Non-compliant formats, incompatible software, unequipped suppliers: a billing audit allows you to identify your points of non-compliance before September 1, 2026.
An audit of your invoicing process is the first action to take to be ready before September 1, 2026: on this date, all companies subject to VAT must receive their electronic invoices via an approved platform. Here are the 5 steps to identify your points of non-compliance before the deadline.
Map all of your current billing flows
The first step of an invoicing audit consists of listing all incoming and outgoing flows: invoices received from suppliers, invoices issued to customers, credit notes and credit notes. According to the DGFiP press release of January 16, 2026, nearly 10 million economic actors are affected by the reform. Almost all of your suppliers will therefore have to be compliant by September 1, 2026.
For each flow identified, three pieces of information must be documented in order to assess the extent of the change to be made and to prioritize actions according to the most critical flows:
- The average monthly volume of invoices
- The current format used (PDF sent by email, paper, EDI, or other)
- The transmission channel (email, mail, third-party platform)
Check the conformity of the invoice formats used
From September 1, 2026, the DGFiP will no longer accept PDF sent by email as a compliant invoicing format, according to impots.gouv.fr. Three structured formats are recognized:
- Factur-X, which combines a readable PDF and an automatically processable XML file
- UBL, native format of the European PEPPOL network
- CII, adopted mainly by large industrial companies
Step 2 of the audit consists of checking, for each flow identified in step 1, whether the format used is among these three accepted formats. If your invoices are today generated in simple PDF and sent by email, your management software must produce one of the three structured formats before the deadline. A systematic manual conversion is a risk signal to be documented now.
Identify the internal and external actors involved in the invoicing circuit
A billing audit is not limited to document flows: it must also identify the people and service providers involved in the circuit. Internally, the accounting, sales administration and financial management departments are systematically concerned. Externally, suppliers, customers, accountants and technical service providers (ERP, invoicing software, EDI platform) must also be identified.
For each external actor identified, two questions must be asked: does it already have an approved platform registered by the DGFiP, and in what format does it issue its invoices today? This information makes it possible to anticipate the necessary adjustments in exchanges with each partner before September 1, 2026, and to avoid disruptions in flows when switching to mandatory electronic invoicing.
Evaluate the compatibility of your management software with an approved platform
Management or accounting software is at the heart of the invoicing process. To comply with the reform of September 1, 2026, it must meet two conditions defined by the DGFiP: generate invoices in one of the three accepted structured formats (Factur-X, UBL or CII) and transmit them via an approved, registered platform.
Software that does not meet these two conditions requires migration or the addition of an intermediary service provider. Among the accounting software natively integrating an approved platform, we find, among the first 101 approved platforms published by the DGFiP on January 16, 2026, solutions such as EBP or Cegid, as well as Sage 50.
Sage 50 is accounting and commercial management software published by the Sage group, listed on the FTSE 100. It integrates Sage Network, its approved platform definitively registered by the DGFiP on December 22, 2025, according to the official list published on impots.gouv.fr. Sage Network supports the three formats accepted by the DGFiP and complies with the PEPPOL standard. VSEs and SMEs that already use Sage 50 for their accounting do not have to migrate to separate software to be compliant before the deadline.
Document deviations and set a dated action plan
The audit produces a concrete result: a list of points of non-compliance, classified by flow and by actor. Each identified deviation must be documented with three pieces of information: its nature (non-compliant format, incompatible software, supplier not yet equipped), its level of criticality, and the corrective action to be taken. Without this formalization, the audit remains a diagnosis without operational follow-up.
The resulting action plan must include dated milestones. For VSEs and SMEs, two regulatory deadlines serve as benchmarks: September 1, 2026 for the receipt obligation, and September 1, 2027 for the issuance obligation, according to the 2026 finance law (LAW no. 2026-103 of February 19, 2026). Corrective actions must be planned in advance of these dates, taking into account the deadlines for deploying approved platforms and training teams.
Summary of the 5 steps to audit an invoicing process
| Stage | Action | Expected deliverable |
| 1. Map flows | List all invoices issued and received: volume, format, channel | List of documented incoming and outgoing flows |
| 2. Check formats | Compare the current formats (PDF, EDI) to the three formats accepted by the DGFiP: Factur-X, UBL, CII | Format compliance table by stream |
| 3. Identify the actors | Identify the internal services and external partners involved in the invoicing circuit | Mapping of actors and their current practices |
| 4. Evaluate the software | Check if the management software natively integrates an approved platform registered by the DGFiP | Decision: migration, addition of a service provider or compliance acquired |
| 5. Document and plan | Formalize deviations and set milestones before September 1, 2026 (receipt) and September 1, 2027 (issuance) | Dated action plan with identified leaders |
By what date should this audit be completed?
The regulatory deadline for the obligation to receive electronic invoices is September 1, 2026, but this date leaves no room for carrying out an audit, correcting discrepancies and deploying an approved platform. According to the DGFiP, registration in the centralized directory and the designation of an approved platform must be effective before this date. These two approaches presuppose having finalized the audit and chosen the solution in advance.
For VSEs and SMEs, the invoicing audit must be finalized no later than June 2026, in order to have a minimum of two months to implement corrective actions and test compliance in real conditions. Approved platforms registered by the DGFiP offer test environments before the deadline: by registering too late, a company takes the risk of not being able to validate its compliance before September 1, 2026.
Failure to comply with the receipt obligation by September 1, 2026 exposes companies to financial sanctions defined by the 2026 finance law (ACT no. 2026-103 of February 19, 2026). Not designating an approved platform exposes the company, after a formal notice which remains without effect for three months, to a fine of €500, then to €1,000 per additional quarter of non-compliance. A grace period of 30 days is provided in the event of a first offense which is spontaneously regularized.
FAQ: electronic invoicing audit before September 2026
Should the audit cover only B2B invoices or also personal and international sales?
The audit must cover all invoicing flows, including sales to individuals and international operations. These flows do not relate to e-invoicing but to e-reporting: the obligation to transmit transaction and payment data to the DGFiP via an approved platform. According to Decree No. 2022-1299 of October 7, 2022, e-reporting follows the same timetable as e-invoicing: September 1, 2026 for large companies and ETIs, September 1, 2027 for VSEs and SMEs.
Is a self-employed person affected by the audit and compliance obligation?
Yes, if the self-employed person is subject to VAT, he or she is subject to the compliance obligation. In this case, it is subject to the same obligations as small businesses: receipt of electronic invoices via an approved platform on September 1, 2026, and issuance on September 1, 2027. Self-employed people benefiting from the VAT-based exemption are, however, not affected by the reform, because they do not collect VAT, according to impots.gouv.fr.
How long should it take to complete a billing audit?
The duration of an audit depends on the complexity of the company’s billing flows. For a small business with a limited volume of invoices and a single management software, the audit can be carried out in a few days. For an SME with several suppliers, existing EDI flows and several services involved, it takes two to four weeks. In all cases, the DGFiP recommends thinking ahead to have sufficient time before September 1, 2026.
Should we hire an accountant to carry out this audit?
No, the audit can be carried out internally, and not necessarily by an accountant. The five steps described in this guide do not require advanced technical skills: they are based on a documentary inventory of existing flows, formats and tools. A chartered accountant can nevertheless assess the tax impacts of the identified discrepancies, particularly for companies subject to both e-invoicing and e-reporting.
Is my current invoicing software automatically compliant with the reform?
No, not automatically. Invoicing software only complies with the reform if it natively integrates an approved platform definitively registered by the DGFiP, or if it is connected to one of them. The official list of registered platforms is published and updated on impots.gouv.fr. Software that generates invoices in simple PDF without transmission via an approved platform is not sufficient to comply with September 1, 2026.
What happens if the audit reveals that my management software is not compatible?
Two options are possible. The first consists of migrating to software natively integrating an approved platform registered by the DGFiP. The second consists of keeping the current software and connecting it to an approved platform via a compatible solution, also called a dematerialization operator. In both cases, compliance must be effective before September 1, 2026 for the receipt obligation, according to the 2026 finance law (LAW no. 2026-103 of February 19, 2026).
Sources
- economie.gouv.fr — Everything you need to know about electronic invoicing
- impots.gouv.fr — Official list of approved platforms (accessed April 29, 2026)
- impots.gouv.fr — I switch to electronic invoicing
- dgfip.finances.gouv.fr — Reform of electronic invoicing
- Finance law 2026 — LAW no. 2026-103 of February 19, 2026 — legifrance.gouv.fr
- Decree No. 2022-1299 of October 7, 2022 — legifrance.gouv.fr
- DGFiP press release of January 16, 2026 — List of the first 101 approved platforms
