With the development of new technologies in the field of banking services, electronic checks have been proposed as an alternative to paper checks in financial systems. This development, in addition to facilitating and accelerating transactions, provides greater security and transparency to the payment system. In the meantime, various countries, including Iran and France, are facing numerous challenges in adapting their legal and technical structures to the requirements of this new financial instrument. A proper understanding of these challenges requires a comparative legal and technical study of the two aforementioned systems. This research seeks to answer the question: What legal and institutional challenges exist in the path of fully establishing electronic checks in Iran and France, and what solutions can be proposed to overcome them? The aim of the research is to identify the obstacles to the full implementation of electronic checks in the two systems by comparative analysis of the existing challenges and to introduce appropriate reform platforms. The research method was analytical-descriptive and made use of library resources, domestic laws, European regulations, and judicial procedures. The findings show that in Iran, the lack of technical infrastructure, the absence of a specific law for e-checks, and the lack of security regulations are the main obstacles; while in France, the challenges are more related to institutional coordination, privacy protection, and judicial interpretation of electronic documents. As a result, the development of e-checks requires the adoption of clear laws, the establishment of reliable technical mechanisms, and the interaction of judicial, financial, and technological institutions in both countries; and France, with its gradual and systematic approach, can provide a useful model for Iran.