From September 1, 2026, the French reform of electronic invoicing will come into effect. While all VAT-registered businesses are affected, foreign companies without a permanent establishment in France are subject to a specific regime. Here are the key points to remember.
E-invoicing: Are foreign companies affected?
Foreign companies without a permanent establishment in France are not subject to e-invoicing. Therefore, they are not required to:
- to the obligation to issue electronic invoices via an approved platform,
- to the obligation to receive electronic invoices.
Even if they have a SIREN number and are listed in the directory, this does not create an obligation to e-invoice.
On the other hand: obligation of e-reporting
Foreign companies without a permanent establishment in France may be subject to e-reporting of transactions (and sometimes payments) when they carry out operations located in France for which they are liable for French VAT.
Examples of operations concerned:
- Sales of goods in France (B2C)
- Internal sales in France
- Services subject to tax in France
- Remote sales outside of OSS
- Intra-Community acquisitions and reverse charge transactions from 1 September 2027:
Intra-Community deliveries (LIC) and exports are excluded.
Implementation schedule for electronic invoicing in France
- September 1, 2026: Mandatory e-reporting for large companies and mid-sized companies
- September 1, 2027: obligation for very small businesses, SMEs and micro-enterprises
From September 1, 2027, the scope is extended to cases where the non-established taxable person is liable for VAT as a purchaser or lessee.
What data should be transmitted?
Depending on the nature of the operations, the following will need to be transmitted:
- Base prices excluding VAT per VAT rate
- VAT amounts
- Date of payment and amounts received (if VAT is due upon receipt of payment)
Should you choose an approved platform for electronic invoicing in France?
Yes, to comply with the e-reporting obligation.
The choice must be made before the applicable effective date (2026 or 2027).
The sanctions
In case of non-transmission:
- A fine of €500 per transmission, capped at €15,000 per year
A right to make a mistake is provided in the event of a first regularization within 30 days.
Key points to remember
Foreign companies without a permanent establishment are not affected by e-invoicing, but may be subject to e-reporting from 2026.
Analyzing VAT flows in France and anticipating platform selection are essential for ensuring compliance. Eurotax assists you with your VAT-related procedures in France. You can visit our VAT page here. You can also contact us if you have any questions.
