DGFiP signals pragmatic enforcement approach despite statutory e-invoicing and e-reporting penalties from 2026
- French tax authorities confirmed penalties under the Finance Law will not be applied immediately from 1 September 2026.
- Leniency for businesses showing genuine implementation efforts and remediation plans on case-by-case during onboarding.
- Statutory penalties remain in force for persistent non-compliance, including €50 per e-invoice and €500 per e-reporting failure.
DGFiP encouraging “trial and error” approach, accepting mistakes rather than inaction
French tax authority officials have indicated that the penalty regime introduced in the Finance Law for the September 2026 e-invoicing and e-reporting mandate (see below) will not be applied immediately or systematically from day one of implementation. Speaking at the Annual E-Invoicing Day event on 7 May 2026, DGFiP Director General Amélie Verdier stated that businesses will first be contacted and asked to demonstrate their compliance approach and implementation progress before sanctions are considered.
The French administration confirmed that a “right to make mistakes” approach will apply during the early stages of the rollout, with remediation periods and case-by-case analysis for businesses encountering genuine implementation difficulties. This reflects recognition of the scale and complexity of the reform, particularly for ERP integrations, PDP onboarding, invoice data mapping, and transactional reporting workflows.
However, the statutory penalties introduced under the Finance Law remain in force. Persistent non-compliance, failure to engage with the reform, or behaviour considered to jeopardize the functioning of the system may still result in sanctions. The current framework includes penalties of €50 per non-compliant e-invoice and €500 per missing or incorrect e-reporting transmission, both subject to annual caps.
The statements suggest that French enforcement policy in the initial phases will focus more on onboarding businesses into operational compliance and stabilising the interoperability ecosystem, rather than imposing automatic sanctions for isolated or transitional errors.
March 2026: Updated e-invoicing & e-reporting penalties for Sept 2026–27 mandate
- France’s 2026 Finance Law clarifies penalties for non-compliance with the upcoming e-invoicing and e-reporting regime.
- Fines apply to invoices issued outside approved platforms, failures to receive e-invoices, and missing e-reporting data.
- Businesses benefit from a limited “first offence tolerance” if errors are corrected promptly.
France has updated its enforcement framework for the upcoming September 2026 e-invoicing and e-reporting mandate through Article 123 of the Finance Law for 2026 (Law No. 2026-103 of 19 February 2026). The reform amends several provisions of the French Tax Code (Code général des impôts or CGI), including Articles 289 bis, 289 E, 290, 1737 and 1788 D, establishing clearer penalties for non-compliance with the country’s structured digital invoicing and e-reporting regime.
The changes come ahead of France’s staged rollout beginning September 2026, when companies must be able to receive structured electronic invoices via the government’s platform network, followed by mandatory issuance and expanded e-reporting obligations.
Penalties for non-compliant electronic invoices
The revised regime introduces a €50 penalty per invoice where businesses:
- issue invoices outside an approved platform, or
- fail to comply with the legal requirements for structured electronic invoicing.
Although modest individually, the per-invoice approach could create significant exposure for high-volume businesses if errors occur systematically.
Failure to receive e-invoices through a platform
Companies that fail to connect to an approved platform for receiving e-invoices face a progressive penalty regime. The tax authority first issues a formal notice, giving the business three months to comply. If the failure continues:
- €500 penalty after the first notice
- €1,000 after a second notice (again with three months to remedy)
- €1,000 every three months thereafter until compliance is achieved
This escalation mechanism is designed to ensure all businesses are integrated into the platform network before mandatory issuance begins.
Penalties for missing e-reporting data
Separate sanctions apply where businesses fail to transmit required e-reporting information to the tax administration.
- Transaction data: €500 per transmission failure, capped at €15,000 annually
- Payment data: €500 per failure, also capped at €15,000 annually
These penalties reflect the importance of e-reporting in France’s broader real-time VAT monitoring system.
Limited tolerance for first errors
The law includes a tolerance clause to encourage early compliance. No penalty applies where:
- the error is the first infringement in the current year and the previous three years, and
- the business corrects the issue voluntarily or within 30 days of the tax authority’s first request.
Preparing for enforcement
While the headline penalties appear moderate, the real compliance risk lies in automated VAT controls and near real-time data analysis enabled by the French platform network. Repeated anomalies may quickly trigger broader tax audits or additional fiscal penalties.
Businesses with French operations should now be:
- preparing structured invoice formats compatible with the platform network
- mapping transaction and payment data required for e-reporting
- testing end-to-end invoice and VAT reporting processes before the September 2026 go-live.
As France moves towards continuous VAT monitoring, robust automation of invoice determination, validation and reporting will be essential to avoid repeated compliance breaches and the associated financial penalties.
