France e-Reporting for Foreign Companies: What Applies, and From When

The short version

France switched on its e-invoicing reform on 1 September 2026. Every business in scope must now be able to receive electronic invoices, and large and intermediate-sized companies must issue them as well. Smaller businesses have until 1 September 2027 to start issuing e-invoices and sending transaction data to the tax authority, as the Ministry for the Economy sets out.

For companies based outside France that hold a French VAT number, this raises an obvious question: does any of it apply to us? The short answer is that e-invoicing probably does not. A separate obligation called e-reporting may well apply, however, and it reaches further than much of the commentary suggests.

What decides whether e-invoicing applies

The French tax authority (DGFiP) is clear on this. E-invoicing covers transactions carried out in France between VAT-taxable businesses established in France. It therefore does not apply to foreign companies that have no permanent establishment in France within the meaning of VAT, and those companies are not required to issue or receive e-invoices.

It is tempting to read "no establishment" as "no office in France". The DGFiP says the concept must be understood within the meaning of VAT, as set out in its official guidance, the BOFiP.

At EU level, VAT rules describe a fixed establishment as one with a sufficient degree of permanence and a suitable structure in terms of human and technical resources. The same rules state that having a VAT identification number is not in itself enough to create a fixed establishment.

If your business has people, equipment or other resources in France on a lasting basis, confirm your status with a VAT adviser before assuming you are outside e-invoicing.

What you can stop worrying about

If your company is not established in France, the DGFiP's guidance settles two points that often cause confusion.

The e-invoicing directory. The directory is a central database, managed by the tax authority, that makes sure invoices reach the right recipient through their approved platform. The DGFiP says it is intended only for companies subject to e-invoicing. Some foreign companies that have a SIREN number (the French business identification number) do appear in it, but being listed does not mean a company is subject to e-invoicing or e-reporting. A foreign company that only has e-reporting obligations as a supplier does not need to be listed at all. Whether or not your company appears when you search the directory, the result tells you nothing about your obligations.

Receiving e-invoices. Because you are not required to receive e-invoices, you do not need to choose a platform to receive them. If you and a French trading partner want to exchange e-invoices voluntarily, the DGFiP suggests contacting your existing provider or a provider on a network such as Peppol, and agreeing the arrangements between you. In its February 2026 presentation for foreign companies, the DGFiP adds that a company wanting to receive invoices does need to be listed in the directory.

What e-reporting covers

E-reporting means sending the tax authority certain details about transactions that fall outside e-invoicing, such as the amount of a transaction and the VAT charged. The data is not sent as each transaction happens. It is sent at intervals that depend on your VAT arrangements, and no transmission is required for a period with no transactions to report.

The DGFiP confirms that foreign companies without an establishment in France have e-reporting obligations when they carry out transactions that take place in France and they are liable for French VAT.

The obligation does not cover everything a foreign company does in France. The DGFiP ties it to who is liable for the VAT: where the customer is liable, the customer is responsible for the e-reporting.

Exports and intra-Community supplies are exempt from VAT and excluded from e-reporting. Imports are also excluded.

When e-reporting starts

When your obligations as a seller start depends on the size of your company. Large and intermediate-sized companies that sell goods or provide services have been subject to e-reporting since 1 September 2026. Micro, small and medium-sized companies follow on 1 September 2027, although they can choose to start earlier.

The DGFiP states that size is assessed on the company's global operations rather than on its activity in France alone. Size is assessed for each legal entity as at 1 January 2025, based on the last financial year that ended before that date. A company with very little French business can therefore already be in scope if it is large overall.

The DGFiP defines SMEs as companies with fewer than 250 employees and either annual turnover of no more than EUR 50 million or a balance sheet total of no more than EUR 43 million. Its FAQ sets out how these combine: a company with 250 or more employees is outside the SME category whatever its accounts show, and a company below 250 employees leaves it only if its turnover and its balance sheet total are both above the thresholds.

Purchases as well as sales

From 1 September 2027, foreign companies of any size must e-report certain purchases where they, as the buyer, are liable for the VAT. This covers reverse charge transactions, where the buyer accounts for the VAT instead of the seller, and intra-Community acquisitions, meaning goods bought from a supplier in another EU country.

The DGFiP states that no e-reporting is required for these purchases between 1 September 2026 and 1 September 2027.

When payment data is also needed

For services, and for advance payments on goods, VAT can become due when payment is received. In these cases, the business that receives the payment must also report payment data, such as the date of collection and the amount collected for each VAT rate.

This does not apply to reverse charge transactions, or where a company has opted to pay VAT on debits (on an invoice basis).

Choosing a platform

Foreign companies without an establishment in France that are subject to e-reporting must choose an approved platform (plateforme agréée) to send their data to the tax authority. The choice must be made before the date the obligation begins, either 1 September 2026 or 1 September 2027. The DGFiP publishes the list of approved platforms on impots.gouv.fr, in French.

Companies can instead use a compatible software solution, provided it is connected to at least one approved platform.

Where a company is required to appoint a tax representative, that representative is responsible for e-reporting. A company can also appoint an agent, but it keeps responsibility for e-reporting.

Penalties and the start-up period

Under the version of the French General Tax Code in force in 2026, failing to meet e-reporting obligations carries a fine of EUR 500 per transmission, up to a maximum of EUR 15,000 per calendar year. The version of the article that Légifrance shows as applying from 1 January 2027 sets the fine at EUR 250 per transmission, with an annual cap of EUR 15,000.

The law and official statements limit when the fine applies, as the table below shows. The DGFiP stresses that its start-up approach is neither a postponement nor a suspension of the obligations, and its start-up guide states that the calendar remains applicable.

Which lane are you in?

Three questions will show you where you stand.

Are we established in France for VAT purposes? If so, the e-invoicing rules are likely to apply to you, and specialist advice is worthwhile. If not, e-invoicing does not apply, but move on to the next two questions.

How large are we worldwide? For large and intermediate-sized companies, e-reporting on sales has applied since 1 September 2026. For SMEs, it starts on 1 September 2027.

Who owes the VAT on each type of French transaction? Map your sales and purchases in France. Wherever your company is liable for French VAT, check whether the transaction needs to be reported and from which date.

On 1 September 2027, smaller French businesses start issuing e-invoices and buyer-side e-reporting begins for foreign companies. More businesses will need answers to these questions over the coming year. The sooner you confirm your position, the more time you have to choose a platform and get your data ready.

Official sources

For questions about your own situation, the DGFiP runs a tax helpline for non-residents on +33 1 72 95 20 31, Monday to Friday from 9am to 4pm.

This article provides general information based on official guidance available on the date of publication. It is not tax or legal advice.