The French text is the legally binding one. This page is a working guide for a reader who does not read French; it is not a substitute for the instruments themselves, and wherever a decision turns on wording, the French wording governs.
What exactly does 1 September 2027 cover?
| Date | Obligation | Who |
|---|---|---|
| 1 September 2026 | Reception | Every business that is a taxable person for French VAT, whatever its size |
| 1 September 2026 | Issuing + e-reporting | Grandes entreprises (GE) and entreprises de taille intermédiaire (ETI) |
| 1 September 2027 | Issuing + e-reporting | PME, TPE and micro-entreprises |
English-language coverage routinely calls 2027 "the SME wave", implying a further step for the smallest businesses. There is none. The administration groups small and medium-sized enterprises together with micro-enterprises, and the deadline covers e-reporting as well as issuing.
Which of your French entities is in this wave?
Size is assessed at 1 January 2025, on the last financial year closed before that date, at the level of the unité légale identified by its SIREN. The reference date is frozen: a threshold crossed since does not change the category. Thresholds from décret n° 2008-1354: micro-entreprise, fewer than 10 employees and turnover ≤ €2m or balance sheet total ≤ €2m; PME, fewer than 250 employees and turnover ≤ €50m or balance sheet total ≤ €43m. Document this once; it does not recalculate.
Nothing that happened after 1 January 2025 changes the answer. An acquisition, a reorganisation, a carve-out or simply a good year does not move an entity between waves: an entity that crossed a threshold in 2025 or 2026 still belongs to the category determined at 1 January 2025. Determine it once, record the evidence — the accounts used and the closing date — and treat the result as static configuration rather than a rule that recalculates. A system querying current headcount or current turnover will be wrong at precisely the category boundaries where being wrong is expensive.
For a group this has a consequence worth stating plainly: a group can hold French entities in both waves. A programme delivered for a GE or ETI subsidiary in September 2026 covers that entity's contract, its platform integration and its e-reporting cadence. None of that transfers automatically to a smaller sister company with its own SIREN, its own VAT regime and, frequently, its own accounting system. Plan per SIREN, not per country.
What is already obligatory today?
Reception, since 1 September 2026, for every taxable person for French VAT, with no size condition. A micro-entreprise treating 2027 as its entry date into the reform is a year late on half of its obligation. A dormant French subsidiary that issues nothing at all is still caught by the reception limb.
Proving reception is a five-minute exercise that groups routinely skip because a vendor has said it works. Have a supplier already in production send a real invoice to the French entity, and confirm three things: that it arrives, that it can actually be processed by the receiving system rather than merely landing somewhere, and that a lifecycle status goes back. Do it for every French SIREN, dormant entities included, because the entity that fails is rarely the one anybody thought to test.
And using a plateforme agréée, because there is no free public option. Article 123 of the loi de finances pour 2026 settled the abandonment of the free public issuing and receiving portal. The portail public de facturation (PPF) keeps only the central annuaire (CGI, art. 289 bis) and the concentrateur (CGI, art. 242 nonies G). Every B2B flow passes through a plateforme agréée (PA) — the official term since décret n° 2026-677 and the arrêté of 27 July 2026, formerly PDP. English-language material still says PDP almost universally; using it as a live term dates a document to before the summer of 2026. An opérateur de dématérialisation (OD), not being registered, cannot transmit to the administration on its own and sits behind a PA. Chorus Pro remains the public-sector (B2G) platform. Our corrections list is at corrections.
What has to be done, and in what order?
| No. | Step | Due by |
|---|---|---|
| 1 | Confirm each entity's category on the frozen assessment at 1 January 2025 | Immediate |
| 2 | Prove you actually receive, with a test invoice from a supplier already in production | Immediate |
| 3 | Register the receiving address in the annuaire, for every SIREN including dormant ones | Immediate |
| 4 | Contract a plateforme agréée covering issuing and e-reporting, not reception alone; check whether registration is sous réserve | End 2026 |
| 5 | Derive the e-reporting frequency from each entity's VAT regime | Q1 2027 |
| 6 | Clean the reference data: SIREN and SIRET, addresses, order references, VAT numbers | Q1 2027 |
| 7 | Settle the base format: Factur-X, UBL or CII | Q1 2027 |
| 8 | In a hybrid format, guarantee that the XML and the PDF come from a single source | Q2 2027 |
| 9 | Test the four statuses and audit the mapping of internal error codes | Q2 2027 |
| 10 | Fix the evidence retained for each issuance | Q2 2027 |
The annuaire at step 3 has been live since June 2025, with a lookup service open since September 2025, and more than a million businesses had registered a receiving address by May 2026. The AIFE opened an offline lookup by CSV upload in mid-June 2026, taking up to 5,000 SIRETs — useful for a group checking a whole portfolio of entities in one pass rather than one at a time.
How is your e-reporting frequency derived?
| VAT regime | Frequency | Deadline |
|---|---|---|
| Réel normal, monthly | Per decade | Within ten days |
| Réel normal, quarterly option | Monthly | Before the 10th |
| Simplified | Monthly | 25th to 30th of the following month |
| Franchise en base | Bimonthly | 25th to 30th after the period ends |
E-reporting covers B2C operations, international operations and payment data for supplies of services. Excluded are imports of goods, VAT-exempt activities, the OSS and IOSS one-stop shops, and defence-classified operations. A business trading purely domestic B2B therefore has a reduced perimeter — never a nil one, once issuing applies.
The line that matters most to a group sits inside "international": a transaction with a taxable person not established in France falls under e-reporting, not under the domestic e-invoicing mandate. An invoice from your French entity to a German, British or US group company is a data feed to the administration, not a document routed through the annuaire. Teams that model every intragroup flow as an e-invoice build a channel they do not need and miss the reporting obligation they do. Under the régime réel normal with monthly VAT that reporting runs three times a month, which is a staffing question in a shared service centre, not a technical one.
Which steps are missed most often?
Step 4. More than 140 platforms are registered, a figure that moves; the official list distinguishes those meeting all conditions, interoperability tests included, from those whose registration is still sous réserve. The decisive nuance: the number of platforms genuinely offering issuing on 1 September 2026 was materially lower than the registration count, because a share of operators position themselves on infrastructure or white-label supply. Verify the use case covered, not just reception.
Step 8. The three base formats rest on EN 16931: Factur-X (hybrid, PDF/A-3 with embedded XML), UBL and CII. In the hybrid, the XML prevails; the PDF is only a rendering, and where they diverge the operative content is the one nobody read. Ask your platform which version of the spécifications externes it applies — 3.2 dates from 30 April 2026. Our comparison is at Factur-X, UBL and CII.
Step 9. Four statuses are mandatory: déposée, rejetée, refusée and encaissée. Rejetée is a technical rejection by a platform; refusée is a commercial refusal by the recipient, admitted on three grounds only: a regulatory non-conformity not caught by the receiving platform, an unrecognised transaction, and a breach of contractual conditions preventing processing. The administration is explicit that refusée must not be used for a simple commercial dispute. An automatic mapping between internal error codes and these normalised statuses therefore issues legal qualifications, not acknowledgements. See our note on the audit trail and the glossary entry.
Why start now rather than in spring 2027?
Connection capacity is finite. At the end of August 2026 a substantial share of smaller French businesses had still not chosen a platform. They will all present themselves in the same window, in a market where onboarding is counted in person-days. Arriving in May 2027 means negotiating at the worst possible moment — and a foreign group has the additional handicap of needing contract review in a language its legal function may not read.
Until September 2027, an error costs nothing. While the issuing obligation is not opposable to the entity, a failed test or a badly projected status has no declarative consequence. Afterwards, each one carries a fine.
| Failure | Amount | Annual cap | Basis |
|---|---|---|---|
| Failure to issue in electronic form | €50 per invoice | €15,000 | CGI, art. 1737 |
| Failure to transmit (e-reporting) | €500 per transmission | €15,000 | CGI, art. 1788 D |
| Failure to use a plateforme agréée | €500 after a three-month formal notice, then €1,000 every three months | — | — |
The first-offence relief is spent only once. It removes any penalty for a first offence committed during the current calendar year and the three preceding ones, provided it is put right spontaneously or within thirty days of a first request from the administration: one protection on a rolling four-year window. Using it in September 2027 on a botched configuration leaves nothing in reserve for the real incident that follows. As for the tolérance de démarrage, the DGFiP states that it is neither a postponement nor a suspension of the obligation: what protects you is not the calendar, it is the ability to document good faith and a remediation path.
Should you wait for the PLF 2027?
No, but you should account for it. The projet de loi de finances for 2027 had not been tabled as at 3 September 2026. Every previous slippage in this reform arrived through a loi de finances; no measure has been announced concerning the 2027 deadline. That is the window to watch, and no more than that. The reasonable course: run steps 1 to 4 without waiting — obligations already in force, or contracts that will take months — and put an explicit checkpoint after the PLF 2027 is published before committing integration spend. A plan that assumes a deferral is a plan with no fallback.
What is different for a smaller French entity of a foreign group?
Five things the domestic guidance has no reason to mention.
- The obligation is the entity's, not the group's. A French subsidiary is caught in its own right, whatever the parent's arrangements elsewhere, and the penalty caps apply per entity.
- Your 2026 programme does not carry over. The GE or ETI entity's platform contract, integration and reporting cadence were built for that SIREN. Check explicitly whether the contract covers the group's other French entities and at what price.
- Intragroup cross-border flows are e-reporting, not e-invoicing. Route them accordingly, and derive their cadence from the French entity's VAT regime rather than the group reporting calendar.
- The reference data usually lives outside France. Step 6 becomes a master-data project spanning systems the French entity does not administer, which is why it belongs in Q1 rather than Q2.
- Nobody in the group may read French. The platform contract, the specifications and the administration's guidance are all in French, and the French text is the binding one. Budget for translation or for local advice on the contract, not just for the software.
In practice
Where the flows cross ERP, platform API, treasury and reporting across several legal units, BarzelOps runs governed cross-system workflows with durable state, approval checkpoints and tenant isolation. Tenant isolation is the property that keeps one French SIREN's flows and evidence separate from another's on a single automation estate.
Frequently asked questions
Do the smallest businesses have a later deadline than PME?
No. 1 September 2027 is a single wave, and it covers issuing as well as e-reporting. There is no separate later step for micro-entreprises.
Does a micro-entreprise under franchise en base do e-reporting?
Yes. The VAT regime does not exempt it, it sets the frequency: bimonthly, between the 25th and the 30th after the period ends.
Is there a free public option for issuing?
No. The PPF keeps only the central annuaire and the concentrateur. Every B2B flow goes through a plateforme agréée. Chorus Pro remains the B2G platform.
What does a sous réserve registration mean?
A complete application whose definitive registration remains conditional on passing the interoperability tests. Check the official list rather than a fixed platform count.
Should we wait for the PLF 2027 before starting?
No. Set a checkpoint after it is published, not a suspension. Every previous slippage came through a loi de finances, and the PLF 2027 had not been tabled as at 3 September 2026.
Does our 2026 programme already cover the 2027 entities?
No. Size is assessed per SIREN, so a group can hold entities in both waves. Contract, integration and cadence do not transfer to a sister company automatically.
In practice
The control has to run before the invoice becomes irreversible.
An accepted structured invoice can be corrected but never deleted, and from the penalty date every defect has a price. Barzel puts the approval threshold, the duplicate check and the signed record in front of submission, so the process can be defended on the day an auditor or the tax authority asks.
338 days leftPME, TPE and micro-entreprises: issuing and e-reporting from 1 September 2027
BarzelOps
Governed workflow automation across the systems that run the business.
- Durable, idempotent execution: a timeout is retried once, never filed twice.
- Human approval checkpoints that pause the workflow and resume it.
- Isolation per entity or client, signed evidence receipts and a portable manifest; HubSpot, Xero, Gmail, Google Drive and Slack.
Free tier: 100 calls a dayPaid plans from $19 a monthLive on MCPize
BarzelVault
The AI action firewall: decide what an agent may do before it does it.
- Approval thresholds and policy checks enforced before execution; human approvals that expire and escalate.
- Cryptographically signed audit receipts: trigger, inputs, policy version, approver, outcome.
- Credential isolation, spend and action limits, and an emergency kill switch.
Free tier: 10,000 calls a monthPaid plans from $199 a monthLive on MCPize
Enterprise: written quote by email within two business days. No sales call.
Related
- France's e-invoicing reform: what changed on 1 September 2026
- Factur-X, UBL and CII: choosing a format and what each costs downstream
- Building an audit trail across ERP, plateforme agréée and recipient
- Keeping control when AI agents issue invoices into an irreversible national system
- Governed workflow automation: the cost is the exit
- Glossary: e-reporting, plateforme agréée and the rest of the vocabulary
Sources
- Article 123 de la loi n° 2026-103 du 19 février 2026 de finances pour 2026, Légifrance.
- Décret n° 2026-677 and arrêté du 27 juillet 2026 (plateformes agréées); décret n° 2008-1354 (size categories).
- CGI, art. 289 bis (annuaire) and art. 242 nonies G (concentrateur); art. 1737 and art. 1788 D.
- impots.gouv.fr, Spécifications externes B2B, version 3.2 of 30 April 2026; Liste des plateformes agréées.
- entreprendre.service-public.gouv.fr, news item of 20 February 2026 (penalty amounts).
- AFNOR standards XP Z12-012, XP Z12-013 and XP Z12-014, and European standard EN 16931 — paywalled, with no free official full text; not linked.
This article is for information and does not constitute tax or legal advice. The French text is the binding one.