Briefing document & Podcast: France’s E‑Invoicing & E‑Reporting Mandate (2024–2026): Scope, Timeline & Requirements

SUMMARY

1. Executive Summary

France is implementing a broad electronic invoicing and digital reporting mandate for Value Added Tax (VAT), which is scheduled to come into force starting in September 2026. All businesses established or VAT-registered in France, including foreign companies with a French VAT number, will be required to issue invoices in electronic format for B2B domestic transactions and report transaction data electronically to the tax authorities. E-reporting will apply to B2C transactions and cross-border sales and purchases. The overarching goals are to combat VAT fraud, enable pre-filled VAT returns, and modernize business processes. This reform will significantly alter how businesses operating in France handle VAT compliance.

2. Background and Objectives

The mandate stems from EU-level authorization granted to France in early 2022, allowing a deviation from certain VAT Directive rules. The key objectives driving this reform are:

• Combating VAT Fraud: The real-time reporting aims to reduce VAT evasion by providing the tax authorities with immediate visibility on transactions. “The primary goals are to tighten VAT fraud control…”
• Enabling Pre-filled VAT Returns: By collecting comprehensive sales and purchase data, the French tax authority plans to offer pre-filled VAT returns, simplifying compliance for businesses. “One of the end-goals of France’s e-invoicing and e-reporting project is the pre-filling of VAT returns by the tax administration.”
• Modernizing Business Processes: The move to electronic invoicing aims to streamline and automate invoicing processes, reducing administrative burden.

3. Scope and Timeline

The mandate will be rolled out in stages, with the start date set for September 2026. “The mandate is scheduled to be rolled out beginning in September 2026 (and 2027 for SMEs).”

• Transaction Types:
  • B2B Domestic Transactions: Mandatory e-invoicing. “Whenever a VAT-registered seller in France invoices a VAT-registered customer in France for a taxable transaction, that invoice must be issued electronically…”
  • B2C Transactions: Mandatory e-reporting of aggregated daily sales data by VAT rate. “Businesses will continue to issue paper or PDF receipts/invoices to private customers… However, the seller must report summary sales data to the tax authorities electronically.”
  • Cross-Border B2B Transactions: Mandatory e-reporting of invoice data, including counterparty details, dates, amounts, and VAT information. “If a French company sells to a business abroad… the French seller must report the invoice data to the French tax authorities via e-reporting.”
  • B2G Transactions: Already subject to e-invoicing via Chorus Pro, and processes will remain largely unchanged. “France has had mandatory e-invoicing for all invoices to public-sector entities since 2017…Under the new reform, B2G processes remain largely unchanged.”
• Taxable Persons:
  • French-established businesses: Subject to e-invoicing and e-reporting.
  • Foreign companies VAT-registered in France: Subject to e-invoicing and e-reporting, though there may be a potential postponement of e-reporting obligations for non-established businesses until 2027. “…recent updates suggest that France may give non-established businesses a bit more time: there’s discussion of postponing the obligation for non-established taxable persons to start e-reporting until 2027…”
  • Businesses with no establishment or VAT registration in France: Outside the scope.

4. How the System Works (“Y-Model” Architecture)

France is adopting a clearance model where all invoices pass through a platform. This involves two types of platforms:

• PPF (Portail Public de Facturation): The state-operated Public Billing Portal will serve as a central hub and data concentrator. “The PPF will purely handle the central directory and forwarding data to the tax authority.”
• PDP (Partner Dematerialization Platforms): Certified private platforms that businesses may use for e-invoicing and e-reporting, and can offer additional services. “Certified private platforms that businesses may use.”

When a supplier issues an invoice, it is sent via either a PDP or the PPF. The platform validates the invoice and transmits key data to the tax administration. E-reporting data for B2C and cross-border transactions is also submitted through these platforms.

5. Data Formats and Requirements

Invoices must be in a structured electronic format that aligns with the European standard. Acceptable formats include:

• Factur-X: A French-German blended format (PDF/A-3 with embedded XML).
• UBL 2.1: An XML format.
• UN/CEFACT CII: Another XML schema.

At a minimum, 24 data points must be sent to the tax authority for each invoice.

E-invoices must guarantee authenticity, integrity, and legibility, and must be archived for 10 years in electronic form.

6. Reporting Deadlines and Frequency

• E-Invoice Data: Data is sent immediately upon invoice issuance. “Whenever a B2B invoice is issued, its data is sent immediately. So effectively, the deadline is at issuance.”
• E-Reporting (B2C and Cross-border):Companies on monthly VAT filings: Three times per month (approximately every 10 days). “For companies on monthly VAT filings… e-reporting must be done in files 3 times per month.”
• Companies on quarterly VAT filings: Likely also monthly or tri-monthly.

7. Penalties for Non-Compliance

The French tax code establishes penalties for failing to comply with the e-invoicing and e-reporting mandate:

• Failure to issue an e-invoice: €15 per invoice, capped at €15,000 per year. “€15 fine per invoice that is not issued via the platform as required…capped at €15,000 per year…”
• Failure to transmit e-reporting data: €250 per unreported transaction, capped at €10,000 per year. “€250 fine per unreported transaction or error in reported data…This is capped at €10,000 per year for e-reporting infractions.”
• Failure to include mandatory details on an invoice: €15 per omission, capped at 1/4 of the invoice’s value.
• Failure to issue an invoice at all: 50% of the transaction’s amount.

While authorities may offer a “soft landing” period initially, businesses are expected to upgrade their systems well before the deadline.

8. Pre-filled VAT Returns

The ultimate goal of the mandate is to enable pre-filled VAT returns. “The ultimate goal is the pre-filling of VAT returns by the tax administration.” The tax administration intends to leverage the collected data to generate draft VAT returns for businesses to review and submit, which could simplify compliance and reduce errors. This is expected to be implemented after the e-invoicing system is fully deployed, potentially in 2027 or 2028.

9. Key Considerations and Recommendations

• Businesses operating in France (including foreign companies with French VAT registration) must prepare for the e-invoicing and e-reporting mandate by upgrading their invoicing systems and selecting a compliant platform (PDP).
• Companies should familiarize themselves with the required data formats and reporting deadlines.
• It is crucial to understand the penalties for non-compliance and take steps to ensure adherence to the new regulations.

INDEPTH ANALYSIS

Timeline of Implementation (2024–2026)

Scope of Transactions and Taxpayers in Scope

• B2B Domestic Transactions (Business-to-Business within France): Mandatory e-Invoicing applies. Whenever a VAT-registered seller in France invoices a VAT-registered customer in France for a taxable transaction, that invoice must be issued electronically via the e-invoicing system. The buyer will receive it through the system as well. This covers both goods and services, with only a few exceptions (e.g. VAT-exempt transactions under certain articles of the VAT Directive and specific defense/security contracts are exempt from e-invoicing). Essentially, if French VAT is due (or the sale is zero-rated but between French entities), and it’s B2B, the invoice falls under this mandate. [impots.gouv.fr], [impots.gouv.fr] [impots.gouv.fr]
• B2C Transactions (Business-to-Consumer): Mandatory e-Reporting applies, but not e-invoicing. Businesses will continue to issue paper or PDF receipts/invoices to private customers as they do today (there’s no requirement to force consumers into the e-platform). However, the seller must report summary sales data to the tax authorities electronically. These reports do not include customer personal details – to comply with privacy rules, the data is aggregated by day and by VAT rate. For example, a retailer will total its daily sales that were taxed at 20% VAT, 10% VAT, etc., and submit those totals via the platform. This provides the tax authority with the output VAT amounts. If a business has no B2C sales in a given period, it simply has nothing to report (no “empty” report needed). [impots.gouv.fr] [impots.gouv.fr], [impots.gouv.fr] [bdo.global]
• Cross-Border B2B Transactions: Mandatory e-Reporting applies. There are two sides:
  • Outbound: If a French company sells to a business abroad (whether an EU customer or outside EU), it cannot issue a “cleared” French e-invoice to a foreign buyer (the buyer isn’t on the French platform). Instead, the French seller must report the invoice data to the French tax authorities via e-reporting. This includes exports (which are zero-rated) and intra-EU B2B supplies (which are exempted as intra-community supply) – those still need reporting even though no French VAT is charged, because France wants visibility on the transaction. The data to report is essentially the same as what an invoice contains (counterparty’s identification, dates, line amounts, VAT or note that reverse-charge applies, etc.). [impots.gouv.fr], [impots.gouv.fr] [impots.gouv.fr]
  • Inbound: If a French company purchases from a foreign supplier (for instance, an import or an intra-EU acquisition where French VAT is self-accounted), the French buyer will be responsible for reporting the relevant details of that transaction via the e-reporting system. In practice, this means capturing purchase info so that input VAT and reverse-charge due VAT are transparent to the tax authorities. [impots.gouv.fr], [impots.gouv.fr]
  • Exception: Cross-border transactions that are already reported through EU-wide special schemes (notably OSS/IOSS for distance sales to consumers) are excluded from French e-reporting, since those are reported via EU mechanisms. [impots.gouv.fr], [impots.gouv.fr]
• B2G Transactions (Business-to-Government): Already subject to e-Invoicing via Chorus Pro. France has had mandatory e-invoicing for all invoices to public-sector entities since 2017 (phased by company size, fully in place by 2020). Suppliers issue these invoices through the Chorus Pro platform. Under the new reform, B2G processes remain largely unchanged – companies can continue using Chorus Pro for invoices to government bodies. Chorus Pro is being integrated as the public platform within the 2026 scheme. So, while B2G invoices are indeed electronic, they are not “new” for 2026 and do not require e-reporting (the government already receives them). The focus of the 2026 mandate is closing the gap for B2B private-sector invoicing and capturing B2C/cross-border data. [impots.gouv.fr] [bdo.global], [bdo.global]

• French-established businesses (including branches of foreign companies in France) – yes, they must comply with e-invoicing for domestic sales and e-reporting for others. [impots.gouv.fr], [impots.gouv.fr]
• Foreign companies not established in France but who are VAT-registered in France (e.g. via fiscal representative or direct registration for French VAT) – yes, they are in scope. For example, if an Italian company is registered in France for VAT to sell goods from Italy to French customers (domestic VAT via distance selling rules or post-OSS scenario), it will have to report those sales. Or a U.S. company with a French VAT number must ensure any France-based B2B sales use e-invoices via the platform. However, recent updates suggest that France may give non-established businesses a bit more time: there’s discussion of postponing the obligation for non-established taxable persons to start e-reporting until 2027, recognizing the extra complexity for foreign companies. (This isn’t law yet, but it’s under consideration.) [impots.gouv.fr], [impots.gouv.fr] [bdo.global]
• Businesses with no establishment or VAT registration in France – no, they are outside the scope. If neither the seller nor buyer is a French taxpayer, the transaction isn’t relevant to French VAT, so of course no e-invoice/report. If a foreign company sells to French consumers under OSS, it reports that through OSS, not to France’s system.
• Micro-entrepreneurs and exempt small businesses in France – if truly under the VAT exemption (franchise en base) with no VAT obligations, they might not be considered “taxable persons” for VAT, so the mandate would not apply until they become liable to VAT. But any business that files VAT returns, even under simplified regimes, will be included according to the phase that matches their size.
• Public sector entities – government bodies themselves will continue to use Chorus for receiving invoices; they don’t issue invoices for sales as typically they are not VAT-taxable persons (except some instances). So the government is mostly a recipient in B2G flows, already catered for.

How the E-Invoicing & E-Reporting System Works

• PPF (Public Portal): The state-operated platform (Chorus Pro’s evolution).
• PDP (Partner Dematerialization Platforms): Certified private platforms that businesses may use.

• Factur-X: a French-German blended format (PDF/A-3 with embedded XML) – convenient because humans see the PDF and machines read the XML. [impots.gouv.fr]
• UBL 2.1: an XML format widely used in e-invoicing. [impots.gouv.fr]
• UN/CEFACT CII: another XML schema. These can carry all required fields. A simple PDF or scanned image is not acceptable unless accompanied by the requisite XML data. Businesses can use whichever of the approved formats suits them; PDPs may offer conversion services if, say, a company’s system produces UBL and the buyer wants Factur-X. The goal is interoperability. [impots.gouv.fr]

• Sending a structured data file via a PDP or the PPF (for example, a CSV or XML with the required fields for all the transactions in the period).
• Using an API to transmit individual transaction data in real time.
• Manually entering data on the PPF’s interface (this is expected to be used only by the tiniest businesses with very few transactions).

Reporting Deadlines and Frequency

• E-Invoice Data: Whenever a B2B invoice is issued, its data is sent immediately. So effectively, the deadline is at issuance. If you issue an invoice on 15 March 2026 (hypothetically during the voluntary phase), that invoice’s data should be transmitted on 15 March 2026. In the live mandate, the platform will handle this instantly or within hours. There is no separate periodic deadline for invoices – it’s continuous transaction-by-transaction reporting (often called CTC, continuous transaction control). Businesses will need to invoice through the system, not outside of it, so compliance is built-in at the time of invoicing.
• E-Reporting (B2C and Cross-border): The law and guidelines set periodic submission deadlines for these reports:
  • For companies on monthly VAT filings (which is most large and mid-sized companies), e-reporting must be done in files 3 times per month. The intervals are typically days 1–10, 11–20, and 21–end of month. Data for each interval is due within a few days after the interval:
    • Transactions from the 1st to the 10th of a month: report by the 15th of that month (the oft-cited guidance is “by the 10th” of the next month, but more recent info suggests mid-month; let’s align with the latest: an October 2023 official update indicated 3 transmissions per month on 10th, 20th, and end of month).
    • 11th to 20th: report by the 20th.
    • 21st to end of month: report by the end of that month. In effect, a company will be submitting e-report data roughly every 10 days through the month. This frequent cadence approaches real-time without doing it per transaction for B2C.
  • For companies on quarterly VAT filings (typically smaller businesses), the authorities will still require monthly reporting of B2C and cross-border data. Likely, they will do one report per month (e.g. by the 15th of the following month covering the whole month’s data), though earlier drafts mentioned possibly just one submission per month. The latest guidance indicates even quarterly filers will do tri-monthly like others, or at least monthly. It’s safer to assume monthly reporting for any active business.
  • If a business has no transactions in a category for a given period, they may not need to send an empty file. France has said it will eliminate “blank e-reporting” obligations – no need to report zero if nothing happened. [bdo.global]
• Payment Data Reporting: For those service transactions where VAT is due on payment (rather than invoice issuance), an additional report is triggered when payment is received. For example, some building and construction services in France have VAT upon collection. In such cases, the supplier would mark the invoice as paid in the platform when payment comes, and that status (with payment date) goes to the tax authority, or they send a separate payment report through the system. The deadline for reporting the payment is tied to the same periodic schedule – essentially include it in the next e-report submission. [bdo.global]

Penalties for Non-Compliance

• Failure to issue an invoice in the required electronic form: €15 fine per invoice that is not issued via the platform as required. This would apply if a company bypasses the system (e.g., sends a paper or email PDF invoice for a B2B sale that should have gone through the platform). The fine is capped at €15,000 per year for this infringement category. Note: The tax authorities have indicated that if it’s a first-time offense and the company quickly corrects it (within 30 days of notice), the fine may be waived as a grace measure. [vandelanotte.be]
• Failure of a platform to transmit an invoice to the tax system: Also €15 per invoice (capped at €45,000 per year for platform operators). This penalty is aimed at certified PDPs or any service provider that fails to forward data properly. (Businesses using a non-approved software that doesn’t report might also fall under this in practice – hence important to use a compliant platform.) [vandelanotte.be]
• Failure to include a mandatory detail on an invoice: €15 per omission, capped at 1/4 of the invoice’s value. This is an existing rule in French VAT law – every invoice must have certain info (e.g., if you forget to put the customer’s VAT number or the invoice date). With e-invoicing, the system should prevent omissions, but if somehow required data is missing or incorrect format, this fine could apply. [bdo.global]
• Failure to transmit e-reporting data (missing transaction data): €250 fine per unreported transaction or error in reported data. This addresses situations like not reporting a B2C sale, or misreporting an amount that misleads the VAT due. This is capped at €10,000 per year for e-reporting infractions. Each incorrect or omitted data point could be another €250, so errors can add up – though “capped at 10k” limits the exposure. [bdo.global]
• General invoice issuance failures: Separate from the above, French law also holds that not issuing an invoice at all when you were required to can trigger a penalty of 50% of the transaction’s amount (this can be reduced to 5% if the transaction is later properly recorded in accounts or by other means). This is actually a broader anti-fraud measure. While this isn’t new to the e-invoicing reform, it’s a harsh reminder: simply not invoicing or trying to do business off the books has very steep fines. Under e-invoicing, authorities will likely catch such omissions more easily. [bdo.global]

Pre-Filled VAT Returns and VAT Reporting Changes

Key Regulations and Official Resources

• Ordonnance n° 2021-1190 du 15 septembre 2021: Established the legal framework for mandatory B2B e-invoicing and complementary e-reporting in France. Status: Enacted (effective), it empowered detailed rules via decrees. [impots.gouv.fr]
• Décret n° 2022-1299 du 7 octobre 2022: Implementation decree specifying the scope, data to be transmitted, platform registration, etc., following the ordinance. Status: Enacted.
• Finance Law for 2022 (Loi 2022-1157 du 16 Aug 2022), Article 26: Initially set out the timetable (since superseded). This was the law that allowed the ordinance and decrees to kick in with dates. Status: Superseded by 2023 law for timeline.
• EU Council Implementing Decision (EU) 2022/133: Gave France permission to mandate e-invoicing (derogation from EU VAT Directive art. 218 and 232). Status: In force from 2022 to 31 Dec 2026 (France will seek renewal to cover 2027+). [impots.gouv.fr]
• Finance Law for 2024 (Loi 2023-1322 du 29 Dec 2023), Article 91: Updated the implementation dates to 2026 and 2027 and affirmed the mandate. Status: Enacted. The key provisions (e-invoicing requirement and e-reporting requirement) will take effect on 1 Sept 2026 (and 2027 for SMEs) as specified. [legifrance.gouv.fr]
• External Specifications & Guidance: The French tax authority’s official External Specifications document (version 2.3) – available on the impots.gouv.fr website – provides technical details on invoice formats, data content, transmission protocols, etc. Status: Updated periodically; serves as binding technical guidance for IT implementations. [impots.gouv.fr]
• Impots.gouv.fr – Official Portal: The government has an English-language presentation and French FAQs which outline the reform. The Budget Ministry also issues press releases (e.g., Oct 2024 confirming the timeline). [impots.gouv.fr], [impots.gouv.fr] [impots.gouv.fr] [kpmg.com]
• French Commercial Code & Tax Code: The mandate also led to changes in the Code de commerce (for archiving and e-invoice obligations) and the CGI (French tax code, art. 289 bis for e-invoicing, art. 290 for e-reporting). These provide the granular legal requirements on each taxpayer. [legifrance.gouv.fr], [legifrance.gouv.fr]