Electronic invoicing in France is no longer a future project. The first stage of the French reform came into force on 1 September 2026, progressively changing how businesses issue and receive invoices and transmit certain information to the French tax authorities.
For a Spanish company doing business with French customers, the obvious question is: does the reform apply to us too?
The answer depends on the company’s circumstances. A business established exclusively in Spain is not automatically subject to the same requirements as a business established in France. Certain transactions carried out in France may nevertheless create specific obligations, particularly in relation to French VAT and e-reporting.
1. What is electronic invoicing in France?
The French reform distinguishes between two mechanisms: electronic invoicing, or e-invoicing, and electronic data reporting, or e-reporting.
E-invoicing primarily covers transactions between businesses established in France and subject to French VAT.
It does not simply mean sending an invoice as a PDF by email. Invoices must contain structured data and follow the prescribed transmission process through an approved platform.
An emailed PDF is not an electronic invoice
An invoice created in Word or Excel, converted to PDF and emailed to a customer may be digital, but this alone does not make it an electronic invoice under the new French system.
The reform introduces specific formats and transmission channels using an officially approved platform.
2. What is the timetable for electronic invoicing in France?
The first major deadline has already passed: 1 September 2026.
Since that date, French businesses within the scope of the reform must be capable of receiving electronic invoices. Large businesses and intermediate-sized enterprises must also issue electronic invoices.
SMEs and micro-enterprises will become subject to the issuing requirement from 1 September 2027.
3. Does a Spanish company have to use French electronic invoicing?
This is where an important distinction arises.
If your company is established solely in Spain and does not have a permanent establishment in France, its transactions do not automatically fall within the French domestic B2B e-invoicing system.
This does not, however, mean that the reform can simply be ignored.
French VAT can change the answer
A Spanish business may carry out transactions located in France and be registered for French VAT without necessarily having a permanent establishment there.
In certain circumstances where the foreign business is liable for French VAT, e-reporting requirements may apply.
The relevant question is therefore not simply “Is my company based in Spain?” but “What transactions do we carry out in France and who is liable for the VAT?”
4. E-invoicing and e-reporting are different
Understanding this distinction is crucial to understanding electronic invoicing in France.
E-invoicing governs the issuing and receiving of electronic invoices between businesses within its scope.
E-reporting involves transmitting certain information to the French tax authorities about transactions that do not fall within e-invoicing.
This may include information such as the value of the transaction and the VAT charged.
Spanish companies may be subject to e-reporting
This is perhaps the most important point for Spanish businesses.
A foreign company without a permanent establishment in France that carries out certain transactions subject to French VAT may have to report transaction information to the French authorities even though those transactions do not fall within the French e-invoicing system.
5. When does e-reporting apply to foreign companies?
For foreign companies without a permanent establishment that are sellers or service providers and fall within the rules, the timetable depends on company size.
Large and intermediate-sized enterprises have been subject to the relevant requirements since 1 September 2026.
Micro-enterprises, VSEs and SMEs become subject to them from 1 September 2027.
From 1 September 2027, certain transactions in which a foreign business is the buyer or customer liable for VAT — including reverse-charge transactions and intra-Community acquisitions — also become subject to transaction e-reporting, regardless of company size.
Company size is assessed globally
There is another point Spanish businesses should note.
For a foreign company, the relevant employee, turnover and balance-sheet criteria are assessed on the basis of its international activity, not merely the size of its operations in France.
A business with relatively modest French sales should therefore not automatically assume that it falls within the SME timetable.
6. What is an approved platform?
Businesses within the system must use an approved platform, meaning an operator officially registered by the French tax authorities.
These platforms play a central role in sending and receiving electronic invoices and transmitting mandatory invoice, transaction and payment information to the authorities.
Invoicing software is not necessarily an approved platform
An ERP or invoicing application may connect to an approved platform without itself being that platform.
Spanish companies should therefore establish how their existing software will interact with the French system and which provider will actually perform the required transmissions.
7. What should a Spanish company check now?
Before changing its entire invoicing system, a company should first establish its precise position.
Determine whether the company has a permanent establishment in France. Identify the transactions carried out in France, their VAT treatment and who is liable for the tax.
Check whether the company has a French VAT number and whether any transactions may fall within e-reporting.
Finally, confirm that the company’s invoicing software and professional advisers are able to deal with the new requirements.
The French tax authorities provide official guidance for foreign companies without a permanent establishment explaining the relevant e-reporting requirements.
8. Electronic invoicing and setting up in France
The situation changes when a Spanish company decides to set up a business in France, establish a subsidiary or develop a structure constituting a permanent establishment.
The French entity or establishment may then fall directly within the French electronic invoicing requirements.
Invoicing should therefore be considered from the outset of a French expansion project.
Legal structure, VAT, recruitment, banking and invoicing arrangements are interconnected decisions.
9. Why you should not wait until 2027
For many Spanish SMEs, September 2027 may still appear some way off.
Yet their French customers, suppliers or entities may already have been affected by the reform since September 2026.
Adapting an ERP, selecting a platform, checking customer data and reviewing accounting processes also takes time.
Electronic invoicing in France should therefore be treated as an organisational project rather than simply a change in invoice format.
Electronic invoicing in France: start by assessing your position
For a Spanish company, the key conclusion is simple: there is no single answer applicable to every business.
Being established in Spain does not automatically make a company subject to the entire French e-invoicing system. But neither does it automatically place the company outside the reform.
A French establishment, VAT registration, the nature of transactions, who is liable for VAT and the company’s size can all affect the applicable requirements.
DA Communication supports Spanish companies with the administrative organisation of their activities in France and, where required, coordinates with specialist tax and accounting professionals.
Does your company invoice in France or are you preparing to enter the French market? Let’s discuss your situation and the procedures you need to anticipate.
