French e-reporting obligations for non-established businesses

In the context of the rollout of France’s e-invoicing and e-reporting reform, the French tax authorities have issued new guidance on e-reporting obligations for non-established businesses.

While mandatory e-invoicing only applies to transactions between VAT taxable persons established in France, non-established companies (without a fixed establishment in France) fall outside this obligation.

However, such companies may be subject to e-reporting obligations if they carry out certain transactions subject to French VAT. In some cases, these e-reporting requirements do not only concern transaction data, but also include payment data.
 

Implementation timeline

The e-reporting requirements will be rolled out in phases:

• 1 September 2026: large enterprises and intermediate-sized enterprises (ISEs) that sell goods or provide services;
• 1 September 2027: micro-enterprises, very small enterprises (VSEs) and small- and medium-sized enterprises (SMEs) that sell goods or provide services;
• 1 September 2027: enterprises in their capacity as buyers or customers liable for VAT (reverse charge transactions and intra-Community acquisitions), regardless of company size.

Early voluntary opt-in is possible for micro-enterprises, VSEs and SMEs as from 1 September 2026.
 

Recommended actions

Although non-established businesses are excluded from French e-invoicing, they may still be subject to broad e-reporting requirements in France.

Non-established businesses should assess the impact of these new French e-reporting requirements by:

• Identify if your organization carries out transactions deemed to take place in France and, if so, which types of transactions (e.g. B2B/B2C, local/cross-border, with VAT charged, exempt or subject to reverse charge, intra-Community acquisitions, etc.);
  
  
• Analyze whether the respective transactions fall within scope of e-reporting;
  
  
• Determine which party is required to fulfil the e-reporting obligations for the respective transaction (cf. the supplier or the customer);
  
  
• Assess system readiness by ensuring that required transaction data & payment data can be extracted and reported in the required format and frequency;
  
  
• Select an authorized Partner Dematerialization Platform (PDP), which will transmit data to the French tax authorities, ahead of the go-live date;
  
  
• Consider early implementation to reduce operational risks.

Our experts remain available to assist with assessing whether your organization falls within the scope of French e-reporting, mapping transactions, identifying reporting obligations, supporting PDP selection and implementing compliant reporting processes.