With VAT e-reporting 2026, B2B e-invoicing has grabbed most of the headlines, but it only covers part of the picture. Everything that falls outside the scope of domestic B2B e-invoicing (sales to individuals, intra-EU trade, exports outside the EU, service transactions) sits beyond the reach of e-invoicing. That is where VAT e-reporting comes in, as the second pillar of the reform: businesses must transmit data on these transactions to the French tax authority (DGFiP) so it can reconstruct VAT in near real time. From 1 September 2026, the first businesses must comply, or face a fine of €250 per missing submission. This article breaks down the scope, the timeline, the penalty, and the steps to take before the deadline.
- E-reporting covers everything that B2B e-invoicing does not: B2C sales, intra-EU transactions, extra-EU transactions, and service transactions.
- 1 September 2026 is the go-live date for large companies and mid-market companies (ETI). SMBs and micro-businesses follow on 1 September 2027, with the option to start early.
- The penalty compounds quickly: €250 per missing submission, subject to an annual cap, which is exactly why early automation pays off.
VAT E-Reporting: What Does It Actually Mean?
VAT e-reporting is the obligation to transmit detailed transaction data to the tax authority for any transaction that does not travel through mandatory e-invoicing. In plain terms: whenever a transaction falls outside the scope of domestic B2B e-invoicing, the business must send a structured summary to the DGFiP. The stated goal is to give the tax authority a near real-time view of VAT collected, making audits more reliable and fraud detection faster[1].
The legal basis is Article 290 of the French General Tax Code (CGI), an extension of the September 2021 ordinance that mandated the rollout of e-invoicing. In practice, e-reporting does not mean sending a full invoice: it is a normalised data stream (identifier, date, transaction type, pre-tax amount, VAT amount and rate), transmitted via the Public Invoicing Platform (PPF) or an accredited Partner Dematerialisation Platform (PDP)[2].
Scope: B2C, Intra-EU, Extra-EU and Services
The boundary with e-invoicing defines the scope of e-reporting. Four categories of transactions are in scope[3]:
| Transaction type | Examples | Transmission format |
|---|---|---|
| Domestic B2C | Sales to individuals, non-taxable associations | Aggregated data by VAT rate |
| Intra-EU | Sales and acquisitions between EU member states | Detailed data + EU VAT number of the counterparty |
| International (extra-EU) | Exports outside the EU, services to foreign clients | Detailed data + identifier of the non-established party |
| Service transactions | Taxable services where VAT is due on receipt of payment | Transaction e-reporting + payment e-reporting |
The important nuance concerns B2C: unlike B2B where each invoice is transmitted individually, sales to consumers are reported on an aggregated basis. You do not submit each individual receipt. You transmit a total per VAT rate and the corresponding VAT amount[3]. For an e-commerce business processing thousands of B2C sales per day, this is what makes the obligation manageable. Cross-border transactions, however, require a finer level of detail and the tax identifier of the counterparty.
If it is not a domestic B2B invoice, it is almost certainly e-reporting. The rule of thumb: individual consumer, EU client, non-EU client, or service transaction → an e-reporting stream is required.
Who Is Affected by VAT E-Reporting in 2026?
Every VAT-registered business established in France is in scope, regardless of size. Foreign businesses registered for VAT in France without a permanent establishment are also subject to the obligation[4]. What varies is the effective date, which is tied to company size:
From 1 September 2026, all VAT-registered businesses must also be able to receive electronic invoices. This is the concurrent obligation that applies across the board. SMBs and micro-businesses have an extra year before they must emit and e-report, but starting early in 2026 is both possible and advisable: getting set up before the wave hits avoids the September 2027 rush[3].
The Penalty: €250 per Missing Submission
This is where things get serious. The ordinance provides for a fine for failure to comply with e-reporting and payment data submission obligations: it is set at €250 per missing submission, subject to an annual cap[5]. On top of that, a surcharge of €1,000 every three months may apply for as long as the situation remains unresolved, under the standard rules governing declarative obligations[6].
The real trap is the mechanics: submission frequency follows the company's VAT filing regime. Under the standard monthly regime (CA3), companies submit monthly, up to three transmissions per month depending on the business profile[7]. Under the simplified annual regime (CA12), it is annual. A company on monthly filing that misses several submissions in a year will accumulate fines quickly. That is precisely the kind of exposure that automation eliminates.
The fine is counted per missing submission, not per year. On a monthly schedule, twelve missed submissions in a year adds up to far more than a single flat penalty, which is why getting the data flow right from day one matters.
How E-Reporting Relates to B2B E-Invoicing
The two obligations are two sides of the same reform. E-invoicing covers the domestic B2B invoice (between French VAT-registered businesses): the invoice itself travels in a structured format via a platform. E-reporting covers everything else: it transmits a data summary, not the commercial document itself[8]. A business that invoices both professional clients and consumers will run both regimes in parallel, which is why a single tool that handles both data streams beats stacking separate solutions.
On the technical side, both share the same gateway: the DGFiP's PPF or an accredited PDP. A business already set up for B2B e-invoicing therefore has a head start: it simply needs to activate the e-reporting module on the same infrastructure. For those still weighing up format and 2026 timeline decisions, now is the right moment to act while there is still time to do it properly.
Getting Ready Before September 2026
Five steps cover the compliance journey, in order:
1. Map your in-scope transactions. List your B2C sales, intra-EU and extra-EU transactions, and service transactions. This picture of the scope drives everything else. Companies regularly discover at this stage that they have more cross-border flows than they realised.
2. Choose your transmission channel. The DGFiP's free PPF, or a private accredited PDP with added services (archiving, accounting integration, multi-country management). The decision turns on volume, flow complexity, and existing software.
3. Format your data correctly. E-reporting streams are standardised. Your accounting system or invoicing tool must produce the required fields (identifier, date, type, pre-tax amount, VAT amount, rate). This is typically where the technical work lives.
4. Test before the deadline. The DGFiP opens testing periods. Proactive businesses connect several months ahead to stress-test the process and catch anomalies without pressure.
5. Automate. Once the data stream is validated, set it to run at the correct frequency without manual intervention. That is what eliminates exposure to the fine — a person who forgets a deadline is still a person.
On the procurement side, the stakes go beyond mere compliance. A supplier procurement solution that structures invoice data upstream naturally simplifies producing e-reporting streams: the information is already clean, dated, broken down by rate, and ready to transmit. It is far better to get the data right at the source than to reconstruct it under pressure at every deadline.
The Frequency Trap
We touched on this above, but it deserves a closer look. A company on the standard monthly VAT regime submits every month; one organisational slip on a single month triggers a fine, and the cycle repeats if nothing is corrected. Service transactions add another layer: their VAT is often due on receipt of payment, which triggers a payment e-report on top of the transaction e-report[7]. For a services business that gets paid in instalments, that is two data streams to keep in sync — a situation where automation is not a convenience, but a necessity.
Frequently Asked Questions
What is VAT e-reporting?
It is the obligation to transmit data on transactions outside the scope of domestic B2B e-invoicing to the DGFiP: B2C sales, intra-EU and extra-EU transactions, and service transactions. This gives the tax authority a near real-time view of VAT[1].
When does VAT e-reporting take effect?
1 September 2026 for large companies and mid-market businesses (ETI); 1 September 2027 for SMBs and micro-businesses, with the option to start early in 2026[3].
What is the fine for a missing submission?
The ordinance sets a fine of €250 per missing submission, subject to an annual cap. An additional surcharge of €1,000 every three months may apply until the situation is resolved[5].
What is the difference between e-invoicing and e-reporting?
E-invoicing covers the domestic B2B invoice, which travels in a structured format. E-reporting covers everything else (B2C, intra-EU, extra-EU, services) and transmits a data summary, not the invoice document itself[8].
How are e-reporting submissions transmitted?
Via the DGFiP's free Public Invoicing Platform (PPF), or via an accredited Partner Dematerialisation Platform (PDP) that adds services such as archiving and accounting integration[2].
Do B2C sales need to be submitted individually?
No. B2C sales are reported on an aggregated basis: you submit a total per VAT rate and the corresponding VAT amount, without a line-by-line breakdown. Intra-EU and extra-EU transactions, however, require a more detailed submission[3].
Pillar guide: this article is part of our e-invoicing and procurement white paper, which connects e-invoicing, e-reporting, PDP/PPF, and supplier workflow automation.
References
- DGFiP, Transaction data transmission (e-reporting). Near real-time VAT visibility objective for the tax authority. impots.gouv.fr. ↩
- France Num, E-invoicing: guide to VAT e-reporting data. Transmission via PPF or accredited PDP, Article 290 of the CGI. francenum.gouv.fr. ↩
- DGFiP / France Num, E-reporting scope (aggregated B2C, intra-EU, extra-EU, services) and 2026-2027 rollout timeline. impots.gouv.fr (e-reporting fact sheet). ↩
- DGFiP, E-reporting for foreign businesses without a permanent establishment in France. impots.gouv.fr. ↩
- Légifrance, Ordinance no. 2021-1193 of 15 September 2021 on the generalisation of e-invoicing. €250 fine per missing e-reporting submission. legifrance.gouv.fr. ↩
- service-public.gouv.fr (entreprendre), €1,000 surcharge every 3 months until the situation is resolved. entreprendre.service-public.gouv.fr. ↩
- La Poste, E-reporting, what data to transmit: CA3 monthly frequency (up to 3 submissions/month), CA12 annual, payment e-reporting for service transactions billed on receipt. laposte.fr. ↩
- TeamSystem Facture / Weproc, E-invoicing vs e-reporting: difference in scope and nature (structured invoice vs data summary). teamsystemfacture.fr. ↩