e-Electronic invoicing and e-reporting for VAT; new requirements effective September 2026 :
France has introduced new requirements for issuing and receiving invoices in electronic form, as well as electronic reporting requirements, which will take effect on September 2026, and September 2027, respectively.
The purpose of this note is to provide guidance on the scope of application, particularly for foreign companies. The implementation of the new requirements, if they apply to a company, will need to be analyzed on a case-by-case basis.
1. E-invoicing
Invoices must be issued and transmitted in a digital format via an approved platform. This does not refer to a PDF invoice sent by email, but rather a fully digital process.
1.1 Scope of application :
Issuer: company established in France
Recipient: company established in France
Transactions covered: transactions subject to French VAT.
Thus, transactions involving foreign companies not established in France—even if they are registered for VAT in France—as well as transactions with individuals or transactions not subject to VAT are not covered by this measure.
Foreign companies not established in France are therefore not subject to either the obligation to issue electronic invoices or the obligation to be able to receive invoices in electronic form.
The concept of a permanent establishment is understood according to the definition used for VAT purposes, which may differ from the concept of a permanent establishment for the purposes of taxing profits under tax treaties.
1.2 Effective Date:
For the issuance of invoices, the date depends on the size of the company:
– For large enterprises (workforce >5,000 employees and revenue >€1.5 billion or total assets > €2,000 million) and mid-sized companies (more than 250 employees and revenue > €50 million or total assets > €43 million): September 1, 2026
– For other companies: September 1, 2027, with the possibility, however, of early implementation.
The thresholds are assessed as of January 1, 2025, at the company level (identified by SIREN number), whether in France or abroad, but not at the group level.
The requirement to accept electronic invoices applies to all companies established in France as of September 1, 2026, regardless of their size.
1.3 Procedures
The reform creates an obligation to subscribe to the services of a platform that will transfer the data.
The choice of platform must be made before the company becomes subject to the electronic invoicing requirement (September 2026 or 2027 depending on its size) and before September 1, 2026, regarding the receipt of electronic invoices. The company may directly engage an approved platform. However, it may also use an existing service provider (e.g., an accounting firm, accounting software, or business software that handles invoicing) that offers a solution involving an approved platform (“compatible solution”).
The selected service provider does not necessarily have to be the same for both issuing and receiving electronic invoices.
2. E-reporting
E-reporting covers transactions not subject to the e-invoicing requirement, in order to track the company’s entire business activity.
2.1 Scope of application:
The e-reporting requirement applies only to transactions not covered by e-invoicing, specifically
– Transactions involving a person not established in France:
– Transactions with a non-taxable person
– Intra-Community transactions originating in or destined for France
– Exports and services provided outside the EU (note: imports are not covered because the data is collected by customs)
The following are affected:
– Businesses established in France and
– Non-established businesses that carry out transactions in France for which they are liable for VAT
o Examples:
▪ Internal sales to non-taxable persons
▪ Domestic sales to legal entities not established or registered in France
▪ Provision of services taxable in France to legal entities not established and not registered in France
▪ Intra-Community acquisitions in France that are not exempt under Article 262 ter II of the General Tax Code
3. Reporting of services rendered and payment data
As a reminder, unlike supplies of goods for which VAT becomes due (and consequently deductible by the customer) on the date of delivery (in practice often corresponding to the invoice date) unless a down payment is made beforehand, VAT on services becomes due on the date of receipt of payment, unless the supplier has opted for the tax to become due upon invoicing, i.e., on the date of invoicing.
In order to track the tax’s chargeability, service providers must electronically report data regarding payments for services rendered.
Advance payments received for the supply of goods must also be reported.
4. New mandatory information on invoices
For invoices issued on or after September 1, 2026, it will be mandatory to add the following information to the details that are already required to appear on invoices:
– The customer’s SIREN number, if available
– The type of transaction: supply of goods, provision of services, or mixed transaction
– If applicable, a statement that the supplier has opted for taxation on the debit.
– The delivery address for the goods if it differs from the billing address.
Pascal Schultze, Avocat au Barreau de Paris