France: Proposed simplification and tolerance measures for e-invoicing and e-reporting reform

The French tax authorities (FTA) have published a letter proposing new simplification and tolerance measures to support the implementation of the country’s electronic invoicing (e-invoicing) and electronic reporting (e-reporting) reform. In addition, the letter also proposes certain compliance obligations for non-established entities registered for value added tax (VAT) in France.

These measures are still pending formal implementation, either through the Finance Bill 2026, which is set to be discussed in parliament this fall, or through updates of guidance and external specifications.

Background

France will roll out a nationwide e-invoicing and e-reporting mandate in phases starting September 1, 2026, when all VAT-registered businesses established in France must be able to receive e-invoices, and large and intermediate businesses must start issuing e-invoices and submitting e-reporting. Small and medium businesses must issue e-invoices and submit e-reporting beginning September 1, 2027.

Companies will connect through certified private platforms (PDPs), while the tax authority (DGFiP) operates a central directory and a data concentrator to route and collect information. The reform covers domestic business-to-business (B2B) invoicing and requires separate e-reporting for consumer (B2C) and cross-border transactions, giving the DGFiP near real-time visibility to reduce fraud and improve VAT administration.

Non-established entities with a French VAT number are also subject to certain e-reporting obligations (for sales and purchases), particularly for domestic sales to B2C, for domestic purchases and intra-EU acquisitions for which they are liable for VAT.

Proposed measures

Terminology updates

To harmonize the provisions of the law with the proposed measures, certain terms would be updated:

• The “Partner Dematerialisation Platform” will be referred to as the “Partner Platform” (Plateforme Agréée – PA).
• The term “public invoicing portal” will no longer be used; the public platform will only collect data from PAs for transmission to the FTA.

Simplification measures

• Removal of line-by-line detail requirement for incoming international flows in e-reporting.
• No obligation to report the number of B2C transactions in e-reporting.
• No requirement to submit a blank e-report when no reportable transactions occur.
• Exclusion of e-reporting for operations outside the EU between taxable persons established in France, as these fall under foreign VAT regimes.
• Abandonment of new data blocks for transmission: Certain new data blocks that were initially planned to be transmitted to the tax authorities would no longer be required. This measure reduces the compliance burden for businesses and approved platforms and helps preserve IT development timelines. It does not require legislative or regulatory changes.

Tolerance measures

• Simplified calculation method for margin scheme VAT (B2C): For B2C transactions subject to the margin scheme, a simplified method for calculating VAT is permitted within e-reporting. This reduces calculation complexity for businesses, with the option to adjust later via their VAT return. This measure is doctrinal and does not require legislative or regulatory changes.
• Exclusion from penalties for entities without SIREN: Entities lacking a French SIREN number, and therefore not included in the invoice recipient directory, would not be subject to sanctions. This tolerance is doctrinal and will be clarified in official frequently asked questions (FAQs) and guidance.
• Tolerance for entities with SIREN not yet in directory: Entities that have a SIREN number but are not yet integrated into the invoice recipient directory due to administrative or technical reasons would also benefit from a tolerance regarding sanctions. This is a doctrinal measure and will be detailed in official FAQs and guidance.

New digital reporting obligations for nonresidents

The recent measures introduced by the French tax authorities significantly affect companies that are not established in France but hold a French VAT registration. Non-established entities have had limited e-reporting obligations in France, primarily relating to their sales activities. However, under the proposed measures, these entities would be required to comply with the new digital e-reporting requirements for the following transactions:

• Domestic purchases subject to reverse charge: When a non-established entity purchases goods or services within France and is liable for VAT under the reverse-charge mechanism, these transactions must be reported electronically to the French tax authorities via e-reporting. This ensures that the DGFiP has visibility over VAT liabilities arising from domestic purchases, even when the supplier is not responsible for collecting the tax.
• Intra-community acquisitions (ICA): Non-established entities making ICAs in France (such as moving own goods from another EU country or purchasing goods from EU suppliers) would also be required to report these transactions electronically. This is a significant change, as it brings cross-border flows by non-residents into the scope of French e-reporting.

Recognizing the additional compliance burden, the DGFiP would require non-established entities to report domestic purchases subject to reverse charge or ICA only starting from September 1, 2027, even if they qualify as large or medium-size entities (subject to the September 1, 2026, rollout).

For further details, contact a KPMG tax professional:

Laurent Chetcuti | laurentchetcuti@kpmgavocats.fr

Armelle Courtois-Finaz | acourtois-finaz@kpmgavocats.fr

Lyubov Skenderova | skenderova.lyubov@kpmg.com

Philippe Stephanny | philippestephanny@kpmg.com

Ramon Frias | ramonfrias@kpmg.com