Expense reports: what France's September 2026 reform really changes for your VAT
Four months from the deadline, finance departments are measuring the scale of a long-underestimated challenge: electronic invoicing does not only impact supplier invoices. It reshapes the entire processing of your employees' expenses, and with it, your ability to recover VAT.
The electronic invoicing reform has, for years, been pitched as an IT and accounting project. The conversation centres on structured formats (Factur-X, UBL, CII), Approved Platforms, and near-real-time data transmission to the tax authority. What gets less attention is the weakest link in the chain: the employee on a business trip paying for a hotel with a personal card.
This everyday gesture, repeated millions of times each month across French companies, suddenly becomes a tax compliance issue from September 1, 2026.
The break introduced by the reform
Until now, the expense report flow has been simple: the employee pays, gets a receipt, hands it to accounting. The reform does not change the underlying rule — an invoice in the company's name remains required to deduct VAT above €150 HT. What it changes is the form that invoice must take: it must be electronic, issued by the supplier via an Approved Platform, and routed directly to the company.
The problem? In most expense report situations, it is the employee — not the company — standing at the counter.
Circuit des notes de frais — avant et après septembre 2026
The €150 HT rule: simple on the surface, complex in practice
Below €150 HT, a simplified invoice suffices. Above, a full invoice in the company's name is required to deduct VAT. The novelty is the mandatory electronic format for that invoice.
In practice, this threshold is the source of many errors. A team meal at €160 HT, a hotel night at €200, a car rental — situations where the employee, having failed to communicate the company's SIREN, walks away with a till receipt instead of an e-invoice. The result: VAT is lost.
From September 2026, a company receiving an expense report above €150 HT without a matching e-invoice will have to choose between not deducting VAT — or asking the supplier to reissue an e-invoice. The latter is rarely possible after the fact.
Arbre de décision — quel traitement pour une note de frais ?
The double-counting risk: the overlooked trap
The reform introduces a new risk: double counting. An employee pays €300 for a car rental, requests an e-invoice with the company SIREN, and submits an expense report. Two channels now feed accounting: the expense report from the employee, and the e-invoice routed automatically from the supplier's Approved Platform. Without rigorous reconciliation, the expense can be booked twice — and VAT deducted twice.
DGFiP specifications require reconciliation between the expense report and the corresponding e-invoice to validate VAT deduction. This reconciliation must be traceable and archived with probative value.
Risque de double comptabilisation
Special cases: mobility and restaurants
For restaurant bills below €150 HT, an administrative tolerance applies: VAT is deductible without e-invoice, provided the receipt mentions the rate and amount of VAT and a sequential number. The restaurateur must still transmit the transaction data via e-reporting.
For tolls and parking paid at automated machines, the machine cannot collect the SIREN, making e-invoicing impossible. These fall under supplier e-reporting. VAT remains deductible on receipt, but must be reported manually in the return — without auto-fill.
Toll subscriptions and corporate fuel cards, on the other hand, generate standard B2B e-invoices issued monthly via the relevant Approved Platforms.
The operational stake: prepare your employees
The reform poses a behavioural problem at the counter. Training your employees to systematically communicate the company SIREN before any purchase above €150 HT is becoming an operational priority.
1. Inform — Explain the €150 HT rule and its VAT impact to all travelling staff. 2. Equip — Provide a card or QR code with the SIREN and the company's e-invoicing address. 3. Integrate — Connect the expense management tool to the Approved Platform to enable automatic reconciliation. 4. Automate — Delegate VAT recovery to a dedicated OCR tool to avoid errors and lost rights.
How TEVASOFT helps
TEVASOFT CONNECT sits between your Approved Platform and your expense management tool (SAP Concur, N2F, Lucca, Cegid…) to automate e-invoice reception, reconciliation with expense lines, and duplicate detection. EVA, our AI audit layer, flags VAT anomalies and lost-right risks before they turn into adjustments.
→ Pillar page: e-invoicing for expense reports — France 2026