Electronic invoicing and crypto payments: organising reconciliation
Published 24/08/2026 · Updated 08/09/2026 · Houssen Issouf Aly, French chartered accountant
Crypto-assets · Companies · Directors
Practical guidance for companies and directors. Revised on 7 September 2026.
Original article: 2026-08-24 · HODL Consulting
Payment does not replace the invoice
A blockchain transaction records an asset movement; it does not by itself provide all the information required on an invoice. A company accepting Bitcoin or stablecoin payments needs to connect four elements: the sale, invoice, receipt and any subsequent conversion. Electronic invoicing does not remove this reconciliation work.
Start with the sale, then document settlement
In the common case of a sale invoiced in euros, the invoice amounts and VAT treatment relate to the commercial transaction. The payment records separately identify the accepted asset, network, quantity, valuation and fees. A transaction identifier does not replace the customer’s identity or the description of the service.
If pricing or contractual documents use another unit, the appropriate invoicing, conversion and accounting arrangements need to be assessed. Copying a wallet balance onto an invoice is not enough.
Distinguish two payment routes
- Immediate provider conversion: connect the invoice with the crypto receipt, fees and euro settlement.
- The company retains the crypto-assets: connect the invoice with payment, then separately track the assets held and any later disposal.
The choice affects the records and monitoring process needed. Our accepting crypto payments page explains the questions to address before implementing the customer journey.
Locate your company in the timetable
Electronic invoice receipt began on 1 September 2026 for businesses within scope. Issuing and e-reporting follow the size-based timetable: large and intermediate-sized companies in September 2026, SMEs and micro-businesses in September 2027. The French small-business VAT exemption does not by itself remove a business from the system.
The payment method does not determine scope. Customers and transactions must be classified, as explained in the DGFiP overview.
Invoices, transactions and receipts: three components
- Electronic invoicing: transactions within the system between businesses established in France.
- Transaction e-reporting: data on relevant transactions, including those with individuals or foreign operators.
- Payment e-reporting: receipt data where VAT chargeability rules require it. In particular, the option for VAT on debits and reverse-charge arrangements need to be considered.
Certain VAT-exempt transactions that are exempt from invoicing under Articles 261 to 261 E of the French Tax Code are excluded. An exempt activity may nevertheless need to receive suppliers’ electronic invoices. The official FAQ on activities without VAT explains the distinction.
An example: French and foreign customers
A company must classify transactions by customer type, place of establishment and transaction regime. Stablecoin payments can occur in several categories. Grouping them under a single “crypto sales” heading would not prepare the required data correctly.
Consult the detailed DGFiP guidance when assessing your position. The timetable does not replace analysis of the scope applicable to each flow.
Build a reconciliation record
For each receipt, retain the invoice number, sale amount, asset and quantity received, network, date, fees and transaction reference. Add the valuation source, provider statement and any conversion record. Together, these should reconstruct the payment route without relying solely on a platform screen.
A numerical example: €1,200 invoiced, €1,188 settled
Assume a €1,200 VAT-inclusive invoice is paid in crypto and immediately converted by the provider for a gross equivalent of €1,200. The provider deducts €12 in fees and pays €1,188 into the bank account. The net settlement alone does not explain the sale: reconcile the €1,200 invoice, €12 fee and €1,188 settlement while retaining the invoice’s net and VAT breakdown.
These figures illustrate reconciliation and are not provider pricing. If the equivalent differs or conversion occurs later, identify and analyse the difference separately using the contracts and applicable accounting treatment.
Four cases to test before scaling the process
- Partial payment: retain successive receipts and the outstanding balance, rather than automatically clearing the invoice after the first transfer.
- Deducted fees: distinguish the amount owed by the customer, the provider’s deduction and the company’s receipt.
- Refund: connect any credit note, refund decision and outgoing transaction with the original sale.
- Late payment: check the validity of the quoted amount, conversion terms and agreement with the customer before treating a difference.
What should you ask software and payment providers?
Give them a complete example with invoice, payment and fees. Check whether exports retain a common identifier, timestamps and statuses, and how relevant receipt data is transmitted. Test corrections too: an incorrect entry must be traceable and correctable in the relevant process.
The approved invoicing platform and the payment provider perform different functions. Their connection with accounting software and crypto tracking tools needs to be verified. A commercial integration claim does not replace testing your actual cases.
Is a PDF sent by email enough?
For transactions subject to electronic invoicing, a simple PDF sent by email does not provide the required process. Formats and exchanges must be organised with your approved platform. See the official implementation portal.
Must the company immediately sell the assets received?
This is a separate decision from processing the invoice. If the company keeps them, tracking continues after receipt. Our crypto accounting page explains how to organise records and reconciliations.
Which accounting rules apply in 2026?
Treatment depends on the transaction and the framework applicable to the financial year. ANC Regulation 2026-01 was endorsed and published in the Official Journal on 3 September 2026. Article 9 provides for financial years beginning on or after 1 January 2027, with early application permitted for the financial year in progress at publication. Our ANC 2026 guide distinguishes these stages.
To prepare a discussion with the firm, gather a sample invoice, a payment export, conversion arrangements and the list of tools used. These help identify the connections and controls to organise.