French Tax Authorities Clarify E-Reporting Obligations for Foreign Companies
On 4 June 2026, the French tax authorities issued long-awaited guidance on the application of France’s e-reporting regime to foreign businesses without a permanent establishment in France.
The clarification arrives just months before the launch of France’s digital VAT reporting framework and provides important certainty for non-resident businesses operating in the French market.
While much of the attention surrounding the French reform has focused on mandatory e-invoicing, the latest guidance confirms that many foreign VAT-registered businesses will not be subject to French e-invoicing requirements. Instead, they may face separate e-reporting obligations that become fully applicable from September 2027.
For many multinational groups, this distinction is significant and should trigger a review of existing French VAT registrations, transaction flows, and reporting processes.
E-Invoicing and E-Reporting: Two Different Obligations
France’s mandatory e-invoicing regime applies only to transactions between VAT-taxable persons established in France. As a result, foreign companies without a French establishment generally fall outside the scope of domestic e-invoicing obligations.
However, this does not mean that foreign businesses escape the reform entirely.
Where a non-resident business carries out transactions that are subject to French VAT, separate e-reporting obligations may apply. These reporting requirements are designed to provide the French tax administration with transaction and, in certain cases, payment information outside the traditional e-invoicing framework.
This distinction is often misunderstood and creates a compliance risk for foreign businesses that have assumed the reform is relevant only to French-established entities.
Key Implementation Dates
The French authorities have confirmed the following implementation timetable:
1 September 2026
- Large enterprises
- Intermediate-sized enterprises (ETI)
1 September 2027
- Small and medium-sized enterprises (SMEs)
- Small businesses
- Micro-enterprises
1 September 2027
- All businesses acting as VAT-liable customers in relation to:
- Reverse charge transactions
- Intra-Community acquisitions
Importantly, company size is determined based on the position as of 1 January 2025, using consolidated group turnover and employee thresholds.
For many foreign VAT-registered businesses, September 2027 will therefore represent the first mandatory reporting deadline.
Which Transactions Must Non-Resident Businesses Report?
The guidance confirms that e-reporting may apply to various French VAT-liable transactions carried out by businesses that are not established in France.
Examples include:
- Supplies of goods or services taking place in France between two non-established businesses where the supplier remains liable for French VAT.
- Taxable intra-Community acquisitions made in France.
- Purchases from foreign suppliers that are not registered for French VAT where the customer becomes liable for French VAT.
- Certain domestic transactions subject to French reverse charge mechanisms.
Businesses should carefully map their French VAT registrations and transaction flows to identify potential reporting obligations.
Important Clarification on Reverse Charge Transactions
One of the most significant aspects of the new guidance concerns reverse charge transactions.
Where a customer holds a French VAT registration and becomes liable for the VAT under French reverse charge rules, the reporting obligation transfers to the customer.
In these situations, the foreign supplier is generally not required to submit e-reporting data.
This clarification removes a substantial volume of transactions from the reporting scope of many foreign suppliers and should simplify compliance for businesses that already rely on French reverse charge mechanisms.
B2C Transactions: OSS Provides an Important Exemption
Foreign businesses making B2C supplies that are subject to French VAT must also consider the e-reporting rules. However, businesses that report their French B2C VAT through the EU One Stop Shop (OSS) benefit from an important exclusion.
Transactions reported through OSS are exempt from French transaction-level e-reporting.
Businesses that are not using OSS may still be required to submit transaction information, typically reported as aggregated daily totals by applicable VAT rate. For many cross-border e-commerce businesses, the continued use of OSS therefore remains an important simplification measure.
Payment Reporting Requirements
The French regime extends beyond transaction reporting and also introduces payment reporting obligations in certain situations.
This primarily affects:
- Supplies of services.
- Advance payments received before goods are delivered.
Reported information may include:
- Date of payment receipt.
- Amount collected.
- Applicable VAT rate.
- Reference to the associated invoice.
The reporting obligation rests with the party receiving the payment.
Transactions subject to reverse charge treatment are excluded from payment reporting requirements.
Transactions Outside the Scope
The French authorities have confirmed that several categories of transactions remain outside the e-reporting regime, including:
- Exports
- Intra-Community supplies of goods
- Imports
- Most VAT-exempt financial services
- Insurance services
- Healthcare services
- Educational services
- Certain defence and national security transactions
Nevertheless, businesses should assess individual transaction types carefully, as exemptions may not apply universally across all business models.
Accredited Platform Requirement for Foreign Businesses
A particularly important operational consideration for non-resident businesses is the reporting channel itself. Foreign businesses cannot submit e-reporting data directly to the French tax administration.
Instead, they must appoint a certified Accredited Platform (Plateforme Agréée) to transmit transaction and payment information on their behalf.
The selection, onboarding, testing, and integration of an Accredited Platform should not be underestimated. Businesses should begin evaluating solution providers well before their mandatory compliance date.
Why September 2027 Matters
Many foreign businesses have understandably focused their attention on France’s domestic e-invoicing requirements and concluded that the reform does not apply to them.
The latest guidance demonstrates that this assumption can be dangerous.
While non-resident businesses may be outside the scope of e-invoicing, they can still face extensive e-reporting obligations where French VAT registrations exist. The challenge is compounded by the need to identify reportable transactions, determine whether payment reporting applies, assess reverse charge scenarios, and establish connectivity with an Accredited Platform.
For multinational groups with French VAT registrations, September 2027 should already be appearing on compliance roadmaps.
The businesses that start analyzing their transaction flows now will be in a far stronger position than those that wait until implementation deadlines are approaching.
How Can KGT Support You?
KGT has created an SAP-integrated e-invoicing add-on solution for France, featuring outbound and inbound functionalities to meet tax reporting requirements. This add-on includes a data extractor and a cockpit for generating periodic electronic invoices in the legal format and controls before submission. When SAP DRC launched a French e-invoicing solution as part of its e-document offerings, KGT emerged as a leading consultancy firm for SAP DRC and tax services. Recognized as an SAP DRC partner for French e-invoicing services, KGT is one of SAP's recommended implementation partners for this solution. We provide comprehensive support, including installation, configuration, customization, and training, to help you maximize the long-term value of your SAP DRC investment.
KGT is an SAP partner for PE services and an SAP Build partner, and to become an SAP partner, strict due diligence requirements must be met, including having certified SAP consultants. You can find us at https://partnerfinder.sap.com/profile/0001925409
