e-reporting obligations in France
For foreign companies without a permanent establishment in France
The French e-invoicing reform, under Article 289 bis of the Code Général des Impôts, requires businesses established in France and registered for VAT there to exchange electronic invoices for domestic B2B transactions. That obligation does not apply to foreign companies with no permanent establishment in France for VAT purposes.
However, a separate and distinct obligation applies to those same foreign companies. Where a foreign company without a French PE carries out a transaction deemed to take place in France, for which it is liable for French VAT under CGI rules, it must transmit certain data about that transaction, and in some cases the related payment, to the French tax administration.
E-reporting does not require issuing or receiving an electronic invoice. It is a data feed to the administration, covering figures such as the transaction amount, the VAT amount charged and the applicable VAT rate.
Two components of e-reporting
Transaction e-reporting for B2B international sales covers non-established companies carrying out any of the following: sales or services deemed located in France and subject to French VAT, made to another taxable person not established in France; intra-EU acquisitions in France not exempt under CGI article 262 ter II 3°; and purchases of goods or services taxable in France from a supplier that is neither established nor VAT registered in France.
Who reports depends on VAT liability, not just who is the seller. If the customer holds a French VAT number, the seller is not liable for French VAT on that sale. Liability shifts to the customer under reverse charge, known as autoliquidation, and it is the customer who carries the e-reporting obligation for that transaction, as acquirer.
For B2C transactions, e-reporting covers sales and services to non-taxable persons, such as retail sales to individuals, where the transaction is subject to French VAT. This is excluded where the foreign operator is registered under an EU VAT one stop shop scheme. OSS reported B2C sales fall outside the e-reporting obligation entirely, since the OSS return already captures that data.
A separate obligation, payment e-reporting, applies to services and deposits on supplies of goods, regardless of the customer’s status, whether French or foreign, business or private individual. This is a broader net than transaction e-reporting: there is no B2B/B2C distinction and no test of whether the customer holds a French VAT number. Excluded from payment e-reporting are transactions where the seller has opted for VAT on debits, meaning VAT due on invoicing rather than on cash receipt, and transactions by the customer.
The party that reports is always the one receiving payment, the invoice issuer, never the customer. Data transmitted includes the date of receipt, the VAT inclusive amount received broken out by VAT rate, and, where VAT becomes due on receipt, the related invoice number.
What is always excluded
Regardless of size or transaction category, several categories are never in scope. Exports and intra-EU supplies are excluded as VAT exempt operations. Operations exempt under CGI articles 261 to 261E and dispensed from invoicing, such as certain banking and insurance operations, medical and health services, education, and non-profit organisations with disinterested management, are excluded. Defence or security procurement contracts under the public procurement code are excluded, as are classified transactions or those covered by a national security confidentiality clause, and imports of goods.
Company size determines the deadline
The applicable deadline depends on company size, assessed at the level of the legal unit, identified by its Siren number or by a foreign VAT or identification number where no Siren is held. Size is measured as of 1 January 2025, based on the last fiscal year closed before that date, using worldwide turnover and balance sheet, not just French activity.
A micro-enterprise has fewer than 10 employees, and turnover or total annual balance sheet under €2 million. An SME has fewer than 250 employees, and annual turnover not exceeding €50 million or balance sheet total not exceeding €43 million. An ETI, or intermediate sized enterprise, is not classified as an SME, has fewer than 5,000 employees, and annual turnover not exceeding €1,500 million or balance sheet total not exceeding €2,000 million. A large enterprise cannot be classified in the categories above, either through having more than 5,000 employees, or, below that threshold, turnover above €1,500 million and balance sheet above €2,000 million.
A company moves up a category once the employee count threshold is exceeded. If the employee count stays below the threshold, it moves up only if both turnover and balance sheet exceed it. Micro, SME and ETI companies may voluntarily anticipate their obligations and begin e-reporting as early as 1 September 2026.
How the deadlines apply in practice
Company size only ever affects the seller side deadline. It does not affect the acquirer or reverse charge deadline, which is 1 September 2027 for every size.
A B2B sale or service by a non-established seller to another non-established taxable person, where French VAT is due, is in scope and reported by the seller, with a deadline of 1 September 2026 for large and ETI companies, and 1 September 2027 for SME and micro companies, with the option to opt in earlier from 1 September 2026.
A B2C sale or service to a non-taxable person, where French VAT is due and the sale is not reported under OSS, is in scope and reported by the seller, on the same deadlines as above.
A B2B sale where the customer holds a French VAT number is in scope under reverse charge, but is not reported by the seller. It is reported by the customer instead, with no size based deadline distinction.
Intra-EU acquisitions located in France that are not exempt under article 262 ter II 3°, and purchases of goods or services taxable in France from a supplier not established or not VAT registered in France, are both in scope and reported by the acquirer, with a deadline of 1 September 2027 for all sizes.
B2C sales reported under OSS are excluded entirely, along with exports, intra-EU supplies, operations exempt under CGI articles 261 to 261E, defence and security procurement contracts, classified transactions, and imports of goods.
How Tax Desk can help
Foreign companies subject to e-reporting must select an approved platform, known as a plateforme agréée or PDP, responsible for transmitting their data to the administration. This choice must be made before the date on which the company becomes subject to the obligation, either 1 September 2026 or 1 September 2027, as applicable.
Tax Desk is developing an e-reporting solution for our clients, ahead of September 2026.
