Electronic invoicing in travel: What every executive needs to understand before September 2026

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

A reform with far more structuring impacts on travel

On September 1, 2026, electronic invoicing becomes mandatory for large companies, mid-sized companies, and members of a VAT group. For SMEs and very small businesses, the obligation to issue invoices is postponed to September 1, 2027, but the obligation to receive invoices applies from September 2026, without exception.

This timetable is now set in stone. It will not be postponed again.

In most sectors, this reform is rightly perceived as a technical and accounting undertaking, delegated to finance and IT teams. In the travel sector, however, the changes are far more impactful. The reform directly affects the business model of agencies and tour operators: the agency's legal position vis-à-vis its clients and suppliers is not always clearly defined in practice; some suppliers are imposing the transparent model to remain competitive; remuneration is based on a combination of fees, margins, and supplier revenues that do not naturally fit into the categories provided for by the reform. And above all, commercial law and tax law do not perfectly overlap: there is no single "industry-specific" rule, and the agency has a degree of choice, which is both a freedom and a responsibility.

This guide is designed for managers of travel agencies and tour operators who wish to understand the real issues of the reform, identify the decisions that belong to them, and manage the compliance of their company with clarity.

Why travel is a unique sector and why this complicates everything

The e-invoicing reform was designed for a "standard" economy: a company sells a good or service, issues an invoice with a price excluding VAT, a VAT rate, and a VAT amount, and its customer receives and pays it. This simple model does not reflect the reality of travel.

Travel operators operate in a structurally atypical tax environment, marked by several unique and cumulative characteristics:

• A special VAT regime applies. When an operator sells a trip in its own name that includes transport and/or accommodation provided by third parties, it is subject to the special regime for travel agencies, known as "VAT on the margin." VAT is not calculated on the total price charged, but on the difference between what the customer pays and what the service providers charge. This regime is not optional; it is mandatory.
• The intermediary role is often unclear in practice. The legal classification of an agency as opaque or transparent is not always clear in daily operations. Some suppliers impose the transparent model to remain competitive against direct rivals. Others accept both models. This reality on the ground creates hybrid situations that the reform will force us to clarify.
• A composite compensation structure. Agencies receive agency fees, margins on certain services, and supplier revenue (commissions, overrides, incentives). This combination does not fit into a single billing model, and translating it into structured electronic flows is a complex exercise.
• Long chains of intermediation. A trip may pass through a tour operator, a travel agency, an online platform, and a payment provider before reaching the traveler. At each link, the intermediary's status determines all tax and documentation processing.
• Payments are frequently collected by third parties. Payment service providers (PSPs), distribution platforms, and agent agencies regularly collect payments on behalf of operators, creating discrepancies between the date of collection, which triggers the VAT liability, and the date of payment.
• A legal framework that allows for choices. Commercial law and tax law do not perfectly overlap in the travel sector. There is no uniform "professional" rule: the agency has considerable leeway in its positioning. This freedom, however, requires conscious and well-informed decisions.

The VAT margin scheme in the face of electronic invoicing

What the reform cannot yet do

The electronic invoicing formats mandated by the reform—XML CII, XML UBL, and Factur-X—were designed to express standard VAT: price excluding VAT, rate, and VAT amount. They do not have a native field for expressing VAT calculated on the margin.

The consequence is documented in the SETO/EDV/KPMG white paper: the pre-filled VAT return by the tax authorities will be structurally incorrect for all transactions falling under the margin scheme. Your company will have to manually correct the pre-filled amounts on its return each month or quarter.

This is a permanent organizational constraint, which requires rigorous internal control processes, impeccable traceability of margins, and finance teams capable of making these corrections within the legal deadlines.

Key question for the leader

Is my organization currently able to make these corrections within the legal deadlines, with impeccable traceability of margins?

What this means for your billing model

In practice, electronic invoices issued under the margin scheme must show the total amount including VAT in the "amount excluding VAT" field, with a VAT amount of zero, and include the mandatory statement "Special scheme – Travel agencies". A single invoice template will not suffice.

Changes are being discussed at the AFNOR commission level to better integrate sector-specific requirements into the standards. This is an issue to monitor, but regulatory progress should not be used as an excuse to postpone preparations.

Opaque or transparent: a decision with concrete tax consequences

A qualification that commits your company

The opaque acts in its own name, presents itself as the seller to the client, contracts with service providers in its own name, and makes a profit on resale. It falls under the margin scheme as soon as the conditions are met.

The transparent intermediary acts in the name and on behalf of an identified principal (the principal). It does not resell; it facilitates, receives a commission, and is only subject to VAT on that commission. However, to be recognized as such by the tax authorities, it must meet a set of cumulative conditions: an explicit written mandate, invoicing in the principal's name, precise identification of the principal (including VAT number), verifiable accounting, and recording of disbursements in suspense accounts.

The presumption of opacity: a real risk, but one that needs to be put into perspective

French law establishes a presumption of opacity : unless documented evidence to the contrary proves otherwise, an intermediary is presumed to be acting in their own name. In current industry practices, many operators behave economically as if they were transparent without possessing the necessary documentation to legally establish this.

It is important to define precisely what reclassification means: in the event of a tax audit, the tax authorities could reclassify as taxable revenue volumes treated as transparent disbursements, and retroactively apply standard VAT rates. The amount can be significant.

That said, this risk deserves to be put into perspective: the entire profession has long been affected by these hybrid practices, and the administration is aware of this. The reform doesn't create the risk out of thin air; it simply makes it more visible, as the flows become structured and traceable. The priority is not to panic, but to document one's choices and align billing practices with one's actual legal position.

Key question for the leader

Do I have a clear and documented understanding of my company's legal role in each of my product lines?

If this is not the case, this is the first project to undertake even before choosing an approved platform.

Third-party payments: a subject to be clarified, not dramatized

The principle of payment upon receipt

For services, which cover the majority of travel expenses, VAT is due upon receipt of payment, not upon delivery or disbursement of funds. This principle is well-known in the sector. The reform does not change it, but it makes it more visible and more complex to manage.

When a distribution platform, PSP or partner agency collects a payment on your behalf, VAT is due on the date of that payment, not on the date those funds are paid to you.

What the reform changes in concrete terms

In the context of electronic invoicing, the "paid" status must be updated throughout the lifecycle of each invoice. This status determines the electronic payment report submitted to the tax authorities. As a direct consequence, the pre-filling of the CA3 tax return will always be delayed for businesses whose payments are processed through third parties; regular manual corrections will be necessary.

It is worth noting here that opting for VAT on an accrual basis is a game-changer: under this system, VAT becomes due upon invoicing, not upon receipt of payment, which simplifies invoice lifecycle management and reduces the need for tax return corrections. Some agencies, in practice, adopt a behavior similar to the accrual basis option without having officially chosen it; the tax authorities do not object, as the VAT is then paid in advance. Nevertheless, this remains a point to clarify and document, as the pre-filled CA3 form will need to be verified in all cases. This topic is discussed in Part 3.

Point of vigilance

This is an issue that needs to be anticipated and addressed with distribution partners and payment providers, rather than treated as an uncontrollable risk. Existing contracts do not provide for this level of information feedback. They need to be updated.

Cancellations, credits, modifications: an operational challenge not to be underestimated

Significant cancellation rates, especially in the corporate sector

Business travel has structurally high cancellation and modification rates. On average, travel management companies (TMCs) observe cancellation rates of 10 to 15%, reaching up to 25% in certain segments (last-minute trips, sectors highly susceptible to unforeseen events). Leisure travel is also affected, with spikes during geopolitical, health, or weather-related crises.

However, the reform is clear: any cancellation or modification of a sale requires the issuance of an electronic credit note referencing the original invoice (including its date and number). This credit note must be processed through the e-invoicing system. It corrects the taxable base and the VAT collected.

For an organization that handles several thousand cases per year with a cancellation rate of 15%, this represents a considerable volume of vouchers to be issued compliantly, quickly, and traceably. Current practices—partial refunds, email exchanges, and manual processing—will no longer be sufficient.

A management question: are you equipped for this?

The question isn't whether your teams know the rule. It's whether your systems can adhere to it at scale, on time, and without errors. This is an investment decision that rests with the leader.

Travel insurance: insulate it, or expose yourself

Why can't insurance be included in the package?

Travel insurance covering cancellation, assistance, and multi-risk coverage is a service exempt from VAT by nature. Its distribution is a regulated activity: the tour operator cannot sell it under its own name. It must act as a transparent intermediary on behalf of the insurer. This results in two separate flows that must never be combined:

• The insurance premium: Amount collected on behalf of the insurer, outside the scope of VAT for the operator, treated as a disbursement.
• The intermediation commission: Remuneration of the operator, exempt from VAT if the legal conditions are met.

In an electronic invoice, each line item must be qualified with the correct VAT code. Combining these data streams into a single line item, a common practice today, will no longer be acceptable.

What this changes in your tools and contracts

Your billing systems must be able to distinguish and correctly code each line item. Your contracts with insurers must clearly reflect the nature of the intermediation. And your sales teams must understand that presenting insurance to the client can no longer be a simple "package" without tax traceability.

Continued in 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 27, 2026), supplemented by practical feedback. It does not constitute legal or tax advice. For any specific situation, it is recommended to consult a chartered accountant or a tax lawyer.