E-Reporting Requirements for Foreign Companies Without a Permanent Establishment — What You Need to Know

E-Reporting Requirements for Foreign Companies Without a Permanent Establishment — What You Need to Know

Summary

• E-invoicing does not apply to non-established companies, but e-reporting obligations do: foreign companies without a permanent establishment in France but registered for French VAT must electronically transmit transaction data — and in some cases payment data — to the French tax authorities for transactions subject to French VAT. [impots.gouv.fr]
• Phased rollout from 1 September 2026: large enterprises and ISEs acting as sellers/service providers must comply from 1 September 2026; micro-enterprises, VSEs, and SMEs follow on 1 September 2027. Reverse charge and intra-Community acquisition reporting (buyer-side) is deferred to 1 September 2027 regardless of company size. [impots.gouv.fr]
• An authorised platform (PDP) is mandatory: non-established companies must select an accredited platform to transmit e-reporting data to the French tax authorities before their applicable go-live date, with penalties of up to €500 per missed transmission (capped at €15,000/year). [impots.gouv.fr], [eurotax.fr]

Article

Background: France’s E-Invoicing and E-Reporting Reform

France’s landmark electronic invoicing reform, underpinned by Article 289 bis of the French General Tax Code (CGI), mandates that all domestic B2B transactions between VAT-taxable persons established in France be conducted through structured electronic invoices. However, the reform’s reach extends well beyond domestic players. [impots.gouv.fr]

On 4 June 2026, the French tax authority (Direction Générale des Finances Publiques) updated its official guidance specifically addressing foreign companies without a permanent establishment in France. The key message: while e-invoicing obligations (issuing and receiving) do not apply to these entities, e-reporting obligations do. [impots.gouv.fr]

What Is E-Reporting?

E-reporting involves the electronic transmission of specific transaction and payment data to the French tax authorities for commercial transactions that fall outside the scope of mandatory e-invoicing. This includes, in particular, transactions carried out in France by non-established entities that are liable for French VAT under the CGI. [impots.gouv.fr]

Who Is in Scope?

Under Article 290 (II) of the CGI, foreign companies without a French permanent establishment are subject to e-reporting when they: [impots.gouv.fr]

• Carry out transactions from France with another taxable person not established in France (sales or services deemed to take place in France and subject to VAT);
• Make non-exempt intra-Community acquisitions in France (Article 262 ter (II)(3) CGI);
• Purchase goods or services in France from a supplier/service provider that is neither established nor VAT-registered in France. [impots.gouv.fr]

Importantly, the following are excluded from e-reporting: exports, intra-Community supplies, imports of goods, certain VAT-exempt transactions (banking, insurance, medical, educational services), and transactions covered by defence/security or national security confidentiality clauses. [impots.gouv.fr]

Implementation Timeline

The rollout follows a phased approach based on company size — assessed as at 1 January 2025 on a worldwide basis (not limited to French turnover): [impots.gouv.fr]

Date	Who
1 September 2026	Large enterprises and ISEs — as sellers/service providers
1 September 2027	Micro-enterprises, VSEs, and SMEs — as sellers/service providers
1 September 2027	All enterprises — as buyers/customers liable for VAT (reverse charge, intra-Community acquisitions), regardless of size

Smaller companies may opt in early from 1 September 2026. [impots.gouv.fr]

The size thresholds are as follows: [impots.gouv.fr]

• Micro-enterprise / VSE: < 10 employees, turnover or balance sheet < €2m
• SME: < 250 employees, turnover ≤ €50m or balance sheet ≤ €43m
• ISE: < 5,000 employees, turnover ≤ €1,500m or balance sheet ≤ €2,000m
• Large enterprise: ≥ 5,000 employees, or turnover > €1,500m and balance sheet > €2,000m

Two Components: Transaction Data and Payment Data

1. Transaction data e-reporting

For international B2B transactions, the data to be reported mirrors e-invoicing data requirements, except that a SIREN number is not mandatory if unavailable — an intra-Community VAT number or foreign tax identification number may be used instead. [impots.gouv.fr]

A critical nuance: when a non-established seller supplies goods or services under Article 259 A CGI to a buyer without a French VAT number, the seller is liable for VAT and must e-report. Conversely, if the buyer holds a French VAT number, the buyer bears the reverse charge obligation and the corresponding e-reporting duty. [impots.gouv.fr]

For B2C transactions (sales to non-taxable persons such as individuals), e-reporting covers daily aggregated data broken down by VAT rate. However, this obligation does not apply if the non-established operator is registered with an EU VAT One Stop Shop (OSS). [impots.gouv.fr]

2. Payment data e-reporting

Payment data reporting applies to supplies of services and advance payments for goods, regardless of customer type. It covers the collection date, amount collected per VAT rate, and, where applicable, the invoice number. This obligation does not apply to reverse charge transactions or when the supplier has opted for VAT on debits. [impots.gouv.fr]

Reporting Frequencies

Unlike e-invoicing — where data flows in near-real-time — e-reporting follows periodic submission intervals determined by the company’s VAT regime (every 10 days, monthly, or bimonthly). [impots.gouv.fr], [cleartax.com]

Choosing an Authorised Platform

All non-established companies subject to e-reporting must select an authorised platform (Plateforme de Dématérialisation Partenaire, or PDP) to transmit data to the tax authorities. This choice must be made before the applicable go-live date. Importantly, registration in the French directory does not create an obligation to issue or receive e-invoices — it is solely for e-reporting compliance. [impots.gouv.fr], [vatcalc.com]

Penalties for Non-Compliance

Non-compliance carries a fine of €500 per missed transmission, capped at €15,000 per calendar year. A right-to-correct (“droit à l’erreur”) exists for first offences if regularised within 30 days of a tax authority request. [eurotax.fr], [fintua.com]

Key Takeaway for Multinational Companies

For multinational groups like P&G with VAT registrations in France but no permanent establishment, the immediate action items are clear: assess company size on a worldwide basis, map all French VAT-liable transaction flows, and select an authorised platform well ahead of 1 September 2026. While e-invoicing is off the table, e-reporting is very much on it — and the clock is ticking.

Source: impots.gouv.fr – E-Reporting Requirements for Foreign Companies Without a Permanent Establishment in France (published 10/11/2025, last updated 04/06/2026)

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Briefing document & Podcast: France’s E‑Invoicing & E‑Reporting – VATupdate

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