France Hits Pause: VAT Move from the CGI to the New CIBS Slips to 1 January 2027

• Ordinance No. 2026-671 of 27 July 2026 (published in the Official Journal on 28 July) postpones the transfer of VAT rules from the General Tax Code (CGI) to the Goods and Services Tax Code (CIBS) from 1 September 2026 to 1 January 2027. [legifrance.gouv.fr], [sepaj.fr]
• The government acted because the original date clashed with the mandatory e-invoicing rollout from 1 September 2026; the delay lets operators absorb the recodification more calmly. The ordinance also groups all VAT deduction rules into a single CIBS subdivision. [vie-publique.fr], [lemondedudroit.fr]
• E-invoicing rules stay substantively unchanged within the CGI; the deadline for using former CGI article references on invoices is extended from 31 December 2027 to 30 June 2028. [sepaj.fr]

Extended article

France has pushed back one of its biggest VAT structural reforms. By Ordinance No. 2026-671 of 27 July 2026, published in the Journal officiel No. 0174 on 28 July 2026, the government deferred the transfer of VAT provisions from the Code général des impôts (CGI) to the Code des impositions sur les biens et services (CIBS). The move — originally set for 1 September 2026 under the recodification ordinance of 17 December 2025 — will now take effect on 1 January 2027. [legifrance.gouv.fr], [sepaj.fr]

The rationale is practical. As the Conseil des ministres explained, the initial 1 September 2026 date coincided with the mandatory transition to electronic invoicing, creating a risk of confusion for businesses managing two major changes at once. Postponing the VAT recodification gives operators and practitioners time to prepare for the new legal framework more serenely. [vie-publique.fr]

The ordinance does more than delay. Responding to the public consultation, it consolidates all VAT deduction provisions into a single subdivision of Book II of the CIBS to improve readability, and it integrates VAT measures adopted since December 2025 — including those from the 2026 Finance Law, such as the harmonisation of the waste-management services rate at 5.5%. It also confirms that opposable administrative doctrine remains unchanged on entry into force of the CIBS. [vie-publique.fr], [lemondedudroit.fr]

Importantly for compliance teams, the e-invoicing rules remain unchanged in substance, form and positioning within the CGI. The December 2025 ordinance had already permitted references to former CGI articles on invoices until 31 December 2027; for consistency, that deadline is now extended to 30 June 2028. Until 31 December 2026, CGI provisions and references (including on immovable-property VAT and rents) continue to apply; from 1 January 2027 they are replaced by the corresponding CIBS provisions. [sepaj.fr]

Sources: Ordinance No. 2026-671 — Légifrance · Conseil des ministres statement — Vie-publique · Practitioner analysis — SEPAJ

• France’s transfer of VAT rules from the Code général des impôts (CGI) into the new Code des impositions sur les biens et services (CIBS) — originally set for 1 September 2026 — is expected to be postponed to 1 January 2027, via an amending ordinance due before autumn 2026. [meridiangl…rvices.com], [easytax.co]
• Launched by Ordinance No. 2025-1247 of 17 December 2025, the reform is carried out “à droit constant” (no substantive change): rates, base and exemptions stay the same, but ~230 CGI articles become nearly 1,000 shorter CIBS articles with updated terminology. [pwcavocats.com], [avocats-gt.com]
• Though formally a renumbering exercise, it codifies CJEU case-law concepts (e.g. “direct and immediate link,” fixed establishment, leasing and travel-agent margin rules), so businesses must update invoice references, software and procedures — with an invoice-reference deadline currently set for end-2027. [meridiangl…rvices.com], [avocats-gt.com]

Article

France is set to delay one of the most structurally significant VAT developments in years. As Meridian Global Services reports, the recodification of VAT from the historic Code général des impôts (CGI) into the newer Code des impositions sur les biens et services (CIBS) — originally planned to take effect on 1 September 2026 — “may be postponed to 1 January 2027,” with an amending ordinance expected before autumn 2026 to confirm the deferral. [meridiangl…rvices.com]

The reform stems from Ordinance No. 2025-1247 of 17 December 2025. The CIBS, in force since 1 January 2022, was conceived to regroup all taxes on goods and services — VAT, excise duties and other indirect consumption taxes — into a single dedicated code, ending the dispersion of rules across some twenty separate corpuses. The stated aims are improved legal clarity, harmonised taxation of goods and services, alignment with the EU VAT Directive, and enhanced legal certainty. [meridiangl…rvices.com], [pwcavocats.com]

Crucially, the recodification is formal, not substantive (“à droit constant”): the rules on tax base, rates and exemptions remain largely unchanged. But this is far more than renumbering — around 230 CGI articles are being replaced by nearly 1,000 CIBS articles, deliberately shorter and more heavily cross-referenced, with updated terminology. It also codifies principles derived from CJEU case law, including the notions of a “direct and immediate link” and fixed establishment, plus rules on leasing and the travel-agents’ margin scheme. [pwcavocats.com], [meridiangl…rvices.com]

Grant Thornton describes the postponement as “a sensible measure and a pragmatic response” to an environment that has not yet stabilised and is evolving alongside other major projects such as electronic invoicing. It also allows feedback from the public consultation (completed 15 April 2026), where practitioners flagged interpretive uncertainties, to inform the amending ordinance. Advisers warn of an “underestimated risk”: even at constant law, changed article numbering and terminology mean invoices, accounting software and procedures must be updated — with the deadline for updating tax references on invoices currently set at end-2027. [avocats-gt.com], [hayot-expertise.fr]

Sources:

• Meridian Global Services – France: Recodification of VAT into the CIBS might be postponed [meridiangl…rvices.com]
• Grant Thornton (avocats-gt) – French VAT legislation into the new CIBS code [avocats-gt.com]
• Easytax – France Postpones CIBS Recodification to 2027 [easytax.co]