This article applies exclusively to companies subject to French tax law (assujetties à la TVA, established in France).
What You Already Know — and What You May Be Underestimating
Since 1 September 2026, all VAT-registered companies established in France have been required to receive electronic invoices. That first step has passed — sometimes painfully, often with last-minute improvisation.
The second step arrives on 1 September 2027: by that date, SMEs, VSEs and micro-businesses will also be required to issue their B2B invoices in a structured electronic format, via an Approved Platform (Plateforme Agréée — PA). A simple PDF will no longer be sufficient.
Ten months. That is all the time left. And on the ground, the majority of SMEs have yet to take any concrete steps. The classic mistake: assuming that because large companies struggled in September 2026, SMEs will benefit from lessons learned. The opposite risk is more likely — SMEs have fewer IT resources, less time, and their service providers (software editors, integrators, accountants) will be overwhelmed with requests from spring 2027 onwards.
Anticipating means choosing. Waiting means being at the mercy of events.
What the Reform Concretely Requires from SMEs in 2027
Structured Electronic Invoicing — Not Just a PDF
An electronic invoice within the meaning of the reform is not a PDF sent by email. It is a file in a structured format recognised by the tax authority: Factur-X, UBL or CII. These formats embed machine-readable data that enable automated processing and transmission to the DGFiP (French tax administration).
The good news for SMEs: the Factur-X format (a hybrid PDF + XML) is generally the most accessible. It looks like a standard PDF invoice but embeds structured data within the file.
Mandatory Routing Through an Approved Platform
Every invoice issued or received must transit through an Approved Platform (PA) — formerly known as a PDP (Plateforme de Dématérialisation Partenaire). These platforms are accredited by the French State and act as trusted intermediaries between your system and the Public Invoicing Portal (Portail Public de Facturation — PPF).
Is your current invoicing software connected to an Approved Platform? This is the first question to ask your software provider.
E-Reporting — the Often-Forgotten Obligation
Alongside B2B electronic invoicing, SMEs will also be required to transmit transaction data to the tax administration for operations outside the main scope: sales to private individuals (B2C), transactions with foreign companies, and exports.
This is e-reporting. It follows the same timetable as the invoicing obligation. Many SMEs are unaware of it. Yet it is a separate legal requirement, with its own frequency and format constraints.
Data Quality — the Underestimated Challenge
The reform is not simply a matter of choosing a platform and clicking "activate." It requires foundational work on the quality of your data:
- Is your client database up to date? SIREN numbers, billing addresses and NAF codes are mandatory fields in a structured invoice.
- Are your VAT rules correctly configured in your software?
- Have you registered your suppliers in the reform's directory (annuaire)?
These tasks take time. Large companies that encountered difficulties in September 2026 consistently cited this data quality work as the most time-consuming element — far more so than the choice of platform.
What Large Companies Learned in September 2026 — and What SMEs Should Take From It
The field speaks for itself. Since 1 September 2026, several lessons have emerged:
Complexity is invisible from the desk. The most serious difficulties appeared during real-world testing: configuring the Approved Platform with the invoicing tool, interoperability between platforms, and managing invoice lifecycle statuses (accepted, rejected, refused, disputed).
The parallel PDF fallback is a safety net that comes at a cost. Many companies continue sending invoices as PDFs alongside the electronic flow to avoid payment delays. The result: double entry, risk of double accounting, and additional burden on teams. SMEs that prepare their transition properly will not need to go through this.
The distinction between technical rejection and commercial dispute is poorly understood. An invoice can be rejected because it is technically malformed. But a commercial disagreement does not justify a rejection — it triggers a specific dispute procedure, including the issuance of a credit note (avoir). SME accounting teams will need to be trained on these new rules.
A 5-Step Action Plan for SMEs Targeting September 2027
Step 1 — Assess Your Current Invoicing System (Now)
Identify your current invoicing software, its provider, and check whether it is already compliant with the reform or being updated. Ask your provider: Which Approved Platform do they offer? On what timeline? At what cost?
Step 2 — Clean Up Your Client and Supplier Database (By End of 2026)
Start now on data quality: SIREN numbers, addresses, NAF codes, VAT configuration. This is a project that takes several weeks in an SME with hundreds of clients or suppliers. Do not leave it for the last quarter of 2027.
Step 3 — Select and Test Your Approved Platform (Q1 2027)
Do not choose a platform from a brochure alone. Test it with your real data flows. Verify that it covers your specific use cases: self-billing (auto-facturation) if applicable, credit note management, B2C e-reporting if you sell to private individuals.
Step 4 — Train Your Teams (Q2 2027)
The reform is not purely an IT matter. It affects your sales teams (who issue quotes), your accounting department (which processes incoming invoices), and your operations staff (who validate orders). Plan short, role-specific training sessions.
Step 5 — Steer the Transition With a Dedicated Lead (Before September 2027)
Appoint an internal project lead — or delegate this role to your accountant. The reform is a genuine IT project, with milestones, risks and interdependencies. It deserves a governance structure, however lightweight, even in a 30-person SME.
Why Not Wait Until the Last Moment?
Service providers — software editors, integrators, accountants — will be saturated from spring 2027. Companies that start their project now will receive more attention, better conditions, and above all enough time to correct the inevitable errors that arise during testing.
The electronic invoicing reform is not just another administrative constraint. It is a fundamental transformation of your invoicing chain — bringing, in return, real automation, shorter closing timelines, and a level of traceability you do not have today.
But that opportunity only materialises if you prepare for it. Not if you are forced into it.
Trevys Is Here to Help
At Trevys, we support SMEs and mid-sized companies (ETI) throughout the preparation and deployment of the reform — from the initial assessment to project management, team training and platform selection.
Do you have questions about your specific situation? Book a call.