What is the purpose of the e-invoicing and e-reporting mandate in France?
The reform aims to modernise VAT reporting and billing processes through:
- Mandatory electronic invoicing between businesses established in France that are subject to French VAT. This applies to all purchases and sales of goods and/or services between such businesses, including those under the VAT exemption regime. Based on the electronic invoice exchanged, the invoice data is simultaneously transmitted to the tax authorities.
- Electronic transmission of transaction and payment data or operations outside the scope of e-invoicing i.e. Exports, intra-EU acquisitions and deliveries, and transactions with non-taxable persons (B2C).
- Improved efficiency, greater transparency, and reduced VAT fraud.
How can a business determine whether a transaction falls under e-invoicing or e-reporting?
The first step is to assess the status of the client involved in the transaction:
- If the client is a private individual or a non-taxable legal entity, whether based in France or abroad, the transaction must be reported to the tax authorities through e-reporting.
- If the client is a taxable professional, the next step is to determine the client’s place of establishment:
- For transactions involving clients established in France, an e-invoice must be issued via an Accredited Platform (PA) which will in parallel transmit the invoice data to the tax authorities. Specifically, e-invoicing applies to transactions that occur between entities subject to VAT and established in France and are governed by French invoicing rules.
- For transactions involving clients established outside France, there is no obligation to issue an electronic invoice. However, relevant data related to these transactions must be transmitted electronically periodically to the tax authorities as part of e-reporting.
What is an Accredited Platform or “Plateforme Agréée” (PA)?
An Accredited Platform (PA), previously referred to as a PDP, is a government-registered service provider responsible for:
- Issuing, transmitting, and receiving electronic invoices between VAT-registered businesses in France, as well as managing the full invoice lifecycle
- Extracting the required invoice data for the French tax authority
- Transmitting data related to transactions that are not subject to electronic invoicing to the tax authorities (e.g., exports, intra-EU acquisitions and deliveries, and transactions with non-taxable persons such as B2C)
- Transmitting payment data for all types of transactions
Is the use of an Accredited Platform (PA) mandatory?
Yes. From 1 September 2026, all VAT-registered businesses in France must use an Accredited Platform (PA) to issue, receive, and report electronic invoices to the tax authorities.
What are the key dates for the mandate?
From 1 September 2026:
- All businesses must receive electronic invoices.
- Large and mid-sized companies must issue e-invoices and transmit transaction/payment data.
From 1 September 2027:
- Small and micro-enterprises must also comply with these obligations.
Are transactions deemed to take place in another EU Member State subject to the French e-invoicing mandate?
The obligation to issue an electronic invoice applies to transactions between two entities established in France only when French invoicing rules apply.
Therefore, if a transaction is considered to take place in another EU Member State, even if both parties are established in France, it does not fall within the scope of either e-invoicing or e-reporting. This is because French VAT does not apply, and the VAT is due in the Member State where the transaction is carried out (based on local VAT identification and rules).
Is a PDF sent by email considered an e-invoice?
No. To qualify as an e-invoice, the document must:
- Be issued, transmitted, and received in structured electronic format
- Include mandatory data fields
- Be transmitted via a PA
Does the mandate replace VAT returns?
No. Businesses must still submit VAT returns according to their usual schedule. However, collected invoice and payment data may eventually enable pre-filled returns.
Why do the tax authorities collect fewer data points than those legally required on an invoice?
The French tax authorities only collect data necessary to perform their duties, especially for the future pre-filling of VAT returns. Therefore, not all legally required invoice fields are included in the data submitted via e-invoicing. Structured data collection will be introduced progressively between 1 September 2026 and 1 September 2027.
How often must e-reporting data be submitted?
Unlike electronic invoices and invoice data, transaction data is not required to be transmitted in real time. The transmission frequency depends on the business’s VAT reporting regime.
- For example, businesses under the VAT exemption regime (franchise en base) must transmit their data every two months.
- Businesses under the standard monthly VAT regime (régime réel normal mensuel) must transmit their data three times per month.
Who is responsible for transmitting payment data?
The invoice issuer is responsible for submitting payment data, particularly for service transactions where VAT is not accounted for on a debit basis.
Do public entities follow different invoicing rules?
No. From 1 September 2026, public sector entities will be subject to the same e-invoicing and e-reporting rules as private businesses. Existing systems like chorus pro will continue to operate, but structured formats and standard data requirements will apply to all.
Can businesses not established in France be subject to the obligation to transmit certain data to the French tax authorities?
Yes. Some transactions carried out by VAT-registered entities not established in France must be reported to the French tax authorities under the e-reporting obligation.
For example:
- Real estate work performed in France by a non-established taxable person for the benefit of a non-taxable property owner located in France
- Certain B2B transactions where goods or services (as defined in Article 259 A of the french general tax code) are supplied from France to another non-established taxable entity that does not have a French VAT number
In such cases, the foreign supplier is responsible for transmitting the relevant transaction data through e-reporting.
What are the penalties for non-compliance?
Failure to issue an electronic invoice when required may result in:
- 50€ per invoice for the taxpayer and the platform failing to comply with their obligations — for the former regarding invoice issuance, and for the latter regarding data transmission.
- 500€ for failure by the taxpayer to transmit transaction and payment data.
- Max of 100K€ penalties for failure by platforms to transmit transaction and payment data.
- New penalty for the taxpayer for failure to choose a receiving platform, starting September 1, 2026. This measure provides for a 500€ fine (after a formal notice to comply within 3 months) and, if no correction is made, a new 1,000€ fine, repeatable every 3 months (always following a formal notice).
No penalty applies for a first infraction committed during the current calendar year or the previous three years, if the error is corrected voluntarily or within 30 days of the first notification from the tax authorities.
