PART 3 : What the leader must decide and manage
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?
Summary
1. Decisions that belong to the leader
The reform of electronic invoicing generates a long list of operational tasks. But before delegating them, there are strategic decisions that only the leader can make.
Choose your approved platform and do it quickly
Using an approved payment platform (AP) is mandatory: no more B2B invoicing transactions can be processed directly between seller and buyer. You have three options:
Option 1: The PA of your back office.
This is the most natural option. In practice, your back office is either an Approved Processor (AP) itself, or it relies on an AP it has selected and whose costs it will pass on to you—costs which, for some, can be far from negligible. It is common practice to use the same AP for both sending and receiving, but this is not mandatory. Every situation is different, and this choice has consequences and side effects that must be carefully considered.
Option 2: An external but uniform PA (Pennylane type…).
Technically feasible, but not the most recommended solution for the specific needs of the travel industry.
Option 3: The multi-PA.
This is also feasible if you anticipate that your customers will be on multiple platforms and wish to preserve your independence, but with complexities that should not be underestimated.
Once you have finalized your strategy, share it with your colleagues. Reform cannot be managed alone by management.
Define your intermediation model
As discussed in Parts 1 and 2, the legal classification of each product line is a prerequisite for any technical decision. This classification falls under the purview of senior management, in conjunction with legal and tax counsel, and may lead to contractual adjustments or even choices regarding market positioning.
Decide on the VAT option on debits
Operators can choose to have VAT due upon invoicing (accrual basis) rather than upon receipt of payment. This option simplifies certain aspects of management, particularly updating the "paid" status in the invoice lifecycle, but it has cash flow and reporting implications. This decision rests with the business owner.
Anticipate the cost impact and decide on your business model
Compliance comes at a cost. This includes the cost of the certified platform, the cost of system upgrades, the cost of legal support, and the cost of team time. This cost is real, partly recurring, and varies depending on the size of the organization and the choices made.
The question the leader must decide is: how will this cost be absorbed? Three options, which can be combined:
- Specific additional charges: Billing the customer for an additional charge line related to electronic invoicing requires a transparent approach that assumes appropriate customer communication.
- Absorption into the overall margin: Integration of the additional cost into the overall margin or the fees already charged is a more commercially fluid approach, but one that compresses profitability.
- Temporary margin reduction: Accepted reduction of operating margin initially, with a gradual recovery plan as a transition option.
This choice has commercial, contractual (particularly for corporate clients with fixed rates) and competitive positioning implications. It's a management decision, not an accounting factor.
Investing in system upgrades
The reform requires a dedicated budget, project management, and prioritization of tasks. The leader must include it on their agenda and ensure that human and financial resources are allocated accordingly.
2. Don't let your accountant manage this project alone
This is perhaps the most important warning in this matter. Electronic invoicing is often perceived as an accounting and tax issue and therefore instinctively entrusted to the accountant or the CFO. This is a governance error.
The accountant is a valuable contact, particularly regarding VAT and tax returns. However, they lack expertise in the complexities of the travel industry: special tax regimes, the distribution chain, GDSs, back offices, supplier relationships, the specificities of travel management companies (TMCs), and event management. These are subjects that fall well outside their usual scope.
The manager of a travel agency or tour operator must take charge of this project himself and assemble a multidisciplinary team including:
- Legal and tax aspects: To secure the classification of flows, customer and supplier contracts, mandatory information.
- Marketing and communication: To prepare customer communication on billing changes, potential new charges, and reassurance tools (newsletter, FAQ, etc.).
- The salesperson: To anticipate the impact on corporate contracts, manage any potential price negotiations related to the new fees, and communicate with clients in the course of the relationship.
- The accountant and the CFO: For declarative corrections, margin monitoring, cash flow reconciliation and CA3 management.
- Technological intermediaries: Back-office, GDS, OBT (Online Booking Tool), HBT (Hotel Booking Tool), TBT (Train Booking Tool): each of these systems is impacted and must be part of the project from the outset.
- Key suppliers: Airlines, SNCF, hotels, insurers: to collect trends, anticipate their billing constraints and align expected flows.
In practice
Appoint a dedicated project manager, not necessarily the CFO, with a clear mandate, an identified team, and regular reporting to management.
The reform is progressing quickly. A well-governed project with multiple stakeholders is better than a project delegated to a single person, however competent they may be.
3. Managing your project: advice from those already in the know
What you need to accept in order to move forward peacefully
Your customer segmentation will never be perfect. Aim for 90% accuracy in your database, and adjust over time. Waiting for perfection means never starting.
The national directory is not up to date and probably never will be. If your PA confirms that everything is in order, then everything is in order. Even a client for whom you have completed the work may not be visible in the directory: this is an informational bug, don't waste your energy on it.
What publishers are announcing today may no longer be true in a year. 2026 is a year of intense commercial warfare in the world of licensed platforms. We must adapt and not remain passive.
Your software publisher is doing everything they can. Certified platform, API, AFNOR standards, interoperability, e-reporting, IT security, UX, business functionalities: it's a colossal undertaking, and no one can do everything perfectly. The three-headed unicorn doesn't exist.
Prices are changing and will continue to change. Learn to navigate an agile environment. The travel industry is used to it.
Communicate with your back office and industry representatives. What they share is sometimes already outdated by the time you receive it; reforms move quickly, very quickly. But these exchanges remain essential. And sometimes, you also have to trust your instincts.
Proceed step by step. It's perfectly valid to tell some clients, "We've chosen our PA for receiving; we'll see about sending and e-reporting in the fall." The ecosystem isn't fully ready yet. Taking it one step at a time is reasonable, provided it's not used as an excuse for inaction.
4. Quick wins to implement now
Here are a few simple, high-impact actions that any leader can implement immediately:
A monthly newsletter for your clients on the progress of the reform and your choices: Inform them, explain the specifics of your profession, and show that you are actively engaged on the issue. It is also a powerful tool for building customer confidence.
Monthly monitoring of the electronic invoicing project: Standards are evolving, use cases are becoming clearer, and vendor positions are changing. Don't let your teams navigate blindly.
Bi-monthly reporting on the progress of PA designations (for large multi-service organizations): Twice a month, a simple point shared with all teams concerned.
Regular communication with your accounting firm: Communicate regularly with them, keeping in mind that you are the one who knows about sector-specific matters.
And above all, remain transparent and humble: with your teams, your clients, your partners. No one has all the answers today. What makes the difference is moving forward methodically, communicating honestly, and not waiting for everything to be perfect before taking action.
5. What you risk if you don't act in time
The penalties provided for by law are as follows:
€15 per invoice not sent by e-invoicing, capped at €15,000 per calendar year.
€250 per missing e-reporting transmission, capped at €15,000 per calendar year.
€50 per non-compliant invoice, a fine that state services can send directly to the agency.
The real risk is large-scale automated non-compliance: thousands of incorrectly routed invoices, erroneous VAT returns, and unissued credit notes. In an environment where tax authorities now have access to structured data in real time, the ability to detect anomalies is vastly superior to what it was before.
It also poses a business continuity risk: a B2B customer whose procure-to-pay systems reject your invoices is a customer who will block payments. In an industry with tight cash flow, this is not a theoretical possibility.
6. This is the crucial moment
Electronic invoicing is not just another technological development. For managers of travel agencies and tour operators, it is a transformation that simultaneously affects their legal positioning, their financial organization, their information systems and their relationships with their partners.
The specific characteristics of the sector—margin regime, complexity of intermediation, third-party payment collection, cancellation volume, corporate and TMC issues—make this reform more demanding than in most other industries. They call for tailored solutions, upstream strategic thinking, and management at the highest level of the company.
The white paper published by SETO and Les Entreprises du Voyage, with the support of KPMG Avocats, provides a solid reference point. It is now up to each manager to take ownership of it, identify the decisions that fall within their purview, and commit their organization without delay.
September 2026 is just a few months away. Time is running out.
A final thought, and a statistic that puts things into perspective
Accountants are often referred to as the experts on this reform. Here is a fact that calls for collective humility and should reassure many business leaders.
By cross-referencing the SIREN numbers identifying accounting firms, approximately 39,031 SIRENs recorded, with 2,810 SIRENs not found in the database (figures therefore approximate), we obtain an average rate of designation of approved platform (PA) of 14.9% for the accounting firms themselves.
In other words, even those who are knowledgeable aren't that far ahead. If you feel like you're falling behind, don't worry, you're not alone. The important thing is not to remain stagnant.
And above all: do not entrust them with the governance of this project. Your professional expertise is your greatest asset.
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?
This document is based on the SETO/EDV/KPMG Avocats VAT & Electronic Invoicing White Paper (February 2026), supplemented by feedback from the field and discussions with numerous professionals. It does not constitute legal or tax advice. For any specific situation, it is recommended to consult a chartered accountant or a tax lawyer.
