VAT e-reporting: understanding the obligation under Article 290 of the French Tax Code

VAT e-reporting and electronic invoicing: a new reporting framework

The French reform of electronic invoicing and VAT e-reporting, governed by Articles 289 bis, 290 and 290 A of the French Tax Code (Code général des impôts – CGI), profoundly reshapes VAT compliance requirements in France.

While electronic invoicing (e-invoicing) mainly applies to domestic B2B transactions, VAT e-reporting broadly affects foreign companies with no permanent establishment in France that carry out taxable transactions on French territory, such as sales to private individuals, supplies of services or other taxable operations.

For these companies, non-compliance entails significant risks, including administrative and criminal penalties. In this context, relying on a French tax representative or fiscal agent becomes essential to secure compliance and ensure proper transmission of data to the French tax authorities.

What is VAT e-reporting under Article 290 of the French Tax Code?

VAT e-reporting, provided for under Articles 290 and 290 A of the French Tax Code, is a standalone reporting mechanism that complements electronic invoicing. It consists of the electronic and periodic transmission to the tax authorities of data relating to:

• transactions not covered by e-invoicing (B2C sales, supplies of services, cross-border transactions, etc.),

• payments relating to those transactions (cash receipts, settlement data, receipts, etc.).

In practice, any foreign company carrying out taxable transactions in France, as well as any company selling to private individuals, falls within the scope of VAT e-reporting.

The objective of VAT e-reporting is to provide the tax authorities with a comprehensive and near real-time view of companies’ economic activity, strengthen the fight against VAT fraud and secure VAT collection. Ultimately, VAT returns will be pre-filled by the administration.

For companies, VAT e-reporting represents a major operational and regulatory challenge. In this context, Fiscalead helps secure compliance, centralise data and automate reporting processes, while minimising risks for the business.

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Companies subject to VAT e-reporting obligations

Foreign companies with no permanent establishment in France

Foreign companies not established in France but registered or identified for French VAT purposes are directly subject to VAT e-reporting when they carry out transactions deemed to be located in France and for which they are liable for VAT.

Unlike companies established in France, these operators are not subject to the French electronic invoicing obligation. However, they remain fully subject to VAT e-reporting obligations, in order to ensure fiscal traceability of their transactions (B2C sales, supplies of services, transactions with non-established clients or partners).

Other operators concerned

VAT e-reporting also applies to:

• companies established in France carrying out transactions with non-established taxable persons (EU or non-EU);

• VAT taxable persons making sales or supplies of services to private individuals (B2C);

• companies providing services subject to VAT on a cash basis, for which payment data must be reported.

💡Note: transactions benefiting from a VAT exemption under Articles 261 et seq. of the French Tax Code are excluded from VAT e-reporting.

Data to be transmitted under VAT e-reporting

Under the VAT e-reporting framework, the tax authorities distinguish two main categories of data that must be transmitted electronically and periodically:

• transaction data (Article 290 of the CGI),

• payment data (Article 290 A of the CGI).

These obligations apply to all transactions falling within the scope of VAT e-reporting and require rigorous data collection, failing which errors or penalties may arise. Data must be transmitted via an authorised platform (approved platform / former PDP).

1. Transaction data – Article 290 of the CGI

Transaction data, detailed in particular under Article 242 nonies M II of Appendix II to the CGI, relates to transactions not covered by electronic invoicing.

For B2C transactions (non-taxable persons), the data to be transmitted includes in particular:

• identification of the VAT e-reporting taxpayer (SIREN or tax identifier),

• reporting period,

• nature of the transaction (taxable supply of goods or taxable supply of services),

• amount exclusive of VAT,

• applicable VAT rate and VAT amount,

• indication of the option for VAT payment on an accrual basis, where applicable,

• currency,

• transaction date,

• invoice number, where applicable.

For international B2B transactions involving a taxable person not established in France, the data includes in particular:

• identification of the parties (EU VAT number or foreign tax identification number),

• nature of the transaction (goods or services),

• invoice date and number, where applicable,

• amounts exclusive of VAT and applicable VAT rate.

2. Payment data – Article 290 A of the CGI

Payment data mainly concerns supplies of services and aims to inform the tax authorities of VAT actually collected.

The following data must be transmitted in particular:

• actual payment collection date,

• amount collected, broken down by VAT rate.

Depending on the nature of the transactions (domestic B2B, international B2B or B2C), reporting may take different forms:

• updating the “paid” status of an electronic invoice,

• submission of a global VAT e-reporting payment flow,

• aggregated reporting, notably for B2C transactions.

Transactions excluded from VAT e-reporting

Certain transactions are expressly excluded from the scope of VAT e-reporting, including:

• transactions between non-taxable persons,

• intra-Community distance sales and certain services reported via the OSS One-Stop Shop,

• VAT-exempt transactions under Articles 261 to 261 E of the CGI (banking, insurance, healthcare, education, etc.).

How does VAT e-reporting work in practice?

Data transmission is carried out on a regular basis, daily or monthly depending on the nature and volume of transactions.

1. Data collection

The company identifies and centralises all data relating to transactions not covered by electronic invoicing, in particular:

• sales to private individuals (B2C),

• international transactions,

• payment data related to certain supplies of services.

2. Transmission via an authorised platform

Data is transmitted via an authorised platform, which verifies compliance with technical and tax requirements. This step is essential to ensure the integrity, authenticity and confidentiality of the transmitted information.

3. Checks and validation

The platform performs automated checks of consistency and completeness. Each transmission is assigned a status (accepted, partially accepted or rejected), enabling accurate monitoring of reporting obligations.

4. Transmission to the tax authorities

Once validated, data is transmitted to the French tax authorities (DGFiP) to feed VAT control systems and, ultimately, enable pre-filled VAT returns.

5. Correction of potential errors

In the event of errors or omissions, the company must correct the data and submit a new transmission via the authorised platform.

Why do these obligations require specialised support?

The volume of data to be collected, the distinction between transaction and payment data, and the use of authorised platforms make VAT e-reporting particularly complex, especially for foreign companies.

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Frequency and deadlines for VAT e-reporting

The reporting frequency depends directly on the company’s VAT regime. Data must be transmitted regularly and within strict deadlines, failing which penalties may apply.

Transaction data

• Monthly standard VAT regime: reporting by ten-day periods (three submissions per month), within 10 days following the end of each ten-day period;

• Quarterly standard VAT regime: monthly reporting, no later than the 10th day of the following month;

• Simplified VAT regime: monthly reporting, generally between the 25th and 30th of the following month;

• VAT exemption scheme: bi-monthly reporting, also between the 25th and 30th following the end of the period.

Payment data

Payment data is generally reported monthly, with adjustments depending on the applicable VAT regime and the nature of the transactions, in particular for supplies of services.

📍 Good to know: depending on their VAT regime, some companies may be required to submit up to three VAT e-reporting transmissions per month, reinforcing the need for reliable, automated and well-monitored reporting processes.

VAT e-reporting implementation timeline

The roll-out of VAT e-reporting forms part of the broader French electronic invoicing reform, with a phased implementation based on company size.

Key dates:

• 1 September 2026: VAT e-reporting obligation for large companies and mid-sized enterprises (ETIs);

• 1 September 2027: extension of the obligation to small and medium-sized enterprises (SMEs) and micro-enterprises.

Penalties for non-compliance with VAT e-reporting obligations

Failure to comply with the obligations set out in Articles 290 and 290 A of the CGI is subject to penalties under Article 1788 D of the CGI:

• €250 per missing or incorrect transmission, capped at €15,000 per year for the company;

• €750 per transmission, capped at €45,000 per year, for authorised platforms.

A right to make mistakes applies in the event of a first infringement, provided that the situation is remedied spontaneously or promptly.

VAT e-reporting and foreign companies: a key VAT compliance issue

For foreign companies with no permanent establishment in France, VAT e-reporting has become a core pillar of VAT compliance. Any error, omission or late submission may expose the company to financial penalties and VAT reassessments, and potentially criminal risk.

Foreign companies must therefore:

1. precisely identify transactions falling within the scope of VAT e-reporting in France;

2. fully understand the reporting obligations under Articles 290 and 290 A of the CGI;

3. secure a reliable process for data collection, validation and transmission via an authorised platform.

Given the scope of the reform and the 2026–2027 deadlines, early preparation is essential. For non-established companies, the complexity of the rules and the multiplicity of data flows make compliance particularly sensitive.

Support from a French tax representative or fiscal agent is a key lever to:

• ensure reliable data,

• meet reporting deadlines,

• secure the relationship with the French tax authorities,

• and sustainably reduce the risk of audits and penalties.

Fiscalead supports foreign companies in the operational implementation of VAT e-reporting, in coordination with authorised platforms and French VAT obligations.

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