France – E-invoicing and e-reporting for French businesses

The e-Invoicing and e-reporting reform

Context

As part of the European Union’s ViDA (VAT in the Digital Age) reform, the European Union plans to make e-invoicing mandatory more broadly, particularly for cross-border transactions, from 2030.

France has already been transitioning to e-invoicing for several years, building on the mandatory e-invoicing requirement between businesses and public-sector entities (B2G), introduced in 2017.

Like other Member States such as Belgium and Luxembourg, France has anticipated the ViDA reform by introducing a national e-invoicing requirement for domestic B2B transactions.

The French reform also introduces two complementary requirements: e-reporting of transactions and e-reporting of payments. These measures will enable the tax authorities to access the data they need to monitor transactions and VAT.

The Objectives of the Reform

This national reform has four main objectives:

• Strengthen business competitiveness through the efficiency gains resulting from the digitalisation of invoicing processes;
• Ultimately simplify VAT reporting requirements, notably through the development of a pre-filled VAT return service;
• Strengthen the fight against VAT fraud, to the benefit of compliant businesses;
• Improve real-time visibility into businesses’ economic activity and enhance the management and implementation of public policies.

The New Requirements Introduced by the Reform

As part of this reform, three new requirements are being introduced:

• E-invoicing;
• E-reporting of transactions;
• E-reporting of payments.

These new requirements will ensure that transaction data is transmitted to the tax authorities, either through e-invoicing or e-reporting of transactions, as well as payment data, through updates to invoicing cycles or the transmission of payment e-reporting data.

To issue and receive electronic invoices, as well as to transmit e-reporting data, businesses must appoint an approved platform.

These approved platforms, officially registered with the French tax authorities, are primarily responsible for issuing, transmitting, and receiving electronic invoices between suppliers and customers, as well as generating and transmitting e-reporting data on behalf of businesses.

Reform Timeline

These new requirements will be introduced gradually, starting on September 1, 2026.

For more information, see the timeline for the implementation of e-invoicing.

The E-Invoicing Requirement

Who is affected and which transactions are covered?

The e-invoicing requirement for certain transaction flows will be introduced gradually from 1 September 2026 through 2027, depending on the type of business and the transactions involved.

In this respect, Article 289 bis of the French General Tax Code (CGI) provides that, by way of derogation from the general invoicing rules set out in Article 289 VI of the CGI, invoices relating to domestic transactions subject to mandatory invoicing requirements, as well as the corresponding advance payment invoices, must be issued, transmitted and received electronically when both the supplier and the customer are taxable persons established, domiciled or habitually resident in France.

E-invoicing therefore applies to transactions:

• Between VAT-taxable persons established in France;
• That fall within the scope of French VAT and for which French invoicing rules apply.

Example 1: Sales of goods in mainland France and in the French overseas departments (DOMs) where VAT applies — Guadeloupe, Martinique and Réunion — to a business customer established in France or in one of the DOMs where VAT applies.

Example 2: Services subject to VAT in France and invoiced to French entities.

Example 3: Purchases from French suppliers that are subject to the mandatory e-invoicing requirement.

Please note: Certain transactions that are exempt under Articles 261 to 261 E of the CGI — including banking, insurance and financial activities, training, healthcare, etc. — are not subject to this requirement.

Expected Format and Content for e-invoicing

Electronic invoices must comply with a standardized format: UBL, CII, or Factur-X, and must include the mandatory information required under Article 242 nonies A.

Important

As of 1 September 2026, four new mandatory items will initially apply to large companies and mid-sized companies (ETIs), and then, as of 1 September 2027, to SMEs and micro-enterprises:

• the customer’s SIREN number when the customer is a company;
• the delivery address if it differs from the customer’s address;
• the nature of the transactions: goods, services, or a combination of both;
• the statement “Option for payment of VAT based on amounts invoiced”, where this option has been exercised.

E-invoice transmission procedures

Electronic invoices must be transmitted to the customer through an approved platform, acting as a partner of the tax authorities.

The tax authorities provide a list of operators that meet all the required conditions, including interoperability testing.

In addition, the invoice data to be transmitted to the tax authorities are those specified in Article 41 septies D of Annex IV to the French General Tax Code (CGI).

The Transaction and Payment E-Reporting Requirement

Transactions covered

The transactions falling within the scope of e-reporting are those provided for under Articles 290 I and 290 A of the French General Tax Code (CGI), relating to:

1. The transmission of payment data for sales of services, where the business has not opted for the VAT-on-debits regime;
2. Transactions involving goods and services carried out in France for the benefit of foreign businesses or entities (international B2B);
3. Sales of goods and services carried out in France for the benefit of private individuals (B2C).

However, transactions exempt under Articles 261 to 261 E of the French General Tax Code, as well as imports subject to VAT in France, do not fall within the scope of e-reporting.

Data to be report

The data to be transmitted as part of transaction e-reporting are those listed in Article 242 nonies M of Annex II to the French General Tax Code (CGI).

The data to be transmitted as part of payment e-reporting are those listed in Article 242 nonies P of Annex II to the French General Tax Code (CGI).

Transaction Data Submission Frequency (Transaction E-Reporting)

For businesses subject to the standard monthly VAT regime, transaction data must be submitted three times a month, every ten days, within 10 days following the end of each ten-day period:

• Deadline: the 20th for the period from the 1st to the 10th of the month;
• Deadline: the 30th for the period from the 11th to the 20th;
• Deadline: the 10th of the following month for the period from the 21st to the end of the month.

For businesses subject to the standard quarterly VAT regime, transaction data must be submitted once a month, by the 10th of the month following the month to which the transaction data relate.

Payment Data Submission Frequency (Payment E-Reporting)

Payment data must be submitted once a month, by the 10th of the month following the month to which the transaction data relate.

E-Reporting Submission Procedures

E-reporting data must be transmitted to the French tax authorities through an approved platform that is a partner of the tax administration.

The French tax authorities provide a list of approved platform operators that meet all the required conditions, including interoperability testing.

Penalties for E-Invoicing and E-Reporting

The 2026 Finance Act amended the existing penalties and introduced a new penalty applicable to businesses as part of the e-invoicing and e-reporting reform.

However, the French tax authorities have provided for a transitional period of flexibility in the application of penalties when the reform is first implemented, depending on the circumstances.

For more information on the applicable penalties and the arrangements for this transitional period, please see our dedicated blog post.

How to Ensure Compliance

1. Identify the current IT system and existing configuration : The first step is to conduct an assessment of the current organization and systems in place: invoicing tools, ERP systems, point-of-sale software, accounting solutions, banking applications, invoice issuance and receipt processes, etc.

The existing configuration should also be analyzed in order to identify the rules currently governing VAT treatment: VAT invoicing, exemptions, reverse charge, mandatory wording, etc.

This assessment makes it possible to determine the company’s level of digital maturity, identify any necessary adjustments, and, above all, determine its needs in light of the reform: volume of invoices issued and received, number of flows to be processed, desired level of automation, integration requirements, and expected services.

2. Carry out a VAT mapping : It is essential to identify the different types of transactions carried out by the company in order to:

• confirm their VAT treatment;
• determine the mandatory information to be included on invoices;

3- Determine the transactions covered by or excluded from e-invoicing, transaction e-reporting and/or payment e-reporting : 

For each type of transaction, it is necessary to determine whether it falls within the scope of:

• e-invoicing;
• transaction e-reporting;
• payment e-reporting;
• or is excluded from the system.

This step makes it possible to define precisely the obligations applicable to each transaction flow.

4- Identify the use cases 

Beyond the main transaction flows, the company must identify the specific invoicing situations it encounters in the course of its business activities.

This analysis makes it possible to determine the applicable requirements regarding format, mandatory data, transmission and invoice lifecycle tracking, within the framework of the B2B use cases defined by the XP Z12-014 standard.

Identifying the use cases is also a criterion to be considered when selecting the approved platform: the company must ensure that the chosen solution is capable of handling the identified situations and processing them in accordance with the requirements of the reform.

5- Define the e-invoicing configuration rules

Based on the VAT mapping, we define the rules required to configure the platform: the nature of the transactions (goods, services or mixed), the applicable VAT categories, and the VATEX codes associated with exemption or reverse-charge regimes.

These parameters ensure reliable VAT processing and compliance of the data required for e-invoicing.

6-Choose your approved platform (formerly PDP)

The choice of an approved platform should be based on the needs identified during the assessment.

The company should in particular verify the platform’s compatibility with its existing tools, its integration capabilities and the services offered. It should also take into account the volume of invoices to be processed and the cost of the solution.

7- Ensure the reliability of Master Data

Finally, data quality is a key element of compliance.

The company should in particular verify and ensure the accuracy and reliability of the information contained in its customer and supplier databases:

• SIREN and SIRET numbers;
• intra-Community VAT numbers;
• addresses and other data required for invoicing;
• information required for the transmission of data to the tax authorities.

A reform that relies heavily on data automation and transmission can only operate effectively if the underlying source data is reliable.

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