France's E-Invoicing Reform

If your company has a French VAT number but no permanent establishment in France, you've probably heard about France's e-invoicing reform and assumed it doesn't really apply to you. That assumption is only half right, and the half that's wrong could cost you.

What is e-reporting?

E-reporting is a mandatory fiscal system that requires businesses to electronically transmit transaction and payment data to the French tax authorities (DGFiP), for commercial operations that fall outside standard domestic e-invoicing.

E-invoicing vs. e-reporting: two different obligations

E-invoicing handles domestic B2B transactions between companies established in France, sent as structured electronic invoices through an accredited platform.

E-reporting covers everything that doesn't go through that domestic e-invoicing channel:

• B2C transactions: sales made to consumers or tax-exempt entities
• Cross-border transactions: international B2B and B2C sales or purchases involving foreign entities
• Payment data: tracking when VAT is due on collection or on delivery of services rather than on delivery of goods

How it works

Companies compile sales, transaction details, or payment records through their accounting software or ERP. That data must be sent via an accredited intermediary, the Plateforme Agréée (PA), rather than filed manually. The PA validates the data format and forwards the required information securely to the public French Tax Administration, allowing the tax administration to monitor VAT and prepopulate tax returns.

Foreign companies without a French establishment: exempt from one, not the other

For foreign companies registered for VAT in France but lacking a permanent physical establishment, the reform creates a critical distinction: you are exempt from the domestic B2B e-invoicing mandate, but you can be heavily impacted by the e-reporting obligations.

Holding a French VAT number alone does not mean you are "established" in France. Because you are non-established, your transaction flows need to be examined individually.

Where e-reporting applies to foreign companies

If your company is the party liable for paying French VAT on a specific transaction, you must transmit that transaction data to the DGFiP (French Tax Authority). The most common scenarios:

• Buyer-side reverse charge: when you purchase goods or services from outside France and are liable for French VAT under the reverse charge mechanism. This is the requirement most frequently missed by foreign procurement teams.
• Intra-community acquisitions: buying and moving goods into France from another EU country.
• French B2C sales: selling to French consumers, unless the sales are already handled and reported via the EU One-Stop Shop (OSS), which are exempt.
• Local domestic B2B sales: making domestic sales within France where the standard reverse charge does not apply.

What you do NOT have to do

• No e-invoice issuance: for cross-border invoices, you're not required to issue a structured French e-invoice to international clients. That said, sending via Peppol is worth considering even where it isn't required. It delivers the invoice in a standardized, machine-readable format your client's system can process automatically, cuts manual entry and errors on both sides, gives you delivery confirmation instead of uncertainty, and reuses the same structured data you already need for your e-reporting obligation to DGFiP.
• No e-invoice reception platform: the DGFiP (French Tax Administration) decided that non-established companies don't need to register for a receiving platform solely to receive e-invoices. This is because companies without a SIREN or SIRET number aren't registered in the Annuaire (the central directory), and the e-invoicing mandate, for both receiving and sending structured e-invoices, only applies to companies listed in it. Without a SIREN/SIRET, you simply fall outside its scope on both ends.

Timeline for E-Reporting

The rollout follows France's broader continuous transaction control reform:

• 1 September 2026: Large enterprises and ETI (mid-size companies) begin their e-reporting obligations, whether or not they are established in France, as long as they hold a French VAT number and act as seller or supplier.
• 1 September 2027: SMEs and micro-enterprises begin their e-reporting obligations. This date also applies to every company, regardless of size, acting as a buyer or customer liable for French VAT: reverse charge purchases and intra-community acquisitions.

For reference, the official French size categories (Décret n° 2008-1354) define an ETI as an Enterprise that has fewer than 5,000 employees, with either annual turnover under €1.5 billion or a balance sheet under €2 billion. A grande enterprise is any company that doesn't fit into the ETI, PME, or micro-entreprise categories, in practice, one that exceeds those ETI thresholds

Two points where an e-report can be rejected

Submitting data to the PA doesn't guarantee it reaches the tax authority, and reaching the tax authority doesn't guarantee it's accepted. The PA first validates the data format; if it doesn't meet requirements, the PA rejects it before it's ever transmitted. Once transmitted, the tax authority runs its own checks and can reject a submitted e-report as well. Because rejection can happen at either stage, companies need to actively monitor the status of each e-report rather than assume submission equals compliance.

Dokapi lets you follow up on that status directly, whether an e-report is accepted, rejected  through either an API integration or a dedicated portal.

Transmission frequencies

Once you're in scope, how often you file depends on your VAT regime and not on a single universal deadline.

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What if you hit a technical issue transmitting the data?

The obligation doesn't pause because your systems do. If you're subject to the e-reporting transmission requirement from 1 September 2026 and run into a technical difficulty, you should not suspend the underlying business activity or interrupt the operations concerned.

What the administration expects instead:

• identify the source of the difficulty and date it
• contact your platform, your software editor, or your service provider
• keep the error messages and exchanges with your provider as evidence
• keep collecting the data that needs to be transmitted, even while the issue is unresolved
• transmit everything as soon as the channel is restored, as quickly as possible

For a temporary issue, the logic is rapid regularisation: what protects you isn't a spotless uptime record, it's being able to show the delay came from a genuine incident rather than an absence of any compliance effort. And if you can't regularise quickly, you still need to be able to demonstrate an active path toward compliance going forward.

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Dokapi is a certified Peppol Access Point and Plateforme Agréée (PA), supporting e-invoicing and e-reporting compliance across France, Germany, the Netherlands, Belgium and Luxembourg. If your company is subject to the e-reporting mandate as of September 2026, reach out to us. We'd be happy to help.

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Note: 

All requirements are subject to change. We recommend always verifying the latest requirements on the official website of the French tax administration (DGFiP). This overview sets out the general rules and isn't tax advice on your situation. Your establishment status, size category and treatment of individual flows should be confirmed with your tax advisor.

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