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

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

From 1 September 2026, foreign companies subject to VAT in France will be required to transmit certain transaction data and, where applicable, payment data to the French tax authorities as part of the new e-reporting system.

This development represents a major change in the management of VAT reporting obligations.

Which companies are affected? Which transactions must be reported? What are the risks of non-compliance? How can you prepare for this new tax requirement?

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

What is e-reporting in France?

E-reporting is an electronic system for transmitting tax data to the French administration.

It complements the mandatory e-invoicing system introduced as part of the VAT reform. Its purpose is to give the French tax authorities a more comprehensive view of economic transactions carried out in France.

Unlike e-invoicing, which is based on the exchange of electronic invoices between businesses established in France, e-reporting covers transactions that cannot be covered by this system.

The data transmitted is used in particular to:

• strengthen the fight against VAT fraud;
• prepare for the future pre-filling of French VAT returns;
• facilitate tax audits;
• improve the quality of the data collected by the administration;
• modernise exchanges between businesses and public authorities.

“The objective is to gain a better understanding of economic activity in real time, reduce blind spots and strengthen the fight against fraud, particularly VAT fraud.”
Sébastien Rabineau – French tax authorities (DGFiP) (Directorate-General for Public Finance)¹

E-invoicing and e-reporting: what are the differences?

The French e-invoicing reform, which will enter into force on 1 September 2026, has two distinct components:

• e-invoicing;
• e-reporting.

E-reporting itself is divided into two categories:

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

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

Unlike companies established in France, foreign companies without a permanent establishment in France are not required to issue or receive electronic invoices through the French e-invoicing system.

The legislator has reserved this requirement for transactions carried out between businesses established in France.

Thus, a German, Italian, Spanish, British or US company that only has a French VAT number will not be required to receive or issue French electronic invoices under e-invoicing.

However, the same company may be subject to the e-reporting requirement where it carries out certain transactions taxable in France.

The French tax authorities (DGFiP) have also published a page² dedicated to the e-reporting requirements of foreign companies without a permanent establishment in France, confirming that these companies may be subject to data transmission when they carry out transactions subject to French VAT.

For non-resident companies, this distinction is one of the key aspects of the reform.

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

For foreign companies registered for French VAT, e-reporting is therefore the main requirement arising from the 2026 e-invoicing reform.

Who is subject to e-reporting in France in 2026?

This requirement applies to foreign companies registered for French VAT that carry out transactions taxable in France.

These include in particular:

• companies holding stock in France;
• companies making domestic sales in France;
• foreign e-commerce sellers or marketplace operators, excluding businesses using OSS;
• companies carrying out intra-EU acquisitions or domestic purchases subject to the reverse charge mechanism.

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

What is the e-reporting timetable for companies established outside France?

The timetable applicable to foreign companies follows the same deadlines as those provided for under the e-invoicing reform.

The effective date depends on the size of the company, not its nationality.

How is the size of the company determined?

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

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

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

Which transactions will be subject to transaction e-reporting?

Article 290 II of the French General Tax Code provides that taxable persons established outside France must provide specific information on their transactions to the French tax authorities when their activities in France are subject to French VAT.

From 1 September 2026, the system applies to supplies of goods and services taxable in France made to:

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

This requirement applies where the transactions are not already reported under a One Stop Shop (OSS) scheme (EU OSS or non-EU OSS).

From 1 September 2027, the scope will be extended to transactions subject to the reverse charge mechanism, including intra-EU acquisitions and domestic purchases subject to reverse charge.

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

The most common cases are as follows:

Which transactions are excluded from the system?

Not all transactions are covered.

In particular, foreign companies do not have to report:

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

These transactions continue to be reported under the usual tax procedures, but are outside the scope of e-reporting.

In which cases must payment data not be transmitted?

Two main situations make it possible not to apply this requirement:

The company has opted for VAT on a cash basis

In this case, VAT becomes due when the invoice is issued rather than when payment is received.

Payment data transmission is therefore not required.

The customer is liable for VAT

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

Collection data therefore does not have to be reported.

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

The data required by the administration mainly concerns transactions and payments.

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

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B2C transaction e-reporting

B2B transaction e-reporting

Payment e-reporting (non-resident companies)

B2C payments

B2B payments

The French tax authorities have defined standardised transmission formats to ensure the consistency of the data collected.

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

How often must you transmit e-reporting data according to your VAT scheme?

The 2026 French reform provides for the transmission of two distinct categories of data: transaction data and payment data. The requirements vary according to your VAT scheme.

Monthly standard VAT scheme

For transaction data:

Companies under the monthly standard VAT scheme must transmit transaction data every ten days and payment data once a month.

Quarterly standard VAT scheme

For transaction and payment data:

Companies under the quarterly standard VAT scheme must transmit transaction and payment data every month.

The detailed deadlines are shown in the table below:

What penalties apply in the event of non-compliance with e-reporting obligations?

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

The French tax authorities may impose:

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

How can you prepare your company for the 2026 deadline?

E-reporting is an important step in the modernisation of the French tax system. Foreign companies with a French VAT number must start preparing now to remain compliant and safeguard their activities in the French market.

Preparations should begin well before the requirements come into force, as compliance projects generally require several months of work.

This process generally involves several steps:

• identify and map transactions subject to French VAT;
• check the quality and reliability of the data used;
• adapt systems (ERP, accounting software, management tools) to generate the required information;
• choose a suitable partner to ensure compliance.

Conversely, waiting until the final months may result in:

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

Why must foreign companies use an approved platform?

Unlike certain current reporting obligations, e-reporting data cannot be transmitted directly to the French tax authorities.

Foreign companies concerned must use an approved platform (PA) (in other words, a partner dematerialisation platform (PDP)), which will provide:

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

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

An in-depth analysis of French VAT flows, reporting obligations and existing information systems is essential to ensure compliance before the 2026 and 2027 deadlines.

ASD Group supports you with your e-reporting compliance

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

As e-reporting data must be transmitted via an approved platform (PA), ASD Group has partnered with such a platform to offer its clients a solution that complies with the requirements of the French tax authorities.

Sources:

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