France e-reporting Sept 2027 non-resident live

While many non-resident businesses have focused on France’s e-invoicing reforms, the new guidance confirms that foreign VAT-registered companies will generally not be subject to French e-invoicing requirements. Instead, they will face separate e-reporting obligations covering transaction and, in some cases, payment data.

The French authorities have also produced e-invoicing FAQ’s.

One of my earlier blogs on non-resident French e-reporting obligations is a bit clearer on the phased approach – so may be worth a read, too.

E-invoicing does not apply to most foreign businesses

France’s mandatory e-invoicing regime only applies to transactions between VAT-taxable persons established in France. Separately, the EU Digital Reporting Requirements impose e-reporting obligation on intra-community requirements from 1 July 2028.

As a result, foreign companies without a French VAT establishment are not required to issue or receive French e-invoices.

However, many non-resident businesses remain within scope of France’s parallel e-reporting regime if they undertake transactions subject to French VAT.

Key implementation dates for French mandate

The French authorities have confirmed the following timetable:

1 September 2026

• Large enterprises
• Intermediate-sized enterprises (ISEs)

1 September 2027

• SMEs
• Small businesses
• Micro-enterprises

1 September 2027

• All businesses acting as VAT-liable customers for:
  • Reverse charge transactions
  • Intra-Community acquisitions

Importantly, company size is determined based on the position as at 1 January 2025, using global turnover and employee thresholds.

Which foreign transactions must be e-reported?

The guidance confirms that e-reporting applies to a range of French VAT-liable transactions carried out by non-established businesses.

These 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 not registered for French VAT where the customer becomes liable for French VAT

Reverse charge transactions – reporting intra-community acquisitions

A particularly important clarification concerns reverse charge transactions.

Where the customer holds a French VAT number and becomes liable for the VAT under France’s reverse charge rules, the foreign supplier is not required to e-report the transaction.

Instead, the reporting obligation shifts to the customer.

This will remove a significant volume of transactions from the reporting obligations of many foreign suppliers already using French VAT reverse charge mechanisms.

B2C transactions e-reporting – but OSS excluded

Foreign businesses making B2C supplies subject to French VAT may also have e-reporting obligations.

However, France confirms that businesses using the EU One Stop Shop (OSS) for their B2C VAT reporting are exempt from transaction e-reporting for those sales.

For businesses outside OSS, transaction data must be reported in aggregated daily totals by VAT rate.

Payment reporting obligations also included

In addition to transaction reporting, some businesses must also submit payment data.

This primarily affects:

• Supplies of services
• Advance payments received before goods are delivered

The reporting obligation covers information such as:

• Payment receipt date
• Amount collected
• VAT rate applied
• Associated invoice reference

The obligation falls on the party receiving the payment.

Reverse charge transactions are excluded from payment reporting.

Important exclusions from e-reporting obligations

The guidance confirms that the following remain outside scope:

• Exports
• Intra-Community supplies of goods
• Imports
• Most VAT-exempt financial, insurance, healthcare and education services
• Certain defence and national security transactions

Authorised platform required for non-residents

Non-resident businesses subject to e-reporting cannot submit directly to the French tax administration.

Instead, they must appoint a certified Plateforme Agréée or Accredited Platforms (APs)  to transmit their transaction and payment data.

This choice must be made before the business’s applicable go-live date.