VAT recoding CIBS 2026: what changes on 1 January 2027

Quick answer. Order no. 2025-1247 of 17 December 2025 moves France's VAT rules from the General Tax Code (CGI) to Book II of the Code of Taxes on Goods and Services (CIBS) on 1 January 2027. This is a constant-law recoding: it changes no rate or regime, but the article references do change. On the same date, the 2025 Finance Act abolishes the simplified VAT regime (CA12).

This reform will not add a single euro of VAT to your bill. It may, however, mean updating article references on your invoices, your terms and conditions, your lease agreements or your software settings. That is the whole point of moving VAT into the CIBS: a change of legal framework, not of taxation. A trading SME director recently called us, worried, after reading that "VAT is leaving the CGI": he feared a tax increase. In reality, it is simply a relocation of legal text, but with very real practical consequences for commercial documentation.

The recoding moves the articles dealing with VAT, currently housed in the General Tax Code (CGI), into a dedicated code: the Code of Taxes on Goods and Services, or CIBS. This code is not new. It was created by order no. 2021-1843 of 22 December 2021, which took effect on 1 January 2022, and until now grouped excise duties (alcohol, tobacco, energy) and various sector-specific taxes.

Order no. 2025-1247 of 17 December 2025, published in the Official Journal on 20 December 2025, adds VAT to this code. From 1 January 2027, the VAT provisions leave the CGI to join Book II of the CIBS, articles L200-1 to L256-12. The administration's stated goal is to end the scattering of tax rules on goods and services, previously spread across some twenty separate bodies of legislation.

In practical terms, the scale is significant: the entire set of VAT articles in the CGI (around 230 articles) is rewritten into a far larger number of articles in the CIBS (close to a thousand according to early analysis), with shorter articles and a redesigned thematic structure. To anticipate the obligations arriving in parallel, see our full guide to the VAT reform in the CIBS.

No, and this is the key point. The recoding is carried out at constant law: the standard rate stays at 20%, the reduced rates (10%, 5.5%, 2.1%) remain, and the rules on territoriality, chargeability, deduction rights and tax regimes are not changed in substance. The 2025 Finance Act, a separate text, nonetheless abolishes the simplified VAT regime (CA12) on 1 January 2027. The report to the President of the Republic states that the operation has "strictly no impact on the applicable substantive rules".

One nuance is needed, though. "Constant law" does not mean "identical copy and paste". The administration used the opportunity to rewrite articles, integrate definitions drawn from Court of Justice of the European Union case law, and reclassify certain provisions between the legislative and regulatory levels. The meaning of the rules does not change, but their wording and location do. That is why we describe this as a new framework to get used to, rather than a mere renumbering.

For the vast majority of businesses, a routine invoice does not cite a legal article. The mandatory mentions (number, date, identity, rate, VAT amount, intra-EU VAT number) remain unchanged. So there is nothing to modify on a standard invoice.

The issue arises whenever a document relies on a precise legal reference. This is the case for invoices issued under an exemption or reverse charge, which often cite a CGI article to justify the regime applied. Also consider your terms and conditions of sale, commercial leases with a VAT option, cross-border service contracts and the wording templates in your invoicing software.

Good news: a transitional period protects these documents. Under the transitional provisions, as amended by order no. 2026-671 of 27 July 2026, deeds, invoices and contracts citing the old CGI articles keep their validity, and references to the old provisions remain admissible until 30 June 2028. You have time, but not forever. To make this work watertight alongside your filings, our corporate tax support in Paris secures the sensitive mentions.

The documents to review

• Invoice templates for exemptions or reverse charge that cite a CGI article.
• Terms and conditions of sale and of service.
• Commercial leases with a VAT option and their amendments.
• International contracts (VAT clauses, place of taxation).
• Wording and automatic mentions configured in your invoicing software.
• Internal certificates and forms referring to a specific article.

The method we apply in client files comes down to a few simple steps, to be spread over the second half of 2026 and the year 2027.

1. Inventory the documents that cite a CGI article on VAT (special invoices, T&Cs, leases, contracts).
2. Identify the matching CIBS article using the concordance tables the administration has committed to publish.
3. Update templates and clauses gradually, keeping a record of both the old and the new reference.
4. Check the settings of your invoicing software and automatic mentions with your vendor.
5. Train whoever issues invoices and handles VAT so they can navigate the new CIBS layout.
6. Document the update in a dated internal memo, useful in the event of an audit.

This approach fits naturally into your bookkeeping and accounts review, where we already check the consistency of your mentions and VAT returns. For the filing rhythm itself, our article on the VAT return remains your operational reference point: the forms and the calendar are not changed by the recoding.

Micro-businesses under the base exemption. If you benefit from the base exemption (37,500 EUR for services, 85,000 EUR for trading), you do not charge VAT and the exemption mention appears on your invoices. The regime does not change; only the legal reference cited in the mention may evolve. The exemption remains a threshold to watch, especially since the single 25,000 EUR threshold was dropped.

Businesses affected by e-invoicing. The switch, once announced for 1 September 2026, was postponed to 1 January 2027 so as not to coincide with the start of the mandatory electronic invoicing obligation (issuing for large companies and mid-sized firms, mandatory reception for all businesses). Running both projects together is sensible. The VAT principles carried by the electronic formats will rely on the CIBS.

Intra-EU and import operations. Businesses carrying out cross-border operations frequently cite articles in their contracts and invoices. This is where updating the references is most worthwhile, particularly for e-commerce players already affected by the ViDA directive and VAT in the digital age.

The underestimated risk is not fiscal, it is documentary. A contract clause or invoice mention pointing to a repealed CGI article will still be legally understood until 30 June 2028 thanks to the transitional rules, but beyond that, an obsolete reference can create ambiguity with a partner, a public buyer or an auditor.

What the administration looks at: the consistency between the regime you apply and the justification you give for it. An exemption or reverse charge that is correctly applied but poorly referenced is not, in itself, a reassessment; but an incorrect mention weakens your file. It is better to migrate your references cleanly than to wait for the end of the transitional period.

Finally, beware of duplicated templates: many businesses have several invoice and contract layouts circulating in parallel. Missing a single template means letting an outdated reference slip through for years.

Our reading is straightforward: this reform is a non-event in tax terms and a genuine organisational matter. Most of our small-business clients will, in practice, have nothing to do beyond checking that their software is up to date. Companies with structured contracts, leases with a VAT option, or exempt or international operations do have a modest clean-up task to carry out, with no urgency but not to be neglected.

The trade-off we recommend: do not redo everything in January 2027, but use the natural renewal of your templates (a new version of your T&Cs, a new lease, a software update) to switch to the CIBS references, relying on the official concordance tables. The transitional period until the end of June 2028 exists precisely for that.

As chartered accountants registered with the professional body and statutory auditors, we follow the BOFiP doctrine closely, and it remains binding despite the change of code. That is reassuring: your legal certainty is preserved, provided you keep your references up to date.

Hayot Expertise tip. Run a targeted inventory of the documents that cite a VAT article rather than an exhaustive review. Wait for the official concordance tables before rewriting your clauses. And synchronise this work with your e-invoicing compliance (SME issuing from 1 September 2027): one project, two deliverables.