A foreign company with no fixed establishment (“établissement stable”) in France may still owe e-reporting. The test is not where it is set up but who owes the tax: as soon as it carries out a transaction deemed to take place in France for which it is liable for French VAT, it transmits the corresponding data to the authorities.
Three dates, not one
The starting point depends on the role played in the transaction and on the size category.
| From | Who | In what role |
|---|---|---|
| 1 September 2026 | large and mid-sized companies | as seller or supplier, liable for French VAT |
| 1 September 2027 | micro, small and medium-sized businesses | the same position |
| 1 September 2027 | every size | intra-Community acquisitions and reverse-charge transactions |
Size is assessed at 1 January 2025 on the last closed financial year. For a foreign company it is worldwide turnover that counts, not the French activity alone. A large company is one with at least 5,000 employees or, below that, turnover above 1.5 billion euros and a balance sheet above 2 billion.
Micro-businesses and small and medium-sized businesses may bring the date forward and start on 1 September 2026.
What falls in scope, and what does not
Transaction e-reporting covers supplies of goods and services taxable in France made by non-established businesses, intra-Community acquisitions taxable in France, certain acquisitions under the reverse charge, and certain supplies to private customers subject to French VAT.
Exports, intra-Community supplies, imports and exempt transactions stay outside.
The point that settles it: where the customer is VAT-registered in France and the reverse charge applies, the reporting obligation sits with the customer, not with the foreign supplier. Liability decides, not the nature of the transaction.
The data matches that required for electronic invoicing, with one exception. The French company number “SIREN” may be replaced by a foreign intra-Community VAT number or, failing that, by another foreign identification number.
Payment e-reporting, easily overlooked
It covers services and down-payments on goods where VAT becomes due on receipt, whatever the customer. Reverse-charge transactions and those on the invoice basis stay outside.
What is expected is the date of receipt, the gross amount split by rate and, where applicable, the invoice number. It falls to whoever issued the invoice and receives the payment.
What to do before the date
The transmission frequency follows the company’s VAT return period. Transmission must go through an approved platform (“plateforme agréée”), chosen before the obligation takes effect.
Two questions are enough to settle whether this reaches you. Is the company VAT-registered in France? If not, the reform does not touch it. If so, does it carry out transactions for which it is liable for French VAT? If so, it is in scope, and the date follows its size. The e-invoicing question set
Sources: articles 289 bis and 290 II of the Code général des impôts. Position as at 23 July 2026.