France is introducing a major reform of its electronic invoicing framework, which will progressively enter into force from 1 September 2026.
While some obligations will only apply to companies established in France, foreign companies registered for French VAT may still be impacted, particularly through new e-reporting requirements. Understanding whether your company falls within the scope of these obligations is essential to anticipate the upcoming compliance changes.
Understanding the Reform: E-Invoicing and E-Reporting
The French reform introduces two distinct obligations.
E-invoicing refers to the electronic exchange of invoices between companies. This obligation only applies to transactions carried out between companies established in France. As a result, companies not established in France are not concerned by the e-invoicing requirement.
However, these companies may still be impacted by e-reporting.
E-reporting requires businesses to transmit certain transaction and payment data to the French tax authorities. This obligation concerns companies not established in France but registered for French VAT, when they carry out transactions falling within the scope of French VAT.
Transactions Subject to E-Reporting
Non-established companies registered for VAT in France must report certain transactions, including:
Domestic supplies of goods or services located in France for which French VAT is due (for example VAT-inclusive sales with French VAT or transactions subject to reverse charge such as intra-Community acquisitions).
Certain transactions are excluded from e-reporting for non-established companies, including:
Intra-Community supplies
Exports outside the European Union
Definition of Company Size
The applicable thresholds are the following:
Micro-enterprise: fewer than 10 employees and annual turnover or balance sheet total below €2 million.
SME (Small and Medium-Sized Enterprise): fewer than 250 employees and annual turnover below €50 million or balance sheet total below €43 million.
Intermediate-size company: fewer than 5,000 employees and annual turnover below €1.5 billion or balance sheet total below €2 billion.
Large company: more than 5,000 employees and annual turnover above €1.5 billion or balance sheet total above €2 billion.
Company size is assessed as of 1 January 2025, based on the last financial year closed before that date.
For companies not established in France, the total number of employees linked to the foreign establishment as well as the overall turnover must be considered, regardless of whether the revenue is generated in France.
Implementation Timeline
E-reporting for large companies and intermediate-size companies acting as sellers or service providers.
- E-reporting for micro-enterprises, SMEs and small businesses acting as sellers or service providers.
- E-reporting for all companies acting as buyers or recipients of services.
RM Boulanger assists international businesses in assessing their exposure to the French e-reporting obligations and ensuring VAT compliance.
