Billing by an association: what to check

Invoicing by an association (loi 1901) is legal: it may sell goods, services or training. As long as the lucrative activity stays accessory and below the commercial-tax threshold (81,051 euros in 2026), the association keeps its non-profit status. Above it, the association becomes liable for corporate income tax, VAT and the CET.

Updated April 2026 - Invoicing by an association is possible, but it requires checking several points: nature of the activity, lucrative nature or not, VAT, commercial taxes, consistency with the association's purpose and, since 2026, e-invoicing obligations.

A French association (loi 1901) is not a company like any other. Its purpose is not to generate profits, but to pursue a disinterested social objective. However, many associations invoice services, memberships, training courses or room rentals. This practice is legal, but it triggers tax and accounting obligations that must be understood.

To complete, also see Accounting plan for association, Credit management association and Tax or social question.

Yes, an association can invoice certain services, sales or services. The law does not prohibit an association from carrying out an economic activity. However, it strictly regulates the conditions under which this activity can be conducted without calling into question the non-profit status of the organization.

The real question is therefore not "can it invoice?", but under what conditions and with what tax consequences. An association that invoices without having analyzed its situation risks being reclassified as a for-profit organization by the tax authorities, with the resulting consequences: subject to corporate income tax, VAT, territorial economic contribution, and loss of the benefits associated with non-profit status.

The tax authorities use the 4P criterion to assess whether an association is carrying out a lucrative activity. This test, detailed in the BOFiP (BOI-IS-CHAMP-10-50-10-20), analyzes four dimensions.

The Product. Does the association offer a product or service comparable to that of the commercial sector? If its offer differs significantly from what private companies offer -- for example, services of a social, cultural or educational nature adapted to a specific audience -- the activity will generally be considered non-profit.

The Public. Who is the association targeting? If it targets an audience in a situation of economic or social vulnerability (elderly people, young people, disabled people, job seekers), the absence of a profit motive is easier to demonstrate. Conversely, if it targets the general public without distinction, the risk of reclassification increases.

The Price. Are the prices charged lower than market rates or do they include mechanisms for adjusting prices according to beneficiaries' resources? Prices significantly lower than those in the compétitive sector are a strong indicator of non-profit status.

The Advertising. Does the association use commercial-style advertising campaigns? Discreet communication, based on informing members and word-of-mouth, is compatible with non-profit status. On the other hand, aggressive advertising campaigns or proactive marketing can be interpreted as a commercial approach.

The detail of this test, the commercial-tax franchise threshold (81,051 euros in 2026) and the ring-fencing of lucrative activities are developed in our guide to the commercial-tax franchise and the 4P rule.

The analysis is global: none of these four criteria is decisive on its own. It is their combination that allows the administration to classify the activity as lucrative or not.

Disinterested management is the first gate, examined before the 4P test: without it, the activity is deemed lucrative whatever its nature. It rests on three cumulative conditions (article 261, 7, 1°-d of the CGI, BOFiP BOI-IS-CHAMP-10-50-10-10).

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Managed and administered on a voluntary basis#

Directors must have no direct or indirect interest in the operating results. Tolerance: a director's pay is allowed up to three quarters of the gross minimum wage (around 15,902 euros in 2024) per director, without challenging disinterested management.

No distribution of profit#

The organisation makes no direct or indirect distribution of profit, in any form whatsoever.

No allocation of assets to members#

Members and their beneficiaries cannot be declared entitled to a share of the assets, apart from recovering their contributions.

Enhanced pay for directors#

Beyond three quarters of the minimum wage, a regulated statutory scheme allows pay of up to three times the social security ceiling, but only for organisations whose own resources exceed 200,000 euros and subject to financial transparency. :::

The 81,051 euro threshold for accessory lucrative activities#

An association whose lucrative activity is secondary benefits from administrative tolerance as long as its lucrative income remains below 81,051 euros for 2026 (the commercial-tax exemption threshold for not-for-profit organisations). This ceiling is not simply rolled over from year to year: it is reindexed annually on the consumer price index excluding tobacco (it stood at 80,011 euros in 2025). It applies to financial years ending on or after 31 December 2025 for corporate income tax and to income collected from 1 January 2026 for VAT. Below this amount, the association retains its non-profit status and is not subject to commercial taxes.

Above this threshold, all of the association's lucrative activities become taxable under the three commercial taxes: corporate income tax (IS), value added tax (VAT) and territorial economic contribution (CET).

The VAT franchise en base#

Even when the association is subject to VAT, it may benefit from the franchise en base if its turnover excluding tax remains below the thresholds provided for in article 293 B of the General Tax Code. In 2026, these thresholds are:

• 36,800 euros for the sale of goods, provision of accommodation and takeaway or on-site sales;
• 85,800 euros for services and liberal professions.

Between the base threshold and the upper threshold, the association benefits from a tolerance régime: it does not charge VAT but may voluntarily opt in to recover VAT on its purchases.

Specific exemptions (articles 261 to 261 E of the CGI)#

Certain associative activities are expressly exempt from VAT under the General Tax Code:

• continuing vocational training (article 261-4-4° of the CGI);
• organizations with disinterested management providing services of a social, educational, cultural or sporting nature (article 261-7-1° of the CGI);
• the rental of unfurnished housing for residential use;
• certain care and assistance services for elderly or disabled people.

In these cases, the association does not charge VAT but must still comply with e-invoicing obligations if it is otherwise subject to VAT.

Sectorisation or filialisation: ring-fencing the lucrative activity#

Crossing the commercial-tax threshold does not condemn the whole association to tax. Two structures make it possible to isolate the lucrative activity so that only it is taxed.

Watch point: sectorisation takes effect for corporate income tax and the CET, but not for VAT, which applies its own rules on distinct sectors of activity. The two logics do not overlap automatically.

VAT on membership fees#

Statutory membership fees, a mere right of admission with no individualised consideration, are outside the scope of VAT. Services rendered to members by a disinterested-management organisation, in return for the fee, are exempt (article 261, 7, 1°-a of the CGI). Conversely, a fee that grants an individualised benefit, comparable to a service the member could obtain on the market, may become taxable again.

The e-invoicing reform comes into force progressively from September 1, 2026. It affects all entities subject to VAT in France, including associations.

Implementation schedule#

• September 1, 2026: obligation to receive electronic invoices for all VAT-registered businesses and associations, whatever their size (including those under the franchise en base); on the same date, the issuing obligation still applies only to large enterprises and intermediate-sized enterprises (ETI);
• September 1, 2027: the issuing obligation is extended to SMEs, very small businesses and micro-enterprises. Reception, for its part, has already been generalised since 1 September 2026: a VAT-registered association must therefore be able to receive an electronic invoice from that date.

Who is affected?#

The reception obligation applies, with no size exception, to any association registered for VAT (even under the franchise en base). The following are therefore particularly exposed:

• non-profit associations carrying out a lucrative activity as their main activity (i.e., when this activity represents the bulk of their resources);
• associations whose lucrative activity is secondary but whose income exceeds 81,051 euros (the 2026 commercial-tax threshold).

On the other hand, an association with no VAT-taxable activity at all (a strictly non-profit activity, accessory income below 81,051 euros that does not compete with the private sector) falls outside the scope of the reform: not being liable for VAT, it has neither an issuing nor a reception obligation.

Issuance and e-reporting#

Only associations actually liable for VAT are required to issue electronic invoices and transmit transaction data to the tax authorities (e-reporting). The issuance obligation only applies when the client is a VAT-registered professional established in France. Invoices intended for individuals or foreign clients do not fall within this scope.

Hayot Expertise advice: among associations, invoicing is not just an administrative subject. This is a subject of tax qualification. Anticipate the reform by checking the compatibility of your invoicing tool with the required formats (Factur-X, UBL, CII).

An invoice issued by an association must comply with the legal formalities provided for in article L441-9 of the Commercial Code and Annex II to the CGI. It must include:

• the association's name and its RNA number (National Register of Associations);
• the SIRET number if the association has one;
• a unique and sequential invoice number;
• the date of issue and the date of service or delivery;
• details of the services or products invoiced with quantities and unit prices;
• the VAT rate and amount, if the association is subject to VAT;
• the intra-community VAT number if the association is subject to VAT;
• payment terms and applicable late payment penalties (ECB rate + 10 points);
• the mention "TVA non applicable, article 293 B du CGI" if the association benefits from the franchise en base.

The absence of these details exposes the association to financial penalties: a fine of 15 euros per omitted or inaccurate mention (article 1737, II of the CGI), the total fines due for a single invoice not being able to exceed a quarter (25%) of the amount shown or that should have been shown on it. An outright failure to invoice is punished more heavily (article 1737, I, 3: 50% of the amount, reduced to 5% if the transaction is properly recorded in the accounts).

Representative example. A sports association invoices a town hall for an activity-leading service. The number to show on the invoice is not the RNA number (the administrative identifier in the Wxxxxxxxxx format, useful for association formalities) but the SIREN/SIRET obtained when the economic activity was registered: that is what the public client and the tax authorities expect on a commercial document. The RNA remains the association's identifier, not an invoicing number.

An association that invoices without having secured its legal and tax framework exposes itself to several types of risks.

From a tax perspective, reclassification as a for-profit organization results in retroactive subjection to commercial taxes. The administration can challenge the financial years that are not time-barred, namely the last three years for corporate income tax and VAT (the ordinary limitation period, articles L169 and L176 of the LPF), with tax reassessments, late payment penalties and surcharges. This period is extended to ten years where the lucrative activity has remained undisclosed, that is, not declared to a business formalities centre. The loss of tax benefits associated with non-profit status (property tax exemption under conditions, eligibility for patronage, favorable régimes for donors) constitutes an additional major risk.

From a legal standpoint, a lucrative activity that does not comply with the statutory purpose can be challenged by members or by the prefect. In extreme cases, the dissolution of the association can be ordered by the judicial court.

From an accounting standpoint, an association subject to commercial taxes must keep complete accounts in accordance with the general chart of accounts (PCG), and no longer solely the chart of accounts for not-for-profit legal entities (ANC regulation no. 2018-06 of 5 December 2018). This transition requires specific support.

The accounting obligations that come with invoicing#

Invoicing also entails bookkeeping. The applicable chart of accounts is ANC regulation no. 2018-06 of 5 December 2018 (annual accounts of private not-for-profit legal entities), applicable to financial years opened on or after 1 January 2020. Beyond that, a threshold triggers reinforced obligations:

• an association that receives more than 153,000 euros in public subsidies per year, or more than 153,000 euros in donations giving entitlement to a tax reduction, must draw up annual accounts (balance sheet, income statement, notes) on an accruals basis, appoint a statutory auditor and publish its accounts in the official gazette for associations (JOAFE);
• the combination of subsidies and donations, where no single category exceeds 153,000 euros on its own, does not by itself trigger the obligation to appoint a statutory auditor.

We can help you check the tax framework of your association, analyze your exposure to the 4P test and set up a compliant invoicing formalism.

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