FRANCE Trends and Developments Contributed by: Marie Frisch and Estelle Rigal-Alexandre, Soulier Bunch
As of 2026, the European financial and banking sec - tors are undergoing a period of profound transfor - mation, driven by an unprecedented convergence between technological innovation and increasingly stringent regulatory frameworks. In this context, fin - tech companies, financial institutions and businesses must adapt to structural reforms that are reshaping their obligations, opportunities and relationships with customers. 2026 is therefore expected to mark a pivotal stage, characterised by the implementation or expansion of major regulatory developments, including: • the generalisation of electronic invoicing; • the completion of the transition to the Markets in Crypto-Assets Regulation (MiCA) regime; • the emergence of the Financial Data Access (FIDA) Regulation; • the tightening of the framework applicable to “Buy Now, Pay Later” (BNPL); and • the rise of agentic AI and autonomous commerce. These legal, technological and operational develop - ments are shaping the key trends that will permanently refine the European and French financial ecosystem. Electronic Invoicing Reform Supporting the Modernisation and Digitalisation of the Economy Electronic invoicing is emerging as a major adminis - trative and tax transformation across Europe, driven by objectives of modernisation, fraud prevention and economic efficiency. In France, this transition is being implemented through an ambitious reform introduced by the Finance Act for 2020 and strengthened by the Finance Act for 2022, which aims to generalise elec - tronic invoicing for all transactions between VAT-reg - istered businesses from 2026. Directive 2014/55/EU requires EU member states to adopt common standards for electronic invoicing in public procurement. France has relied on this frame - work to extend electronic invoicing requirements to the private sector. The objective of the French legislature is not only to reduce VAT fraud – estimated at several billion euros annually – but also to simplify administrative proce -
dures, reduce costs, improve transaction traceability, and enhance the efficiency of tax audits. Invoices will be required to be issued and transmit - ted through accredited partner dematerialisation plat - forms (PDPs), ensuring their authenticity and auto - matic transmission to the tax authorities. The French General Directorate of Public Finances ( Direction générale des Finances Publique – DGFiP) defines an accredited platform as “a dematerialisation ser - vice provider registered by the State. As part of the reform, its role will be to issue, transmit and receive electronic invoices, extract relevant data for the tax authorities, and collect and transmit transaction and payment data”. In France, the reform will be implemented progres - sively: • from 1 September 2026, all VAT-registered busi - nesses will be required to be capable of receiving electronic invoices through accredited platforms; • from the same date, large companies and mid- sized companies will also be required to issue electronic invoices; and • from 1 September 2027, small and medium-sized enterprises (SMEs) and micro-enterprises will be required to issue electronic invoices. A central e-invoicing directory listing all registered connections will ultimately enable the exchange of invoices between businesses with referenced elec - tronic addresses. These obligations – in particular the 1 September 2026 implementation deadline – make electronic invoicing reform one of the key regulatory trends for 2026, at least during the first eight months of the year. Several EU member states have already implemented mandatory electronic invoicing, providing a range of models: • Italy imposed electronic invoices for all B2B transactions as early as 2019 via the SdI system, significantly reducing VAT fraud; • Spain has adopted a phased approach, with obli - gations applying to large companies since 2023
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