France – Proposed Grace Period for B2B E-Invoicing Requirement

The gradual implementation of statewide e-invoicing and e-reporting reform could be amended in some parts. The two-phase implementation framework is scheduled to be fully implemented by September 1, 2027. The first phase, scheduled for September 1, 2026, with accompanying requirements that affect all domestic VAT-registered taxable persons, is approaching. 

To make things “more interesting,” there is a proposal pending in the Senate, part of the draft bill for Finance Law 2026, that expressly “seeks” to introduce a grace period for taxable persons that are covered by the e-invoicing and e-reporting reform. 

The submitted proposal requests the introduction of a two-year grace period (without penalties) for “all” VAT-registered taxable persons under the e-invoicing and e-reporting mandate who couldn’t comply with the mandated requirements. 

There could be “different” reasons behind this legislative proposal. It should be noted that this is still a proposal, but a very important one. The proposal’s language remains vague, and if accepted, it would benefit from clearer, more self-explanatory notes. 

We can summarize the primary arguments of the proposal as follows: 

• Two-year grace period(no penalties) for taxable persons under the new mandate 
• Grace period starts on September 1, 2026, and ends on August 31, 2028 
• Only taxable persons acting in a good-faith capacity could adhere to the “grace period scheme.” 

In the upcoming weeks, the proposed amendment to the General French Tax Code that references Invoicing and Reporting requirements under the forthcoming reform shall be discussed in detail, and the final decision “should” be made on the grace period for the e-invoicing and e-reporting reform.