Quick answer
Foreign companies without a French VAT permanent establishment are generally outside France's domestic B2B e-invoicing mandate, but they can still have e-reporting duties for French VAT transactions. Large and intermediate-sized sellers or service providers start on 1 September 2026; smaller sellers and providers, and buyers liable under reverse charge or intra-Community acquisition rules, start on 1 September 2027.
France e-reporting is not the e-invoicing mandate
France's electronic invoicing reform contains two related but different systems. Domestic B2B e-invoicing under Article 289 bis of the French General Tax Code concerns purchases and sales of goods or services carried out in France between VAT-taxable persons established in France. The French tax authority states that this receiving and issuing obligation does not apply to a foreign company that has no permanent establishment in France for VAT purposes.
E-reporting fills part of the resulting information gap. It sends selected transaction data, such as the taxable amount and VAT charged, to the tax authority for transactions that are not covered by domestic e-invoicing. Certain payment data can also be required. A French VAT number therefore does not, by itself, put a non-established company inside the domestic B2B e-invoicing mandate, and being outside that mandate does not, by itself, remove e-reporting.
Start by confirming the relevant legal entity, its French VAT registration and whether it has a French VAT establishment. Our French VAT and fiscal representation service explains how registration, representation and ongoing filing fit together for EU and non-EU businesses.
Do not use the two terms interchangeably
For a foreign company without a French VAT establishment, the practical question is usually whether transaction and payment e-reporting applies, not whether it must issue every invoice through the French domestic B2B e-invoicing system.
Who France e-reporting applies to
The current DGFiP guidance is aimed at foreign companies without a permanent establishment in France. E-reporting may apply where the company carries out a transaction considered to take place in France and is the person liable for French VAT. The analysis therefore depends on the place-of-supply and liability rules, not simply on the seller's country or the customer's delivery address.
For international B2B activity, the official examples include taxable sales or services from France to another non-established taxable person, non-exempt intra-Community acquisitions in France, and certain purchases in France from a supplier that is neither established nor registered for VAT in France. A non-established seller can also be liable for French VAT on specified French-situs supplies when its customer does not have a French VAT identification number.
The buyer or customer can instead carry the reporting obligation when French VAT is reverse charged to it. That distinction matters because the buyer-side date is 1 September 2027 regardless of company size. If your facts are uncertain, reconcile them with your French VAT returns and transaction ledger rather than classifying the business from its headline sales channel.
- Identify the company that is registered for French VAT and carries each transaction.
- Confirm whether that company has a French permanent establishment for VAT purposes.
- Determine where each supply takes place and who is liable for the French VAT.
- Separate seller or provider obligations from buyer or customer reverse-charge obligations.
Which e-reporting deadline applies
Use the table as a first decision aid. It follows the implementation timetable published by the French tax authority for foreign companies without a French VAT permanent establishment. A company can fall into more than one row because it may act as a seller for some transactions and as a reverse-charge buyer for others.
Micro-enterprises, VSEs and SMEs may opt into the seller-side system early from 1 September 2026. Early adoption should be coordinated with the selected platform, accounting data and VAT return process so that the same transaction is not omitted or reported twice.
| Situation | Start date | Immediate preparation |
|---|---|---|
| Large enterprise or intermediate-sized enterprise selling goods or providing services | 1 September 2026 | Map transaction and payment data, then choose an authorised platform before the start date. |
| Micro-enterprise, VSE or SME selling goods or providing services | 1 September 2027 | Prepare for the 2027 start, or coordinate a voluntary early start from 1 September 2026. |
| Buyer or customer liable for VAT on reverse-charge transactions or intra-Community acquisitions | 1 September 2027, regardless of size | Identify buyer-side reportable transactions and the identifiers needed by the platform. |
| Company not registered for French VAT or without a covered French VAT liability | Normally outside this DGFiP decision route | Verify the registration and liability facts before concluding that no reporting is required. |
This table is a screening tool, not a substitute for classifying each transaction under the French VAT rules.
Transactions included and excluded
International B2B transaction e-reporting can cover French-situs supplies for which the foreign seller or provider owes French VAT, non-exempt intra-Community acquisitions in France, and specified purchases from non-established suppliers. The data broadly follows the information required for e-invoicing. A company without a SIREN uses its intra-Community VAT number or, if it has none, a foreign tax identification number.
Not every international transaction belongs in the report. The DGFiP guidance excludes exports, intra-Community supplies, imports, and transactions that are both VAT exempt under the cited provisions and exempt from invoicing. It also describes exclusions for certain defence, security and legally confidential transactions. These exclusions should be applied to individual flows rather than to the whole company.
B2C reporting concerns French VAT transactions with non-taxable customers. The reported information is generally aggregated daily by VAT rate. The current guidance says transaction e-reporting does not apply to a non-established operator's B2C transactions when that operator is registered with an EU VAT One Stop Shop. See our OSS registration and returns service for the separate quarterly OSS process and its relationship with local French VAT obligations.
A useful control is to map the e-reporting population beside the VAT return, OSS return and accounting ledger. The categories should reconcile, but they do not have identical scopes or submission frequencies. Our EU VAT deadlines guide provides the broader filing context while this article focuses on the French data reform.
When payment data is also required
Payment e-reporting is a separate component. The official guidance covers services and advance payments for deliveries of goods when VAT becomes chargeable on receipt of payment. It can apply regardless of whether the customer is a business or a consumer and regardless of whether the customer is established in France or abroad.
The entity receiving the payment reports the collection date, the amount collected for each VAT rate and, where applicable, the invoice number. Payment reporting does not apply to transactions under the option to account for VAT on debits, and it does not apply to reverse-charge transactions reported by the customer.
This creates a data-quality requirement that goes beyond invoice export. A company may need reliable links between invoices, receipts, instalments, credit notes and VAT rates. Review how the accounting system records partial payments before deciding that an invoice file alone is sufficient for the platform.
How company size changes the start date
Seller and provider timing depends on the enterprise category. The DGFiP guidance assesses company size at 1 January 2025 using the last financial year ended before that date. If the company did not carry on business in that year, the first financial year ending from that date is used.
The assessment is made at legal-unit level, identified in France by a SIREN where one exists. Overall turnover is counted, including turnover generated outside France. A foreign group should not use only French revenue as a shortcut for deciding that its seller-side deadline is 2027.
Keep the calculation and evidence used to classify the entity. Workforce, annual turnover and balance-sheet totals all matter, and the rules determine when crossing a threshold moves the company into the next category. If group structures or incomplete accounts make the category uncertain, resolve that point before configuring the reporting start date.
A practical implementation plan
A subject company must choose an authorised platform before its applicable deadline. The platform transmits transaction and payment data to the tax authority. Use the current official list rather than assuming that an invoicing, ERP or accounting provider has the required French authorisation.
Begin with a scoped transaction inventory and a sample data reconciliation. Then compare platform coverage, integration method, validation controls, error handling and price. Our pricing page shows the VAT compliance services we provide, but platform charges and technical integration can depend on the selected operator and transaction volume.
Treat e-reporting as part of the VAT control environment rather than a stand-alone technology project. Ownership should be clear for source data, platform submissions, rejected records, VAT return reconciliation and retained evidence. Contact our VAT team with the legal entity, French VAT number, transaction types, 2025 size evidence and accounting-system details for a focused scope review.
- Confirm the entity, French VAT registration and establishment position.
- Classify seller, buyer, B2B, B2C and payment-data flows separately.
- Document the company-size assessment and applicable start date.
- Select an authorised platform and test the required identifiers and data fields.
- Reconcile reported data to VAT and OSS returns, then retain submission and correction evidence.
Official sources
Last reviewed 29 July 2026. Rules and operational procedures can change, so confirm the current position for your exact products and sales flows.
- DGFiP: E-reporting requirements for foreign companies without a permanent establishment in France
- DGFiP decision tree for foreign companies without a permanent establishment
- DGFiP: E-reporting transaction data specification
- DGFiP: E-reporting payment data specification
- DGFiP: E-reporting transaction and payment transmission frequencies
- DGFiP: Electronic invoicing and authorised platforms
- DGFiP list of authorised platforms