Electronic Credit Notes in France: New Rules & Deadlines

Key takeaways

• A credit note issued from 1 September 2026 is no longer a simple "cancel and replace" document: it is a fully structured electronic invoice in its own right, carrying type code 381 instead of 380 for an invoice.
• The credit note must mandatorily reference the original invoice: at least one BT-25 reference and its BT-26 date, or references carried on each line.
• The amounts on a Factur-X (the Franco-German electronic invoicing standard combining PDF and structured XML data) credit note remain positive: it is the TypeCode 381 that signals the credit nature, not the sign of the amounts.
• From 1 September 2026, all companies must be able to receive electronic invoices, and large companies and mid-sized enterprises (ETI) must issue them: an SME can therefore still issue its credit notes on paper until 1 September 2027, but must be able to receive those from its suppliers.

Who must issue credit notes in electronic format from 1 September 2026?

Only large companies and ETIs (mid-sized enterprises, 250 to 5,000 employees) are required to issue their credit notes in electronic format from this date. Everyone else only needs to be able to receive them.

The official timeline from the French Ministry of the Economy leaves no room for ambiguity: from 1 September 2026, all companies must be able to receive electronic invoices, while large companies and mid-sized enterprises must issue them. SMEs and micro-businesses with fewer than 250 employees, along with sole traders (micro-entrepreneurs), move into the issuing and e-reporting obligation on 1 September 2027.

In practical terms, for a 40-person accounting firm receiving 300 supplier invoices a month: your large corporate clients are already sending you their credit notes in XML via an accredited platform (PDP, plateforme de dématérialisation partenaire), and you must be able to receive them. But your own credit notes to clients can stay in PDF until September 2027.

One point often overlooked: the obligation to receive applies to any entity liable for VAT in France, including certain associations, SCIs (French property-holding companies) or furnished-letting landlords (LMNP). Being under the VAT exemption threshold does not exempt you from anything on the receiving side.

How do you issue a credit note as an electronic invoice, step by step?

You never modify the original invoice: you issue a new document typed as a "credit note," which references the original invoice and passes through your accredited platform.

A transmitted invoice is immutable: altering the file would break its integrity, so any correction must take the form of a new document, whose type depends on the nature of the error.

The steps, in order:

1. Identify the invoice concerned: its number and exact date. Without this, the credit note will be rejected.
2. Choose the right document. A corrective invoice if the original invoice hasn't been paid, a credit note if it has already been settled.
3. Type the document correctly in your software (381 for a standard credit note).
4. Carry over all mandatory particulars, including the four new ones introduced by the reform.
5. Transmit via the accredited platform, never by email.
6. Track the status returned by the platform: a credit note can be rejected just like an invoice.

The credit note must carry the mandatory particulars set out in Article 242 nonies A of Annex II to the French General Tax Code (CGI), follow a continuous numbering sequence, be archived like an invoice and, once the obligation applies, pass through an accredited platform in a structured format.

You no longer correct an invoice: you issue another one, and it's the type code that carries the entire legal meaning.

Which type code should you use: 381, 384, 503 or 262?

The type code (field BT-3 under the EN 16931 European standard) determines how the platform and accounting software process your document. Getting the code wrong distorts the accounting entry on the client's side.

Every document must be qualified with a BT-3 type code, notably 380 for a commercial invoice, 386 for a deposit invoice, 381 for a credit note and 384 for a corrective invoice. This typing drives the checks, the references and the document's lifecycle.

A key structural difference between 381 and 384: a 381 credit note can reference several invoices, but a 384 corrective invoice references only one. If you grant a discount covering six invoices from the same quarter, that's a credit note, not a corrective invoice.

The classic trap for an accounting department configuring its ERP: a credit note issued with code 380 will pass XML validators but will be misinterpreted by ERP systems. The file is technically valid, but the accounting treatment is wrong.

What mandatory particulars must appear on an electronic credit note?

A credit note carries the same particulars as an invoice, plus an explicit reference to the original document, plus the four new particulars introduced by the reform.

Since a credit note is treated as equivalent to an invoice, it must in principle carry all the particulars listed in paragraph I of Article 242 nonies A of Annex II to the CGI. Since September 2026, four additional particulars from Decree No. 2022-1299 apply: the client's SIREN (the nine-digit French business identification number), the delivery address if it differs from the billing address, the category of the transaction (goods, services or mixed), and the option to account for VAT on a cash basis (débits).

Also keep the "business" content in mind: the credit note must always clearly state the reference of the original invoice along with the precise reason for the credit note. A vague reason ("commercial gesture") complicates justification in the event of a tax audit.

On format: three base formats are accepted, UBL XML, UN/CEFACT CII XML and Factur-X. The current Factur-X version is 1.09 / ZUGFeRD 2.5, applicable from 1 July 2026. If you receive structured credit notes in bulk, reliably reading the fields becomes an operational issue in its own right: that is precisely what our page on electronic invoicing in France covers.

Credit note or corrective invoice: which should you choose?

The practical criterion is payment status. Invoice not yet paid: corrective invoice. Invoice already paid: credit note.

A corrective invoice cancels and replaces the erroneous invoice; a credit note records a reduction or cancellation, typically when the invoice has already been paid. If the client has already settled the debt, issuing a corrective invoice is no longer possible: you must opt for a credit note instead.

Tax doctrine distinguishes several scenarios. Sale cancelled in whole or in part: credit note or new invoice cancelling the previous one (CGI, Art. 272, 1). Rebate, discount, rebate-back or early-payment discount granted after issuance: credit note. Error in price, quantity, rate or client identity: corrective invoice (CGI, Art. 289, I-5). Unpaid invoice: duplicate of the original invoice, not a credit note. This last point surprises many business owners: an unpaid debt is not wiped out by a credit note, since VAT recovery is conditional on the debt being definitively irrecoverable.

On timing: VAT remains recoverable until 31 December of the second year following the date it became due. Beyond that, issuing a credit note remains possible for accounting purposes, but VAT adjustment is no longer available.

What happens if a credit note is issued incorrectly?

A non-compliant credit note is either rejected by the platform or reclassified as a failure to invoice, with a fine attached.

Failure to issue an invoice in electronic format is punishable by a fine of 50 euros per invoice, capped at 15,000 euros per year. For an ETI issuing several hundred credit notes a year, that cap is reached quickly.

Platforms run automated checks. The amounts in the XML must be consistent with those on the PDF: this is one of the checks carried out by platforms and validation tools. A credit note whose PDF shows -1,200 € while the XML carries 1,200 € as a positive figure will pass, provided the type code is 381; the reverse triggers a rejection or an accounting inconsistency.

Another edge case documented by the FNFE (the French national electronic invoicing forum): a credit note that references no prior invoice is not forwarded to the buyer by the issuer's platform. The document exists in your software, your client never receives it, and your aged receivables balance stays wrong.

A credit note rejected by the platform doesn't warn you: it simply vanishes from the flow, and it's the accounting reconciliation that reveals the problem three weeks later.

On the receiving side, the practical burden is real. A firm processing 300 supplier invoices a month also receives credit notes that need to be automatically matched to the right invoice, which requires correctly extracting the referenced number. Sygnet extracts the structured fields and attachments from this type of document flow, notably for accounting firms.

FAQ

Must a credit note necessarily go through an accredited platform?

Yes, as soon as your company is subject to the issuing obligation. An electronic invoice must follow a standardised electronic format, include the mandatory particulars in a dedicated field, and be transmitted to the client through an accredited platform (PDP) acting as the administration's partner. Since a credit note is treated as equivalent to an invoice, the same rule applies identically. A credit note sent as a PDF by email to a VAT-liable client is not compliant.

Must the amounts on an electronic credit note be negative?

No, and this is the most common mistake. The amounts are positive, contrary to what many people assume: it is the TypeCode 381 that signals the credit nature, not the sign of the amounts. Your software must therefore produce an XML file with positive values and the correct type code. If your ERP outputs negative amounts with code 380, you are compounding two non-compliance issues at once.

Must an SME already accept electronic credit notes from its suppliers?

Yes, since 1 September 2026. You must be able to receive all B2B invoices from your French suppliers via your accredited platform; without a platform in place by that date, your suppliers cannot send you their compliant invoices. This applies to credit notes just as it does to invoices. The obligation to issue your own credit notes, however, only kicks in from September 2027.

Do credit notes need to be transmitted through e-reporting?

That depends on the nature of the transaction, not the document itself. Transactions falling outside the scope of e-invoicing (individual consumers, foreign clients) are subject to transaction data reporting, and large companies and ETIs must issue their electronic invoices and transmit their e-reporting data from September 2026. Corrections follow the same regime as the original transaction. The details of which flows are concerned are covered in our article on e-reporting in France.