Starting September 1, 2026, large French companies and mid-sized enterprises will be required to issue electronic invoices and submit their e-reports. As of that same date, all affected companies—regardless of size—must be able to receive electronic invoices. SMEs, very small businesses, and micro-enterprises will be subject to the e-invoicing and e-reporting requirements starting September 1, 2027. For a company that operates across borders, the distinction between e-invoicing and e-reporting becomes an operational headache: which transactions fall under which requirement, and how can redundancies be avoided? An Approved Platform (PA) such as Docoon Invoice makes it possible to organize these various data flows, verify the data, and transmit it in accordance with the reform’s requirements.
E-invoicing and e-reporting: Two Requirements, One Framework
E-invoicing: Structured Invoicing Between French Companies
E-invoicing applies to invoices exchanged between VAT-registered entities established in France. A VAT-registered business established in France that invoices another VAT-registered business established in France issues a structured electronic invoice, which is transmitted via the supplier’s and customer’s approved platforms. The data required by the tax authorities is extracted by the platform and then transmitted to the data hub (formerly PPF). The format is standardized, traceability is ensured, and the tax authorities retrieve the data directly.
E-reporting: What E-invoicing Doesn't Cover
E-reporting primarily covers B2C sales in France, relevant international B2B transactions, and payment data related to transactions for which VAT is due upon receipt of payment, including certain services and advance payments. Payment e-reporting does not apply when the business has opted to pay VAT based on debits or when the transaction is subject to reverse charge.
For electronic transaction reporting, the filing frequency depends on the company’s VAT regime: it can be decadal, monthly, or bimonthly, depending on the situation. In B2C, data is aggregated daily, specifically by VAT rate, but this daily granularity does not mean that it is transmitted every day. Payment data follows a separate transmission schedule. There are multiple data sources (point-of-sale systems, e-commerce platforms, ERP systems), and the VAT rules applicable to international transactions add another layer of complexity.
Certain transactions that fall outside the scope of e-invoicing are also excluded from e-reporting: imports of goods; certain transactions that are exempt or exempt from invoicing under Articles 261 through 261 E of the General Tax Code (CGI); B2C transactions carried out by a business not established in France that is registered with a European VAT OSS/IOSS portal, provided they meet the conditions of the relevant regime; and transactions falling under special cases related to national defense or national security.
E-reporting is not limited to filing a report. It complements e-invoicing by covering transactions that do not generate a mandatory electronic invoice, though it does not cover everything. For an international company, e-reporting often involves the greatest amount of work and risk.
Billing a Foreign Customer: E-Invoicing or E-Reporting?
Does a French company that bills a customer abroad need to use e-invoicing or e-reporting? French e-invoicing requirements do not apply; however, the transaction may be subject to e-reporting depending on its nature and territorial scope. Here is a breakdown, situation by situation, of which requirement applies in each case.
Cross-border B2B Sales
A French company that sells to a foreign company does not issue an electronic invoice as defined by the French reform. However, international transactions that fall within the scope of the system must be reported via e-reporting. This applies in particular to exports outside the EU, intra-Community deliveries, and services provided to customers established abroad. When no French VAT is charged, the classification provided must correspond to the nature of the transaction and the applicable territoriality rules.
Conversely, a supplier not established in France that invoices a French company is not subject to French e-invoicing. However, not all purchases made from this supplier are subject to e-reporting. This includes, in particular, intra-Community acquisitions subject to VAT in France and certain transactions subject to VAT in France for which the French purchaser is liable for VAT under the reverse charge mechanism. Imports of goods, on the other hand, are excluded from e-reporting.
B2C Sales and International Customers: Scattered Data Collection
Sales to individuals made in France (retail outlets, e-commerce, mobile apps) are subject to e-reporting. Sales to foreign customers—whether individuals or businesses—are subject to e-reporting when they fall within the scope of the system. Their treatment depends on the nature and territorial scope of the transaction as well as, for certain B2C sales, the VAT reporting procedures.
For the CFO, the challenge is clear: this data is scattered across heterogeneous systems (point-of-sale systems, ERP systems, marketplaces, payment solutions), each with different formats and VAT rules.
Summary Table of International Casesl
Location | E-invoicing | E-reporting | Clarification |
B2B transaction falling within the scope of the reform between taxable persons established in France | ✅ Yes | ❌No | Mandatory electronic invoicing via a PA |
Sale to a foreign customer (business or individual) | ❌No | ✅ Yes | Relevant international transactions, including exports and intra-Community shipments. Transactions that are exempt or exempt from invoicing under Articles 261 through 261 E of the General Tax Code remain outside the scope of this provision. |
Purchase from a supplier not based in France | ❌No for the supplier | ⚠️Depending on the transaction for the French buyer | Intra-Community acquisitions subject to tax in France and certain reverse-charged transactions: yes; imports of goods: no |
B2C Sales in France (Retail, E-commerce) | ❌No | ✅ Yes | Cumulative data by day: pre-tax bases and VAT amounts broken down by rate, date, and transaction category. |
A company with its headquarters abroad but established in France for VAT purposes | ⚠️Depending on the operation | ⚠️Depending on the operation | French B2B transactions covered by the reform fall under e-invoicing. Affected B2C or international transactions may fall under e-reporting. |
A foreign company not established in France for VAT purposes, regardless of whether or not it is registered for VAT in France | ❌No | ⚠️ Depending on the operation | It is subject to e-reporting for transactions deemed to be located in France for which it is liable for French VAT. In all other cases, it is outside the scope of the requirement. |
Payment for a French B2B service for which VAT is due upon receipt of payment | ✅ Yes | ✅ Yes | Excludes the option to pay VAT based on debits and excludes reverse charge. The invoice is subject to e-invoicing; the receipt date, the amount received including tax (broken down by VAT rate), and the invoice number are transmitted via e-reporting for payments. |
Payment for a B2C or international service subject to French VAT, for which the tax becomes due upon receipt of payment | ❌No | ✅ Yes | Excluding the option to pay VAT based on debits and excluding reverse charge. The data submitted includes the date of receipt, the amount received including tax broken down by VAT rate, and, if applicable, the invoice number. |
Centralize e-invoicing and e-reporting with Docoon
A single repository for all your data streams
An ERP system like Docoon Invoice does more than just transmit files. It consolidates e-invoicing and e-reporting workflows from the company’s various business applications into a single environment, including e-reporting workflows related to B2C and international operations.
Streamline data collection and ensure compliance
Docoon focuses on three operational functions:
- the centralization of data flows from ERP systems, point-of-sale software, e-commerce solutions, and payment tools;
- checking data quality and compliance to identify duplicates, inconsistencies, or missing information before the data is sent;
- the transmission of data in the required formats and in accordance with the applicable regulatory frequencies and deadlines.
Beyond compliance, this system also serves as a tool for business management. For example, reconciling B2C sales with cash receipts enables the CFO’s office to more quickly identify discrepancies between reported amounts and amounts actually received.
6 Key Points to Remember
- E-invoicing applies to B2B invoices between taxable entities established in France; e-reporting supplements the system for certain B2C and international transactions, as well as certain payment data.
- Internationally, the treatment depends on the nature and territorial scope of the transaction, the location of the businesses, and the party liable for VAT.
- Not all purchases from foreign suppliers are subject to e-reporting: imports of goods, in particular, are excluded.
- The daily aggregation of B2C data does not mean that it must be uploaded every day.
- Filings must comply with the formats, frequencies, and deadlines applicable to the company’s VAT regime and the nature of the data being submitted.
- Docoon combines e-invoicing and e-reporting into a single platform connected to business applications, transforming a regulatory requirement into a management tool.
Frequently Asked Questions
1. Is a foreign supplier that invoices a French company required to use e-invoicing?
No. A supplier not established in France is not subject to the French e-invoicing requirements. On the buyer’s side, only certain transactions are subject to e-reporting, notably intra-Community acquisitions subject to tax in France and certain transactions giving rise to reverse-charge VAT. Imports of goods are excluded.
2. Is a foreign company registered for VAT in France automatically required to use e-invoicing?
No. VAT registration in France is not sufficient. The treatment depends, in particular, on whether the company is established in France for VAT purposes, the territoriality of the transaction, and who is liable for the tax.
3. Does B2C sales data need to be reported daily?
No. They are aggregated by day, but the frequency of filing depends on the company’s VAT regime. It can be every ten days, monthly, or bimonthly.
4. Which transactions and which data are covered by electronic payment reporting?
This applies to transactions for which VAT is due upon receipt of payment, excluding transactions subject to the debit option and reverse-charged transactions. The required data includes, in particular, the date of receipt, the amount received (including VAT) broken down by VAT rate, and, if applicable, the invoice number.
⏩E-invoicing, e-reporting, international data flows, payment data: Request a demo with the experts at Docoon to ensure the secure processing and transmission of your data.
