Dutch and Belgian companies selling into France have mostly heard one reassurance in recent months: without a permanent establishment in France, the French e-invoicing mandate does not apply to you. That is correct. It is also half the story. Alongside e-invoicing, the French reform carries a second obligation, and that one does not stop at the border. E-reporting France has applied since 1 September 2026 to foreign companies without a French establishment, provided they meet two conditions.
This article walks through those conditions in the order you can check them yourself, based on the rules published by the French tax authority. The outcome tends to surprise people in both directions. Companies that assumed they were safe because their French turnover is small turn out to be in scope. Companies already preparing turn out to be exempted by a reverse-charge rule.
Why exempt from e-invoicing is not the same as exempt
The French reform consists of two separate mechanisms. E-invoicing, governed by Article 289 bis of the Code général des impôts, covers invoices between two VAT-taxable persons that are both established in France. If you are not established there, you fall outside it: no French e-invoices to send or receive.
E-reporting is something else. Instead of an invoice you send transaction data to the French tax authority: the transaction amount, the VAT amount and, in certain cases, payment data. That obligation does not hang on your establishment but on your VAT liability. If you owe French VAT on a transaction, e-reporting comes into play, with or without an office, a warehouse or staff in the country.
Step 1: does your size put you in scope
The first test is company size, and this is where most organisations misjudge the detail. France uses four categories:
- Micro-enterprise or VSE: fewer than 10 employees and turnover or a balance sheet total below 2 million euro.
- SME: fewer than 250 employees and turnover of at most 50 million euro or a balance sheet total of at most 43 million euro.
- ISE, the intermediate category: outside the SME bracket, fewer than 5,000 employees and turnover up to 1.5 billion euro or a balance sheet total up to 2 billion euro.
- Large enterprise: everything above that.
Since 1 September 2026 the obligation applies to large enterprises and to intermediate-sized enterprises that sell goods or provide services. That second group is regularly overlooked: this is emphatically not a rule for listed multinationals only. A company with 300 employees already sits outside the SME category and therefore in scope.
The turnover that counts is your worldwide turnover
This is where many exporters misread the rule. For the turnover threshold France counts total turnover, generated in France and abroad. Your French sales may be modest; if your company exceeds the SME thresholds worldwide, you land in the category that has to report from 1 September 2026.
Two further rules decide which category you fall into exactly. You move up a category as soon as you exceed the headcount criterion. If that criterion is not met, you only move up when turnover and balance sheet total are both above the threshold. Size is assessed as at 1 January 2025, based on the last financial year closed before that date. For a company on a calendar year that means 2024. A growth spurt in 2025 or 2026 changes nothing.
Note the definition of a company. France looks at the legal unit, identified by a single SIREN number, not at the group as a whole. A small Dutch subsidiary of a large group is assessed on its own figures.
Step 2: which transactions count
If your size puts you in scope, the next question is which transactions are covered. The obligation applies to transactions on which you owe French VAT. In practice:
- supplies of goods or services from France to another taxable person that is also not established in France;
- non-exempt intra-Community acquisitions in France;
- purchases of goods or services taxable in France from a supplier that is neither established nor VAT-registered in France;
- sales to private individuals on which French VAT is due.
What falls outside matters just as much. Exports and intra-Community supplies are VAT-exempt and therefore excluded from e-reporting. The same applies to the exemptions in Articles 261 to 261 E, such as certain banking and insurance services, medical care and education. Imports of goods are excluded as well. And if you sell to French consumers while registered for the EU One Stop Shop, those transactions do not need separate reporting.
The reverse-charge rule that keeps many companies out
Here is the provision that most often leads to a relieved conclusion. If you supply a customer that is VAT-registered in France, then as a non-established company you are not the party liable for the VAT. The VAT is reverse-charged to your customer, and the reporting obligation moves to that customer with it.
For many Dutch and Belgian companies that covers the bulk of their French turnover. If you sell almost exclusively to French business customers holding a French VAT number, there is a real chance you have nothing to set up by 1 September 2026. That is not an assumption to rely on, but it is the first question to answer before you start selecting a platform.
Step 3: are you selling, or buying
The phasing distinguishes your role in the transaction, and in many cases that difference is worth a year.
- 1 September 2026: large enterprises and intermediate-sized enterprises that sell goods or provide services.
- 1 September 2027: micro-enterprises, very small enterprises and SMEs that sell or provide services.
- 1 September 2027: companies in their capacity as buyers liable for the VAT, so reverse-charge transactions and intra-Community acquisitions, regardless of company size.
That last rule is the counterpart of the reverse-charge provision above. If the VAT shifts to your French customer, the reporting obligation lands with them, and only from September 2027. If you are yourself the buyer owing French VAT, for instance on an intra-Community acquisition in France, 2027 applies to you as well, however large you are.
Smaller companies may opt in early, from 1 September 2026. That is worth weighing if you are setting up a platform for other countries anyway.
What you submit, and how often
E-reporting has two components. For international B2B transactions the transaction data are the same fields as under e-invoicing, with one exception: the SIREN number drops away if you do not have one as a non-established company. Instead you supply your intra-Community VAT number, or a foreign tax identification number if you have neither. For sales to private individuals it is not individual transactions but daily aggregated amounts per VAT rate.
The payment data form the second component and apply to services and to advance payments on supplies of goods. You supply the collection date, the amount collected per VAT rate and, where applicable, the invoice number. This does not apply if you have opted to account for VAT on debits, nor to reverse-charge transactions your customer already reports. The party receiving the payment does the reporting.
Unlike e-invoicing you do not submit continuously or daily. The frequency depends on your French VAT regime, and the deadlines are set per regime.
An authorised platform is mandatory
You cannot submit directly to the French tax authority. Foreign companies without a permanent establishment must choose a Plateforme Agréée, which forwards the data on their behalf. That choice has to be made before 1 September 2026, or before 1 September 2027 if you only come into scope then. The French tax authority publishes the current list of authorised platforms.
A practical note for anyone already on Peppol: e-reporting is not a Peppol obligation, but many service providers offering Peppol are also authorised or work with an authorised platform. If you will be reporting in several countries, it pays to fold that question into your provider selection rather than bolting a separate solution alongside it.
Checklist: are you in scope
Work through these four questions. One no is usually enough to conclude that nothing needs to happen by 1 September 2026.
- Do you hold a French VAT number without a permanent establishment in France? If not, this article does not apply to you.
- Does your legal unit fall outside the SME category, measured as at 1 January 2025 and on your worldwide turnover? That means 250 employees or more, or turnover above 50 million euro and a balance sheet total above 43 million euro.
- Do you carry out transactions on which you owe the French VAT? If you sell exclusively to French customers holding a French VAT number, the obligation sits with them and only from 2027.
- Are you the selling party? As a buyer, 1 September 2027 applies to you in any case.
Four times yes means you need an authorised platform and must be able to supply transaction and payment data. The French tax authority publishes a decision tree that walks through the case law step by step, and runs a telephone helpdesk for non-residents.
What happens if you are late
The DGFiP has indicated it will take a lenient view of formal errors in the first year for companies that are demonstrably implementing. That is not a postponement of the obligation itself, as we described earlier in the French penalty regime. The difference between a tolerant stance and an exemption is exactly the difference between a corrected return and a fine.
The practical risk matters more than the penalty. Reported data that does not reconcile with your VAT return raises questions, and those questions come from an authority that sees the data per transaction rather than per return period. Check now, before your first submission, that your ERP export, your VAT return and your e-reporting feed use the same transaction totals.
What this means for your preparation
Work through the checklist above before you set anything up: your worldwide figures decide whether you are in scope, and the reverse-charge rule can take you straight back out. Both are easy to misjudge in either direction.
If you are the entrepreneur selling into France, the scope question is yours to answer first, not your accountant’s afterthought: four yeses means an authorised platform is mandatory, and that choice has to be made before your obligation starts.
If you are an integrator or software provider building this into a client’s stack or your own platform, treat e-invoicing and e-reporting as two separate integrations with two separate triggers, since a client can be out of scope for one and in scope for the other.
Either way, the overview of Peppol service providers offers an independent comparison of providers that also support the French reporting chain, so you are not running two separate procurement processes for e-invoicing and e-reporting.
