Year-End French Invoice Checklist: What Finance Needs Before May 20

The French year-end accounting close (cloture des comptes / cloture de l'exercice) is not a single deadline. It is a chain of five deadlines, each dependent on the one before it, and the first link — having every supplier invoice (facture fournisseur) extracted, entered, and assigned to the correct accounting period — determines whether the rest of the chain holds or breaks. When that first link fails, the comptable does not simply catch up in January. They create a facture non parvenue (FNP) entry, a provisional accounting estimate that must be tracked, reversed, and replaced when the real invoice arrives — and if the estimate was wrong, the TVA (VAT) declaration is wrong too. This article is the operational checklist that sits between "the supplier sent a December invoice" and "the liasse fiscale was transmitted on May 20." It covers what happens before the journal entries — and what happens after if something was missed.

Why Year-End Close Is Different for French Invoices

Monthly closes have their own pressure, but year-end close (cloture de l'exercice) is structurally different for three reasons that do not apply to the other eleven months.

The FNP problem does not exist mid-year. If a supplier invoice for November delivery arrives on December 5, you book it normally — the invoice date is in the same fiscal year. But when a December 28 delivery's invoice arrives on January 15, that charge belongs to the closed year under the PCG (Plan Comptable Général) principle of séparation des exercices (separation of accounting periods), codified in Articles 511-3 and 512-4 of the PCG and reinforced by the arrêté du 11 janvier 1990. The charge must be attached to the closed year, not the year the invoice arrived. That is what creates a facture non parvenue — a provisional entry that must be estimated, booked at close, reversed at opening, and reconciled when the real invoice appears. Every December invoice you do not process before the books close creates one more FNP to track.

Annual TVA reconciliation replaces monthly returns. If your company is under the régime réel simplifié (simplified real VAT regime) — which covers businesses with annual turnover between €85,500 and €840,000 for goods or €37,500 and €254,000 for services, per current thresholds — you do not file monthly CA3 declarations. You make two advance payments (acomptes) in July (55% of prior-year VAT) and December (40%), then file a single annual CA12 declaration that reconciles the full year. That CA12 requires you to know the total TVA déductible (deductible VAT) across every supplier invoice for the entire year — split by rate — by early May. If December invoices were not processed, the CA12 numbers are incomplete. If FNPs were estimated with wrong TVA amounts, the CA12 is wrong. The simplified regime eliminates monthly compliance in exchange for a single high-stakes annual reconciliation — and that reconciliation is only as accurate as the invoice data feeding it.

The deadline chain compresses into four months. For a standard December 31 fiscal year-end, the clock starts on January 1 and ends with the liasse fiscale transmission by May 20 (May 5 legal deadline plus the 15-day automatic extension for electronic filing via EDI-TDFC, per BOFiP doctrine). Within those four months, the company must: close the books, finalize the trial balance, compute the accounting result, make tax restatements, prepare the liasse fiscale, obtain the director's signature, and transmit the package. At the front end of that chain, every unprocessed supplier invoice is a block in the pipe. A finance team that spends January locating and manually entering December invoices has already lost a quarter of the available close window before any analytical work begins.

These three structural pressures — FNP creation, annual TVA reconciliation, and the compressed deadline chain — are not separate problems. They are three faces of the same problem: the speed at which supplier invoices become structured accounting data determines how much of the close window is available for everything else. The steps below cover what that means operationally, from the day the fiscal year ends to the day the liasse is transmitted.

The December-to-May Timeline: Deadlines Every Finance Team Needs

Here is the chain of deadlines for a company with a December 31 fiscal year-end. Each deadline is non-negotiable — penalties apply automatically, not after warning.

Deadline	Date (2026)	What It Covers	Penalty for Missing It
Fiscal year close (cloture)	Dec 31, 2025	Last day charges can be directly attributed to the closing year. Any invoice arriving after belongs to N+1 — and may need FNP treatment if the delivery was in N.	FNP entry required; if missed, the result (résultat net) is overstated and IS (corporate tax) is overpaid.
CA12 annual VAT return	May 5, 2026 (May 20 with electronic filing)	Annual VAT reconciliation for simplified regime: total TVA collectée (output VAT) vs TVA déductible (input VAT) for the full year. The CA12 uses form 3517-S.	10% surcharge on VAT due under Art 1728 CGI if late; + late-payment interest at 0.20%/month (Art 1727 CGI).
Liasse fiscale (tax return package)	May 5, 2026 (May 20 electronic)	Form 2065 (IS declaration) + annexes 2050-2059 (BIC) or 2033 (simplified). Must be transmitted via EDI-TDFC through an accredited partner.	10% on IS due (no formal notice), 40% after formal notice, 80% for undisclosed activity (Art 1728 CGI).
Relevé de solde IS (corporate tax balance)	May 15, 2026	Final IS payment after deducting the four quarterly advance payments (acomptes) paid during the year.	5% late-payment penalty (Art 1731 CGI) + interest.
AG d'approbation des comptes	By June 30, 2026	Shareholder approval of annual accounts — within 6 months of close. The procès-verbal (minutes) is required before accounts can be deposited at the greffe.	None directly, but failure to approve blocks dépôt des comptes.
Dépôt des comptes annuels	By July 31, 2026	Filing of approved accounts at the greffe du tribunal de commerce (now via Guichet Unique INPI). Within 1 month of AG approval.	Injonction de faire from the président du tribunal; €2,000 astreinte possible.

The critical insight in this calendar is not the dates — it is the dependency structure. The CA12 requires reconciled invoice data. The liasse fiscale requires the CA12. The AG requires the liasse. The dépôt requires the AG. If the invoice data is incomplete at the start, everything downstream carries an error — and the correction cost multiplies as it propagates through the chain.

For the simplified regime specifically, note that the CA12 deadline applies to the full calendar year even if your accounting year is offset. If your exercise runs July 1 to June 30, you file a CA12-E within 3 months of your close date, but the underlying TVA numbers must still reconcile across your fiscal periods. The principle is the same: the annual TVA return depends on complete invoice data for the entire period.

FNP and Cut-Off: What Happens When December Invoices Arrive in January

The facture non parvenue is the accounting mechanism that bridges the gap between "the goods arrived in December" and "the invoice arrived in January." The mechanism is well-documented in every French accounting textbook. What is less discussed is the operational reality that creates FNP situations — and the downstream consequences of getting the estimate wrong.

The operational root cause. An FNP exists because a supplier invoice was not processed before the books closed. The most common scenario: a December 28 delivery from a wholesaler, the invoice is dated December 31, but the supplier's billing cycle runs on the 5th of the month — the PDF arrives January 5. If the accounting team has already closed the purchase journal (journal d'achats) for December, that invoice cannot be booked normally. The charge belongs to December, but the document belongs to January. The FNP entry bridges the gap.

The journal entry at close (31/12/N):

Account (Compte)	Name (Intitulé)	Debit (Débit)	Credit (Crédit)
607 (or 601, 602, 606 depending on purchase type)	Achats de marchandises (or raw materials, supplies, external services)	HT amount
44586	TVA sur factures non parvenues	TVA amount
4081	Fournisseurs — Factures non parvenues		TTC amount

The HT amount posts to the appropriate class 6 expense account. The TVA is isolated in compte 44586 — it is not immediately deductible. TVA on an FNP cannot be claimed until the actual invoice is received and booked, because the right to deduction is conditional on holding the invoice (Article 271-I-1 of the CGI).

At the opening of N+1 (01/01/N+1), the entry is reversed (contrepassation): debit 4081, credit the charge account and 44586. When the real invoice arrives — say January 15 — it is booked normally: debit charge account HT + debit 44566 (TVA déductible on biens et services) + credit 401 (Fournisseurs) for TTC.

Where the estimate goes wrong. The most common FNP error is underestimating the TVA. If the comptable estimates the charge at €1,000 HT based on the bon de livraison (delivery note) but the actual invoice carries items at three different VAT rates — food at 5.5%, non-alcoholic drinks at 10%, equipment at 20% — the single estimated TVA figure is wrong. When the real invoice arrives in January, the reversal and rebooking produce a TVA discrepancy that flows into the CA12. If the CA12 has already been filed, this requires a déclaration rectificative (corrective return).

The cut-off procedure (procédure de cut-off) that prevents this. The PCG's cut-off concept, defined in the arrêté du 11 janvier 1990, requires that every transaction near the close date be assigned to the correct period — even without an invoice. The operational cut-off for invoices involves three actions:

Reconcile all bons de livraison (delivery notes) received in December against invoices booked. Any delivery note without a corresponding purchase invoice by January 15 is a candidate FNP.
Request missing invoices from suppliers before the close window shuts. A supplier who habitually invoices late can be asked for a provisional facture to support the FNP estimate. Most wholesalers (Metro, Transgourmet, Pomona) can provide electronic copies on request.
Set a matériality threshold. Not every missing €20 office supply invoice requires an FNP. A common practice is to set a threshold — e.g., €200 HT — below which late-arriving invoices are simply booked in N+1. This is a pragmatic judgment, not a PCG requirement, but it aligns with the accounting principle of materiality (importance relative).

The difference between a clean close and one riddled with FNP corrections is not accounting knowledge — every comptable knows the FNP journal entry. It is whether December invoices were extracted and entered before the books closed. If the extraction step takes 12 minutes per invoice — the standard manual processing time — a month-end batch of 50 December factures requires 10 hours of data entry before any FNP analysis can begin. If extraction takes 5-10 seconds per page, the data is in the spreadsheet before the close meeting starts. The operational bottleneck is not the accounting — it is the data entry.

The Annual TVA Reconciliation: CA12 and What Your Invoices Must Prove

The CA12 is not just a VAT form. It is the annual reconciliation that determines whether your simplified-regime company overpaid or underpaid TVA across the full year — and the numbers on it must be traceable to individual supplier invoices in the event of a contrôle fiscal (tax audit).

Under the simplified real regime, the CA12 requires you to declare the total TVA déductible — the sum of all deductible VAT on supplier invoices for the year — split into categories that the administration uses to cross-check against sector norms. A restaurant declaring 80% of its input VAT at 20% when the sector average is closer to 30% (because food purchases are mostly at 5.5%) triggers an automatic anomaly flag. The comptable needs to show not just the total number — they need to show which invoices produced it.

The per-rate split matters. A single Metro supplier invoice (facture fournisseur) for a French restaurant might carry:

Food items at 5.5% TVA (taux réduit) — compte 44566, CA3/CA12 ligne for reduced-rate input VAT
Non-alcoholic drinks at 10% TVA (taux intermédiaire) — same compte 44566, different reporting line
Kitchen equipment at 20% TVA (taux normal) — compte 44566 or 44562 if immobilisation

If the extraction output collapsed all three rates into a single "TVA" column, the comptable must return to the original invoice to split them — for every invoice. At 200 invoices per year with an average of 2 TVA rates each, that is 400 manual split operations. Performed once at year-end, under the May deadline. This is the kind of rework that extraction is supposed to eliminate.

A structured extraction approach that defines separate columns per TVA rate — "HT 20%," "TVA 20%," "HT 10%," "TVA 10%," "HT 5.5%," "TVA 5.5%" — means the CA12 numbers are pre-split before the comptable opens the spreadsheet. At 200 invoices, the difference between pre-split columns and a single-TVA-column-extraction is not a convenience — it is the difference between filing the CA12 on May 5 and filing on May 20 after two weeks of manual reconciliation.

The TVA on FNP is a separate reconciliation headache. Because TVA in compte 44586 is not deductible until the real invoice is received, the comptable must track which FNPs have been reversed (invoice received, TVA moved to 44566 and included in CA12) and which are still outstanding (TVA still in 44586, not on CA12). A spreadsheet that started the year with 15 FNPs at €2,300 total TVA in 44586 ends the year with 3 still outstanding at €420 — and the CA12 must only include the €1,880 that was actually received and booked. Tracking this across dozens of FNPs is manual, error-prone, and exactly the kind of task that gets compressed into the final week before the CA12 deadline.

None of this is unique to French accounting. Every VAT jurisdiction requires rate-level reconciliation. What is specific to France is the annual nature of the simplified regime — the CA12 aggregates 12 months of transactions into one return — and the penalty schedule: a single rate misclassification that produces a €500 underpayment triggers a €50 late-payment penalty plus 0.20% monthly interest, and if the administration deems it a deliberate error (manquement délibéré), the penalty rises to 40% of the underpaid amount under Article 1729 of the CGI.

The Year-End Invoice Processing Checklist

This checklist is structured around the operational sequence — not the accounting sequence. The accounting entries (FNP, contra-passation, CA12) are the output. The steps below are the input: what must happen for those entries to be correct.

Set a supplier invoice cut-off date. Announce an internal deadline — e.g., January 15 — after which any supplier invoice received is treated as N+1 unless the delivery date proves it belongs to N. Do not wait until March and then attempt to reconstruct December. The cut-off date creates a clean boundary: invoices received before = process for close; invoices received after = evaluate for FNP treatment.

Collect all December supplier invoices — digital and paper. Gather PDFs from email, downloaded factures from supplier portals, scanned paper invoices, and photos of handwritten artisan factures (factures manuscrites). Do not pre-sort by supplier — a single folder of all unprocessed invoices is the starting point. If you use a Collection Link (lien de collecte) for supplier uploads, send the link to any fournisseur who has not yet submitted their December invoice.

Match delivery notes (bons de livraison) to booked invoices. For every December bon de livraison or bon de commande where goods were received, verify that a corresponding purchase invoice is either booked or flagged for FNP treatment. This is the single highest-value cut-off control — it catches invoices that were never received because the supplier's billing cycle crossed the year-end boundary.

Extract invoice data into accounting-ready columns. Process the collected invoices through extraction. Define columns that match your accounting import schema: "Date Facture," "Numéro Facture (Invoice Number)," "Fournisseur (Supplier Name)," "SIREN Fournisseur," "N° TVA Fournisseur (Supplier VAT ID)," "HT 20%," "TVA 20%," "HT 10%," "TVA 10%," "HT 5.5%," "TVA 5.5%," "Total TTC." The TVA-by-rate columns eliminate the post-extraction split that would otherwise consume hours. For a batch of invoices from multiple suppliers, batch processing applies the same column structure across all formats — one supplier's "N° Facture" and another's "Facture N°" both land in the "Numéro Facture" column.

Verify TVA intracommunautaire numbers against SIREN. For each supplier, confirm that the two-digit check key in the VAT ID (FR + key + SIREN) validates against the SIREN. The EU VIES database confirms the pairing instantly. A supplier whose TVA number does not validate on VIES means the input VAT on their invoices may be disallowed — this must be identified before the CA12 is filed, not after.

Identify and estimate FNPs. For every delivery note without a matching invoice by the cut-off date, create an FNP estimate. Use the bon de livraison, bon de commande, or the supplier's price list to estimate the HT amount. For the TVA estimate, apply the rate that applies to the majority of that supplier's goods — if in doubt, use the standard 20% rate for non-food, 5.5% for food, and flag for correction when the real invoice arrives. Record each FNP in a tracking sheet with: supplier name, estimated amount, estimated TVA, date of delivery, and expected invoice date.

Book the FNP journal entries at close (31/12/N). For each FNP: débit the appropriate charge account (6xxxx) for HT + débit 44586 for TVA + crédit 4081 for TTC. The TVA in 44586 is isolated — it does not appear on the CA12 until the real invoice is received and the entry reversed.

Contrepasser (reverse) FNP entries at opening (01/01/N+1). Reverse every FNP: débit 4081 + crédit the charge account and 44586. This clears the provisional entry and makes room for the real invoice. If a real invoice arrives for that supplier, book it normally through the purchase journal. If it has not arrived by the time the CA12 must be filed, the FNP TVA remains unrecovered.

Reconcile annual TVA by rate for the CA12. Sum TVA déductible across all booked supplier invoices for the year, split by rate: 20%, 10%, 5.5%, 2.1%. Add the TVA from FNPs that were reversed and booked (now in 44566, included in CA12). Exclude TVA still in 44586 from FNPs not yet resolved. The CA12 form 3517-S requires the total TVA déductible — and while the form does not explicitly split by rate, the comptable's working papers must support the split for audit purposes. Pre-split columns in the extraction output make this step a SUM formula rather than a manual reconciliation.

Match HT expense totals to the PCG compte de charges. Verify that the sum of HT amounts by purchase type maps to the correct class 6 accounts: food purchases → compte 607, consumable supplies → compte 602, external services → compte 606, subcontracting → compte 604. If your extraction output includes a "Compte Charge" inferred column — where the AI classifies each invoice by expense type — this step is automated. If not, it requires manual classification of every invoice by account code before the liasse fiscale can be prepared.

Prepare the FEC (Fichier des Écritures Comptables) for transmission. The FEC is a mandatory electronic file containing all accounting entries for the year, in a standardized format defined by Article A47 A-1 of the Livre des Procédures Fiscales. It must be produced if requested during a contrôle fiscal. Your accounting software (Pennylane, Cegid, Sage, EBP) generates the FEC from the general ledger — which means every supplier invoice entry, including FNP reversals and rebookings, must be correctly recorded before the FEC is generated. The penalty for a non-compliant or missing FEC is a minimum €5,000 fine plus a 10% surcharge on reassessed tax.

Archive source invoices for 10 years. Under Article L123-22 of the Code de commerce, original accounting documents — including supplier invoices — must be preserved for 10 years. The extraction spreadsheet is not a substitute for the original facture. Both must be archived: the original PDF/image and the structured extraction output. During the dual-track e-invoicing transition (Factur-X structured invoices arriving through a Plateforme Agréée alongside traditional PDFs), archive the original format that arrived — a Factur-X PDF with embedded XML preserves more data than a flat PDF scan.

The checklist above is a workflow, not a set of accounting rules. Steps 1-3 are operational: they determine whether the rest of the chain has clean input data. Steps 4-6 are where extraction tools change the arithmetic — compressing the data-entry phase from days to minutes, and producing TVA-by-rate columns that make step 9 (CA12 reconciliation) a SUM operation rather than a manual re-read of every invoice. Steps 7-12 are the accounting mechanics that every comptable knows, but they are only as clean as the data that feeds them.

JPG/PNG/PDF AI Extraction

Define columns like "Date Facture," "SIREN Fournisseur," and "TVA 20%" — the output maps directly to your close entries. Processed securely, not stored.

What Happens If You Miss Invoices After Close

Despite the best checklist, invoices get missed. A supplier sends a January invoice with a December date. A bon de livraison was overlooked during the cut-off review. The comptable discovers the omission in March — after the books are closed and the CA12 is filed. Here is what happens next, and what it costs.

If discovered before the CA12 is filed (before May 20): The charge belongs to N but was not booked. The comptable uses compte 672 (charges sur exercices antérieurs — charges from prior periods) to record the expense in N+1's books, per Articles 511-3 and 512-4 of the PCG. At year-end N+1, compte 672 is reclassified to the appropriate expense account by nature. The TVA on the invoice is booked to 44566 if the invoice was received in N+1 — and the CA12 for N is already filed, so this TVA cannot be claimed for N. The TVA is permanently lost for the closed year. For a €1,000 HT invoice at 20% TVA, that is €200 in non-recoverable VAT — plus the IS overpayment on the inflated N result (because the expense was not deducted).

If discovered after the CA12 is filed: The comptable must file a déclaration rectificative (corrective CA12) if the omission is material. This triggers an automatic review by the DGFiP and resets the three-year audit window under Article L47 of the Livre des Procédures Fiscales. If the correction results in additional TVA due, late-payment interest applies at 0.20% per month under Article 1727 of the CGI. If the administration determines the omission was deliberate, the 40% penalty under Article 1729 of the CGI applies on the underpaid amount.

The practical cost of one missed invoice. A single €3,000 TTC December supplier invoice from a fournisseur, not booked in N and discovered in March N+1:

Lost TVA déductible: €500 (at 20% TVA) — cannot be reclaimed for N because the CA12 is closed
IS overpayment: €375 (25% IS on €1,500 overstated result — assuming the €2,500 HT expense would have reduced the result)
Comptable time to correct: 2-3 hours to locate the original invoice, verify the omission, pass the corrective entry, file the déclaration rectificative if needed
Total direct cost: approximately €875 plus 3 hours of comptable time — for one missed invoice

The cost of a missed invoice is not hypothetical. Under Article 1737 of the CGI, a missing or incorrect mandatory field on an invoice carries a €15 penalty per field, capped at one-quarter of the invoice amount. A supplier invoice missing the SIREN and the TVA intracommunautaire — both mandatory under Article L441-9 of the Code de commerce and Article 242 nonies A of Annexe II to the CGI — triggers €30 in penalties. A late-payment indemnity under Article D441-5 of the Code de commerce adds a fixed €40. The penalties compound with every missed invoice and every missed field.

The structural fix is not better accounting after the fact — it is faster invoice processing before the close window shuts. The 12-minute manual entry cycle creates a queue that pushes December invoices into January's close window, generating FNPs and the associated TVA tracking overhead. Compressing that cycle to seconds per invoice, through column-name-based extraction that reads fields by meaning rather than position, eliminates the queue — and with it, the majority of FNP situations. The accounting entries for the invoices that truly cannot arrive in time (because the supplier's billing cycle crosses the year boundary) are the ones FNP was designed for. The rest are avoidable.

FAQ

How long after the fiscal year-end can I still book an invoice to the closed year?

Under the PCG principle of séparation des exercices, the cut-off is the closing date itself — December 31 for a calendar-year exercise. Any invoice dated before that date for goods or services delivered before that date belongs to the closed year and should be booked either directly (if received before close) or via FNP (if received after close). In practice, most finance teams set an internal cut-off date — e.g., January 15 — for booking invoices directly to the closed year, and treat later arrivals as FNPs. There is no legal grace period; the internal date is pragmatic, not statutory. Once the books are formally closed and the liasse fiscale is filed, any N charge discovered later must use compte 672 (charges sur exercices antérieurs) and cannot reduce N's taxable result.

Can I reclaim TVA on a December invoice that arrives in March?

It depends on the timing relative to the CA12 filing. If the invoice arrives before the CA12 is filed (before May 5 or May 20), and the FNP was correctly booked at close, the contra-passation and rebooking at the real amounts moves the TVA from compte 44586 to compte 44566 — making it deductible on the CA12 for the closed year. If the invoice arrives after the CA12 is filed, the TVA is permanently lost for the closed year. You can claim it on the N+1 CA12 only if the goods or services relate to N+1 operations — which they do not, by definition, for a December invoice. The practical takeaway: prioritize resolving FNPs for the highest-TVA invoices before filing the CA12.

What is the difference between an FNP and a charge constatée d'avance (CCA)?

An FNP (compte 4081) records a charge for which goods or services were received but the invoice has not arrived — the charge belongs to the closing year. A CCA (compte 486) records a charge for which the invoice has arrived and been paid, but the goods or services relate to the following year — the charge must be removed from the closing year. Example: a 12-month insurance premium paid in December with the policy starting January 1 is a CCA — the entire premium is removed from N and spread across N+1. A December delivery from Metro invoiced on January 5 is an FNP — the charge is added to N. They are opposite operations: FNP adds a charge to the closing year, CCA removes one.

Does the new e-invoicing reform (facture électronique) change the year-end close process?

Not in the short term. The reform mandates that all VAT-registered businesses must receive structured electronic invoices (Factur-X, UBL, CII) through a Plateforme Agréée (PDP) from September 1, 2026. Issuance obligations for SMEs start September 1, 2027. During the transition, your year-end close will handle a mix: some structured Factur-X invoices arriving through a PDP, and many traditional PDFs from suppliers not yet obligated to issue electronically. The close process — identifying which invoices belong to N, extracting their data, reconciling TVA — does not change. What changes is that structured invoices carry machine-readable data that reduces extraction time for those specific invoices. The dual-track reality — structured + unstructured invoices in the same close period — means the extraction step remains necessary for the PDFs, and useful as a uniform pipeline that handles both formats. For more on the reform's operational impact, see the analysis of the dual-track burden.

What software do French comptables actually use for year-end close?

The French accounting software market is split across several platforms. Pennylane (€30-60/month) is the fastest-growing, with over 500,000 companies on the platform as of late 2025, and is particularly strong in collaborative workflows between SMEs and their experts-comptables. Cegid (Quadra for accountants, Loop for SMEs) and Sage (50cloud, 100 Cloud, Générations Experts) remain the traditional leaders, particularly in established cabinets d'expertise comptable. EBP Comptabilité (€20-45/month) is popular with artisans and small businesses. Indy (€9-29/month) targets freelancers and micro-enterprises. Regardless of the platform, the year-end close workflow is the same: supplier invoice data must enter the system — whether via manual entry, structured e-invoice import, or AI extraction — before the close can proceed. The software automates the downstream accounting; it does not solve the upstream data-capture bottleneck. For details on how extraction output maps to these platforms, see the three-line cost framework.

What is the penalty for filing the CA12 late?

A late CA12 triggers a 10% surcharge on the VAT amount due under Article 1728 of the CGI, applied automatically even without a formal notice (mise en demeure). If the administration sends a formal notice and the CA12 is not filed within 30 days, the surcharge rises to 40%. Late-payment interest at 0.20% per month (Article 1727 CGI) applies from the deadline date. In addition, if the CA12 is not filed at all, the administration may proceed to taxation d'office — assessing VAT based on available information, which typically produces a higher assessment than the actual liability. For a company with €15,000 in annual VAT due, a 10% surcharge is €1,500 — before interest. Separately, a missing or incomplete liasse fiscale carries an amende forfaitaire of €60 per missing document, capped at €1,200 per exercise.

The Chain Holds at the First Link

The French year-end close is a chain of deadlines, and the chain holds or breaks at the first link: whether supplier invoices are in the system, with TVA split by rate, before the close window compresses into May. A comptable who knows the FNP journal entry by heart but still receives 40 December invoices on January 10 has not solved the problem — they have identified it. The accounting rules for handling late invoices are well-defined. The operational bottleneck that creates those late invoices in the first place — the 12 minutes per manual entry, the per-supplier format differences, the multi-rate TVA split done by hand — is what determines whether the close produces a clean liasse or a cascade of corrective entries.

The extraction approach matters not because it changes accounting — the PCG does not care how data enters the journal. It matters because it compresses the upstream bottleneck that determines how much of the four-month close window is available for analytical work rather than data entry. When a December invoice takes 10 seconds to extract with per-rate TVA columns instead of 12 minutes to type and split manually, the queue evaporates. The FNPs that remain are the ones truly caused by supplier billing cycles — not the ones caused by a data-entry backlog. Test the workflow on your own December factures. See if the close window opens up.

Extract a French Invoice for Close Preparation