France: BOFiP Commentary BOI-TVA-DECLA-20-30-60 Sets Out the Payment Data E-Reporting Rules, the "Encaissée" Status and the Filing Deadlines
KGT Country Update | 21 October 2026 | VAT, e-invoicing and SAF-T monitor
On 30 September 2026, the French tax administration (DGFiP) published in the BOFiP-Impôts database the commentary BOI-TVA-DECLA-20-30-60, "Obligation de transmission des données de paiement", together with the news item ACTU-2026-00145 that introduces the transaction-data and payment-data e-reporting commentary.
The document explains which operations require payment data to be reported, which data fields are sent, how the "Encaissée" invoice status is used, and the monthly and bimonthly filing deadlines. It is an administrative doctrine, not a change to the law, and it follows the 1 September 2026 go-live for large and intermediate-sized companies and single VAT taxpayers.
Background
France’s reform has two limbs: e-invoicing for domestic B2B transactions and e-reporting of transaction data (article 290 CGI) and of payment data (article 290 A CGI). KGT’s update of 5 October 2026 analyzed the three BOFiP documents on transaction data; it noted that the fourth document, on payment data (BOI-TVA-DECLA-20-30-60), had not been opened.
That document is now readable on the BOFiP site and is the subject of this update. The transaction-data modalities document (BOI-TVA-DECLA-20-30-50-30) was already covered and is not repeated here.
The Legislative Change
This is not a legislative change. The commentary operates within the existing legal framework (articles 289 bis, 290, and 290 A CGI and the timetable already set).
It is nonetheless binding in practice: it is the administration’s published reading of the obligation, it sets the data fields and deadlines on which platform rejections and penalty assessments will be based, and it fixes how the payment lifecycle must be reported.
Payment data means data on collections made by the taxable person performing the operation. The obligation covers operations within the e-invoicing obligation (article 289 bis) or the transaction-reporting obligation (article 290) where VAT is due on collection, for example, services, advance payments, and certain agricultural operations.
Operations subject to reverse-charge VAT are excluded. Where a self-billing mandate is used, the supplier remains responsible.
Scope
The obligation applies to invoices issued, or to operations whose taxable event occurs, from 1 September 2026 for large companies, intermediate-sized companies and single VAT taxpayers (article 256 C CGI), and from 1 September 2027 for SMEs and micro-enterprises.
The commentary states that a taxpayer that opted for VAT on debits is not exempted from reporting payment data; for operations still taxed on collection, the penalty of article 1788 D II CGI does not apply to such a taxpayer who does not transmit payment data, as a tolerance. VAT exigibility and return rules are unchanged, and the commentary gives no penalty amount.
Timeline
-
30 September 2026 — BOI-TVA-DECLA-20-30-60 and ACTU-2026-00145 published in BOFiP.
-
1 September 2026 — payment data obligation applies for large companies, intermediate-sized companies and single VAT taxpayers (in force).
-
1 September 2027 — payment data obligation applies for SMEs and micro-enterprises.
Businesses Affected
Every French-established taxable person that issues invoices or performs operations in scope where VAT is due on collection, and the platforms and ERP landscapes that feed them. The first population is already in the obligation; SMEs and micro-enterprises follow on 1 September 2027, including those that issue from 2027 under the timetable for small entities.
Data, status and format
-
Data fields (paragraph 50): the company SIREN; the period covered (for XML files) or the invoice date (for e-invoices); the invoice number where one was issued; the actual collection date; and the amount collected, split by VAT rate, in euros. The collection date follows the rules in BOI-TVA-BASE-20-20 and BOI-TVA-BASE-20-40.
-
Channel: payment data goes through an approved platform (plateforme agréée) chosen by the taxable person, in structured form following the published external specifications. The platform checks that the required data is present.
-
Status: platforms expose four invoice statuses, "Dépôt", "Rejet", "Refus" and "Encaissée"; "Encaissée" carries the payment data. For e-invoiced operations the issuer reports payment by updating the invoice to "Encaissée" through the platform used for issuance; the administration recommends doing so within 24 hours of the status timestamp. For operations reported without an invoice, the platform sends a structured XML file.
-
B2C: payments from non-taxable customers are aggregated per day and per VAT rate.
-
Frequency and deadlines: monthly for the real normal and simplified regimes; each civil bimester for franchise-in-base and flat-rate refund regimes. Real normal regime (monthly or quarterly): within 10 days after the end of the month; real simplified: between the 25th and the end of the following month; franchise and flat-rate regimes: between the 25th and the end of the month following the bimester.
Required Actions
-
Check that accounts-receivable postings can produce the actual collection date and the amount collected per VAT rate for each in-scope invoice, and can distinguish operations taxed on collection.
-
Define who sets the "Encaissée" status, from which event, and how quickly, so that the 24-hour recommendation can be met.
-
Build or confirm the aggregation of B2C collections per day and per VAT rate.
-
Confirm with each approved platform how it handles the monthly deadline and the XML payment file.
Practical Implications
The commentary is silent on several points that matter in an ERP: partial payments, refunds and credit notes, corrections of payment data already sent, consequences of a platform rejection, several payments against one invoice, and the use of several platforms.
KGT therefore does not state a position on them; confirm them with your platform and, where material, with the DGFiP before relying on an interpretation. Payment lifecycle data is where invoice-level reporting meets cash application, so the first filing cycles after 1 September 2026 are the best test for the design that SMEs will adopt in 2027.
Expected Next Steps
The BOFiP news item states that e-invoicing under article 289 bis will be covered in later commentary. KGT will monitor BOFiP and the DGFiP external specifications for that commentary and for any guidance on the open points above.
How Can KGT Support You?
KGT delivers SAP-integrated e-invoicing and e-reporting add-ons and SAP Document and Reporting Compliance (SAP DRC) services. We can help map FI-AR collection data to the payment e-reporting fields, design the "Encaissée" status workflow, and test the feeds against your approved platform before the SME population joins in September 2027.
This country update is provided for general information only and does not constitute tax, legal or professional advice. Partial payments, refunds, corrections and multi-platform handling are not addressed by the commentary and are not analyzed here.
