions focused primarily on the preparation for the reform.

From September 1st, they will increasingly focus on managing incidents caused by its practical application.

And some of these incidents will quickly go beyond purely tax or IT issues.

4. New regulatory texts published on July 27, 2026

Just over a month before the reform comes into effect, its regulatory framework has evolved again.

Decree No. 2026-677 of July 27, 2026 relating to the generalization of electronic invoicing was published in the Official Journal of July 28.

A decree dated July 27, 2026 relating to the generalization of electronic invoicing was published simultaneously.

These texts adapt and supplement the regulatory framework applicable to the system.

They relate in particular to the operation of the system, the approved platforms, their registration, their obligations and the methods of data transmission.

The decree modifies several provisions of Annex II to the General Tax Code, while the order modifies, in particular, various provisions of Annex IV.

For businesses, this publication is primarily a reminder that the regulatory framework for electronic invoicing continued to be clarified until the final weeks before it came into effect.

5. Approved platforms and compatible solutions: don't confuse them

Another key development: the final architecture of the system is now based on approved platforms.

To send and receive their electronic invoices in accordance with the new system, businesses can:

• to use an approved platform directly;
• or continue to use a business solution, billing software or other compatible tool, provided that it is interfaced with an approved platform ensuring the required regulatory functions.

This distinction is important.

Therefore, a billing solution used daily by the company is not necessarily itself an approved platform.

AIFE indicates that 108 platforms have obtained their final registration, following in particular the tests carried out with the public invoicing portal.

Each company should, in particular, check:

• that an approved platform has indeed been chosen;
• that it is properly registered to receive its invoices;
• that his billing email address is correct;
• that its billing software, ERP or business tools communicate correctly with the chosen device;
• that the respective roles and responsibilities of its publisher, its compatible solution and its approved platform are clearly identified.

This last point is far from being purely technical.

6. New mandatory information: invoices themselves are changing

The entry into force of the reform also entails a change in the content of invoices.

From September 1, 2026, four new pieces of information must be included:

• the customer's SIREN number;
• the category of the transaction being billed: sale, provision of services or a combination of both;
• where applicable, mention of the option for VAT payment on debits;
• the full delivery address when it differs from the customer's billing address.

Therefore, it is not enough to verify that the company is able to transmit an invoice via the new channel.

The content of the invoices themselves and the software settings must also be checked.

With just a few days to go before the deadline, this check is still a useful reflex.

7. Technical issue: the debt does not disappear with the invoice

This is probably one of the most interesting aspects of the reform for legal departments.

The introduction of electronic invoicing will bring to light situations that were previously less frequent:

• Invoice rejected;
• routing error;
• platform unavailability;
• error in the directory;
• incompatibility between systems;
• failure to transmit a status;
• faulty intervention by a service provider.

However, an invoice is not solely a fiscal or accounting object.

It is part of a contractual relationship between a creditor and their debtor.

An anomaly in its electronic circuit does not, in itself, mean that the debt disappears, that the invoice ceases to be payable, or that the debtor can automatically suspend payment.

It will be necessary to distinguish the tax and technical obligations attached to the invoice from the existence and enforceability of the debt in the contractual relationship.

This distinction is likely to become particularly important from September 1st.

It also reinforces the importance of retaining other elements that can establish the debt : contracts, purchase orders, delivery notes, acceptance reports, exchanges with the client or proof of performance of the service.

The platform is one element of the invoicing process. It should not become the sole source of proof of the business relationship.

8. Payment terms: what will be the invoice receipt date?

The reform will also have consequences for payment deadlines.

The dematerialization and traceability of exchanges will allow for much more precise information on the circulation of invoices and their processing.

But they can also create new difficulties.

On what date should an electronic invoice be considered received?

Does a technical rejection prevent the payment period from starting?

Can a company cite a routing error to justify a late payment?

What is the consequence of a discrepancy between the date recorded in the supplier's system, the date recorded by the platform, and the date appearing in the client's system?

These questions are not secondary.

On the contrary, electronic invoicing could make compliance – or non-compliance – with legal and contractual payment deadlines much more visible.

It therefore becomes useful to review the contractual clauses relating to the receipt of invoices and the starting point of payment periods, in order to verify their compatibility with the new electronic environment and to limit, as much as possible, uncertainties about the relevant date.

9. Sanctions: administrative leniency does not make them disappear

The announcement made by Bercy in July should not make us forget that the electronic invoicing system comes with sanctions.

The administration has indeed announced that it will adopt a proportionate and benevolent approach to start-ups towards companies in good faith.

But the principle remains: the obligations do indeed come into effect.

Failure to comply with electronic invoicing and data transmission obligations may be subject to tax penalties.

Furthermore, regardless of the sanctions specific to the reform, companies remain exposed to the consequences and sanctions attached to non-compliance with the rules relating to payment deadlines.

The difference between a company that encounters a difficulty despite the steps it has taken and a company that has not prepared itself could therefore become decisive.

Hence, once again, the importance of keeping track of the compliance steps taken.

10. Contractual issues: the next challenge of electronic invoicing?

The reform has long been presented from three main perspectives:

tax, accounting and IT.

These three dimensions are obviously essential.

But they are no longer sufficient.

As electronic invoicing becomes more commonplace in businesses, new questions will arise:

Who is responsible for a misrouted invoice?

On what date should it be considered received?

What is the impact of a rejection on the payment deadline?

Who bears the consequences of a failure of the billing platform or software?

Are the terms and conditions stipulating that invoices be sent by email still appropriate? ?

How to contractually manage a platform change?

How to distribute responsibilities between the company, its software publisher, its compatible solution and its approved platform?

These questions call for a review of several categories of clauses:

• the clauses defining the method of transmission and receipt of invoices ;
• clauses relating to the starting point of payment deadlines ;
• the procedures applicable in the event of rejection or dispute of an invoice ;
• clauses governing a change of platform or billing system ;
• the clauses defining responsibilities in the event of a technical incident ;
• and, in contracts with service providers, commitments of availability, assistance, security and responsibility.

Compliance with electronic invoicing should therefore not be limited to verifying that "technically, it works".

With just a few days to go before September 1st, 2026, another question deserves to be asked:

Are the company's contracts, terms and conditions and internal procedures legally adapted to electronic invoicing?

Electronic invoicing September 1, 2026: the last points to check

With the reform coming into effect in just a few days, companies can still carry out some essential checks:

• Has the approved platform been chosen and correctly configured?
• Is the company properly registered to receive its invoices?
• Are the software, ERP and business solutions compatible with the chosen platform?
• Have the new mandatory information details been incorporated?
• Do employees know how to handle a rejected invoice or an incident?
• Does an internal procedure document the handling of rejections, routing errors, and platform unavailability?
• Have the contracts and general terms and conditions been reviewed in light of the new billing procedures?
• Are the rules regarding invoice receipt and payment deadlines sufficiently precise?
• Have the responsibilities of the various service providers been identified?
• Are the compliance procedures documented and evidence of them kept?

1 , 2026 marks a major milestone in the reform of electronic invoicing.

But that's probably not its end point.

On the contrary, it is from this date that the concrete difficulties related to its application will begin to appear.

And with them, a dimension of the reform that has not been sufficiently anticipated: its legal and contractual consequences for companies.

If you would like assistance in adapting your contractual documentation, please contact ARST Avocats.

Article written by Morgan Jamet, Partner Lawyer.