France asked for three things. Getting paid was not one of them.

There is a moment in every compliance project when the work is done and nothing feels different. The invoices still go out. The customers still owe the same amount. The only thing that changed is the file format and who else gets a copy. France reached that moment on 1 September, and it is not the only market heading there.

Martin Svane

Article2026.09.23

The new rules ask for three things: an e-invoice, meaning a structured file rather than a PDF, delivery through a platform the state has approved, and transaction data that reaches the tax authority. Emailing an XML file, even a correct one, does not count.

From 1 September every French business has to be able to receive e-invoices, while for now only the large and mid-sized ones have to send them and report, with smaller companies following in September 2027. Everyone had to be ready to receive; only some had to be ready to send. That asymmetry is the whole design, and it is also where the risk sits, because in France it puts a capable recipient on the other end of every invoice you issue.

For the businesses billing through us in France, the first bill run after that date went out as planned. We did not build the French platform ourselves. We deliver through an accredited partner, under one contract, and we say so plainly because this market is not always precise about which company holds which approval.

The harder part was the timing, because France runs two clocks at once. An invoice to a business customer goes through the platform. A sale to a consumer never becomes that kind of invoice at all. It is reported as data instead, which the rules call e-reporting, on a separate schedule. Most recurring revenue businesses have both kinds of customer in the same monthly run, which means one process now has to satisfy two obligations moving at different speeds.

Cross a border and the shape changes again. Belgium went live on 1 January 2026 and left consumers out entirely, while Italy has run both consumer and business invoices through one national system since 2019. Germany has required businesses to receive since January 2025 and will not require them to send until January 2027, or 2028 if they are small. Norway does it the other way round, issuing from 2027 and receiving not until 2030. Spain is phasing its obligations in from 2027, with the reporting dates set and parts of the e-invoicing rollout still open. Anyone planning for a single European e-invoicing requirement is planning for something that does not exist.

There is one thing worth checking this week. In every market where you invoice a business customer, find out whether those customers are already obliged to receive structured invoices. Where they are, they have a reason to turn down a PDF, and the date they were equipped is usually earlier than the date in your own calendar.

And then there is the part the rules say nothing about. An invoice can satisfy every requirement on the list and still sit unpaid in an inbox in Lyon while your own ledger says it went out on time. The authority is satisfied. The money has not moved.

That gap is where we spend our time. We built the invoicing and the reporting because the law requires them, but we built both inside the same platform that handles the payment, the reminder and the recovery. An invoice does not stop being our problem when a tax authority accepts it. It stops being our problem when the money arrives.


Every advisor in Europe is writing about the dates. The question worth an hour of your time is a different one: which of your customers can already refuse a PDF, and what it does to your cash if they do. If you want to work that through for your own billing, in France or in the markets coming next, we will.


Martin Svane