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French e-invoicing reform: What obligations for foreign companies not established in France?

French e-invoicing reform: What obligations for foreign companies not established in France?

Published on : 17/02/2026 17 February Feb 02 2026
Focus

The French e-invoicing reform, whose phased entry into force begins on 1 September 2026, does not only concern companies established in France. Foreign companies without a permanent establishment in France, but registered for French VAT purposes, are also concerned – not by e-invoicing, but by e-reporting.

The French Tax Office for Non-Residents (DINR) recently organized an informative webinar on the subject. The presentation provided welcome clarifications regarding the scope and practical implementation of these new obligations.

1. No e-invoicing, but an obligation to perform e-reporting


Foreign companies without a permanent establishment in France are not subject to the obligation to issue or receive electronic invoices (e-invoicing).
However, they fall within the scope of e-reporting when they carry out transactions deemed to take place in France for which they are liable for French VAT (Article 290 II of the French General Tax Code).

In particular, the following are concerned:
  • Supplies of goods or services deemed to be located in France, where the foreign company is liable for VAT (for example, taxable B2B supplies in France to taxable persons not established and not VAT-registered in France);
  • Certain B2C supplies carried out in France;
  • From 1 September 2027, transactions for which the non-established taxable person is liable for VAT as acquirer or recipient (reverse charge), including intra-Community acquisitions.

However, intra-Community supplies and exports are excluded from the e-reporting system.

2. Implementation timetable


The applicable timetable depends on the size of the company:
  • 1 September 2026: e-reporting obligation for large companies and medium-sized enterprises acting as sellers or service providers;
  • 1 September 2027: extension to SMEs, very small enterprises and micro-enterprises, as well as to companies liable for VAT as acquirers or recipients (reverse charge), regardless of their size.

It is therefore essential to anticipate the company’s classification according to the applicable size criteria.

3. What data must be transmitted?


Non-established companies will have to transmit, via e-reporting:
  • Transaction data (net amounts, VAT rates and amounts, identification of the parties, etc.);
  • In B2C transactions, aggregated data per day and per VAT rate;
  • Where applicable, payment data where VAT becomes chargeable upon receipt of payment (services, advance payments).

The frequency of transmission will depend on the applicable VAT regime (monthly or quarterly real regime), with close deadlines, sometimes even more frequent than monthly.

4. Mandatory choice of an accredited platform


A key point confirmed by the DINR: foreign companies not established in France and subject to e-reporting must mandatorily choose an accredited platform before their entry date into the system (1 September 2026 or 1 September 2027 depending on the case).

Even though they are not concerned by e-invoicing, these companies must use an accredited platform to transmit their data to the tax authorities.

It is important to note that registration in the directory does not, in itself, create an e-invoicing obligation for foreign non-established companies, whether for issuing or receiving invoices.

5. Penalties in the event of non-compliance


Failure to transmit the required data exposes the company to a fine of €500 per missing transmission, capped at €15,000 per calendar year.

However, a “right to make mistakes” mechanism is provided for in the event of a first infringement that is remedied within 30 days following a request from the tax authorities.

Anticipate to secure your compliance


For foreign companies registered for VAT in France, this reform represents a major development: new reporting obligations, adaptation of IT systems, selection of an accredited platform and securing data flows.

A precise analysis of transactions carried out in France is essential in order to determine the scope of obligations, the applicable entry-into-force date and the practical implementation requirements.

Companies concerned may contact us for any additional information or for personalized assistance in identifying their obligations and ensuring compliance with the reform.
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