E-reporting vs e-invoicing: key differences and who is affected

France's VAT digitisation reform is one of the most significant compliance changes in recent years for businesses operating in France. It introduces two distinct mechanisms — e-invoicing and e-reporting — that serve different purposes and cover different transaction types. Conflating the two leads to gaps in compliance projects and, ultimately, exposure to the sanctions introduced by the 2026 Finance Act.

Understanding which obligation applies to which transaction type, and how to manage both simultaneously, is the essential starting point before selecting a technical solution or accredited platform.

In brief: e-invoicing covers structured invoices exchanged between VAT-registered businesses established in France (domestic B2B), transmitted via an accredited PDP (Plateforme de Dématérialisation Partenaire). E-reporting covers the periodic transmission to the tax authority of transaction data not captured by e-invoicing: B2C sales, international transactions, and payment data for services. Businesses with mixed B2B and B2C flows are subject to both obligations simultaneously.

E-invoicing is the obligation to issue and receive invoices in a structured electronic format for domestic B2B transactions — that is, sales and purchases between two VAT-registered entities established in France. The invoice is no longer a PDF sent by email. It must transit through an accredited PDP in one of the accepted formats: Factur-X, UBL 2.1, or CII. The tax authority receives a copy of the invoice data automatically through the process.

E-reporting does not involve invoices sent to customers. It is the periodic transmission of transaction data to the French tax authority (DGFiP) via the same accredited PDP. It covers all transactions that fall outside the e-invoicing scope: sales to non-taxable persons (B2C), cross-border transactions, and payment data for service transactions.

The table below summarises the principal differences:

E-invoicing applies to any VAT-registered business established in France that carries out domestic B2B transactions — purchases from or sales to other French VAT-registered entities.

Company size determines the deadline for the issuance obligation, but not for receipt. All businesses — large groups, mid-size companies, SMEs, micro-enterprises — must be capable of receiving electronic invoices from 1 September 2026. Refusing or ignoring a structured invoice after that date is not a compliant option.

A point that is frequently misunderstood: businesses under the VAT franchise threshold (micro-enterprises below the relevant thresholds) are not exempt from receiving electronic invoices if their suppliers are VAT-registered. The issuance obligation, however, only applies to VAT-registered entities.

Excluded from e-invoicing scope: sales to private individuals (B2C), exports outside the EU, intra-EU supplies and acquisitions, and cross-border services. These fall under e-reporting.

E-reporting covers three categories of transactions:

1. B2C sales. Any sale to a non-taxable person — a private individual, a non-taxable association, or a final consumer — falls outside e-invoicing scope. The business does not transmit a structured invoice to the customer, but must periodically report aggregated data on these sales to the DGFiP via its PDP.

2. International transactions. Intra-EU supplies (sales to VAT-registered customers in other EU member states), intra-EU acquisitions (purchases from EU suppliers), exports outside the EU, and cross-border services — whether provided to foreign clients or received from foreign suppliers — are not subject to French e-invoicing rules. They fall within e-reporting scope.

3. Payment data for service transactions. For services, French VAT generally becomes due upon receipt of payment. The reform therefore requires businesses to transmit, in addition to invoice data, the payment information for service transactions: date, amount, and payment method.

The table below maps transaction types to the applicable obligation:

The timeline was revised following the abandonment of the Portail Public de Facturation (PPF) as an issuance and receipt platform — a decision confirmed in October 2024. The PPF continues to function only as a routing directory and data concentrator towards the DGFiP; it no longer supports invoice issuance or receipt. All businesses must use an accredited PDP.

The current deadlines are as follows:

• 1 September 2026: obligation to receive electronic invoices for all VAT-registered businesses, regardless of size. Obligation to issue and comply with e-reporting for large companies and mid-size enterprises (ETI).
• 1 September 2027: obligation to issue and comply with e-reporting for SMEs, micro-enterprises, and sole traders.

In practice, a small business with only B2B flows needs to be ready to receive from September 2026, but has until September 2027 to deploy structured issuance and e-reporting transmissions. That window exists, but compliance projects typically take three to six months depending on the complexity of existing flows and the level of integration required with accounting or ERP systems.

Since the PPF no longer serves as an operational platform for issuance or receipt, passing through an accredited PDP (Plateforme de Dématérialisation Partenaire) is the only available route. PDPs are private operators accredited by the DGFiP. They handle:

• Conversion of your data into accepted formats (Factur-X, UBL 2.1, CII)
• Routing to the recipient's PDP for e-invoicing transactions
• Periodic transmission of e-reporting data to the DGFiP
• Retention of proof of deposit and receipt

The AIFE (Agence pour l'Informatique Financière de l'État) maintains an official list of accredited PDPs. Selecting a PDP requires analysis beyond price: integration with your accounting software or ERP, coverage of both e-invoicing and e-reporting flows, handling of payment data, format capabilities, and support arrangements.

This is the most common situation, and it means managing both obligations in parallel. Here is a structured approach:

Steps to identify and organise your obligations#

1. Map your invoicing flows. List all customer categories: French VAT-registered businesses, EU VAT-registered businesses, non-EU customers, private individuals. Each category generates a different obligation.
2. Qualify each transaction type. For each flow, determine whether the transaction falls under e-invoicing (domestic B2B), e-reporting (B2C, international, payment data), or both depending on customer status.
3. Identify payment data obligations. If your business provides services, flag the flows for which payment data must be transmitted alongside invoice data.
4. Select a PDP that covers both flows. Not all PDPs handle e-reporting with the same depth. Verify that the platform supports both structured B2B invoice transmission and periodic B2C/international data reporting.
5. Configure your accounting or billing software. Set up transaction codes, export formats, and e-reporting transmission frequencies aligned with your VAT filing regime (monthly or quarterly).
6. Run end-to-end tests before the deadlines. Test issuance, receipt, and DGFiP transmission before go-live to avoid discovering a technical blockage in production.

Worked example: a business with both B2B and B2C sales#

Consider a specialist joinery manufacturer generating 60% of revenue with property developers (B2B, French VAT-registered) and 40% with private homeowners (B2C). From September 2027 (SME deadline):

• For each sale to a developer: a structured invoice is issued via PDP, routed to the developer's system, and data is transmitted to the DGFiP automatically. No separate e-reporting action is needed for this flow.
• For each sale to a private homeowner: a standard invoice is provided to the customer (paper or PDF), but aggregated data on these sales must be transmitted periodically — monthly, if the business files VAT monthly — via the PDP.
• If a service contract is invoiced in stages (deposit and balance), the payment data for each receipt must also be transmitted.

The PDP centralises both flows. The administrative overhead is concentrated in the initial configuration; once flows are set up, transmission is automated.

The 2026 Finance Act introduced a proportionate penalty regime:

• Failure to issue an electronic invoice: €50 per invoice, capped at €15,000 per calendar year.
• Failure to transmit e-reporting data: €500 per missing transmission, capped at €15,000 per calendar year.

The financial distinction matters: a business that misses several monthly e-reporting transmissions can reach the annual cap relatively quickly. The risk is not theoretical — the tax authority will have access to PDP data and will be able to cross-reference it against VAT returns.

In compliance projects we support, the most common blind spot concerns businesses with mixed flows that plan their project thinking only about B2B invoices. E-reporting is treated as secondary — sometimes until it becomes clear that 30% to 40% of revenue involves private customers or foreign clients, and a separate periodic transmission flow still needs to be built.

PDP selection is often approached too late, and evaluated solely on B2B invoice management capabilities. The ability to handle e-reporting — aggregated data formats, transmission frequencies, payment data management — must be a selection criterion from the outset.

A further point to watch: businesses growing into cross-border activity. A company that develops intra-EU sales after its PDP is already in place may find that an e-reporting flow was not anticipated in the original configuration. Mapping future flows, not only current ones, is sound practice.

Last updated: 2026-05-26. This article is for informational purposes and does not replace personalised professional advice. Rules, deadlines, and penalties are subject to change. For your specific situation, consult a registered expert-comptable (chartered accountant).