France: How does the 2026 e-reporting system work for foreign companies subject to VAT?

The electronic invoicing reform in France is gradually entering its operational phase. While the e-invoicing obligation mainly concerns domestic operations between companies established in France, e-reporting also applies to foreign companies with a French VAT number.

From September 1, 2026, foreign companies subject to VAT in France must transmit certain transaction and, in some cases, payment data to the French tax administration as part of the new e-reporting system.

This development constitutes a major change in the management of VAT-related reporting obligations.

Who is affected? Which operations must be declared? What are the risks in case of non-compliance? How can you prepare for this new tax obligation?

Here is everything foreign companies need to know about e-reporting in France.

What is e-reporting in France?

E-reporting is an electronic tax data transmission system intended for the French administration.

It complements the mandatory electronic invoicing system (e-invoicing) implemented as part of the VAT reform. Its objective is to allow the tax administration to have a more comprehensive view of the economic operations carried out on French territory.

Unlike e-invoicing, which relies on the exchange of electronic invoices between companies established in France, e-reporting concerns operations that cannot be covered by this mechanism.

The transmitted data allows, in particular:

• strengthening the fight against VAT fraud;
• preparing for the future pre-filling of French VAT returns;
• facilitating tax audits;
• increasing the quality of data collected by the administration;
• modernizing exchanges between companies and the State.

“The goal is to better read economic activity in real time, reduce blind spots, and strengthen the fight against fraud, particularly regarding VAT.”
Sébastien Rabineau – DGFiP (General Directorate of Public Finances)¹

E-invoicing vs e-reporting: What is the difference?

The French electronic invoicing reform that will come into effect from September 1, 2026, is based on two distinct pillars:

• e-invoicing (electronic invoicing);
• e-reporting.

E-reporting itself is broken down into two categories:

• transaction e-reporting;
• payment data e-reporting.

This distinction is particularly important for foreign companies with a French VAT number.

Indeed, unlike companies established in France, foreign companies without a permanent establishment in France are not subject to the obligation to issue or receive electronic invoices via the French e-invoicing system.

The legislator has reserved this obligation for operations carried out between companies established within French territory.

Thus, a German, Italian, Spanish, British, or American company that simply has a French VAT number will not have to receive or issue French electronic invoices under e-invoicing.

However, this same company may be concerned by the e-reporting obligation as soon as it carries out certain taxable operations in France.

The DGFiP has, moreover, published a page² dedicated to e-reporting obligations for foreign companies without a permanent establishment in France, confirming that these companies may be concerned by data transmission when they carry out operations subject to French VAT.

This distinction is one of the most important points of the reform for non-resident companies.

Obligation	Company established in France	Foreign company not established in France but identified for French VAT
Receipt of electronic invoices	Yes	No
Issuance of electronic invoices	Yes	No
Transaction e-reporting	Yes (extended depending on operations)*	Yes (limited depending on operations)**
Payment e-reporting	Yes (extended depending on operations)*	Yes (limited depending on operations)**

* Yes (extended): obligation covering all operations concerned by the reform.
** Yes (limited): obligation limited to certain operations carried out by companies not established in France but identified for French VAT.

For foreign companies registered for French VAT, e-reporting therefore constitutes the main obligation resulting from the 2026 electronic invoicing reform.

Who is affected by e-reporting in France in 2026?

This applies to foreign companies registered for VAT in France and carrying out taxable transactions within the country.

This includes in particular:

• companies storing goods in France;
• companies making domestic sales in France;
• foreign e-commerce retailers or marketplace operators, excluding OSSs;
• businesses making intra-Community or domestic purchases under the reverse charge mechanism.

“This far-reaching reform of the economy is an opportunity for businesses to take a step back and reassess how they operate.”
Laure Collignon – DGFiP – French Public Finance Directorate (Business Support Unit)³

What is the e-reporting timetable for foreign companies not established in France?

The schedule applicable to foreign companies follows the same deadlines as those set for the electronic invoicing reform.

Date	Requirement
1 September 2026	E-reporting for large enterprises (GE) and medium-sized enterprises (ETI)
1 September 2027	Extension to small and medium-sized enterprises (SMEs), very small enterprises (VSEs) and micro-enterprises

The date of entry into force depends on the size of the company, not its nationality.

How to determine the size of the company?

The size of the company is assessed as of January 1, 2025.

The analysis is based on the last financial year closed before this date or, failing that, on the first financial year closed after it.

A foreign company will be subject to e-reporting from 1 September 2026 if it meets at least one of the following criteria:

Criteria	Threshold
Number of employees	250 employees or more
Turnover	More than 50 million euros
Balance sheet total	More than 43 million euros

Which transactions will be subject to transaction e-reporting?

Article 290 II of the French General Tax Code (Code général des impôts) stipulates that taxable entities not established in France must submit specific information to the tax authorities regarding transactions carried out in France when they are liable for French VAT.

As of 1 September 2026, the scope concerns taxable supplies of goods and services in France made to:

• Taxable entities (B2B) not identified for VAT purposes in France;
• Non-taxable entities (B2C).

This obligation applies when the transactions are not already covered by a One-Stop Shop (OSS) scheme (EU-OSS or non-EU OSS).

From 1 September 2027, the scope will be extended to include transactions subject to the reverse charge mechanism (intra-Community acquisitions and domestic purchases subject to the reverse charge).

Examples of transactions subject to e-reporting for non-resident companies

The most frequent cases are as follows:

Operation	E-reporting transaction	E-reporting payment	Large/Mid-cap	SME/Micro
Sale of goods taxable in France (excl. OSS)	Yes	If down payment	09/26	09/27
Sale of services taxable in France (excl. EU/non-EU OSS)	Yes	Yes	09/26	09/27
Intra-Community supply	No	No	—	—
Intra-Community acquisition	Yes	No	09/27	09/27
Exports	No	No	—	—
Sales under reverse charge (Art. 283-1 para. 2 CGI)	No	No	—	—
Purchases under reverse charge (Art. 283-1 para. 2 CGI)	Yes	No	09/27	09/27
Subcontracted construction service sales (Art. 283-2 nonies CGI)	No	No	—	—
Subcontracted construction service purchases (Art. 283-2 nonies CGI)	Yes	No	09/27	09/27
Import of goods	No	No	—	—
Intra-Community distance sales (OSS)	No	No	—	—
Exempt operations	No	No	—	—

Which operations are excluded from the system?

Not all transactions are affected.

In particular, foreign companies must not submit:

• exempt intra-community deliveries;
• exports outside the European Union;
• distance sales reported via the OSS;
• certain transactions covered by special schemes that are already subject to other reporting mechanisms.

These transactions are still reported via the usual tax channels but do not fall within the scope of e-reporting.

In which cases should payment data not be transmitted?

Two main situations allow you to avoid this obligation:

The company has opted for VAT on debits

In this case, VAT is due as soon as the invoice is issued and not upon receipt of payment.

La transmission des données de paiement n’est alors pas requise.

The customer is liable for VAT

When the reverse charge mechanism applies, the supplier is not liable for VAT.

Les données d’encaissement n’ont donc pas à être déclarées.

What data must be transmitted as part of e-reporting?

The data required by the authorities mainly relates to transactions and payments.

The exact content depends on the nature of the transactions carried out.

E-reporting of B2C transactions

Data to be transmitted	Description
Supplier SIREN	Identifier of the reporting company
Period	Period covered by the declaration
Current date	Date of transmission
Number of transactions	Total transactions carried out
Transaction category	Goods, services, intra-Community operations, or margin VAT
Amount excl. VAT	Total daily transactions excluding tax
VAT amount	Corresponding VAT, by rate
Tax on debit option	Where applicable

E-reporting of B2B transactions

Data to be transmitted	Description
Supplier SIREN or VAT number	Seller identification
Customer SIREN or VAT number	Buyer identification
Supplier’s country	Country of establishment
Customer’s country	Country of establishment
Nature of the transaction	Sale of goods (LB), supply of services (PS), or mixed (LBPS)
Invoice date	Date of invoicing
Invoice number	Invoice reference
Total excl. VAT by rate	Amounts excl. tax broken down by VAT rate
VAT amount by rate	VAT broken down by rate
VAT rate	Applied rates
Total excl. VAT of the invoice	Total excluding tax
Total VAT of the invoice	Total VAT
Currency	Currency used
Fiscal representative number	If applicable
Reference of corrected invoice	In case of credit note or correction
Tax on debits option	Where applicable
Reference to VAT exemption	If applicable
Reference to a special scheme	Example: Margin VAT
Date of delivery or completion of service	Date the transaction was carried out
Down payment date	If different from the invoice date
Specific mentions	Reverse charge, self-billing, or single taxable person

E-reporting of payments (non-resident companies)

B2C payments

Data to be transmitted
SIREN of the collecting entity
Current date
Total amount collected by VAT rate
Period covered

B2B payments

Data to be transmitted
SIREN of the collecting entity
Current date
Total amount collected by VAT rate
Period covered
Invoice number

The tax authorities have established standardised submission formats to ensure the consistency of the data collected.

Companies will therefore need to ensure the quality of the information generated by their accounting and ERP systems.

How often do you need to submit e-reporting data under your VAT scheme?

The France 2026 reform requires two distinct types of data to be submitted: transaction data and payment data. The requirements vary depending on your VAT regime.

Standard monthly tax regime

For transaction data:

Businesses subject to the standard monthly tax regime must submit transaction data every ten days and payment data on a monthly basis.

Quarterly standard tax regime

For transaction and payment data:

Businesses subject to the standard quarterly tax regime must submit transaction and payment data on a monthly basis.

The detailed deadlines are set out in the table below:

VAT Scheme	Transmission of transaction data		Transmission of payment data
	Submission frequency	Submission deadline	Submission frequency	Submission deadline
Standard monthly regime	3 submissions per month (per ten-day period): – Period 1: from the 1st to the 10th – Period 2: from the 11th to the 20th – Period 3: from the 21st to the end of the month	10 days after the end of the ten-day period: i.e., the 20th, 30th of the month and the 10th of the following month. *except for February	Monthly	Before the 10th of the following month
Standard quarterly regime	Monthly	Before the 10th of the following month	Monthly	Before the 10th of the following month

What penalties apply for non-compliance with e-reporting?

Failure to comply with reporting obligations is punishable under Article 1788 D I and II of the French General Tax Code⁴.

The tax authorities may impose:

• a fine of €500 for each missing or incorrect report;
• up to a maximum of €15,000 per calendar year.

How to prepare your company for the 2026 deadline?

E-reporting represents a significant step in the modernisation of the French tax system. Foreign companies with a VAT number in France would be well advised to start preparing now to ensure they remain compliant and safeguard their operations in the French market.

Preparations must begin well before the obligations come into force, as compliance projects generally require several months’ work.

This process generally involves several stages:

• mapping transactions subject to French VAT;
• verifying the quality and reliability of the data used;
• adapting systems (ERP, accounting software, management tools) to generate the required information;
• selecting a suitable partner to ensure compliance.

Conversely, waiting until the last few months can generate:

• additional costs;
• technical difficulties;
• risks of non-compliance;
• delays in transmissions.

Why must foreign companies use an approved platform?

Unlike certain current reporting obligations, e-reports cannot be submitted directly to the tax authorities.

The foreign companies concerned must use an approved platform (PA) (or, in other words, a partner digitalisation platform (PDP)), which will ensure:

• data collection;
• consistency checks;
• format conversion;
• secure transmission to the tax authorities.

Choosing a technical partner is therefore a strategic decision for non-resident businesses.

A thorough analysis of French VAT flows, reporting obligations and existing information systems is essential to ensure compliance ahead of the 2026 and 2027 deadlines.

ASD Group supports you in ensuring your e-reporting compliance

In this context, ASD Group supports non-resident companies registered for French VAT in identifying their obligations and implementing e-reporting in practice.

As e-reporting data must be submitted via an approved platform (PA), ASD Group has entered into a partnership with one such platform in order to offer its clients a solution that complies with the requirements of the French tax authorities.

Sources :

1. itforbusiness.fr (in French) ↩︎
2. DGFiP Note (in English) ↩︎
3. aucoeurduchr.fr (in French) ↩︎
4. Article 1788 D I and II of the French General Tax Code (in French) ↩︎

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