VAT statements on invoices under the CIBS: what to write

Quick answer. On 1 January 2027, French VAT rules move from the General Tax Code (CGI) to the Code on Taxes on Goods and Services (CIBS), on an unchanged-law basis. On your invoices you may keep citing the old CGI articles until 30 June 2028, but from 1 January 2027 the small-business exemption references article L. 233-3 of the CIBS.

An invoice is not just a request for payment: it is a document that must carry the correct legal statements, especially when you charge no VAT. Since Ordinance no. 2025-1247 of 17 December 2025, those statements are changing their legal basis. The real question owners ask is not "what is the CIBS", but "what do I write, line by line, on my invoices from January 2027". That is the focus here.

For the overall mechanics of the reform, you can first understand the move of VAT to the CIBS. Here we stay on a single track: the documentary compliance of your invoices.

The recodification is announced as unchanged-law. That means one simple thing and one tricky thing.

The simple thing: no rate moves. VAT stays at 20%, 10%, 5.5% and 2.1%. No new mandatory statement is created by the reform alone. If an operation was exempt yesterday, it still is; if it was reverse-charged, it still is.

The tricky thing: the numbering of the legislative articles changes (only the legislative provisions move to the CIBS on 1 January 2027; the rules determining invoice format remain governed by the CGI). An invoice citing "article 293 B of the CGI" to justify the absence of VAT will point, in the new framework, to article L. 233-3 of the CIBS. The substance is identical, but the reference shown must, in time, follow.

The tolerance until 30 June 2028

You do not have to change everything on 1 January 2027. During the transition, references to CGI articles remain accepted on documents until 30 June 2028. In practice, an invoice issued in March 2027 still mentioning "article 293 B of the CGI" is not irregular. That breathing space is useful, especially if your software is not yet updated.

Here are the most common situations where an invoice carries an article reference, with the historical CGI reference and its CIBS counterpart.

Our reading. The only correspondence that is already clear for an invoice statement is the exemption one: article 293 B of the CGI to article L. 233-3 of the CIBS. For the other statements (intra-EU exemption, reverse charge), we recommend relying on the official correspondence table rather than guessing a number. Until that table is fully rolled out, the tolerance through end-June 2028 protects you if you keep the CGI reference.

The small-business exemption: the wording

This is the most widespread statement, carried by micro-entrepreneurs and small businesses under the VAT exemption scheme (franchise en base). A possible wording from 1 January 2027 is: "VAT not applicable, article L. 233-3 of the Code on Taxes on Goods and Services (CIBS)". Article L. 233-3 of the CIBS defines the small-business (exempt) firm in France; it takes the place of former article 293 B of the CGI. Until 30 June 2028, the statement citing article 293 B of the CGI remains accepted.

Here is the approach we apply on client files, from spotting to configuration.

1. Spot every VAT statement on your templates: exemption, intra-EU, reverse charge, margin. Note the CGI article cited next to each.
2. Map each CGI article to its CIBS counterpart using the tax authority's correspondence table.
3. Decide your timeline: switch to the CIBS on 1 January 2027, or keep CGI references until end-June 2028.
4. Correct your invoice, credit-note, quote and slip templates with the chosen reference.
5. Configure your software: edit the automatic statements that inject a legal article and ask the vendor when CIBS wording will be updated.
6. Check the sensitive statements: intra-EU exemption, construction reverse charge, international services, often hard-coded in templates.

If you work in Pennylane, the configure Pennylane step means checking the legal-statement wording tied to your rates and regimes. For subcontracting, our notes on subcontracting invoicing and reverse charge detail the cases. For cross-border work, see how to invoice a foreign client and keep the proof.

On client files, the most frequent friction is not the substantive rule but the software automation. Many ERPs and invoicing tools generate the legal statement by pasting a CGI article number frozen in the initial setup. If no one updates that parameter, your invoices will keep showing the old reference well after the tolerance ends on 30 June 2028.

This is not in itself a VAT reassessment risk during the transition. But it is a source of confusion in an audit, and a wrong statement weakens the evidential quality of the invoice. Better to fix the configuration once, cleanly, than to correct hundreds of invoices afterwards.

A small professional-services firm under the small-business exemption issued invoices from an office template showing "VAT not applicable, art. 293 B of the CGI". During a compliance review ahead of the wider e-invoicing rollout, two adjustments were chosen: align the statement on the new L. 233-3 CIBS reference when the tool was migrated, and use the tolerance until end-June 2028 to avoid re-issuing invoices already sent. The template was corrected once, and an internal note set the switch date so the whole team used the same wording.

• The CGI-CIBS correspondence table is the essential working tool: as long as a correspondence is not clearly listed, keep the CGI reference under the tolerance.
• The same statement must not coexist under two wordings: harmonise all templates at once.
• E-invoicing is rolling out in parallel: use the format-compliance work to also handle legal statements, rather than running two separate projects.
• Framework contracts and general terms citing a CGI article deserve the same care as invoices.

• On 1 January 2027, VAT moves from the CGI to the CIBS, unchanged-law, under Ordinance no. 2025-1247 of 17 December 2025.
• CGI references remain accepted on your documents until 30 June 2028.
• The small-business exemption references article L. 233-3 of the CIBS, the counterpart of former article 293 B of the CGI.
• No VAT rate changes: 20%, 10%, 5.5%, 2.1%.
• The real project is the software configuration of automatic statements, not the substantive rule.
• For complex cases, rely on the official correspondence table and our e-invoicing compliance 2026 support.