France Extends Tax Record Retention from Six to Ten Years: Article 36 of Law No. 2026-534 Applies from 1 January 2027

Country Update — France  |  3 August 2026  |  Topic: VAT Compliance / Record Retention & Archiving

Article 36 of LOI no. 2026-534 du 25 juin 2026 relative à la lutte contre les fraudes sociales et fiscales amends Article L. 102 B of the Livre des procédures fiscales to extend the general tax record retention period from six years to ten.

The extension applies to documents whose existing retention deadline expires after 1 January 2027, which means records created as far back as 2021 are pulled into the longer period rather than falling out of scope.

Coming five weeks before the 1 September 2026 e-invoicing go-live, the measure lands on systems that are already being rebuilt.

Background

Article L. 102 B of the Livre des procédures fiscales sets the period for which books, registers, documents, and records must be kept available to the French tax administration in support of its rights of communication, enquiry, and audit. That period has been six years. It sat somewhat awkwardly alongside the administration’s own audit powers, which in cases of fraud or undeclared activity can reach considerably further back.

The law of 25 June 2026 is a broad anti-fraud instrument covering both social security and tax fraud, and it includes a range of measures directed at company officers and at documentary traceability. Article 36 is the retention provision. Its logic is straightforward: align the period during which evidence must exist with the period during which the administration can ask for it.

The Legislative Change

Article 36 replaces the six-year period in Article L. 102 B of the LPF with a ten-year period. The obligation attaches to the same categories of material as before — the books, registers, documents, and records on which the administration may exercise its rights of communication, enquiry, and audit.

In practice this covers accounting books and journals, sales and purchase invoices, supporting documentation, computerized accounting data, and the evidence constituting the reliable audit trail (piste d’audit fiable). For businesses moving to structured e-invoicing, it also covers the invoice files themselves together with the lifecycle status data that establishes when an invoice was transmitted, received, accepted, or rejected.

The transitional rule is the part most likely to be missed. The extension applies to documents whose retention deadline expires after 1 January 2027. A record that would otherwise have become disposable in, say, 2028 does not benefit from the old six-year period; it must now be kept for ten years from its original starting point. Only material whose six-year period has already run out before 1 January 2027 escapes.

Scope

The obligation applies to all persons subject to French tax record-keeping duties under Article L. 102 B, which in practice means every business with French accounting and VAT obligations, including French establishments of foreign groups. It is not confined to VAT: the article governs the documentary basis for the administration’s audit powers generally.

Timeline

• 25 June 2026 — Law no. 2026-534 is enacted; published in the Journal officiel on 30 June 2026.
• 1 September 2026 — Wave 1 of the B2B e-invoicing mandate begins, materially increasing the volume of structured data subject to retention.
• 1 January 2027 — The ten-year period applies to all records whose retention deadline falls on or after this date.

Businesses Affected

Every business with French tax obligations is affected, but the operational impact is concentrated in two places. The first is IT: archive sizing, storage cost, retention policy configuration, and the legal-hold and deletion logic in document management and ERP systems.

The second is corporate transactions — a ten-year evidentiary window changes the shape of tax due diligence and of the record-delivery obligations in carve-outs and divestments, where the buyer of a French business now needs a decade of accessible history.

Groups running SAP ILM or a comparable retention framework should expect the change to touch policy configuration rather than architecture, but the volumes are not trivial: extending retention on structured invoice data by four years is a material increase in the archive footprint for a high-volume French entity.

Required Actions

• Suspend any scheduled destruction of French tax records pending a review. Documents that were due for disposal under the six-year rule may now be within the ten-year period, and premature destruction exposes the business to penalties.
• Update retention policies in ERP, archiving, and document management systems, and check that automated deletion jobs have been re-parameterized. In SAP landscapes, review ILM retention rules and audit-area assignments for the French company codes.
• Extend the retention design for e-invoicing data before the September go-live rather than after. Original invoice files, the structured data, lifecycle statuses, and the platform’s transmission evidence all need to remain readable, searchable, and producible for ten years.
• Confirm what your Approved Platform retains, in what format, and for how long — and what happens to that archive if you switch platforms or the provider exits the market. Platform retention is not a substitute for your own obligation under Article L. 102 B.
• Re-size archive storage and revisit the cost assumptions in your e-invoicing business case. A four-year extension on a high-volume French entity is a real number.
• Check format durability. A ten-year horizon raises the question of whether today’s XML profiles and the software needed to read them will still be available at the end of the period, and whether a migration path is documented.

Practical Implications

The measure is easy to overlook because it is not an e-invoicing rule and it sits in a law about fraud rather than in the Finance Act. But its practical effect is to make archiving a first-order workstream in the French e-invoicing program rather than a downstream consequence of it.

Structured e-invoicing generates far richer datasets than paper or PDF ever did, and the administration will now be entitled to interrogate ten years of that data with automated tooling.

The combination is what matters. From 2027, the French tax administration will hold transaction-level data for every domestic B2B invoice, will be able to reach back ten years, and will expect the taxpayer’s own records to reconcile to what the platforms transmitted.

Discrepancies that were previously buried in an accounting system are now visible, comparable, and durable. Data quality at the point of issuance is therefore worth considerably more than it was.

Expected Next Steps

Administrative guidance from the DGFiP on the application of the amended Article L. 102 B — in particular on the interaction between the retention rule and the archiving duties attaching to electronic invoices — would be helpful and may follow through the BOFiP. Businesses should not wait for it before suspending scheduled deletions. KGT will report on any BOFiP commentary and on how the retention requirement is reflected in the Approved Platform service terms.

How Can KGT Support You?

KGT supports French e-invoicing and e-reporting from SAP through our SAP-integrated add-ons and through SAP Document and Reporting Compliance (DRC) implementations, and archiving is part of that design rather than an afterthought. We can review your retention configuration against the amended Article L. 102 B, extend it to cover structured invoice data and lifecycle statuses, assess what your Approved Platform actually retains on your behalf, and build the reconciliation between archived invoice data and your filed VAT returns that a ten-year audit window makes worth having.

Official sources

• Légifrance – LOI no. 2026-534 du 25 juin 2026 relative à la lutte contre les fraudes sociales et fiscales: View source
• Légifrance – Article 36 of Law no. 2026-534 of 25 June 2026 (amending Article L. 102 B LPF): View source
• Légifrance – Article L. 102 B, Livre des procédures fiscales: View source
• impots.gouv.fr – Réforme de la facturation électronique : documentation juridique: View source
• impots.gouv.fr – Facturation électronique (main reform portal): View source

This publication is provided for general informational purposes only and does not constitute tax, legal, or professional advice. Please consult your advisor before acting on any information contained in this update.