French e-invoicing one month in: what it means for expense reports
No breakdown, but friction
On September 1, 2026, every company established in France became required to receive e-invoices. Large companies and mid-caps must also issue them and transmit their e-reporting data. One month later, the picture is twofold: no paralysis, but a rougher start than project plans suggested.
The French government had set the tone in late August: September 1 is "not a cut-off date", and no penalties will be applied before the end of 2026. The French tax authority (DGFiP) summed up its doctrine in one line: the goal is adoption, not fines.
Three points of friction reported from the field
Feedback from accounting firms, software vendors and finance teams converges on three points:
- Rejections for missing data. An invoice missing a mandatory field, or in a non-compliant format, is rejected by the platform. What used to go through as a PDF no longer does.
- Addressing errors in the national directory. A company that is listed incorrectly, or whose receiving address points to the wrong platform, simply doesn't receive its invoices.
- Registrations never completed. Many companies thought they were ready when their platform onboarding (rights, synchronization, configuration) was still unfinished.
Add to that technical incidents on the platforms themselves. Of the 31 incidents logged in September, some directly affected issuance, reception, statuses or the directory. Nothing unusual for a launch of this scale, but enough to delay invoices by several days.
What actually changes for expense reports
Most e-invoicing projects were scoped on the supplier side. The expense report channel is discovering the effects week by week. Three situations now coexist:
Hotel or car rental company subject to issuance, invoice in the company's name
The invoice arrives through the certified platform, and often also as an attachment to the expense report
Small merchant (independent hotel, restaurant)
Not yet required to issue: paper or PDF invoice until September 1, 2027
Till receipt or low-value expense
Remains a standard receipt, checked in the expense tool
The first case is the trickiest. An employee pays for a hotel night with their card, asks for an invoice in the company's name and attaches it to their expense report. If the hotel is a large company, the same invoice is also sent to the company's platform. Two channels, one expense. Without reconciliation, accounts payable may process the invoice while the expense report is reimbursed.
The second case complicates control rules. For a year, a hotel invoice will be electronic or PDF depending on the size of the issuer. A control that always requires an e-invoice would block legitimate expenses; one that never requires it would let duplicates through.
Tolerance is not exemption
The absence of penalties in 2026 is a tolerance, not a suspension of the law. The fines set out in the French General Tax Code are very much in force. The announced leniency targets companies that have started their compliance work and can document their difficulties, not those that have done nothing.
Keep evidence of every incident (time-stamped status page screenshots, exchanges with the platform, rejected invoices). In an audit, that file is what demonstrates your good faith.
Five actions to take before December 31
- Check your directory entry: company ID, receiving addresses and linked platform, for every entity in the group.
- Identify the T&E suppliers already issuing: hotel chains, car rental companies, travel agencies. They are the ones creating the dual-channel risk.
- Reconcile e-invoices with expense reports: every invoice received in the company's name should be matched against expense lines from the same supplier, on the same date, for the same amount.
- Adapt your control rules: distinguish issuers already subject to the mandate from those that are not yet, rather than applying a single rule.
- Prepare for September 2027: on that date, SMEs and micro-businesses will start issuing too. Nearly all hotel and restaurant invoices will then switch over.
Mandatory reception for all companies, issuance for large companies and mid-caps
End of the penalty-free period announced by the government
Mandatory issuance for SMEs and micro-businesses
The format is compliant, the content still needs checking
The first month made it clear: format compliance is a technical issue that platforms and the directory will eventually stabilize. The real question on the expense side lies elsewhere. A compliant e-invoice doesn't tell you whether the expense has already been reimbursed, whether it follows the travel policy, or whether it is business-related. That is the role of content audit.
That is what CONNECT does: automatically reconcile the e-invoice received by your certified platform with the matching expense line in SAP Concur or N2F. EVA then takes over to audit the content of 100% of expenses.
Read more: SAP Concur and 2026 e-invoicing, expense reports over €150 and e-invoicing and duplicate expense reports.
Want to know how many of your expenses currently arrive through two channels? Discover EVA or contact us.