Electronic invoicing: are you truly ready for September 1, 2026?

The countdown has begun.

Starting September 1, 2026, all companies subject to the reform must be capable of receiving electronic invoices. On that same date, large companies and mid-sized enterprises must also issue them and ensure the transmission of their e-reporting data.

On paper, the timeline is clear. In reality, one question remains: will your system actually work on the big day?

Choosing a certified platform is essential. However, that alone does not guarantee that your invoices will be correctly transmitted, received, integrated, and processed.

Flows, data, formats, directories, statuses, rejections… With one month to go before launch, every detail must now be verified.

To help companies and certified platforms perform this check, the FNFE has published an operational checklist organized into three sections.

Consult the FNFE checklist

September 1, 2026: what is actually changing

The rollout of the reform will take place in two stages.

As of September 1, 2026, all companies falling within the scope of the reform must be able to receive electronic invoices, regardless of their size.

On that same date, large companies and mid-sized enterprises must:

• issue their electronic invoices;
• transmit their e-reporting data;
• manage the new lifecycle statuses;
• use a Certified Platform to route their data flows.

SMEs, VSEs, and micro-businesses will benefit from an extended deadline for e-invoicing and e-reporting, now set for September 1, 2027. However, they must be ready to receive electronic invoices by September 2026.

The first question to ask yourself is simple: have you chosen and designated your Certified Receiving Platform?

If not, discover DEMATRUST, the Certified Platform from ICD International.

For SMEs looking for a simple start, DEMATRUST Light allows you to approach the reform with a solution tailored to your needs, with the option to gradually add invoicing, integrations, or automation features later on.

Choosing a platform doesn't necessarily mean the project is finished

This is likely the biggest trap to avoid.

Signing with a Certified Platform is an essential step. However, operational compliance depends on many other factors.

Has your platform been properly registered? Are your billing addresses published in the directory? Are your software systems connected? Is your data complete? Are formats being handled correctly? Do your teams know what to do when an invoice is rejected?

A platform can be chosen without the system being ready to operate.

That is precisely the purpose of the FNFE checklist: to shift from a project-based mindset to a validation-based one.

Phase 1: all companies must be ready to receive

The first phase concerns all taxable companies falling within the scope of the reform.

Starting September 1st, they must be able to receive electronic invoices sent by suppliers who are either required to issue them or have voluntarily joined the system.

This requires designating an accredited platform, as well as preparing the entire downstream processing workflow.

Is your company's information correctly listed in the directory?

The central directory will make it possible to identify the platform chosen by each company and the address to which its invoices should be sent.

Missing or incorrect information can be enough to block the delivery of an invoice.

Before getting started, be sure to check:

• the SIREN and SIRET numbers for your entities;
• the relevant establishments;
• the billing addresses;
• the routing rules for your various departments;
• the accredited platform associated with each scope.

For a company with multiple establishments, brands, subsidiaries, or management centers, this task can quickly become complex. It should not be left until the last minute.

Can you actually process the invoices you receive?

Receiving an invoice on a platform is not enough.

You must also be able to read it, extract its data, integrate it into the right tools, match it with a purchase order, and proceed with the standard validation and payment process.

Tests must therefore cover the entire workflow:

1. invoice receipt;
2. format and data verification;
3. integration into the accounting system;
4. matching with the purchase order or receipt;
5. internal validation ;
6. payment processing ;
7. transmission of expected statuses.

An invoice that is received but blocked at the entry point of your ERP remains an operational problem.

Part 2: what you should expect from your Certified Platform

The second part of the checklist is aimed at Certified Platforms. It is just as useful for their clients, as it helps them understand what a platform must actually be able to handle.

Its role is not limited to transporting a file from point A to point B.

A Certified Platform must, in particular, ensure:

• recipient identification ;
• directory lookup ;
• data validation ;
• format management ;
• invoice transmission ;
• status circulation ;
• error and rejection management ;
• exchange traceability ;
• transmission of data required by the tax authorities.

Have exchanges with other platforms been tested?

Your client will not necessarily use the same Certified Platform as you.

Platforms must therefore be able to exchange data with each other without data loss, format disruption, or systematic manual intervention.

This interoperability is essential to ensure that invoices, data, and statuses flow correctly between the various stakeholders.

Read our article to better understand the challenges of interoperability between Certified Platforms.

Are all your formats covered?

Factur-X, UBL, CII, industry-specific formats, attachments… Not all companies use the same standards.

Your Certified Platform must be able to receive, verify, and transmit the formats required for your business. It must also ensure a readable representation of the invoice and preserve data integrity.

Therefore, you should not just test a standard format on a simple case. Scenarios specific to your business must also be covered.

Part 3: Issuance and e-reporting for large companies and mid-sized enterprises

For large companies and mid-sized enterprises, the level of urgency is even higher.

Starting September 1, 2026, they must be able to issue their electronic invoices and transmit data subject to e-reporting.

The first step is to map your workflows.

Which operations are subject to electronic invoicing? Which ones are covered by e-reporting? How should you handle sales to individuals, international transactions, service provisions, down payments, credit notes, or corrective invoices?

Each scenario must be identified and linked to the appropriate process.

If this mapping is not yet finalized, ourelectronic invoicing consulting services allow you to analyze your current setup, identify gaps, and build an action plan tailored to your organization.

Data quality will be a deciding factor

The reform is based on the transmission of structured data.

An incorrect address, a missing identifier, an erroneous VAT number, or a misclassification of the transaction can lead to rejection or incorrect transmission.

You must therefore verify that your systems can generate all the required information, including:

• supplier and customer identification;
• invoice number and date;
• SIREN and VAT numbers;
• nature of the transaction;
• amounts excluding tax;
• VAT rates and amounts;
• currency;
• specific notes;
• data required for e-reporting.

This check should not be limited to an ideal sample. It must also cover incomplete files, long-standing clients, and data originating from multiple systems.

Rejections: the scenario you absolutely must test

A compliant invoice reaching the correct recipient is the simplest case.

But what happens when an identifier is incorrect? When an address does not exist in the directory? When mandatory data is missing? When a format is not recognized? Or when the client's platform rejects the invoice?

These situations must be tested before go-live.

For each type of error, teams must know:

• who receives the alert;
• how to identify the cause;
• who needs to take action;
• which tool to use to make the correction;
• how to return an invoice
• how to track its resolution.

Without a clear process, rejections can pile up, disrupting both payments and relationships with suppliers and clients.

To anticipate these challenges, also check out our article on mistakes to avoid regarding the electronic invoicing reform.

The six questions to ask yourself now

With one month to go before the deadline, here are the six questions that should guide your final checks:

1. Has our Certified Platform been selected and properly designated?
2. Is our directory information complete and reliable?
3. Have our workflows been tested from end to end?
4. Is all mandatory data available in our systems?
5. Do we know how to detect, process, and correct a rejection?
6. Do we have a business continuity plan in place in case of an incident?

If you cannot clearly answer any of these questions, the matter should become an immediate priority.

No automatic penalties does not mean you can wait

The DGFiP plans to take an approach that accounts for real difficulties encountered during the rollout phase. The goal is to prevent a one-off incident from blocking operations, invoice processing, or payments.

However, this leniency should not be interpreted as a postponement of the reform.

A company must be able to demonstrate that it has taken the necessary steps, conducted tests, identified its challenges, and launched appropriate corrective actions.

It is therefore important to keep a record:

• decisions made;
• discussions with service providers;
• tests performed;
• incidents identified;
• corrective actions;
• temporary procedures implemented.

By September 1st, everything may not be perfect. However, your company must be committed to a genuine, documented, and managed process.

Secure your final steps with DEMATRUST

The time for observation is over. The time for verification has begun.

With DEMATRUST, ICD International supports companies in managing their electronic invoices, formats, statuses, directory, and e-reporting obligations.

Our teams can assist you with:

• assessing your level of readiness;
• mapping your workflows;
• checking your data quality;
• connecting your tools;
• organizing your tests;
• securing rejection management;
• building a remediation plan.

Contact our experts to assess your readiness and secure your transition to electronic invoicing.

Review the checklist before September 1, 2026

The FNFE checklist provides a concrete foundation for conducting your final checks and identifying any outstanding issues.

Use it to audit your own system, as well as to challenge your certified platform, software providers, clients, and suppliers.

Access the full FNFE checklist

September 1st is approaching. The question is no longer whether your project has started, but whether it is ready to go live.

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