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Are non-established entities with a French VAT number required to comply with France’s e-invoicing/e-reporting mandates starting September 1, 2026?

3 days ago
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4 min read

 

  • They are not required to issue e-invoices
  • They are not required to receive e-invoices via Chorus Pro or PDPs in 2026.
  • Their e-reporting obligations are deferred to September 1, 2027.

1. E-Invoice Reception (Sept 1, 2026): A non-established company with a French VAT number is not required to be able to receive e-invoices via Chorus Pro or a PDP by 1 September 2026. France’s official guidance makes clear that e-invoicing requirements (sending and receiving) apply only to entities established in France. Foreign VAT-registered entities without a French establishment are excluded from the 2026 e-invoicing mandate, as they are not listed in the French Global Directory (Annuaire) of invoice recipients. The French government explicitly announced that all e‑invoicing obligations for non-established businesses are deferred to 1 September 2027. In practical terms, this means such a company does not need to onboard onto the e-invoice platform network in 2026, and can continue receiving invoices via traditional means (PDF, paper) without penalty until the deferred date. No fines will apply for not using the e-invoicing system when the customer lacks a SIREN identification, which is the case for non-established VAT users. [impots.gouv.fr] [kpmg.com] [ey.com], [ey.com]

2. E-Reporting of Transactions (Sept 1, 2026): Similarly, a non-established VAT-registered entity is not immediately required to begin e-reporting transactions in 2026. The French authorities have postponed the e-reporting obligations for non-resident taxpayers to 1 September 2027. Originally, under the mandate, foreign companies were to report certain France-related transactions (e.g. domestic B2C sales, exports, or French reverse-charge operations) via the e-reporting system. However, the August 2025 simplification measures grant these entities an additional year. As EY summarizes, “non-established taxpayers will have their e-reporting obligations postponed to September 2027”. This deferral covers the detailed reporting of transactions carried out in France by such entities. In fact, France’s tax administration site confirms that while non-established companies do have e-reporting duties for French transactions, the start date is aligned with the deferred schedule: large and mid-size foreign companies would have begun in Sept 2026, but **the implementation for key scenarios (like reverse-charge sales and intra-EU acquisitions) is formally postponed to 1 September 2027. [ey.com] [impots.gouv.fr]
Bottom Line: A foreign company with only a French VAT registration (no fixed establishment) does not need to comply with the e-invoice reception capability in 2026, nor do they need to start submitting e-reporting in 2026. Their compliance deadline for both aspects is 1 September 2027. Until then, they are outside the 2026 mandate’s scope: they won’t appear in the e-invoicing platform directory and are not expected to exchange invoices through Chorus Pro. If they carry out taxable operations in France during 2026, they will handle invoicing and VAT as today (issuing or receiving PDF invoices, filing VAT returns), and French authorities will not require real-time digital reporting from them until the deferral expires. All official communications emphasize this grace period to allow non-established entities to prepare for the new system. [kpmg.com], [ey.com] [ey.com]
Sources:
  • French Government (Aug 2025) – “Obligations for non-established businesses are deferred to September 2027.” This announcement covers both e-invoicing and e-reporting duties for foreign VAT registrants. [kpmg.com]
  • Impots.gouv.fr (Tax Authority FAQ, Nov 2025) – Confirms that e-invoicing does not apply to companies with no establishment in France, and that such companies will only face e-reporting requirements from 2026/27 per their size (with small ones in 2027). [impots.gouv.fr]
  • EY Tax Alert (Sept 2025) – Highlights that non-established taxpayers’ digital reporting obligations are postponed to Sept 2027, due to their exclusion from the French e-invoice recipient directory. This means no mandatory e-invoice reception or transaction e-reporting for them in 2026. [ey.com]

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

  • Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
  • Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE

 

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