Invoicing customers in France: What the new e-invoicing mandate means for you

As of 8 October 2026. For businesses in Austria and Germany with business customers in France. The examples are hypothetical.

Suppose your customer in Lyon writes: “Since September, we only accept invoices through our platform. Please register.”

Until now, you have sent them a PDF. Now you are being asked to create an account, supply a different invoice format and perhaps sign a paid contract. Do you have to?

Having a French customer does not, by itself, put you under France’s e-invoicing mandate. Foreign businesses without a fixed establishment in France for VAT purposes are excluded from mandatory French e-invoicing. The French tax authority states this explicitly. Whether you must report data to the French tax authority yourself is a separate question. 1 · DGFiP: Foreign businesses

That does not settle your customer’s request. They may have a good reason for changing their process. You may also have already agreed a particular submission method in your contract.

What changed in September

France’s mandatory rollout began on 1 September 2026. Businesses established in France that are taxable persons for VAT purposes and fall within the scheme must now be able to receive e-invoices. Large businesses and ETIs, the French size category above small and medium-sized enterprises, must also issue them. For smaller businesses, the issuing obligation starts on 1 September 2027.

The mandatory invoice exchange generally covers transactions within the scheme between businesses established in France. It uses state-approved providers known as plateformes agréées. An ordinary PDF sent by email does not meet that requirement. 2 · Ministry of Economy: Timetable and scope

The shorthand claim “France no longer accepts PDF invoices” therefore leaves out something important: which invoices does the rule actually cover?

Your customer may have to report what they buy from you

An Austrian merchant supplies goods from Austria to a business in Lyon. The merchant has no fixed establishment in France, and the purchase is an intra-Community acquisition for the customer.

French rules require the French purchaser to report data on purchases of this kind. Certain services bought from foreign suppliers are also covered. The obligation starts on the rollout date applicable to the customer. This is expressly set out in the administrative guidance published on 30 September 2026. 3 · BOFiP: Section II-B, paragraph 60

This submission is called e-reporting. The customer sends transaction data to the tax authority. You still issue an invoice to the customer; their report does not replace it.

Their accounts team may find it convenient to process foreign invoices through the same channel as domestic ones. Structured data avoids retyping and can make reporting easier. A platform request may therefore come from the customer’s new working arrangements, without you being legally subject to French e-invoicing yourself.

The tax authority expressly allows voluntary electronic invoice exchange with foreign businesses. Supplier and customer should agree how to exchange those invoices. 4 · DGFiP: FAQ on voluntary invoice exchange

A French VAT number does not make you a French business

Your business may already have a French VAT number. That alone does not change its status.

VAT registration is not a fixed establishment. Article 11(3) of EU Implementing Regulation 282/2011 expressly states that a VAT identification number is not, by itself, sufficient to establish that a taxable person has a fixed establishment. 5 · EUR-Lex: Article 11

Even an entry in France’s e-invoicing directory does not establish an obligation. Foreign businesses may appear there because they have a French business identifier, known as a SIREN. According to the tax authority, that entry alone creates neither an e-invoicing nor an e-reporting obligation. 4 · DGFiP: FAQ on the invoicing directory

If you have staff or technical resources in France, however, ask your tax adviser to check whether you have a fixed establishment for VAT purposes. A registered address in Austria or Germany does not conclusively answer that question.

When you might need a platform yourself

Change the example: the Austrian merchant also sells goods from a warehouse in France to French private customers, without having a fixed establishment there for VAT purposes.

If these sales are subject to French VAT and the merchant is liable for that tax, the merchant may have e-reporting obligations of their own. Exceptions need to be considered, including those for certain transactions handled through an EU VAT One Stop Shop. A business that must carry out e-reporting itself needs an approved platform for that purpose. 1 · DGFiP: Reporting obligations and platform selection

For small and medium-sized foreign businesses acting as sellers, this obligation generally starts on 1 September 2027; for large businesses and ETIs, it started on 1 September 2026. In each case, the transactions must actually fall within the reporting requirement. 4 · DGFiP: FAQ on the rollout dates

If you already file French VAT returns, discuss the individual transactions with your tax adviser. Which sales must you report yourself? Which reports are the customer’s responsibility? When does each obligation start? Those questions are more useful than a general request to make your business “France-compliant”.

What about Factur-X?

Factur-X is one of the French system’s core exchange formats, alongside UBL and CII. It combines a readable PDF with structured XML invoice data. Having a customer in France does not automatically require you to use it. 6 · DGFiP: Invoice formats, page 11

If your customer requests Factur-X, you need a specific technical requirement. Which version and profile do they accept? Where should the file go? Can you send it from your existing invoicing software, or is an upload required?

Clarify this before buying software. An export your software already supports may be enough. The customer may need additional details. “Please invoice electronically” is too vague to set up a reliable process.

Back to the message from Lyon

First check the purchase order, contract and agreed invoicing terms. The tax reform alone does not determine whether you must use the customer’s requested channel.

If your business really has no fixed establishment in France for VAT purposes, you could ask:

We are established in Austria and have no fixed establishment in France for VAT purposes. Does your new submission requirement also apply to foreign suppliers?

Which invoice format and submission method should we use? Will you provide a supplier account, or do we need our own contract with a platform provider? Please also let us know about any costs.

Could you confirm that the invoice we have already sent has been received and is being processed?

That last question matters. While you agree the future process, the outstanding invoice should not be left unprocessed.

This article concerns private-sector business customers. Public-sector customers have separate procedures; Chorus Pro remains France’s central public-sector invoicing platform. The examples explain the distinctions and do not replace tax advice on your particular transactions. 7 · DGFiP: Chorus Pro

Further reading: E-invoicing obligations in Germany and Austria and the differences between Factur-X, XRechnung and other invoice formats.