Electronic Invoicing in Côte d'Ivoire: What the DGI's September 2026 Controls Actually Enforce
Since 1 September 2026 the Direction générale des Impôts has been running unannounced "sortie magasin" checks on the facture normalisée électronique across every tax regime — a control power that has existed since 2008 but whose fine schedule and legal basis are still widely misstated. Here is what the Livre de Procédures Fiscales actually says.
Direct answer. Since 21 August 2026, the Direction générale des Impôts (DGI) has announced — and since 1 September 2026 has been carrying out — a nationwide control campaign on the facture normalisée électronique (FNE), covering taxpayers under all four regimes: régime réel normal (RNI), régime réel simplifié (RSI), régime des microentreprises (RME) and régime de l'entreprenant. The obligation to issue an electronic invoice is not new — it rests on Articles 144 and 145 of the Livre de Procédures Fiscales (LPF), most recently amended by Loi n°2024-1109 du 18 décembre 2024 (2025 tax annex, art. 6-7 and 6-8) — but the control mechanism being deployed this month, the "contrôle sortie magasin" of Article 13 bis LPF, and its accompanying fine schedule under Article 168 LPF, are frequently summarised inaccurately in commercial guidance circulating on the obligation. This note sets out the actual texts.
Legal basis — the obligation to issue an electronic invoice
Article 144 LPF requires any industrialist, trader, artisan or service provider to issue a facture normalisée électronique to a professional client, and requires it on request from an ordinary consumer, subject to the specific detail regime for detailers, artisans, farmers and fishermen outside the régime réel. Article 145 LPF adds that the invoice must carry an uninterrupted sequential number, the printer's identification, and — pending full platform rollout — a secure hologram, and it lists the businesses dispensed from the requirement: public-service concession holders for water, electricity and telephony within their concession, multi-counter retailers using secured tickets generated through the FNE platform, pharmacies, the national identification concessionaire, airlines, oil companies under production-sharing contracts, service stations (for fuel sales only), La Poste de Côte d'Ivoire, banks, insurance companies, non-concession transport operators, businesses with no professional establishment in Côte d'Ivoire, licensed telephony operators, and toll-road concessionaires for toll receipts. Article 145 bis extends the same obligation to remote and electronic sales. Both articles were last updated by Loi n°2024-1109 du 18 décembre 2024, and the list of exempt transport operators was further adjusted by Loi n°2025-987 du 19 décembre 2025 (2026 tax annex, art. 18-7) — the finance law currently in force.
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Legal basis — the control power being exercised this month
The specific power the DGI is using in September 2026 is not the general audit power under Articles 2, 4 and 5 LPF — Article 13 quinquies LPF expressly says the FNE control derogates from those procedures. It rests on Article 13 bis LPF (introduced by the 2025 tax annex, art. 6-2), which authorises any agent holding at least the rank of contrôleur des Impôts to carry out a "sortie magasin" check verifying that invoices are actually being issued as goods leave the premises, and on Article 13 ter LPF, which allows the administration to conduct this control at any time and without notice, following delivery of a control notice to the taxpayer or a representative, and to record the results in a procès-verbal signed on the spot. This is the mechanism referenced in the DGI's own communication announcing that inscription on the FNE platform and use of normalised electronic invoices or receipts would be checked nationwide from 1 September 2026, across the RNI, RSI, RME and entreprenant regimes alike.
The fine schedule — precise amounts, not "exposure to sanctions"
Article 168-1° LPF sets the fine for each undelivered invoice by regime: 10,000 francs per invoice for taxpayers under the entreprenant tax or the microenterprise tax, 30,000 francs for taxpayers under the régime réel simplifié, and 50,000 francs for taxpayers under the régime réel normal. The cumulative fine for a single control is capped, respectively, at 500,000 francs, 3,000,000 francs and 10,000,000 francs. Article 168-2° adds that failure to pay within 72 hours triggers closure of the premises, cumulatively with the fine itself. Repeat offending is punished more severely still: Article 13 sexies LPF sends a taxpayer caught a further time to the fraud sanctions of Article 171 LPF — a fine of 500,000 to 30,000,000 francs and imprisonment of one month to two years for a first repeat instance (Art. 171-2°), rising to 1,500,000 to 100,000,000 francs and one to five years' imprisonment in case of a second repeat within five years (Art. 171-4°). Article 171 bis LPF further treats deliberate disconnection of FNE equipment as tax resistance, carrying the same Article 171 penal exposure.
Analysis — why the distinction matters
Commercial guidance on the FNE obligation frequently cites the wrong articles of the Code général des Impôts for its legal basis and omits the regime-specific fine schedule altogether, which leaves businesses unable to gauge their actual exposure or to check whether they fall within one of the eleven categories Article 145 LPF exempts from the obligation. The regime-based fine structure also means that a group operating subsidiaries or branches under different tax regimes cannot apply a single compliance standard across the group — a retail subsidiary under RNI faces a materially higher per-invoice fine and cap than an affiliated entreprenant-regime outlet, even for the identical failure. Because the September 2026 campaign uses the no-notice "sortie magasin" power of Article 13 bis rather than a scheduled audit, the practical compliance window is the point of sale itself, not a later document review.
Practical procedure
Businesses across all four regimes should confirm, before any unannounced visit, that registration on the FNE platform is current, that point-of-sale staff issue an invoice or receipt bearing the sequential numbering and identification data Article 144 requires without waiting to be asked by professional clients, and that any exemption relied upon under Article 145 is one of the categories the article actually lists rather than an informal industry practice. Groups with mixed-regime entities should map the applicable fine tier per entity rather than assuming a single group-wide exposure figure, and any entity that has previously been the subject of a procès-verbal under Article 13 ter should treat a further lapse as carrying the Article 171 récidive exposure, not merely a repeat of the Article 168 fine.
Recommendation
We recommend that clients under all four regimes verify FNE platform registration and point-of-sale compliance now, ahead of an unannounced control, and that groups with entities across several regimes document, entity by entity, which of the Article 168 fine tiers and which Article 145 exemptions (if any) apply, rather than relying on a single group-wide compliance summary.
This analysis reflects our reading of Articles 13 bis, 13 ter, 13 quater, 13 quinquies, 13 sexies, 144, 145, 145 bis, 168 and 171 of the Livre de Procédures Fiscales as consolidated through Loi n°2025-987 du 19 décembre 2025 (2026 tax annex) and Loi n°2024-1109 du 18 décembre 2024 (2025 tax annex), and does not constitute legal advice on any particular set of facts.
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