E-Invoicing Deadlines: France 1 Sept 2026, Germany 2028

From 1 September 2026 — thirteen days from now — every business established in France and liable for VAT must be able to receive an electronic invoice.

Not a PDF. A structured electronic invoice, through an approved platform.

Germany got there differently and is further along in one respect: electronic invoicing between domestic German businesses is already mandatory, with paper permitted only under transitional rules that run out at the end of 2027.

If you invoice into either country, here is what actually applies to you — and, importantly, what does not.

The short version, if you are outside the EU

Both mandates bind businesses established in that country.

Germany's rule applies where the recipient is another business in the domestic territory. France's applies to businesses established in France, and France explicitly exempts invoices issued to foreign enterprises, which may stay on paper or ordinary PDF.

So a freelancer in Johannesburg, London or Chicago invoicing a French or German company is very probably not directly caught by either obligation.

That is not the same as "ignore this", for three reasons:

1. Your client is caught, and their systems are changing. What they can accept, and how they want it, will change with them.
2. Non-established but VAT-registered is a genuine edge case, and this page does not answer it. If you hold a French or German VAT registration, ask.
3. Your invoice still has to satisfy everything else — the German mentions under §14 UStG or the French mentions obligatoires — which have not changed.

France: the dates

Two features of the French model matter more than the dates.

It runs on approved platforms. An electronic invoice is issued, transmitted, received and preserved through an approved platform — a plateforme agréée — or through a compatible solution connected to one. The government maintains the list. This is not "email a structured file"; it is a network you have to be on.

Consumers and foreign enterprises are exempt. Invoices to private customers and to foreign businesses may continue on paper or ordinary digital formats. That exemption is what puts most non-EU freelancers outside the mandate — and it is also why a French client may treat your invoice differently from their domestic ones.

Note the asymmetry in the first two rows. From 1 September 2026 everyone must be able to receive, but only the largest businesses must issue. That is deliberate: the receivers have to be ready before the senders start.

Germany: already mandatory, with transitional relief

Germany did not phase in the obligation. It phased in the relief.

Under §14 UStG, transmitting an electronic invoice normally needs the recipient's consent — except where the recipient is another business in the domestic territory, where it is mandatory rather than optional. That is why German businesses already need to be able to receive structured invoices.

What is being phased is your ability to keep sending something else. §27 UStG sets out the transitional periods:

The €800,000 line is the one small German businesses should note: it buys an extra year of sending non-compliant electronic formats, and it is measured on the previous year's turnover.

What actually counts as an e-invoice

Germany defines it precisely, and the definition is worth reading because it rules out the thing most people assume qualifies:

Eine elektronische Rechnung ist eine Rechnung, die in einem strukturierten elektronischen Format ausgestellt, übermittelt und empfangen wird und eine elektronische Verarbeitung ermöglicht.

An invoice issued, transmitted and received in a structured electronic format, enabling electronic processing.

A PDF is not an e-invoice. Neither is a scan, nor a PDF attached to an email, however neat it looks. A PDF is a picture of an invoice that a human reads. A structured e-invoice is data a machine reads without a human interpreting it.

The format must meet the European standard for electronic invoicing under Directive 2014/55/EU — or a format the parties agree, provided it allows correct and complete extraction of the required data into a compliant format.

That last clause is the pragmatic escape hatch, and it is how EDI arrangements survive the transition.

What this means for our invoice generator

Plainly: our generator produces a PDF, and a PDF is not a structured e-invoice.

That is the honest position and it is worth stating on a page that exists next to a tool. If you are a business established in France or Germany invoicing domestic businesses, you will need e-invoicing software or an approved platform, and no free PDF generator — ours included — substitutes for that.

Where our generator remains genuinely useful:

• Invoicing from outside the EU into France or Germany, where the mandate binds your client rather than you
• Invoicing consumers, who are exempt in France
• Invoicing foreign enterprises, explicitly exempt in France
• Everywhere outside these mandates entirely

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What to do now, by situation

You are a freelancer outside the EU with French or German clients. Do nothing structural. Ask your client, once, how they want to receive invoices after their date — the answer may be "exactly as now". Keep your French or German mentions correct, because those requirements have not changed.

You are established in France. You must be able to receive from 1 September 2026, whatever your size. Choose an approved platform now if you have not — this is a fortnight away, not a project for next quarter.

You are established in Germany and turn over more than €800,000. Your window for sending non-compliant electronic formats closes at the end of 2026; paper runs to the end of 2027.

You are established in Germany under €800,000. You have until the end of 2027 on non-compliant electronic formats — but you must already be able to receive a compliant one.

What this page does not cover

The EU ViDA package and its timetable, which we have not read.

What any approved platform costs, or which to choose.

Whether your business is an ETI or an SME under the French sizing rules.

The position for businesses that are not established in France or Germany but are VAT-registered there. That is a real gap and a real edge case, and guessing at it would be worse than saying so.

Check with the French government business portal, the German Bundeszentralamt für Steuern, or an accountant in the country concerned. This page describes the rules as published; it is not tax advice, and dates and thresholds change.

How does this affect YOUR Money OS?

An invoice a client cannot process is an invoice that does not get paid, and the date it stops being processable is now known. Asking one question before September costs nothing; discovering the answer in October costs a payment cycle.

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FAQ

When does e-invoicing become mandatory in France? Every business established in France and liable for VAT must be able to receive electronic invoices from 1 September 2026. Large enterprises and ETI must issue from the same date; SMEs and micro-enterprises from 1 September 2027.

Is e-invoicing already mandatory in Germany? Between domestic German businesses, yes — §14 UStG makes it mandatory rather than subject to the recipient's consent. What is phasing out is the relief that still allows paper and non-compliant formats, which ends fully in 2028.

Does a PDF count as an electronic invoice? No. German law defines an e-invoice as one issued, transmitted and received in a structured electronic format enabling electronic processing. A PDF is a document a human reads, not data a machine processes.

I invoice French or German clients from outside the EU — am I affected? Probably not directly. Germany's mandate covers domestic business-to-business supplies, and France's binds businesses established in France while explicitly exempting invoices to foreign enterprises. Your client is affected, so ask how they want to receive invoices.

What is the €800,000 threshold in Germany? Businesses whose prior-year turnover was not more than €800,000 may keep using non-compliant electronic formats through 2027, a year longer than larger businesses.

Do I need an approved platform in France? For invoices within scope, yes — an electronic invoice is issued, transmitted, received and preserved through an approved platform or a compatible solution connected to one. The government publishes the list.

Can I still send paper invoices in Germany? For supplies during 2027, yes, until 31 December 2027. From 2028, no.

Does your invoice generator produce e-invoices? No. It produces a PDF, which is not a structured e-invoice. It remains useful for invoicing from outside these mandates, for consumers, and for foreign enterprises — but a business established in France or Germany invoicing domestic businesses needs e-invoicing software.

Related

• Free invoice generator for Germany
• Free invoice generator for France
• Free invoice generator for Ireland