In short
- France: all businesses established in France must be able to receive electronic invoices from 1 September 2026. An SME will have to issue them from 1 September 2027.
- Belgium: between businesses established in Belgium and subject to VAT, structured e-invoicing via the Peppol network has been mandatory since 1 January 2026.
- Spain: Verifactu is still set for 2027 in the texts in force, but a postponement to October 2028 has been announced. E-invoicing between businesses arrives on 6 October 2027 or 6 October 2028, depending on the business's volume of transactions.
Three countries, three timetables. Here is where each obligation stands, with its official source. The rules are still moving: check the verification date before relying on the table.
The timetable in one table (verified on 13 October 2026)
| Country | Obligation | Who for | Date |
|---|---|---|---|
| France | Receive electronic invoices through an approved platform | All businesses established in France | Since 1 September 2026 |
| France | Issue electronic invoices and transmit the data (e-reporting) | Large businesses and mid-sized businesses (ETI) | Since 1 September 2026 |
| France | Issue electronic invoices and transmit the data (e-reporting) | SMEs, micro-businesses and micro-enterprises | 1 September 2027 |
| Belgium | Send and receive structured invoices via Peppol | Businesses established in Belgium and subject to VAT, between themselves | Since 1 January 2026 |
| Spain | Verifactu: compliant invoicing software | Companies subject to Spanish corporate income tax | Before 1 January 2027 (postponement to October 2028 announced, not yet published) |
| Spain | Verifactu: compliant invoicing software | Other businesses and self-employed people | Before 1 July 2027 (same announcement) |
| Spain | E-invoicing between businesses | Volume of transactions in the previous year above €8 million | 6 October 2027 |
| Spain | E-invoicing between businesses | All other businesses | 6 October 2028 |
France: receiving from 2026, issuing in 2027
Since 1 September 2026, every business covered by the reform must be able to receive electronic invoices. It receives them through an approved platform: a provider registered by the tax authority, which carries the invoices and passes certain data on to the authority. You choose yours from the official list, published on 16 January 2026 and updated regularly.
For SMEs, micro-businesses and micro-enterprises, issuing becomes mandatory on 1 September 2027. The official sheet defines an SME as follows: between 10 and 250 employees, and less than €50 million in turnover or €43 million in balance sheet total. Self-employed micro-entrepreneurs exempt from VAT (those who do not charge VAT) are also covered.
Until then, an SME can invoice as it does today or start voluntarily. The reform does not allow a customer to impose e-invoicing on you before your deadline. A commercial agreement between you can, however, provide for a paperless exchange. Invoices addressed to the public sector keep their own rules.
An electronic invoice is not a PDF sent by email. It is a structured format, a data file that software can read: UBL, CII, or a mixed format that attaches this data to an image of the invoice.
E-reporting means sending the tax authority, through your platform, the data on transactions that do not go through a French electronic invoice: sales to individuals, transactions with businesses established abroad. Payment data for certain services is added. The timetable is the same: 1 September 2027 for SMEs.
During the start-up phase, the tax authority does not apply a penalty to a business that is struggling but is seriously working towards compliance. This is neither a postponement nor a suspension. The texts provide for a fine for each invoice not issued electronically (Article 1737 of the French General Tax Code). For receiving, a formal notice to comply within three months comes before the fine.
Belgium: Peppol mandatory between businesses since 1 January 2026
Since 1 January 2026, businesses established in Belgium and subject to VAT exchange structured electronic invoices with each other. A PDF by email is no longer enough. The FPS Finance, the Belgian tax authority, provides for a few exceptions, for example for businesses in bankruptcy.
They go through Peppol, a network for exchanging documents between businesses, in the Peppol BIS format (based on the European standard EN 16931). You do not register directly on Peppol: you go through an approved service provider, also called an access point. In practice, it is often the invoicing software that is connected to the network.
Invoices to individuals are not covered. The FPS Finance had announced a tolerance without penalties for the first three months of 2026, reserved for businesses that had acted in time and reasonably. That period has ended.
Spain: Verifactu, then e-invoicing between businesses
Verifactu is the common name for the Spanish regulation on invoicing software (Real Decreto 1007/2023). It sets requirements for the integrity, retention, accessibility, legibility, traceability and inalterability of invoicing data. The dates in force come from Real Decreto-ley 15/2025: before 1 January 2027 for companies subject to corporate income tax, before 1 July 2027 for the others.
On 5 October 2026, the Spanish Ministry of Finance (Ministerio de Hacienda) announced a postponement to October 2028. According to its note, the requirements of integrity, traceability or inalterability will be maintained in “substantially equivalent” terms. This is an announcement, not yet a text. As of 13 October 2026, the text in the Spanish Official Gazette (BOE) has not been amended and the Spanish tax agency (AEAT) still shows the 2027 dates: they remain the rule.
E-invoicing between businesses is set by Real Decreto 238/2026 of 25 March 2026. The countdown began with Orden HAC/1028/2026, published on 5 October 2026 and in force the next day. The AEAT draws these dates from it:
- 6 October 2027 for businesses whose volume of transactions (a term of Spanish tax law) in the previous year exceeds €8 million;
- 6 October 2028 for all the others.
The invoice follows the European model EN 16931, in one of four formats: UBL, CII, EDIFACT or Facturae. The AEAT must open a free public solution at least two months before the first deadline. A business can also use a private platform: it then sends a copy of each invoice to the public solution.
The customer tells its supplier whether the invoice is accepted or refused, then when it is paid in full. It also informs the public solution of the payment. The deadline is four days, excluding Saturdays, Sundays and national public holidays. For self-employed people (natural persons), this notification only becomes mandatory on 6 October 2029, according to the AEAT timetable.
Sales abroad: what falls under e-reporting
- From France: French e-invoicing covers sales between businesses established in France. An invoice to a business established in Belgium or Spain therefore does not go through it. Its data falls under e-reporting, on the same timetable.
- To Belgium: the obligation does not apply to businesses not established in Belgium and with no permanent establishment there. Peppol can still be used with any partner connected to the network.
- To Spain: the obligation covers invoices addressed to a business established in Spain, by an issuer required to invoice under Spanish rules. The text does not say explicitly whether a French supplier with no establishment in Spain is bound by it: check with your adviser.
- At EU level: the European ViDA package (VAT in the Digital Age) provides for digital reporting of transactions between businesses in different countries from 1 July 2030.
What this changes for your tools and your agents
An AI agent is software that prepares tasks in your tools and submits them to you. Here, an agent could help on four points:
- Reading structured invoices. These are data, not images: the agent would extract the supplier, amounts, VAT and due date, then suggest the accounting coding and the bank reconciliation.
- Preparing your invoices in the right format. Your software then sends them through your platform.
- Tracking statuses. Invoice rejected, refused or paid: the agent would prepare the correction, the reminder or, in Spain, the four-day notification.
- Spotting duplicates, a risk that the official French guide highlights when an invoice arrives through several channels. As this guide recommends, the agent would compare the number, the supplier, the date and the amounts. In case of doubt, it would stop and ask you.
One limit does not change: the agent does not replace the approved platform, the Peppol access point or the Spanish platform, which carry the legal chain. It can connect to your software or your platform through their official interfaces (APIs) where they exist. Issuing an invoice or a credit note remains approved by someone on your team. If the structured data contradicts the readable version, the agent will stop and ask you.
Take an example: a French SME of 40 employees that also sells in Spain. Today, it receives electronic invoices from its large suppliers: an agent could read them, match the payments and prepare the batch for the accountant. In 2027, it will issue its French invoices through its approved platform, and the data on its sales to Spanish customers will fall under e-reporting. For Spanish e-invoicing, its case remains to be checked with its adviser. The agent prepares, the team approves.
Sources and date of last verification
Pages consulted on 13 October 2026.
- impots.gouv.fr, practical start-up guide (DGFiP, July 2026): https://www.impots.gouv.fr/sites/default/files/media/1_metier/2_professionnel/EV/2_gestion/290_facturation_electronique/guide_pratique_facturation_electronique.pdf
- impots.gouv.fr, sheet 1 (timetable and definition of an SME): https://www.impots.gouv.fr/sites/default/files/media/1_metier/2_professionnel/EV/2_gestion/290_facturation_electronique/fiche-1_que-va-t-il-se-passer-pour-mon-entreprise.pdf
- impots.gouv.fr, “Je découvre la facturation électronique”: https://www.impots.gouv.fr/professionnel/je-decouvre-la-facturation-electronique
- impots.gouv.fr, “À partir de quand suis-je concerné par la réforme ?”: https://www.impots.gouv.fr/professionnel/questions/partir-de-quand-suis-je-concerne-par-la-reforme-de-la-facturation
- impots.gouv.fr, list of approved platforms: https://www.impots.gouv.fr/actualite/facturation-electronique-publication-de-la-liste-des-plateformes-agreees
- efacture.belgium.be, who is covered: https://efacture.belgium.be/fr/article/pour-qui-la-facturation-electronique-deviendra-t-elle-obligatoire
- einvoice.belgium.be, tolerance for the first quarter of 2026: https://einvoice.belgium.be/en/news/period-tolerance-during-first-three-months-2026
- einvoice.belgium.be, questions about Peppol: https://einvoice.belgium.be/en/FAQ/general-questions-about-peppol
- BOE, Real Decreto 238/2026: https://www.boe.es/buscar/doc.php?id=BOE-A-2026-7295
- BOE, Orden HAC/1028/2026: https://www.boe.es/buscar/doc.php?id=BOE-A-2026-20587
- BOE, Real Decreto 1007/2023 (Verifactu), consolidated text: https://www.boe.es/buscar/act.php?id=BOE-A-2023-24840
- Ministerio de Hacienda, note of 5 October 2026 on Verifactu: https://www.hacienda.gob.es/sgt/gabsehacienda/nota-informativa-verifactu.pdf
- AEAT, adaptation deadlines for invoicing software: https://sede.agenciatributaria.gob.es/Sede/iva/sistemas-informaticos-facturacion-verifactu/nota-informativa-ampliacion-plazo-adaptacion-facturacion.html
- AEAT, e-invoicing timetable (7 October 2026): https://sede.agenciatributaria.gob.es/Sede/todas-noticias/2026/octubre/7/solucion-publica-facturacion-electronica.html
- European Commission, ViDA: https://taxation-customs.ec.europa.eu/taxation/vat/vat-digital-age-vida_en
Going further
- Our Payment Reminders and Invoices and Accounting Documents agents, in preparation: the agents.
- How we will supervise each agent: supervision.
- Where your invoices stay and who can access them: data and security.
- What these deadlines change for you: the audit reviews your tools and invoice flows, for €490 excl. VAT: request an audit.