PART 2, The burning issue of TMCs and mixed agencies: opaque, transparent, and now what?

Based on the SETO/EDV/KPMG Lawyers VAT & Electronic Invoicing White Paper (February 2026)

Enriched with feedback from the field: network presidents, CEOs of back-office publishers, GDS, CEOs of agencies, CFOs of large groups, airlines.

Part 1: The fundamentals: what the reform really changes for the travel sector

Part 2: The burning issue of TMCs and mixed agencies: opaque, transparent, and now what?

A hot topic, rarely discussed publicly

This section draws on the EDV/SETO/KPMG white paper, published in February 2026, which primarily addresses issues in the leisure sector. A white paper specifically for Travel Management Companies (TMCs) is expected at the end of May 2026 and will likely provide further details on use cases specific to business travel. In the meantime, this report incorporates feedback from discussions held with network presidents, CEOs of back-office software providers, Global Distribution Systems (GDSs), travel agency CEOs, CFOs of major industry groups, and airline representatives.

The conclusion is clear: everyone has started working, but at the day-to-day operational level, crucial questions remain unanswered. A relative consensus has emerged on the fundamentals of VAT. However, the debate surrounding transparent versus opaque invoicing methods remains very heated. And for good reason: this isn't a technical issue. It's a business model issue.

1. The central question: opaque, transparent, or both?

A reality that defies simple categories

The issue is primarily concentrated among TMCs (Travel Management Companies) and so-called "mixed" agencies, which manage both leisure and corporate clients. For these players, the reform forces a clarification that could previously be avoided: what is the agency's position, service by service?

The reality on the ground is that the answer is neither simple nor uniform. The same TMC can be simultaneously opaque and transparent, depending on:

• The nature of the service sold: a group trip is typically treated in an opaque manner; an air ticket at a public fare is often treated in a transparent manner.
• The contract signed with the corporate client: some contracts explicitly specify the expected billing method, others remain silent.
• What the supplier requires: some airlines or hotels position the agency as a de facto agent, regardless of its preferences.
• The nature of the purchase: public price, negotiated price (agency, network or corporate), package or isolated service, each configuration may require different treatment.
• The economic model with the supplier: commission on the transaction or not, override, incentive, the remuneration structure influences the qualification.
• Collective agreements of the profession: for example, the EDV/SNCF agreement positions the agency as a de facto agent for train tickets, which determines the tax treatment independently of the individual contract with the client.

This issue remains unresolved within the industry. A TMC white paper is expected by the end of May 2026 and should provide further clarification. In the meantime, each TMC must document its position on a product line-by-product basis without waiting for a uniform response that is unlikely to materialize.

Key question for the leader

Have you mapped all your product lines and determined, for each one, whether you are in an opaque or transparent position? This work is a prerequisite for any system or billing decision.

The issue of negotiated rates and confidentiality

One point deserves particular attention: so-called "R,U" fares, negotiated (agency or network) fares between airlines and travel agencies, are by nature confidential. The question of how airlines will integrate these models into their direct electronic billing processes to corporate clients remains, to date, partially unanswered. This is an issue on which GDSs, IATA, and industry representatives continue to work.

2. The mechanics of agency billing: services (opaque), disbursements (transparent), fees and other

In this new model, the invoice issued by the agency to its corporate client can consist of four distinct types of lines, which it is essential not to confuse:

(opaque) service:

These are the amounts charged by the agency to its client; this can include airline tickets (e.g., UK fares negotiated by the agency or network), hotel services that the agency wants to mark up in addition to these fees (but be careful of the contract between the agency and the corporate client), etc. If we follow the rules, these amounts should be recorded as "business volume" as production.

Disbursement notes

These are the amounts advanced by the agency on behalf of the client for airline tickets, train tickets, and hotel services purchased directly from French establishments. These amounts are shown with the VAT code "O" (out of scope), because they represent funds collected on behalf of a third party, not services provided by the agency. The agency must be able to substantiate these disbursements with supplier invoices.

Agency fees

This is the agency's own remuneration for its intermediation services. Standard VAT applies to these amounts. They are contractually defined with the corporate client and appear as a separate line item on the invoice.

Other (example: the debit note)

This is a specific and frequent case in business travel, yet still relatively unknown: some transactions don't generate a standard supplier invoice. This is particularly true for purchases made with virtual cards from low-cost airlines, where the only available documentation is a charge on the card statement. For these situations, regulations stipulate a "debit note" (currently being validated), a separate line item from standard expenses, with specific processing. This is an area that billing systems will need to address.

Point of vigilance

Disbursements, fees, other: three types of line items, three different VAT treatments. Current invoicing systems do not always make this distinction. This is a non-negotiable upgrade requirement before the reform takes effect.

3. Who invoices what and to whom? The reality on the ground of corporate flows

Airlines: the 4 fields project

In this transparent model, corporate companies will receive invoices directly from their service providers: airlines, SNCF (French National Railways), and hotels located in France. These invoices are intended for review but not payment by the companies; payment is processed through the agency, which summarizes the expenses in its own invoice.

To ensure airlines can route these invoices to the correct corporate recipient, agencies will need to complete four identification fields in their company profiles, which will be sent to the airlines as Remarks (RM) when the ticket is issued. Technically, this operation is not insurmountable for travel management companies (TMCs): it simply involves enriching the company profiles in the back office and ensuring that the data is correctly transmitted to the Global Distribution System (GDS).

The real obstacle today lies not with the agencies, but with the GDS: the ability of distribution systems to develop and deploy these new functionalities within the required timeframe. This is a project that extends beyond the agencies themselves and is being actively monitored by travel agencies and IATA.

Operational vigilance point

Once the ticket is issued, the airline can no longer send the invoice to the corporate client as part of its process. The window of opportunity is narrow: the data must be in the right place at the right time.

Low-cost companies established in France (including Transavia) are among the topics still under construction; work is underway, answers will come, but delays must be anticipated.

SNCF: the good student, but the FCE profile still needs clarification

SNCF is able to send invoices directly to corporate clients, provided they correctly complete the FCE (Corporate Client Form). The problem is that the final format of this form is not yet known.

In practice, it will be the agencies that will have to support their corporate clients in filling out the forms. A CEO of a major travel management company has thus planned individualized follow-up with each of his corporate clients. This represents a real operational workload that needs to be factored into team workload plans now.

Hotels: the vast majority are outside the scope, a few cases need to be addressed

The vast majority of hotel nights booked for business trips are purchased through Bedbanks established abroad, outside the scope of the French reform. For these transactions, there will be no immediate change.

However, if an agency purchases directly from a hotelier based in France, transparency is essential. Two distinct situations must be managed: either the hotelier issues an electronic invoice (standard disbursement), or payment is made via virtual card without an invoice (debit note). The ability of independent hoteliers to issue compliant electronic invoices remains highly variable.