France’s B2B e-Invoicing and e-reporting mandate is moving ahead for a phased go-live from 1 September 2026, with full coverage by 1 September 2027. All VAT-registered businesses established in France will have to receive and issue structured e-invoices and transmit transaction data (e-reporting) through certified platforms or the public portal.
With the clock ticking, an amendment to the 2026 Finance Bill (PLF 2026) has been made: Amendment n° I-1028, which proposes a two-year “grace period” on e-invoicing and e-reporting penalties from 1 September 2026 to 31 August 2028 for businesses acting in good faith.
It is essential to understand that, as of 18 November 2025, this is only a proposal tabled in Parliament. It is not yet law, it may be revised, or it may be rejected entirely.
1. What is Being Proposed?
An amendment to the 2026 Finance Bill (often referred to as Amendment I-1028) would add a new rule to the e-invoicing section:
- Certain fines for e-invoicing and e-reporting failures would not be applied
- For infringements recorded between 1 September 2026 and 31 August 2028
- But only where the business is acting in “good faith”
2. Which Penalties Does the Proposal Target?
The amendment references two specific sanction provisions in the Code général des impôts:
2.1. Article 1737 III – invoicing penalties
In the e-invoicing context, Article 1737 III underpins fines for failure to comply with prescribed invoicing formats and content, including not issuing an e-invoice when required or issuing one that is materially non-compliant.
2.2 Article 1788 D I–II – e-reporting and platform penalties
Article 1788 D sets out the e-reporting data transmission penalties, both for taxpayers and for certified platforms. It provides for fines where taxable persons fail to send, or incorrectly send, the required transaction data, and a stricter penalty regime for PDP operators when the data they transmit on behalf of their clients is missing, inaccurate or non-compliant.
Amendment I-1028 does not delete these sanctions. It simply proposes a temporary shield from their application for good-faith businesses during the 2026–2028 transition period. The detailed conditions and what counts as “good faith” would be set out later in a government decree, not in the amendment itself.
3. Crucial Point: This is Not in Force Yet
It’s vital to be clear:
- The grace period is only a proposal attached to the 2026 Finance Bill.
- It is still going through the parliamentary process and can be changed or rejected.
4. How the “Grace Period” Would Work in Practice (if adopted)
Amendment I-1028 does not change the go-live dates and the legal obligations will still start on schedule.
- From September 2026: all businesses must be able to receive e-invoices, and large/ETI businesses must also issue e-invoices and e-report.
- From September 2027: SMEs and micro-businesses join the issuing and reporting obligation.
The proposed grace period would run from 1 September 2026 to 31 August 2028, covering the first years of live operation: first the go-live for large and mid-sized entities, then the entry of smaller businesses. During this two-year window, businesses acting in good faith would be shielded from the specific fines for non-compliant e-invoicing under CGI 1737 III and for e-reporting failures under CGI 1788 D I–II, even though the underlying obligations still apply.
Final note
The proposed grace period acknowledges the implementation challenges of France’s e-invoicing reform and seeks to avoid sanctions for early technical problems encountered by good-faith taxpayers. It is not yet in force, and, if adopted, will mainly assist those who are making clear efforts to comply.
