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

Payhawk has a French entity, so we ran the exercise ourselves. Dilyana Peycheva, our Tax Director, walked us through what that looked like. We didn't flip a switch once and move on. We kept checking, because the answer can change at any point.

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

The mandate splits into two obligations with different start dates. From September 1, 2026, every business established in France must be able to receive eInvoices, no exceptions. Dilyana explains:

My first step was to check when the mandate kicks in for receiving and issuing invoices, and figure out what that timeline 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.

Issuing is where your entity's size matters. France splits businesses into four categories for this purpose, based on the last closed fiscal year of the French legal entity itself, not the parent company that owns it.

Category	Employees	Revenue	Balance sheet	Issuing Deadline
Large enterprise	5,000 or more	Over €1.5bn	Over €2bn	Sept 1, 2026
Mid-sized enterprise (ETI)	250 to 4,999	Up to €1.5bn	Up to €2bn	Sept 1, 2026
Small and medium-sized enterprise (PME)	10 to 249	Up to €50m	Up to €43m	Sept 1, 2027
Micro-enterprise (TPE)	Under 10	Up to €2m	Up to €2m	Sept 1, 2027

Headcount decides first. Cross the employee ceiling and you move up a category whatever the financials say. Stay under it and you only move up if turnover and balance sheet both exceed their thresholds. So an entity with 300 employees and €30m turnover is an ETI, issuing from 2026, because the headcount alone settles it.

Payhawk ran that assessment on its French entity with its tax advisor. The dates came out a year apart: receiving from September 1, 2026, issuing from September 1, 2027.

One review process, repeated in every country

France isn't the only place Payhawk is running this analysis. The same tax team is working through it for every entity, including Spain, the Netherlands, Lithuania, Germany and the UK. Every country has its own eInvoicing timeline, and even the confirmed dates keep moving. Dilyana says:

We work with our local tax advisors who help us navigate this complexity, and quickly adapt to updated or tight deadlines.

That turns into a process the team repeats each time a new mandate lands. Track the legislation in each jurisdiction, work with a local tax advisor in each one, and run the same internal transaction review to work out which entity moves first. Payhawk used it to decide France was urgent and to deprioritize, for now, the countries where the rules are still being finalised.

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:

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.

On paper, Payhawk's French entity has a simple setup. It issues invoices for international cross-border supplies that sit outside mandatory eInvoicing. Incidental transactions tell a different story: recharges to other VAT registered French entities can pull a company back into scope without warning.

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

That's the reason Payhawk started preparing for the issuing side now, well ahead of its 2027 deadline. The rule doesn't demand it yet, but waiting would put the business in a worse position later. Dilyana describes the situation she's trying to avoid:

There is no way to know for sure if extraordinary recharge transactions will pop up down the road. 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 to be.

Receiving and issuing could run through different providers, and for a company solving them a year apart, they easily can. Payhawk isn't going that way:

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.

There's a second obligation running alongside all of this that's easy to miss. Any transaction that falls outside mandatory eInvoicing, 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."

Payhawk expects e-reporting to run through the same platform as the eInvoicing, rather than a third system on top.

What changes for accounts payable

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, it lands in Payhawk automatically, matched to the underlying expense, 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. That covers invoices from domestic suppliers, which are the ones a finance team needs for VAT deduction. For a business with meaningful domestic spend, that frees up real time.

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 issuer and recipient get connected. Dilyana says:

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

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

What to do if you're starting late

Dilyana's advice for finance leaders who are behind is sequenced. Take it 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 whatever its category, so you can do this before you've worked out which category you're in.

Second, check where your French entity sits against the PME, ETI and large enterprise thresholds, using its own last closed fiscal year, not the parent company's. If it's a large enterprise or ETI, issuing is due on the same date as receiving. If it's a PME or micro-entity, you have until 2027, though Dilyana's advice is to start preparing anyway, because a year goes quickly.

For a business starting late, that's what makes a platform like Payhawk's worth having. Built with Invopop over the Peppol network, it gives a company a fast, compliant way to register and start receiving eInvoices without a long implementation project, which buys the time to do the harder work properly: reviewing the operating model, asking sales and the business what's coming, and taking the specifics to your tax advisor. "It will make the decision easy for them and give them the time to figure out the next steps," Dilyana adds.

The obligation to issue eInvoices, as Dilyana says, "can arise overnight."

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

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Staying ready is easier when the receiving and issuing sides run in one place. Follow one invoice from supplier to ERP. Watch our 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.