From 1 September 2026, a foreign company can have a French electronic-reporting obligation even when it has no French branch, no French office and no obligation to receive French electronic invoices. That distinction is the source of most implementation errors. A company selling to French consumers, a company invoicing a French business under the reverse-charge mechanism, and a company operating through a French permanent establishment do not follow the same path.

This guide is written for founders, finance directors and overseas parent companies that make French-taxable sales or services. It answers the practical question: what must be reported, through which channel, on which date, and what evidence should be kept when a French VAT record is rejected? The answer starts with the place of supply and the person liable for French value added tax, then moves to company size, identifiers and the approved platform.

The reform is not a replacement for the underlying French VAT rules. It is a new transmission layer built around them. A foreign seller should therefore map each transaction before selecting software. The map should show the customer’s status, the French VAT debtor, the relevant invoice or transaction data, the payment event and the evidence proving why the chosen treatment is correct. For the wider incorporation sequence, see this foreign-founder guide to setting up a company in France; this article addresses the narrower electronic-reporting decision that follows.

I. Does French e-invoicing apply to a foreign company selling in France?

A. When is the foreign company outside e-invoicing but inside e-reporting?

The first question is not whether the customer is French. It is whether the transaction falls within French VAT rules and who is liable for the tax. “E-invoicing” means the regulated electronic issue, transmission and receipt of an invoice between parties within the domestic scope of the reform. “E-reporting” means the electronic transmission to the French tax administration of transaction data, and in some cases payment data, where the transaction is not exchanged as a domestic French electronic invoice.

The principal statutory rule is in Article 289 bis of the French General Tax Code (Code général des impôts, CGI). It applies, by reference to Article 289, when the issuer and recipient are taxable persons established, domiciled or habitually resident in France for the operations covered by the provision. The operative sentence states: “L’émission, la transmission et la réception des factures électroniques s’effectuent en recourant à une plateforme agréée.” A plateforme agréée, commonly called an approved platform, is the platform authorised to perform the regulated exchange and transmission functions. The rule is not triggered merely because a foreign company has a French customer.

For a foreign company without a French permanent establishment, the official guidance of the French tax administration draws a different line. It explains that the company does not have a French electronic-invoice reception obligation. It may exchange invoices voluntarily through a provider or the Peppol network, but that voluntary choice should not be confused with a mandatory French reception channel. The distinction matters for a foreign parent that buys goods or services in France: it may need a process for collecting compliant invoices, but it does not automatically need to appoint a French reception platform because it is registered for French VAT.

The same company may, however, have to transmit transaction data. Article 290 of the CGI covers data transmission for operations located in France where a non-established taxable person is liable for the tax. The provision states that non-established taxable persons transmit data to the administration “par voie électronique”. The data may concern supplies of goods or services made in France, or supplies received for which the foreign company itself is the French VAT debtor. The practical consequence is simple: absence of a French establishment does not equal absence of a French reporting duty.

Three transaction families should be separated in the accounting system.

• Business-to-consumer sales. A foreign seller may be liable for French VAT on a sale to a private individual or another non-taxable person. Where the seller is using the European Union One Stop Shop, usually called the OSS, the special regime may exclude particular transactions from the French e-reporting flow. The seller should document the OSS treatment and should not send the same sale twice through two reporting channels.
• Business-to-business services subject to reverse charge. A foreign provider may invoice a French taxable customer without charging French VAT when the French customer is liable under the reverse-charge rule. In that case the customer or recipient bears the French reporting consequence identified by the tax administration. The supplier must still preserve the evidence supporting the customer’s taxable status, VAT identification and place of establishment.
• French-taxable supplies for which the foreign seller remains liable. Examples can include specific domestic supplies of goods, certain property-related services, or transactions that do not qualify for reverse charge. The foreign company must determine whether it needs a French VAT identification, a representative, a French return and e-reporting data. A VAT number alone does not decide every reporting question.

The place-of-supply analysis must be recorded before a platform is configured. Article 259 of the CGI begins its services rule with: “Le lieu des prestations de services est situé en France”. The rest of the provision distinguishes the customer’s economic seat, a stable establishment, domicile and habitual residence. A foreign company should therefore keep the contract, customer master data, VAT number, establishment information and the reason why the service is located in France or outside France.

Reverse charge is not a slogan that can be applied to every foreign invoice. Article 283 of the CGI states, for the relevant services, that “la taxe doit être acquittée par le preneur”. The preneur is the customer receiving the service. The supplier should verify the customer’s French VAT identification and taxable-business status, while the customer should be able to show why it declared the tax. If the invoice mentions French VAT incorrectly, the same Article 283 also makes the person who mentions VAT on an invoice liable for the tax solely because it was invoiced. A corrected invoice is then more than an administrative convenience.

Identification is the second layer. Article 286 ter of the CGI provides: “Est identifié par un numéro individuel”. In practice, the system may need the customer’s French SIREN, a nine-digit identifier for the legal unit, the SIRET, a fourteen-digit identifier for an establishment, a French VAT number or a foreign European Union VAT number. The French SIREN is not the same thing as the VAT number. The SIRET is not the same thing as the registration number printed in a foreign commercial register. Mapping these fields incorrectly can cause a technically valid invoice to fail a platform or administration check.

A foreign group should also test whether it has crossed the permanent-establishment boundary. For VAT purposes, a permanent establishment is assessed by reference to the human and technical resources that allow the business to receive or make supplies. A local warehouse, sales team or operating site can require a separate analysis from a French customer or a French VAT registration alone. The official tax-administration FAQ for foreign companies without a permanent establishment explains that the permanent-establishment question is a VAT concept. The board should not reuse an income-tax or corporate-law definition without checking the transaction.

The decision file for each flow should therefore answer five questions:

1. Where is the supply located under the French VAT place-of-supply rule?
2. Is the customer a taxable business, a private individual or another non-taxable person?
3. Who is liable for French VAT: the seller, the French customer or an intermediary?
4. Is the company established in France for the relevant VAT analysis, or is it a non-established company?
5. Does an OSS or another special regime remove the transaction from the French e-reporting channel?

That file is also the answer to an internal audit question. It shows that the company did not choose e-reporting simply because the customer’s address contained “France”. It connected the reporting result to the legal location of the operation and the person liable for VAT. The firm’s company-formation practice page is the broader service pillar for founders who need the corporate structure reviewed alongside the reporting flow.

B. Which deadline applies on 1 September 2026 and 1 September 2027?

The calendar depends on the category and size of the company. The official FAQ confirms that, from 1 September 2026, the first compulsory e-reporting population includes large foreign companies and intermediate-sized enterprises, known in French as entreprises de taille intermédiaire or ETIs, without a French permanent establishment when they make relevant transactions for which French VAT is due. From 1 September 2027, the obligation expands to foreign companies of every size for the taxable transactions covered by the reform. This makes 1 September 2026 a live compliance date for large groups and a preparation deadline for smaller businesses, even where their compulsory date is later.

Size is not calculated only from the company’s French turnover. The official guidance states that the size assessment is made at 1 January 2025 and takes account of the company’s global or international activity. A foreign group should preserve the figures and accounting perimeter used for that classification. A French subsidiary’s local turnover may be small while its legal entity belongs to a group whose statutory classification is materially different. The person signing the tax process should be able to explain which legal entity was classified and on what evidence.

The reform’s timing also separates receiving from issuing and reporting. A foreign company without a French permanent establishment generally has no compulsory French e-invoice reception duty. That does not postpone its transaction-reporting duty if its size and taxable activity place it in the 2026 population. Conversely, a small company may voluntarily prepare before 2027, but voluntary preparation should be labelled as such in the project plan. It should not be presented to the board as proof that the 2026 legal deadline applies to every foreign entity.

Payment reporting has its own trigger. Article 290 A of the CGI concerns payment data for operations covered by the electronic-invoice and transaction-reporting provisions when VAT becomes chargeable on collection. It expressly excludes operations for which the customer is liable for the tax, “à l’exception de celles pour lesquelles la taxe est due par le preneur”. Therefore, an accounts-receivable team must not transmit every cash receipt merely because a French invoice exists. It needs a payment-status rule tied to the VAT chargeability rule and the reverse-charge result.

Article 269 of the CGI supplies the chargeability framework for services and refers, in the relevant cases, to VAT becoming chargeable “lors de l’encaissement des acomptes, du prix, de la rémunération”. If the supplier has opted for a debit-based method or a special rule applies, the timing may differ. The accounting design should retain the tax point, the payment event, the chosen method and the exception code. A date extracted from the bank statement without that legal context is not a reliable reporting rule.

In addition to the date, the reform changes the data expected in the transaction. The official tax guidance describes two streams: transaction data and payment data. Transaction data may cover the identity of the parties, the taxable amount, the VAT rate, the nature of the operation and the place of supply. For a foreign company without a SIREN, the administration’s guidance explains that the foreign European Union VAT number, or another foreign identifier where relevant, may be used instead of a French SIREN. The system must not create a fictitious French identifier merely to satisfy a mandatory field.

Decree no. 2026-677 on electronic invoicing and electronic transmission of transaction data updates the regulatory framework that supports the reform and entered into force on 1 September 2026. It should be read with the CGI provisions and the technical specifications rather than treated as a replacement for them. A software supplier’s generic “France e-invoicing” label is not a legal classification. The company should ask which data the product transmits, on behalf of which entity, under which role and for which tax regime.

The deadline decision can be reduced to a controlled table in the group’s tax calendar:

• 1 September 2026: large companies and ETIs without a French permanent establishment must assess their relevant French-taxable supplies and reporting channels. They should have selected and tested the approved platform where mandatory transmission applies.
• 1 September 2027: the obligation reaches foreign companies of smaller size for the covered taxable transactions, and the wider population of non-established recipients liable to French VAT must be considered.
• Every month or at the applicable frequency: transaction data must be reconciled with VAT returns, invoices, credit notes and OSS or reverse-charge records.
• At collection where applicable: payment data must follow the chargeability rule, subject to reverse-charge and other exclusions.

The company’s written calendar should also include a fallback for a platform outage, a late customer VAT number, a credit note issued after the reporting cut-off and a change in the customer’s establishment. Each event needs an owner. Otherwise a deadline that appears simple on paper becomes a manual spreadsheet exercise with no evidence of who validated the tax treatment.

The commercial contract deserves a short review as well. If the foreign seller’s terms promise “French-compliant e-invoices” without identifying whether that means domestic e-invoicing, voluntary receipt or e-reporting, the promise is ambiguous. The contract should state the legal entity invoicing, the VAT treatment, the customer data required, the approved platform or provider used for transmission and the process for correction. This protects the company when the customer’s procurement portal uses a different vocabulary from French tax law.

II. How should a foreign company prepare its French VAT and e-reporting file?

A. Which platform, identifiers and evidence must be prepared?

Platform selection should follow the legal map, not lead it. The French tax administration explains that an approved platform is the actor authorised to send and receive electronic invoices and transmit the relevant transaction and payment data. Its official platform guidance warns that compatible invoicing software, by itself, cannot perform the regulated transmission unless it operates through the authorised channel. A foreign company can keep its existing enterprise-resource-planning system, but it must identify the interface or provider that actually carries the French tax transmission.

The platform contract should be tested against the company’s legal entities. A provider may support French domestic invoices for the subsidiary but not e-reporting for the overseas parent. It may accept a French VAT number but not a foreign European Union VAT number when the company has no SIREN. It may support invoice data but not payment data. These are separate capabilities. The procurement file should include a written answer for each entity, transaction family and reporting stream.

Every identifier should have a source and a validation date. The French one-stop portal for business formalities, the Guichet unique or GU, is operated by the National Institute of Industrial Property, known as INPI. The GU feeds the National Business Register, the Registre national des entreprises or RNE, and other public bodies use the resulting information. The company should not treat a filing acknowledgement from the GU as the same document as a final registry extract.

For a French subsidiary, the master data pack may include the legal name, registered office, SIREN, SIRET, French VAT number, registration in the Register of Commerce and Companies (registre du commerce et des sociétés, RCS), the Kbis extract and the contact point for the court registry, called the greffe. For the foreign parent, the pack may instead include its legal name as registered abroad, foreign registration number, country of establishment, European Union VAT number where available, French VAT number if any, and a statement confirming whether it has a French permanent establishment. The two packs should never be merged simply because the entities share a brand name.

Article 289-0 of the CGI confirms that the French invoicing rules apply to operations situated in France, subject to stated exceptions, including situations in which a foreign European Union supplier and the French customer are arranged so that the customer is liable for the tax. The legal exception is not a reason to remove all invoice controls. It is a reason to make the invoice show the correct reverse-charge treatment and to retain the evidence supporting it.

Article 289 of the CGI remains the anchor for the invoice obligation and mandatory invoice information. A foreign company should reconcile the French invoice template with its home-country template instead of assuming that a foreign invoice is sufficient. The French template should be able to show the parties’ legal identities, their relevant identifiers, the date, the nature and quantity of the supply, the taxable amount, the applicable VAT treatment and the reason for reverse charge or exemption when used.

The official Service Public Entreprendre guide to mandatory invoice information is useful for the operational checklist. It explains the difference between the seller, the customer, pre-tax amounts and amounts including VAT, and lists the information that must appear in the invoice. A company being incorporated should be particularly careful: an invoice issued during the registration process must be in the company’s name with the registration identifier shown as being assigned where appropriate, rather than in the founder’s personal name. That control is relevant to overseas founders who sign French contracts before the subsidiary has received its final identifiers.

The evidence pack should be designed as if a reviewer knew nothing about the transaction. For each recurring flow, retain:

1. the signed contract or order showing the customer, supplier, service and delivery terms;
2. the customer’s VAT number and the date and source of its validation;
3. the customer’s status as a taxable business or non-taxable person;
4. the place-of-supply analysis under Article 259 or the applicable goods rule;
5. the invoice, credit note and any correction history;
6. the French VAT return or reverse-charge record showing who declared the tax;
7. the transmission acknowledgement from the approved platform; and
8. payment evidence, or the reason payment data was excluded.

Identifiers must also be governed through change management. If the customer changes its registered office, business unit or VAT number, the company should preserve the old value on historical invoices and apply the new value only from the validated effective date. If a foreign parent transfers the contract to a French subsidiary, the invoice issuer changes even when the customer and sales team remain the same. A master-data ticket with an effective date is safer than an informal email to the accounts-receivable team.

Companies that use a French VAT representative should make the mandate visible in the evidence file. The representative’s role, the entity represented and the transactions covered should be distinguished from an accountant’s software-support role. A software provider can transmit data without becoming the legal debtor of French VAT. The board minutes, tax registrations and platform account should all identify the same taxable entity.

Security and delegation should be checked before production. The user account that selects a platform, validates a VAT number or sends a correction should be attributable to a person or controlled service account. A group should retain the transmission receipt, response code, timestamp and payload version. Screenshots without the underlying receipt may show that a user clicked a button but not what data was actually transmitted. The retention policy should cover the French tax limitation period applicable to the company’s records, with the final period confirmed by the company’s French tax adviser.

Finally, reconcile three totals: the total of invoices issued, the total of transaction data transmitted and the total of French VAT reported or reverse-charged by the liable party. Differences can be legitimate, such as credit notes, OSS transactions, exempt supplies or payment-based chargeability. They should nevertheless carry a reason code and a document. A zero-difference reconciliation is not the goal; an explainable difference is.

B. What should the company do when a French invoice or VAT record is rejected?

A rejection should be classified before anyone edits the invoice. The first category is a technical rejection: a missing field, an invalid date, a malformed identifier, a duplicate transmission or a platform schema error. The second is a master-data rejection: the legal name, SIREN, SIRET or VAT number does not match the selected entity. The third is a legal-treatment rejection: the platform or customer disputes the place of supply, the reverse-charge flag, the VAT rate or the OSS exclusion. The fourth is an evidence rejection: the data may be technically accepted, but the company cannot prove why the treatment was chosen.

Do not solve a legal-treatment rejection by changing a code until the transaction has been reanalysed. Article 259 may place a service in France, while Article 283 may make the French customer liable for the tax. A different result applies if the customer is not a taxable person, if a French establishment receives the service, or if the service belongs to a specific place-of-supply category. The correction note should identify the rule, the facts and the document supporting the conclusion.

The French tax litigation shows why the evidence file matters. In Conseil d’État, 26 September 2019, no. 415916, the official decision considered invoices and the reality of the underlying services; the decision records that “les factures produites ne correspondaient pas à des prestations réelles”. The lesson for a foreign company is not that an invoice is irrelevant. It is that an invoice cannot by itself prove that the described service was actually performed. Keep deliverables, correspondence, project records, acceptance evidence and the link between the invoice and the French-taxable operation.

In Conseil d’État, 2 April 2003, no. 233375, the court examined the conditions for deducting VAT and required invoices to correspond to the actual service. Its wording refers to invoices “qu’elles correspondent effectivement à l’exécution de la prestation de service dont elles font état”. A foreign company should apply that principle to its own purchase records and sales records: the document, the contractual party, the service and the amount must describe one real operation.

An identifier error should be corrected transparently. In Conseil d’État, 30 December 2010, no. 316022, the court held, in the context of an exemption, that “l’absence de mention de ce numéro sur une facture ne saurait entraîner à elle seule la perte du droit à exonération”. That does not authorise a company to omit required data systematically. It shows that a missing VAT identifier must be assessed with the surrounding evidence rather than treated as an automatic answer in every case. The correction file should record the customer’s valid number, the validation result, the affected invoices and the reason the initial field was absent.

A fourth useful warning comes from Conseil d’État, 31 May 2021, no. 441762. The official decision did not regard a small set of invoices as sufficient proof of the reality of services performed in France. A recurring cross-border flow should consequently have a recurring evidence process. One contract copied across hundreds of invoices may establish the framework, but it should be supplemented by delivery, performance or acceptance records for the relevant period.

The remediation workflow should be short and auditable:

1. freeze the rejected payload and record the platform’s code, message, timestamp and affected invoice;
2. identify whether the error is technical, master-data, legal treatment or evidence-related;
3. reconstruct the transaction facts from the contract, customer data, tax registration and payment record;
4. obtain a corrected customer identifier or corrected invoice where the facts support it;
5. send a correction or cancellation and reissue through the approved platform, keeping the original and new references;
6. reconcile the corrected data with the French VAT return, reverse-charge record or OSS report; and
7. close the incident only after the platform acknowledgement and the accounting reconciliation have been stored together.

Where a French customer refuses an invoice because its procurement portal does not recognise a foreign entity, the company should separate commercial acceptance from tax compliance. Ask the customer which data is missing and whether the issue concerns its own incoming-invoice process or the French administration’s reporting requirement. A foreign company without a French permanent establishment may be outside mandatory French invoice reception, yet the customer may still require a PDF or a structured invoice under the commercial contract. The two obligations can coexist without turning a voluntary exchange into a statutory French reception duty.

Where the company discovers that it charged French VAT when the customer should have reverse-charged it, stop issuing the same invoice pattern and assess the correction process. The amount shown as VAT can create liability under Article 283 even if the commercial parties intended reverse charge. The finance team should issue the legally appropriate correction, notify the customer, update the return or claim process and preserve the reason for the change. The priority is to make the invoice, the return and the reporting transmission tell the same story.

Where the company discovers the opposite error, namely that it used reverse charge even though it was the French VAT debtor, the response should be equally controlled. Identify the affected dates and customers, review whether VAT registration or a fiscal representative was required, calculate the tax and interest exposure with French advice, and correct the invoices and declarations. Do not silently replace the invoice PDF while leaving the original platform payload and VAT return unchanged.

Management reporting should measure the quality of the process. Useful indicators include the percentage of French-taxable transactions with a documented place-of-supply decision, the percentage with validated customer identifiers, rejected payloads by cause, time to resubmit, unreconciled amounts, payment data missing at the chargeability date and the number of invoices corrected after customer challenge. The indicator should identify the legal entity and flow, not only the software account. A group-wide acceptance rate can hide a failure concentrated in the overseas parent’s French sales.

Before 1 September 2026, a large foreign company should run at least one complete test from order to tax reporting. The test should include a French business customer under reverse charge, a French consumer sale where French VAT is due, a credit note, a payment received after the invoice date and a deliberately invalid identifier. It should verify which cases are reported, which are excluded, what the platform acknowledgement says and how the accounting ledger reconciles. Smaller companies should use the same test before 1 September 2027, even if they choose not to activate voluntary transmission immediately.

The board pack for the project can be concise but should contain five signed decisions: the classification of each foreign legal entity, the transaction flows in French scope, the person liable for French VAT, the approved platform and backup process, and the owner of rejected-data remediation. Attach the official guidance, the relevant CGI articles and the test evidence. This gives the company a defensible record when a customer, auditor or tax officer asks why the company did not issue a domestic French electronic invoice for a transaction it reported through e-reporting.

Conclusion

For a foreign company selling in France, the decisive question is not whether the business has a French customer or a French VAT number. It is whether the operation is located in France, who is liable for French VAT, whether the company is established in France for the relevant VAT analysis, and whether a special regime such as OSS applies. A non-established foreign company may have no compulsory French e-invoice reception duty while still having to transmit transaction or payment data.

The safe preparation sequence is to map the flows, classify the company at global level, validate the legal entity and identifiers, choose an approved platform that supports the correct reporting role, test reverse-charge and taxable-sales cases, and preserve the evidence behind every exception. The 1 September 2026 deadline affects large foreign companies and ETIs in the first population; 1 September 2027 brings smaller foreign companies into the wider obligation. Rejections should trigger a documented legal and data review, not an unexplained change to an invoice code.

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