E-reporting for B2C and international transactions: what is required

Quick answer. E-reporting covers operations not covered by e-invoicing: sales to individuals (B2C), transactions with taxable persons not established in France or outside the EU, and transmission of payment data. Frequencies range from three transmissions per month (normal regime) to one every two months (VAT exemption). Each affected company must identify its scope and obligations starting 2026.

The electronic invoicing reform in France rests on two distinct pillars: e-invoicing (structured electronic invoices between VAT-taxable businesses) and e-reporting (transmission of transaction data). Together, these two mechanisms cover most economic activity, but they do not target the same operations.

At Hayot Expertise, we observe that e-invoicing benefits from extensive communication, while e-reporting remains less well understood. Yet the latter directly impacts a significant proportion of businesses: retailers selling to individuals, international service providers, businesses accepting online payments, and any structure carrying out multi-channel operations.

The challenge of e-reporting is not merely technical. It is regulatory (mandatory transmission of data), accounting (impact on VAT tracking) and strategic (increased visibility of the tax administration on cash flows).

E-reporting does not apply to all transactions. It specifically targets operations that are not covered by e-invoicing. This is a definition by exclusion, which deserves clarification.

This table shows that e-reporting covers three main categories:

1. B2C transactions (sales to individuals)#

A sale to an individual – whether made in a physical store, online or by mail – falls within e-reporting. The customer is not VAT-taxable, so there is no electronic invoice to issue in the sense of e-invoicing. However, the tax administration wishes to have visibility on these flows.

In concrete terms, a baker selling bread to 100 individual customers per day, a hairdresser providing professional services, or an e-commerce store selling products to individuals must all declare these transactions in e-reporting.

2. International transactions with taxable persons not established in France#

When a French company supplies goods or provides services to another business established outside of France, the transaction falls within e-reporting, even if the foreign customer is VAT-taxable.

Common cases include:

• intra-community supply to a taxable person in another member state (customer who has provided their VAT ID)
• sale or service to a taxable person established outside the EU
• provision of digital services to a non-resident
• outsourcing or processing contracts for foreign customers

This transmission of international data is part of the ViDA directive (VAT in the Digital Age), adopted on March 11, 2025 (Council Directive (EU) 2025/516), which harmonizes VAT reporting rules across the EU and will introduce digital reporting of cross-border transactions from July 1, 2030.

3. Payment data#

Any business that collects funds for operations subject to VAT, via a payment institution (credit card, digital wallet, third-party account) or a third-party collector, must transmit associated payment data. This includes:

• amounts collected
• dates and times of transaction
• identity of payer (if collected)
• payment method used

This obligation applies to online sales platforms, SaaS (software as a service), travel agencies and any business accepting electronic payments.

The transmission of e-reporting is the responsibility of the business that carries out the transaction (the VAT-taxable person established in France). In practice, it goes through an approved platform — formerly "partner dematerialization platform" (PDP) — as with e-invoicing, which automates transmission from your software.

However, several situations must be distinguished:

Case 1: Business issuing an invoice (even partially)#

If the business issues an invoice (for example, a summary invoice for a series of B2C sales), it must transmit the corresponding declarative data in e-reporting.

Case 2: Business without invoice (point-of-sale sales, direct payments)#

Even without a formal invoice (common case in B2C), transaction data must be reported to the administration. The required detail depends on the VAT regime and volume.

Case 3: Business receiving payments via a third party (platform, aggregator)#

An e-merchant selling through a marketplace, a service provider served via a payment aggregator, or a business whose payments pass through a third party must still report the transaction. The platform itself may have reporting obligations (especially if it is subject to DAC7 rules, relating to platform operator declarations).

Transmission frequencies vary depending on the VAT regime of the company:

Key point: the e-reporting schedule must be synchronized with the VAT return schedule (CA3, CA12, etc.). Failure to transmit is penalized by a fine of €250 per missing transmission, capped at €15,000 per year.

The minimum data expected varies depending on the type of transaction:

For B2C transactions#

• Date of transaction
• Type of good or service provided
• Amount excluding tax and amount including tax
• Applicable VAT rate
• VAT amount collected
• Payment method (if capturable)
• Currency (if international transaction)

For international transactions#

• Identification of foreign customer (VAT ID or address)
• Nature of transaction (sale, service, work)
• Amounts excluding and including tax
• VAT amount (often 0% in intra-EU, or assessment of applicable regime)
• Contract or invoice reference (if available)

For payment data#

• Amount paid
• Date and time of transaction
• Payment method (card, transfer, digital wallet)
• Transaction references (system reference number, authorization number)
• Payer identity (if available in the flow)

We regularly observe errors among companies preparing for e-reporting. The most common pitfalls:

Error 1: Confusing e-invoicing and e-reporting#

Many managers believe that preparing for e-invoicing is sufficient. However, a company that sells 80% B2C must first secure its e-reporting, secondly its e-invoicing for the remaining 20% B2B.

Error 2: Forgetting payment data transmission for minor amounts#

The obligation to transmit payment data applies even for small amounts. A startup accepting €5 payments for a digital service must declare them.

Error 3: Misidentifying international transactions#

A delivery to a French customer who orders from abroad remains a B2C transaction in France, not an international transaction. Conversely, a service provided to a foreign address falls within international e-reporting, even if the customer pays in euros.

Error 4: Neglecting synchronization with declarative VAT#

E-reporting must align perfectly with the CA3 (or CA12) return. Gaps between e-reporting and the VAT return create discrepancies and assessments.

Error 5: Ignoring quarterly and annual transmission deadlines#

For companies in the simplified real regime, transmission of e-reporting before May 25 is a strict deadline. An omission or delay cancels the right to deduct upstream VAT and exposes to a penalty.

As a chartered accountant registered with the Ordre and a statutory auditor, we support managers through this reform. Recently, an SME manager contacted us to audit his preparation. He had invested heavily in an e-invoicing tool with his approved platform, but had completely forgotten that he generated 65% of his turnover in direct B2C. E-invoicing was useless for these sales. The real issue was to structure the capture of payment data and implement a monthly e-reporting declaration process. This example shows that good preparation is based on prior diagnosis of the B2B / B2C / international mix, not a uniform approach.

At Hayot Expertise, we recommend a three-step approach:

1. Scope mapping: precisely identify which transactions fall under e-reporting versus e-invoicing
2. Technical audit: verify that the current system captures the right data (dates, amounts, payment methods, customer identity)
3. Operational compliance implementation: implement transmission workflows, test expected formats, train teams

Hayot Expertise advice. E-reporting is not an obligation "to manage after e-invoicing". It is a fundamental obligation from September 2026 for B2C businesses, and may be equally or more complex than e-invoicing depending on your business model. Identifying your scope and use cases early will allow you to prepare the right tools and processes, without last-minute improvisation.