France Considers Two-Year Grace Period for E-Invoicing Penalties
The French authorities have introduced a significant amendment to the 2026 Finance Bill aimed at providing a “soft landing” for businesses transitioning to the mandatory electronic invoicing and e-reporting regime. The proposal seeks to suspend penalties for non-compliance during a two-year transitional phase, acknowledging the complexity of the digital reform and the need to ensure business continuity.
Legislative Proposal for Suspension of Penalties
Under the proposed amendment, companies acting in “good faith” would be exempt from administrative fines for specific non-compliance issues between September 1, 2026, and August 31, 2028. This measure is designed to ensure that businesses attempting to adapt to the complex digital transformation are not penalized for technical or operational hurdles during the rollout.
The waiver specifically targets fines outlined in the General Tax Code, covering:
- Article 1737, Section III: Penalties related to the issuance and reporting of electronic invoices.
- Article 1788 D, Section I: Fines applicable to taxpayers regarding e-reporting obligations and payment data transmission.
- Article 1788 D, Section II: Sanctions applicable to dematerialization platforms (PDPs) concerning e-reporting and payment reporting requirements.
Regulatory Definition and Next Steps
The proposal specifies that the precise conditions for this tolerance period (specifically the criteria determining “good faith”) will be defined by a forthcoming decree from the Council of State.
While the amendment seeks to secure business continuity and prevent systemic disruptions such as payment blockages or mass invoice rejections, it does not delay the entry into force of the mandate itself. It functions instead as a safety net to prevent unintentional non-compliance from becoming financially punitive.
This measure is currently a legislative proposal awaiting discussion and subsequent approval within the 2026 Finance Bill process. It has not yet been enacted into law.
There’s more you should know about e-invoicing in France – learn more about the new and upcoming regulations.
