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Spotlight PEPPOL BIS Billing 3.0 The EU e-invoicing mandate is here — France Sept 2026, Belgium Jan 2026, Germany 2025.

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2026-2027 timeline

After four years of deferrals and three interministerial arbitrations, the timeline of the French B2B e-invoicing reform is set: 1 September 2026 for reception and emission by large enterprises and ETIs, 1 September 2027 for emission by SMBs and micro-businesses.

Key dates

Date Step Actors
1 June 2026 PPF directory opens in read mode for candidate PDPs and interoperable test phase Registered PDPs + AIFE
1 September 2026 Full go-live. MANDATORY RECEPTION for all businesses liable to French VAT. MANDATORY EMISSION for large enterprises and ETIs. All businesses (reception) + LE/ETI (emission)
1 September 2027 MANDATORY EMISSION extended to SMBs and micro-businesses. Full coverage of domestic B2B. SMBs (10 to 250 employees) + micro-businesses (< 10 employees)
1 September 2028 End of the transitional tolerance period; sanctions fully applicable (art. 1737 CGI) DGFiP — in-depth audits

Who is affected?

Scope is defined by business size per INSEE criteria (decree 2008-1354 of 18 December 2008):

Category INSEE criteria Mandatory emission Mandatory reception
Large enterprise (LE) Revenue > EUR 1.5 bn or balance sheet > EUR 2 bn or > 5,000 employees 1 September 2026 1 September 2026
Intermediate-sized enterprise (ETI) 250 to 4,999 employees, revenue ≤ EUR 1.5 bn, balance sheet ≤ EUR 2 bn 1 September 2026 1 September 2026
Small and medium business (SMB) 10 to 249 employees, revenue ≤ EUR 50 M, balance sheet ≤ EUR 43 M 1 September 2027 1 September 2026
Micro-business < 10 employees, revenue ≤ EUR 2 M, balance sheet ≤ EUR 2 M 1 September 2027 1 September 2026

Scope of operations

The e-invoicing obligation only applies to domestic B2B operations liable to French VAT. Excluded:

  • B2C (sales to individuals) — covered by e-reporting, not e-invoicing.
  • B2G (sales to public entities) — already mandatory since 1 January 2020 (1 January 2017 for large enterprises) through Chorus Pro, out of PPF scope.
  • Cross-border with non-French counterpart — covered by e-reporting (flow 2), not e-invoicing.
  • VAT-exempt operations (health, education, certain financial operations art. 261 C) — out of obligation.
  • VAT base franchise (art. 293 B CGI) — businesses below the EUR 25,000 / EUR 85,000 thresholds in 2026 not affected.

Deferral history

The reform underwent three major deferrals since its initial announcement in 2020:

  • 2020 — Initial announcement. Finance law for 2020, article 153: the generalisation of B2B e-invoicing is announced for 2023, with rollout in 2024-2025.
  • 2021 — Ordinance 2021-1190. Sets out legal principles. Timeline kept: July 2024 reception + large enterprises, January 2025 ETIs, January 2026 SMBs.
  • July 2023 — First deferral. DGFiP communiqué of 28 July 2023: the timeline is suspended sine die due to industrialisation complexity of the PPF. Announcement of a new architecture around private PDPs.
  • Finance law 2024 (law 2023-1322 of 29 December 2023, art. 91). New timeline: September 2026 reception + LE/ETI, September 2027 SMBs/micro.
  • Decree 2024-266 of 25 March 2024. Technical overhaul: the PPF becomes a concentrator, PDPs become the central routing actors.
  • Decree 2024-1099 of 4 December 2024. Final post-interministerial arbitration timeline, confirming 2026 and 2027 dates.

Sanctions

Article 1737 of the French Tax Code (CGI) sets two distinct regimes:

  • Default of electronic format emission — EUR 15 per invoice emitted in a non-conforming format (paper, non-Factur-X PDF, etc.), EUR 15,000 cap per calendar year and per business.
  • Default of PDP transmission — EUR 250 per invoice transmitted through a non-conforming channel (e.g. direct e-mail to the client without passing through PDP / PPF), EUR 15,000 cap.
  • E-reporting default — EUR 250 per untransmitted transaction, EUR 15,000/year cap (see e-reporting for details).
  • Additional sanctions — for repeated breaches, DGFiP may launch an in-depth accounting examination procedure (art. L13 of the Tax Procedures Book) with up to 80% surcharge on evaded duties (art. 1729 CGI).
  • LAW 2022-1157 of 16 August 2022, art. 26 — supplementary finance law for 2022, which re-authorises the empowerment to generalise e-invoicing by ordinance.
  • Ordinance 2021-1190 of 15 September 2021 — sets out the principles of the obligation, the two twin flows (e-invoicing + e-reporting), and PDP certification.
  • Decree 2022-1299 of 7 October 2022 — implementation modalities, PDP registration procedure, 24 mandatory clauses.
  • Order of 7 October 2022 (NOR ECOE2326772A) — sets acceptable semantic models and syntaxes (UBL 2.1, CII D16B, Factur-X).
  • Decree 2024-266 of 25 March 2024 — technical overhaul with PPF concentrator and PDPs at the centre.
  • Decree 2024-1099 of 4 December 2024 — final post-interministerial arbitration timeline.
  • BOI-CF-INF-10-40-50 — DGFiP administrative instruction on sanctions and tolerance period.