Regulatory Update | June 2026
The French tax authorities have issued new guidance clarifying how the country’s upcoming e-reporting regime will apply to foreign businesses registered for VAT in France.
While foreign companies without a permanent establishment in France will generally remain outside the scope of France’s domestic B2B e-invoicing requirements, they may still be required to submit transaction and payment data where they undertake activities subject to French VAT.
The clarification forms part of France’s broader e-invoicing and e-reporting reform, which begins to take effect from September 1, 2026.
Key Developments
The guidance confirms that:
- France’s mandatory B2B e-invoicing regime applies only to transactions between VAT-taxable persons established in France.
- Foreign businesses without a French establishment will generally not be required to issue or receive French electronic invoices.
- Foreign VAT-registered businesses may nevertheless be subject to e-reporting obligations where they carry out transactions that are taxable in France.
- The rollout of e-reporting obligations will begin on September 1, 2026, for large and intermediate-sized enterprises, with SMEs and micro-enterprises joining from September 1, 2027.
- Businesses acting as VAT-liable customers will also become subject to certain reporting obligations from September 1, 2027, including transactions subject to reverse charge rules and intra-Community acquisitions.
Transactions Potentially Within Scope
Depending on the circumstances, e-reporting requirements may apply to:
- Supplies of goods or services taking place in France where French VAT is due.
- Taxable intra-Community acquisitions made in France.
- Transactions where a French VAT registration is used and reporting obligations arise under French VAT rules.
- Certain B2C transactions subject to French VAT.
Businesses using the EU One Stop Shop (OSS) regime for B2C reporting will generally be exempt from transaction-level e-reporting for those sales.
Reporting Platform Requirements
Foreign businesses required to comply with the new regime will need to transmit relevant transaction and payment data through a certified and accredited platform approved by the French tax authorities.
Business Impact
Foreign VAT-registered businesses with activities giving rise to French VAT obligations should assess whether they fall within the scope of the new e-reporting requirements and begin evaluating the systems, processes, and reporting infrastructure needed to comply with the phased implementation timetable.
Early preparation will be particularly important for organizations with complex cross-border transactions, French VAT registrations, or significant transaction volumes.