France is moving full speed towards mandatory eInvoicing and eReporting. For international businesses trading with or in France, the changes are critical and time-critical.

On 10 February 2026, the French Tax Office responsible for non-established VAT registrations and refunds hosted a webinar to clarify how the new eInvoicing  and eReporting mandate rules will apply in practice. The session focused heavily on non-established businesses, reverse charge transactions and cash-based VAT reporting.

eInvoicing vs eReporting in France

France’s reform introduces two related but distinct obligations:

  • eInvoicing: The structured electronic exchange of invoices between businesses established in France
  • eReporting: The transmission of transaction and payment data to the French tax authorities for certain transactions that fall outside B2B eInvoicing

eReporting is particularly relevant for:

  • Cross‑border transactions
  • Sales to foreign customers
  • Transactions subject to VAT on a cash basis

Many non‑established businesses will not be required to issue French eInvoices, but they may still have eReporting obligations.

Sales under the reverse charge: Still reportable

A key question raised during the webinar concerned sales to French VAT‑registered customers where the reverse charge applies.

Under Article 283‑1 of the French Tax Code (Code général des impôts, CGI), the customer accounts for VAT rather than the supplier. Some businesses assumed this would exclude the transaction from eReporting.

The French Tax Office confirmed this is not the case.

What was clarified

Sales made by non‑established sellers to customers registered for VAT in France, where VAT is due under the reverse charge, are not excluded from eReporting.

When does this apply?

The start date depends on the size of the non‑established seller:

  • Large companies: eReporting obligation starts on 1 September 2026
  • All companies, regardless of size: obligation applies from 1 September 2027

Importantly, from September 2027 onwards, the buyer’s location no longer matters. If you fall within scope, the transaction must be reported.

Article 44 services: No payment data reporting required

Another area of uncertainty concerned services supplied under Article 44 of the EU VAT Directive. These are B2B services taxed where the customer is established and usually subject to the reverse charge.

The confirmed position

Companies established in France that supply Article 44 services to:

  • EU customers, or
  • Non‑EU customers

Do not need to electronically report payment data for these services. Why?

The French Tax Office pointed to Article 290 A of the CGI, which governs electronic transmission of payment data.

This provision only applies to transactions where:

  • VAT is due upon collection of payment, and
  • VAT is not taxed at the recipient’s location

Because Article 44 services are taxed at the customer’s location under the reverse charge, they fall outside this payment reporting requirement.

Cash receipt transactions and foreign customers

The webinar also addressed whether cash‑based VAT transactions must be e‑reported when the customer is a foreign company.

The key takeaway

The customer’s location does not automatically remove the eReporting obligation.

If:

  • VAT is due upon receipt of payment, and
  • The transaction otherwise falls within scope

then eReporting may still be required, even if the recipient is established outside France.

This is a critical point for non‑established businesses that apply cash accounting or receive advance payments.

Platform registration: Mandatory even without eInvoicing

One of the most practical clarifications related to platform registration.

France requires businesses to use an approved Partner Dematerialisation Platform (PDP) to transmit eInvoicing and eReporting data.

Who must register?

Companies without a permanent establishment in France must still register with an approved platform, even if:

  • They are not required to issue French eInvoices, and
  • Their only obligation is eReporting

Registration deadlines

The deadlines again depend on company size:

  • Large and mid‑sized non‑established companies: Must select an approved platform by 1 September 2026
  • SMEs, small businesses and micro‑enterprises: Deadline postponed to 1 September 2027

The tax authorities strongly recommend early registration to avoid delays once reporting obligations go live.

Penalties for non-compliance

France has confirmed that non‑compliance with eReporting obligations will be subject to financial penalties.

Under Articles 1788 DI and 1788 D II of the CGI:

  • A fine of €500 per transmission applies
  • The total penalty is capped at €15,000 per calendar year

Is there a grace period?

There is no formal grace period written into the legislation.

However, the French Tax Office indicated that a tolerance period is expected during the first months following implementation, allowing businesses time to adapt their systems and processes.

This tolerance should not be relied upon as a compliance strategy. The fines are real, and enforcement is coming.

Who should act now?

Based on the webinar clarifications, the following groups should already be preparing:

  • Non‑established businesses with a French VAT registration
  • Businesses making reverse charge sales to French VAT‑registered customers
  • Companies applying cash‑based VAT accounting
  • Groups operating across multiple jurisdictions with centralised billing or ERP systems

Even businesses that believed they were “out of scope” for French eInvoicing may still face eReporting and platform registration obligations.

The French reform is not just a technical change. It affects:

  • Transaction mapping and VAT determination
  • Invoice and payment data flows
  • ERP and billing system configuration
  • Ongoing compliance monitoring

Missing a reporting obligation because a transaction is reverse charged or cross‑border is no longer a safe assumption.

Final thoughts

France’s eInvoicing and eReporting mandate is fast approaching, and the latest guidance makes one thing clear: non‑established businesses are firmly in scope.

If you trade with France, hold a French VAT registration or apply cash accounting, now is the time to:

  • Confirm which transactions require eReporting
  • Identify your applicable start date
  • Select and onboard an approved platform well ahead of the deadline

As always, clarity and preparation are your best tools for staying compliant in an increasingly digital VAT landscape.

If you want to explore how platforms like Fintua eInvoice can support cross‑border eReporting and future‑proof your VAT compliance, this is the moment to start the conversation.

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Authors

101094France B2B eInvoicing and eReporting: What global businesses need to know

Lisa Dowling

Chief Tax & Compliance Officer at Fintua

Specialising in International VAT Compliance solutions, Lisa brings a wealth of knowledge and insight in her dealings with a host of international clients ranging from start-ups through to multinationals. With 21 years VAT experience behind her, Lisa has managed VAT compliance issues and solutions globally for over 11 years. Fintua have 12,000 + corporate clients in over 109 countries and many of these are members of the Fortune 500.