What Payhawk’s Tax Director Learned Preparing Payhawk for France's eInvoicing Mandate

So we asked our own Tax Director, Dilyana Peycheva, to walk us through it. Payhawk has a French entity. We had to run this exercise ourselves, and the honest version of that process is less "flip a switch" and more "keep checking, because the answer can change."

Two dates, four categories, and one entity you have to place correctly

The mandate has two separate obligations with different start dates. From 1 September 2026, every business established in France must be able to receive eInvoices, no exceptions. Issuing is where it gets specific to your size.

France splits businesses into four categories for this purpose, based on the last closed financial year of the French legal entity itself, not the group. A micro-enterprise or PME (SME) has fewer than 250 employees and turnover under €50 million or a balance sheet under €43 million. An ETI (entreprise de taille intermédiaire) sits between a PME and a large enterprise: up to 5,000 employees, and turnover under €1.5 billion or a balance sheet under €2 billion. Anything bigger than that is a large enterprise.

Large enterprises and ETIs must issue eInvoices from 1 September 2026, the same date as the receiving obligation. PMEs, and the smaller micro-entities that sit inside that same category, get an extra year for issuing: 1 September 2027.

"My first step was to check when the mandate actually kicks in for receiving and issuing invoices, and figure out what that timeline actually means for Payhawk in France. The deadline for receiving eInvoices was clear-cut and honestly, it didn't worry me - I knew Payhawk's own product had us covered”, Dilyana says. Issaunce was a different story and when Payhawk assessed its own French entity against those categories with its tax advisor, it came out that it became mandatory for Payhawk SAS from 1 September 2027, not 2026.

The same exercise, repeated for every entity

France isn't the only place Payhawk is running this analysis. The same tax team is doing it for every entity it operates, including Spain, the Netherlands, Lithuania, Germany, and the UK, because none of those countries are on the same eInvoicing timeline, and the ones with a confirmed date may keep adjusting it. "We work with our local tax advisors who help us navigate this complexity, and quickly adapt to updated or tight deadlines" Dilyana says.

In practice that means a standing process rather than a one-off review: track the legislation in each jurisdiction, lean on a local tax advisor for each one, and run the same internal transaction review to work out which entity needs to move first. Payhawk used that process to decide France was the urgent one and deprioritise, for now, the countries where rules are still being finalized.

Why this isn't an IT ticket

The instinct in a lot of finance teams is to treat eInvoicing as something you hand to IT: pick a connector, plug it in, done. Dilyana pushed back on that framing directly. "eInvoicing isn’t just an IT task to complete. Rolling it out means businesses, including Payhawk, have to take a step back and really dig into their own operating model. For Payhawk SAS that meant looking back at the types of supplies provided and received over the past year, checking in with the sales team on newly signed or upcoming contracts that might introduce new types of supplies, confirming with the business whether any restructuring or new intercompany transactions were on the horizon that may give rise to new sales or purchases transactions, and validating vendor and client master data - plus any other business specifics that could tip the scale." she explains, meaning a full look at the type of activities the company actually runs or might run, to see whether the business model falls inside the mandate at all.

On the surface, Payhawk's French entity has a fairly simple setup. It issues invoices for international cross-border supplies that sit outside mandatory eInvoicing. That's the version on paper, though. In practice, incidental transactions such as recharges to other VAT registered French entities can pull a company back into scope without warning.

Dilyana pointed to joint marketing campaigns, where participants could share the full cost and then recharge part of it to local entities. Such recharges could be domestic VAT taxable B2B transactions, which do fall within the scope of the mandate. "That said, extraordinary events can change our position. If one comes up, we may need to be ready to issue eInvoices," she added.

That's the reason Payhawk started preparing for the issuing side now, well ahead of its 2027 deadline. Not because the rule demands it yet, but because waiting would put the business in a worse position later.

"There is no way to know for sure if extraordinary recharge transactions will pop up down the road ," Dilyana says. "Otherwise, the scenario is: someone on the business side comes to finance wanting to recharge a cost, and our answer is ‘we can’t - we’re not set up to issue that invoice’. That’s not the finance function we want us to be."

When it does implement issuance, Payhawk will be keeping the setup deliberately simple: the same platform it already uses to receive eInvoices will handle issuing them too, rather than adding a second provider to manage. "For practical reasons, we'll use the same platform for issuing invoices as we will be using for receiving invoices. It just makes sense to keep things with a single provider rather than juggling multiple platforms for the same entity and the same type of activity," Dilyana states.

There's a second obligation running alongside all of this that's easy to miss: e-reporting.

Any transaction that doesn't go through the mandatory eInvoicing platform (PA), including the invoices for international cross-border transactions that Payhawk issues every month, still has to be reported to the French tax authorities. "These invoices will fall outside the mandatory eInvoicing scope," Dilyana explains, "however, we are still required to report the fact that we have issued these invoices to the tax authorities."

That monthly e-reporting filing is expected to run through the same consolidated platform as the eInvoicing, rather than a third system on top.

What changes for accounts payable, in practice

On the receiving side, the day-to-day change is more straightforward, and it's the part Dilyana is most confident about. Once a supplier issues a structured eInvoice, Payhawk's own product makes it land in automatically, matched to the underlying expense in Payhawk, with no one on the finance team chasing a PDF.

"No more chasing local suppliers or employees who are dealing with them for PDF copies, because everything will show up automatically in Payhawk ," she says. It applies to B2B invoices from domestic suppliers, which, for a business with a meaningful B2B spend, frees up real time, since those B2B invoices are the ones critical for VAT deduction.

There's a second benefit that has nothing to do with speed. Structured eInvoicing forces issuers to validate VAT numbers, addresses and SIRET/SIREN registration numbers before an invoice goes out, because that's how the connection between issuer and recipient gets made on the network. In practice, that means fewer invoices arriving with the wrong VAT number or an outdated address, and fewer rounds of ‘please correct and resend.’

"Invoices will arrive correctly from the start - no back-and-forth required."

A valid VAT invoice is a requirement for VAT deduction, so if a domestic supplier isn't ready to issue compliant eInvoices on time, that might be a real problem for whoever is trying to reclaim the VAT. Dilyana is hoping tax authorities will show some transitional tolerance while the market catches up, but she's not pretending the risk isn't there for anyone whose suppliers are behind.

If you're one of the late movers, here is what to do today

Dilyana's advice for finance leaders who are behind schedule is deliberately sequenced, and it's worth following in order rather than trying to solve everything at once.

First, get a platform in place to receive eInvoices. This isn't optional and it isn't a size-based decision: 1 September 2026 applies to every business regardless of the category, without any further analysis of the business in terms of current transactions, volumes and expected future activity.

Second, check where your French entity actually sits against the PME, ETI and large enterprise thresholds, using the last closed financial year for that entity specifically, not the group. If you're a large enterprise or ETI, issuing is due on the same date as receiving. If you come out as a PME or micro-entity, you have until 2027, but Dilyana's advice is to start preparing anyway, because a year disappears faster than it looks like it will.

That's where Dilyana thinks a platform like the one Payhawk built, in partnership with Invopop over the Peppol network, earns its place for a business that's starting late. It gives a company a fast, compliant way to register and start receiving eInvoices without a long implementation project, buying real time to do the harder work properly: reviewing the operating model, talking to sales and the business what changes or transactions might be coming, having that conversation with your tax advisor about what your specific entity actually needs. "It will make the decision easy for them and give them the time to figure out the next steps.," Dilyana adds.

Her closing point is the one worth holding onto longest: the obligation to issue eInvoices "can arise overnight."

Two French related parties that don't currently trade with each other, can start doing so for transfer pricing reasons. An incidental, one-off supply can show up out of nowhere. Whatever your operating model looks like on paper today, it's worth staying ready to issue an eInvoice the moment something outside the norm comes up.

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Curious how the receiving and issuing side actually works once eInvoices start landing in your AP workflow? Watch the eInvoicing automation webinar for a walkthrough of how Payhawk and Invopop handle capture, validation, approval and ERP sync for every mandate across the entities you run.