France's electronic-invoicing reform started on 1 September 2026, but a foreign company without a French permanent establishment for VAT purposes is not automatically subject to the domestic e-invoicing obligation. Instead, it can fall under French e-reporting when it carries out transactions considered to take place in France for which it is liable for French VAT. The first step is therefore to determine whether the business is established in France for VAT purposes and which transactions create French reporting duties.
Is a foreign company subject to French e-invoicing?
The answer depends on establishment. The French tax authority states that the domestic e-invoicing system covers purchases and sales of goods or services carried out in France between VAT-taxable persons established in France. A foreign company that does not have a permanent establishment in France for VAT purposes is outside that e-invoicing scope.
That does not mean a non-established business is outside the reform. If it carries out transactions located in France for which it is liable for French VAT, it can have an e-reporting obligation. E-reporting transmits transaction information, and in some cases payment information, to the French tax authority even though the commercial invoice itself is not exchanged through the domestic e-invoicing flow.
If the group has a French branch, office or other presence, do not decide the position from the corporate label alone. The relevant question is whether there is a French permanent establishment for VAT purposes that changes how the transaction is treated. That point should be checked before configuring invoicing software or choosing a reporting route.
What changed on 1 September 2026?
For businesses established in France and subject to the reform, 1 September 2026 is the first major operational date. All businesses, regardless of size, must be able to receive compliant electronic invoices. Large enterprises and intermediate-sized enterprises must also issue electronic invoices from that date. Small and medium-sized enterprises and micro-enterprises move to mandatory issuance on 1 September 2027.
The timetable is different for foreign companies without a French permanent establishment. Their relevant obligation is generally e-reporting rather than domestic e-invoicing.
| Business situation | From 1 September 2026 | From 1 September 2027 |
|---|---|---|
| Business established in France | All sizes must receive e-invoices; large and intermediate-sized businesses must issue them | SMEs and micro-enterprises must also issue e-invoices |
| Foreign business without French permanent establishment, acting as seller/service provider | Large and intermediate-sized businesses can be subject to e-reporting for French VAT-liable transactions | Micro, VSE and SME businesses can be subject to the same seller-side e-reporting obligation |
| Foreign business without French permanent establishment, liable for VAT as buyer/customer | Check existing transaction-specific obligations | E-reporting extends to relevant reverse-charge transactions and intra-Community acquisitions regardless of company size |
The company-size test and transaction scope should be reviewed using the current DGFiP guidance before the first reporting period. Do not assume that being incorporated abroad automatically postpones every obligation until 2027.
When does a non-established foreign company have to e-report?
DGFiP's current guidance focuses on transactions involving goods or services considered to take place in France where the foreign, non-established company is liable for French VAT. In that situation, transaction data has to be transmitted through the French e-reporting system according to the applicable timetable.
For seller-side transactions, large enterprises and intermediate-sized enterprises entered the system on 1 September 2026. Micro-enterprises, very small enterprises and SMEs follow on 1 September 2027. The tax authority also explains that from 1 September 2027 the scope extends to non-established taxable persons of any size when they are liable for VAT as buyer or customer, including relevant reverse-charge transactions and intra-Community acquisitions.
This is why a VAT registration review should be done before the technical setup. The business needs to know which French transactions it reports, whether it is acting as supplier or customer for VAT purposes and which date applies to its size and role.
What information is sent through e-reporting?
E-reporting is not simply a copy of the invoice. It is the transmission of defined transaction data to the tax authority and, for some operations, payment data. DGFiP gives examples such as the amount of the transaction and the amount of VAT charged. The exact fields and frequency depend on the transaction and the company's VAT situation.
For an international business, the accounting system therefore needs to distinguish at least the legal entity, customer location, transaction type, French VAT treatment, invoice amount, VAT amount and payment information where payment reporting applies. If those fields are not reliable in the source system, the reporting platform cannot correct the underlying accounting logic.
Does a PDF invoice sent by email count as an e-invoice?
For transactions that fall inside the French domestic e-invoicing obligation, an ordinary PDF sent by email is not the new compliant e-invoice. DGFiP explains that an e-invoice uses a structured format such as UBL, CII or a permitted hybrid format and is exchanged through an approved platform.
A foreign company outside the domestic e-invoicing scope should not force its invoices into that workflow merely because it has French VAT obligations. It may continue using the appropriate commercial invoicing channel while separately transmitting the required e-reporting data through the approved platform. The correct setup follows the legal scope of the transaction, not the file format preferred by the customer or accounting software.
Which platform does a foreign company need?
A foreign company without a French permanent establishment that is subject to e-reporting must choose an approved platform capable of transmitting its data to the French tax authority. DGFiP states that the platform should be chosen before the date on which the business becomes subject to e-reporting.
Platform selection should come after the obligation map. Before signing a contract, confirm that the provider supports the company's legal status, French VAT number where relevant, transaction types, accounting integration, reporting frequency and any payment-data requirement. A platform can transmit data, but it does not decide the VAT treatment of an incorrectly classified transaction.
What should an international company check now?
- Confirm whether the company has a French permanent establishment for VAT purposes.
- List the French VAT registrations used by the business.
- Map sales, services, imports, intra-Community acquisitions and reverse-charge transactions that touch France.
- Identify which transactions make the company liable for French VAT.
- Determine the company-size category used for the 2026 or 2027 timetable.
- Separate domestic e-invoicing obligations from e-reporting obligations.
- Choose an approved platform that supports the required data flow.
- Check that accounting and invoicing systems store the fields needed for transmission.
- Test the process before the first mandatory reporting period rather than waiting for a failed submission.
If the business already has a French company, the accounting setup should also be checked against the new invoice flow. Francosetup's accounting service in France can help organise the recurring accounting, VAT and reporting workstream around the obligations that apply to the company.
How does e-reporting connect with French VAT registration?
E-reporting does not replace VAT registration. A foreign business first needs to determine whether its activities require a French VAT number and which transactions are taxable in France. The reporting reform then determines how information about relevant transactions is transmitted to the administration.
For ecommerce businesses, stock location and marketplace flows can change the VAT analysis. The French marketplace VAT guide explains why stock, customer location and platform role should be mapped before the reporting process is configured.
Common questions about France's e-invoicing reform
Does every foreign company with a French VAT number have to receive French e-invoices?
No. A French VAT number alone does not automatically mean the company is established in France for the domestic e-invoicing rules. Non-established foreign companies have a separate e-reporting framework that depends on their transactions.
When do SMEs outside France start e-reporting?
For seller-side French VAT-liable transactions covered by the foreign-company rules, micro-enterprises, VSEs and SMEs move into mandatory e-reporting from 1 September 2027. Specific buyer-side obligations also expand from that date, so the transaction role must be checked.
Can the accounting software send the data directly?
The required data reaches the tax authority through an approved platform. Accounting or invoicing software can integrate with that platform, but the business should confirm the actual transmission architecture with its provider.
Is e-reporting the same as filing a French VAT return?
No. E-reporting is an additional data-transmission obligation. It does not remove the VAT returns, payments or other tax filings that apply to the business.