France: DGFiP Publishes Its BOFiP Commentary on the E-Reporting of Transaction Data, Fixing Scope, Data Content and Transmission Frequency for the Obligation Live Since 1 September 2026

KGT Country Update | 5 October 2026 | VAT, e-invoicing and SAF-T monitor

On 30 September 2026 the French tax administration (DGFiP) published in the BOFiP-Impôts database its administrative commentary on the obligation to transmit VAT transaction data (e-reporting), under reference BOI-TVA-DECLA-20-30-50 with three sub-documents on scope, data content and transmission procedures, announced by the news item ACTU-2026-00145.

The commentary covers article 290 of the General Tax Code and applies to large enterprises, mid-sized enterprises and single VAT taxpayers since 1 September 2026, and to small and micro-enterprises from 1 September 2027. The same news item lists a fourth document on payment data, BOI-TVA-DECLA-20-30-60, which we have not been able to open and which is therefore not analyzed here.

Background

France's generalized e-invoicing reform has two limbs. E-invoicing proper covers domestic business-to-business invoices between VAT-registered taxpayers. E-reporting covers everything that is outside that flow: sales to non-taxable persons (B2C), and cross-border transactions where the counterparty is not established in France.

The legal basis is article 26 of the 2022 amending finance law (law no. 2022-1157), which created articles 290 and 290 A of the General Tax Code, and the go-live was 1 September 2026 for the first wave.

Until now, businesses and their approved platforms have relied on the technical specifications and on the decree and order that complete the rulebook. What was missing was the administration's own reading of the law, which is the document taxpayers can invoke in a dispute.

The BOFiP commentary is that reading: under French practice, doctrine published in BOFiP can be relied on by taxpayers against the administration.

The Legislative Change

This is administrative doctrine, not new legislation. It operates within the existing legal framework (article 290 of the General Tax Code and its implementing texts) and does not create new obligations or change the application dates.

It is nonetheless binding in practice, because it determines how the administration will assess compliance, what a platform must be able to validate, and which positions a taxpayer can safely adopt. The news item states that commentary on the e-invoicing provisions (article 289 bis) will follow separately.

Scope

Who is obliged. According to the commentary, the obligation applies to VAT-registered persons established, domiciled or habitually resident in France, and to non-resident VAT-registered persons. It expressly includes taxpayers benefiting from the VAT exemption on turnover (article 293 B), agricultural operators under the flat-rate regime (articles 298 quater and 298 quinquies) and public-law entities registered for VAT. Company size is determined under the 2008 Economic Modernization Law criteria.

What is in scope. For businesses established in France, the scope sub-document covers deliveries of goods and services to other taxable persons that are not subject to domestic e-invoicing, including intra-EU and export-related supplies and services to taxable persons established outside France, and operations with non-taxable persons such as distance sales, goods in France and services located in France.

For non-established businesses it covers operations located in France with non-taxable persons. The commentary also states that operations between two non-established taxable persons where one is the VAT debtor come into scope from 1 September 2027.

What is out of scope. The commentary lists operations exempt and exonerated from invoicing under articles 261 to 261 E, operations classified for national security reasons, and non-established persons that use the EU single-window schemes (OSS and IOSS).

Territorial rules. Guadeloupe, Martinique and Réunion are treated as export destinations, and Monaco is treated as France for these purposes.

Data and Transmission Rules

B2C data. Data on sales to non-taxable persons is transmitted in aggregated form, globalized by day. The fields include the supplier's SIREN number, the reporting period, an indicator where the cash-basis option applies, the transaction category (taxable supplies, supplies not located in France such as intra-EU distance sales, special margin schemes, and other VAT regimes), the taxable base and VAT by rate, the total VAT due in France in euros, and currency and dates.

International B2B data. For transactions with counterparties not established in France, the data to be transmitted is identical to that required between two French VAT-registered persons subject to e-invoicing, except that line-item detail is waived for purchases from non-French suppliers. Foreign counterparties are identified by their EU VAT number or, outside the EU, by an ISO country code plus the first sixteen characters of the name.

Format and controls. Data must follow the semantic standard published on the impots.gouv.fr specifications portal. Approved platforms verify that data is present, that identifiers are valid and correctly formatted, and that VAT is arithmetically consistent with the base.

Channel and frequency. Data is transmitted by the taxpayer's approved platform in XML. As summarized from the procedures sub-document, businesses under the normal monthly regime transmit three times a month (days 1 to 10, 11 to 20, and 21 to month-end), with a deadline ten days after each period closes; quarterly and simplified-regime businesses transmit monthly; and micro-enterprise and flat-rate businesses transmit every two months.

Nothing needs to be sent for a period without operations. Non-resident businesses must appoint a French representative under article 289 A. Because these frequency rules are taken from an extract of the page, readers should confirm them against the full BOFiP text before building process calendars.

Timeline

• 1 September 2026: e-reporting live for large enterprises, mid-sized enterprises and single VAT taxpayers.

• 30 September 2026: BOFiP commentary BOI-TVA-DECLA-20-30-50 and sub-documents published.

• 1 September 2027: obligation extends to small and micro-enterprises, and to operations between non-established taxable persons where one is the debtor.

• To follow: BOFiP commentary on the e-invoicing provisions (article 289 bis).

Businesses Affected

Every multinational with a French VAT registration, directly or through a fiscal representative, is affected, particularly where it makes B2C sales, exports, intra-EU supplies of goods or services to taxable persons, or buys from foreign suppliers.

Groups with French entities in the large or mid-sized categories have been in scope since 1 September 2026, so the commentary is relevant to the compliance already running and not only to future projects.

Required Actions

• Map every transaction type of each French entity to the scope categories in the commentary, and document the treatment of exclusions such as exempt operations and OSS/IOSS supplies.

• Confirm with your approved platform how the daily aggregation of B2C sales, the transaction categories and the foreign counterparty identifiers are produced from your ERP data.

• Align the transmission calendar to the frequency applicable to each entity's VAT regime, and confirm who monitors rejections.

• Check the position of any non-established entities, including the need for a French representative, and note the 1 September 2027 extension.

• Re-run the classification of overseas-territory and Monaco transactions against the stated territorial rules.

Practical Implications

The commentary turns the specifications into a legal reading. Where a platform's interpretation of a category differs from the doctrine, the doctrine prevails for the purposes of a dispute, so differences should be raised now. The treatment of Monaco and the overseas departments, and the waiver of line detail for purchases from foreign suppliers, are examples of points that commonly differ in ERP master data and tax code mappings.

Expected Next Steps

The administration has announced further BOFiP commentary on e-invoicing and the payment-data document BOI-TVA-DECLA-20-30-60 is listed in the same news item. We will review both when they can be read in full. Small and micro-enterprises should plan for 1 September 2027.

How Can KGT Support You?

KGT's SAP-integrated e-invoicing add-ons and our SAP Document and Reporting Compliance (DRC) services can map SAP tax codes and transaction types to the French e-reporting categories, generate the required data from SAP, and connect to your approved platform. Contact us for a scoping discussion.

This update is general information on a regulatory development and does not constitute tax or legal advice. Please consult your tax adviser before acting.