E-invoicing in France 2026-2027 – electronic invoicing and reporting for foreign companies
The French e-invoicing reform entered its first phase on September 1, 2026. However, the most important piece of information for foreign companies is this: a French VAT number alone does not mean that you are obligated to issue French e-invoices.
If a company is based in Poland, for example, and has a French VAT number but does not have a fixed establishment in France for VAT purposes (établissement stable), it is generally not subject to electronic invoicing (e-invoicing). However, it may be subject to electronic reporting (e-reporting) of transactions and, in some cases, payments.
E-invoices in France – two different mechanisms
The French reform separates the electronic circulation of domestic B2B invoices from the transmission of data on other transactions to the administration.
Electronic invoicing (e-invoicing)
Mandatory electronic issuance, transmission and receipt of invoices for certain B2B transactions between taxpayers established in France.
Electronic reporting (e-reporting)
Transmission to the French administration of data on transactions not covered by national electronic invoicing and payment data in cases specified by law.
| Situation | Electronic invoicing | Electronic reporting |
|---|---|---|
| B2B between taxpayers established in France | Yes, if the transaction is within the scope of the reform | Data is transferred in the system |
| Foreign company with only FR VAT, without a permanent place of business | As a rule, no | It may occur |
| Inland waterways settled by a foreign company in France | NO | Yes, according to the buyer's schedule |
| Local B2C sales subject to French VAT | NO | May be subject to electronic reporting |
| B2C settled in the appropriate EU VAT OSS | NO | It is planned to exclude these operations from reporting |
| Import of goods | NO | Excluded from transaction reporting |
| Export and exempt ICT | NO | Excluded from electronic reporting |
| VAT is settled by the buyer under the reverse charge (French: autoliquidation) | Not on the side of an unestablished seller | The obligation may arise on the part of the buyer |
Since when have e-invoicing and electronic reporting been in force in France?
The reform has been divided into two main stages: September 1, 2026 and September 1, 2027. For a foreign company without a permanent establishment, the role of the seller or buyer is also important.
Large enterprises and ETI as sellers or service providers
Start of electronic reporting for foreign large companies and ETIs performing covered transactions as sellers or service providers.
SMEs, TPEs and micro-enterprises as sellers
Electronic reporting has begun for smaller foreign businesses operating as sellers or service providers. They can voluntarily begin reporting as early as September 1, 2026.
Buyers liable for French VAT
Start for foreign buyers and service recipients, including for intra-Community acquisitions of goods and certain transactions covered by the reverse charge, regardless of the size of the company.
Is my company subject to the French reform?
First, determine the company's VAT status, and only then the type of transaction and the role of the company.
Analyze electronic invoicing
Check whether a specific B2B transaction is within the scope of the national system and from when the company is obliged to issue and receive e-invoices.
Check transactions that trigger reporting obligations
Does your company make sales, intra-Community acquisitions, purchases subject to the reverse charge or local B2C sales in France that result in the obligation to settle French VAT?
Does a Polish company with a FR VAT number have to issue French e-invoices?
Not just because it has a French VAT number. Domestic electronic invoicing generally covers certain transactions between taxpayers established in France.
A Polish company can be based in Poland, have a French VAT number, file French VAT returns, and store goods in France, yet not have a fixed establishment for VAT purposes there. In this case, French VAT alone does not cover it for domestic electronic invoicing, but it may trigger electronic reporting obligations.
The legal basis for the national system is Article 289 bis of the French Tax Code.
What is the difference between electronic invoicing and electronic reporting?
These are two separate obligations that should not be confused with each other.
Electronic invoicing: structured invoice
The invoice is issued, transmitted, and received electronically through an approved platform (French: plateforme agréée). The system uses formats such as UBL, CII, and Factur-X. Factur-X combines readable PDF with structured XML data.
DGFiP clearly explainsthat a simple PDF sent by email is not an e-invoice within the meaning of the reform. Technical documentation is available in the official specifications of the French system.
Electronic reporting: transaction and payment data
Reporting involves providing the government with data on transactions that do not go through the national electronic invoicing system. Therefore, a company may be exempt from e-invoicing while still being required to report.
The current rules expand on BOFiP’s explanations regarding transaction data and payment data.
What transactions of a foreign company are subject to electronic reporting?
The scope depends on the nature of the transaction and who is responsible for settling French VAT. For companies without a fixed establishment, B2B, intra-Community acquisitions, certain purchases subject to the reverse charge, and B2C are particularly relevant.
Sales taxed in France
Reporting may cover certain transactions originating in France on behalf of a non-established taxpayer if the operation is subject to French VAT and the foreign seller remains liable for its settlement.
Reverse charge
If the buyer is VAT-registered in France, they may be responsible for reporting. However, the reverse charge does not automatically apply to every sale of a foreign business.
Consumer sales
Sales or services to consumers may be subject to electronic reporting if they are subject to French VAT. Data may be reported daily in aggregated form according to rates.
WNT in France and electronic reporting
Intra-Community acquisitions of goods located in France may be subject to electronic reporting. This is particularly important for companies storing inventory in French warehouses.
What's happening tax-wise?
On the Polish side, an IDT of own goods may be created, and on the French side, a corresponding INT. From September 1, 2027, a foreign company acting as a buyer obligated to settle such INT will be included in the reporting schedule, regardless of size.
Warehouse and fulfillment
Simply using a logistics provider doesn't eliminate the need for goods movement analysis. The guide "Warehousing Abroad and VAT", while the model with an external provider is covered in the article on fulfillment and 3PL warehousing abroad.
B2C sales in France and electronic reporting
Sales or services provided to consumers may be subject to electronic reporting if the transaction is subject to French VAT. However, not all B2C sales need to be reported as a separate e-invoice.
Local B2C sales from FR stock
The goods are shipped to the consumer from a warehouse located in France. Local VAT settlement and reporting obligations must be determined separately. This is not considered a mail order sale from Poland simply because the seller is based in Poland.
B2C sales settled in VAT OSS
DGFiP indicates an exclusion from transaction reporting for relevant transactions with consumers if an unestablished operator settles them in the EU VAT One-Stop Shop.
Amazon FBA and a warehouse in France – is it necessary to implement e-invoicing?
Not automatically. Simply storing goods in an Amazon warehouse in France and having a French VAT number does not mean that a foreign company is established in France for electronic invoicing purposes.
Goods moved to Amazon warehouse
Moving your own inventory from another EU country to France can result in an ITA. As of September 1, 2027, your company's reporting as a buyer must be reviewed.
Sales from the FR warehouse to the consumer
These are essentially local sales in France. They require separate VAT settlement and reporting requirements.
Sales from the FR warehouse to the company
First, determine the buyer's status and who is responsible for settling French VAT. Only then determine the reporting obligation.
Export, import and VAT declarations
Exclusion from electronic reporting does not automatically mean the absence of other documentation, customs or declaration obligations.
Export and exempt ICT
VAT-exempt exports of goods and exempt intra-Community supplies of goods are excluded from this reporting.
Import of goods
Import is excluded from transaction reporting but may still involve customs clearance, import VAT, EORI and the inclusion of import in VAT returns.
CA3 Declaration
Electronic reporting does not replace the French VAT return. Companies with a French VAT registration continue to fulfill their reporting obligations under the local system.
How often is data reported and what does payment reporting cover?
Electronic reporting doesn't work as if you were sending every single invoice the moment it's issued. The frequency depends on factors such as the type of data, the company's VAT settlement system, and the reporting period.
Transaction data
For B2C, the administration provides, among other things, aggregated data that allows for the determination of daily sales values according to VAT rates. Transaction and payment data have their own rules and transmission deadlines.
Payment details
Separate reporting may be required for specific services and advance payments prior to delivery of goods, if VAT is payable upon payment. Data may include the payment date, gross amount, breakdown by rate, and invoice number.
It does not cover, among other things, reverse charge transactions or cases covered by the appropriate choice of VAT settlement by invoice (French: TVA sur les débits).
What is an approved platform?
This is a platform approved by the administration that handles the flow of e-invoices and data required by the reform. Older materials may use the abbreviation PDP (French: plateforme de dématérialisation partenaire).
Sends e-invoices
Transmits structured invoices to the client platform.
Receives e-invoices
Provides access to documents received from suppliers.
Reports transactions
Provides required transaction data to the administration.
Reports payments
Handles payment data within the scope of the reform.
A foreign company without a fixed establishment that is subject to electronic reporting should select a platform before commencing its obligations. DGFiP maintains an up-to-date list of approved platforms.
The lack of a SIREN does not always exclude reporting: if a foreign company does not have one, its foreign EU VAT number can be used in the relevant data, and then the relevant foreign identification number.
What are the penalties for failing to invoice or report electronically?
French regulations provide for separate sanctions for specific obligations. First, it is necessary to correctly determine whether the company is subject to reform, in what capacity, from what date, and for which transactions.
Breach of the electronic invoicing obligation
For mandatory electronic invoicing, a penalty of EUR 15 per invoice is indicated, with a limit of EUR 15,000 per calendar year.
No data transmission
For foreign companies, EUR 500 is indicated for the lack of data transmission, with a limit of EUR 15,000 per year on the company side.
What should a foreign company do with VAT FR?
Don't start by assuming your company needs to "implement French e-invoicing." First, answer these seven questions.
- Does the company have a permanent establishment in France for VAT purposes?
- Is it just a foreign entity with a French VAT number?
- What transactions does FR perform using VAT?
- Does it carry out intra-Community transfers or transfers of its own goods to France?
- Do you sell locally B2C?
- Are some B2C sales settled through VAT OSS?
- Are there any transactions where French VAT is settled by the buyer?
Do you have VAT FR and want to determine the scope of reporting?
We'll analyze your transactions, your company's role, and the reform deadlines, then integrate electronic reporting with your current VAT obligations in France. We'll also assist you with registration and filing if necessary.
Related Taxenlight Guides and Services
Choose the material that corresponds to the next obligation, instead of mixing registration, declarations, OSS and storage in one process.
E-invoices in France – FAQ
Does every company with a FR VAT number have to issue French e-invoices?
No. A Russian VAT number alone does not trigger the obligation to use electronic invoicing. For a foreign company without a fixed establishment, electronic reporting will be much more important.
Is a Polish company without a permanent place of business in France subject to electronic invoicing?
As a general rule, no. The French national system covers certain transactions between taxpayers established in France.
Can such a company be subject to electronic reporting?
Yes. A company without a fixed establishment may be subject to reporting if it carries out transactions covered by the reporting requirement that trigger the obligation to settle French VAT.
Do WNTs need to be reported in France?
ITCs located in France must be included in the electronic reporting analysis. For foreign companies as buyers, the obligation begins on September 1, 2027, regardless of size.
Does moving your own goods to a warehouse in France make a difference?
Yes. Transferring your own goods from another EU country may result in an ITC in France and therefore affect your reporting obligations.
Does Amazon FBA in France automatically mean electronic invoicing is mandatory?
No. An Amazon warehouse and a French VAT number alone do not mean that a foreign company is established in France for electronic invoicing purposes.
Are B2C sales subject to electronic reporting?
May be subject to French VAT if applicable. A significant exception is for relevant transactions settled through the EU VAT One-Stop Shop.
Are imports to France subject to electronic reporting?
No. Imports of goods are excluded from transaction reporting, although they may still result in customs duties and import VAT.
Are exports from France subject to electronic reporting?
Exempt exports and exempt intra-Community supplies of goods are excluded from this reporting.
Is a PDF sent by email a French e-invoice?
No. A regular PDF sent by email does not meet the definition of an e-invoice under the reform.
Does electronic reporting replace the CA3 declaration?
No. Electronic reporting and the French VAT declaration are separate obligations.
Does a foreign company need an approved platform?
Yes, if it is subject to reporting obligations. The platform provides the required data to the administration.
Since when are foreign SMEs subject to electronic reporting?
As sellers or service providers – from 1 September 2027. As purchasers liable for VAT, e.g. for intra-Community acquisitions of goods, also from 1 September 2027.
Legal Notice: This material is for informational purposes only. The scope of French electronic invoicing and reporting depends on the company's status, the specific transaction, the place of taxation, and the entity liable for VAT.
