France's e-invoicing rules for foreign companies: when you are in scope

Published 19 October 2026 · 7 min read

A foreign company is subject to France's e-invoicing mandate only if it has a permanent establishment in France for VAT purposes; a French subsidiary is a French company, in scope in its own right. A company merely registered for French VAT, with no establishment in France, does not have to issue or receive e-invoices through an approved platform, but it may have to send e-reporting data to the French tax authority for its transactions located in France on which it is liable for French VAT. That is the position of Articles 289 bis and 290 of the French General Tax Code (CGI), in force since 21 February 2026, and of the DGFiP's English presentation of 10 February 2026; check your own case with your tax adviser.

The short answer

Established in France: full scope

Article 289 bis I CGI applies e-invoicing to supplies of goods and services between taxable persons established in France. The DGFiP's FAQ (version of 1 September 2026) draws the line at the permanent establishment "within the meaning of VAT": a company with its seat abroad and such an establishment in France has the same obligations as one established in France. The full regime then applies, as described in France's e-invoicing mandate: what applies in 2026 and 2027: receiving through an approved platform (plateforme agréée) since 1 September 2026, issuing from 1 September 2026 or 2027 depending on size, and e-reporting of sales to non-taxable persons and of cross-border business transactions, including purchases from non-established suppliers (Article 290 I CGI).

The size category that fixes the issuing date is assessed per legal entity (SIREN number) as at 1 January 2025, on the last financial year closed before that date (Article 91 of the Finance Act for 2024). A small French subsidiary of a large foreign group is therefore an SME or a micro-enterprise under Decree 2008-1354 of 18 December 2008, with 1 September 2027 as its issuing date, unless it belongs to a French VAT group (assujetti unique).

VAT-registered without establishment

The DGFiP states that foreign companies without a permanent establishment in France, within the meaning of VAT, "are not subject to e-invoicing requirements". Your invoices to French customers are not e-invoices under Article 289 bis: your French business customer reports the purchase through its own e-reporting, with your intra-Community VAT number or foreign tax number in place of a SIREN. E-reporting may, however, apply to you under Article 290 II CGI, which covers taxable persons not established in France, or their representative where one must be appointed under Article 289 A, for supplies of goods and services located in France that they carry out, or of which they are the customer or recipient, and for which they are liable for French VAT.

The dates follow the same two steps, with one addition the DGFiP attributes to the Finance Act for 2026 (Law 2026-103 of 19 February 2026, Article 123): e-reporting as seller from 1 September 2026 for large and intermediate-sized enterprises and from 1 September 2027 for the others; e-reporting as buyer liable under the reverse charge, including intra-Community acquisitions, from 1 September 2027 whatever the size. The DGFiP assesses size on the foreign legal entity as a whole: worldwide turnover, balance-sheet total and headcount. A company subject to e-reporting must choose an approved platform before its date (list on impots.gouv.fr, in French only).

Transactions covered and e-reporting

The DGFiP lists the typical transactions of a non-established, VAT-registered company that fall under e-reporting:

• selling goods from France to non-taxable persons domiciled in France;
• distance sales from another Member State, or services taxable in France, to non-taxable persons in France, outside the One Stop Shop;
• sales of goods or services taxable in France to non-established taxable persons not registered for French VAT;
• from 1 September 2027, non-exempt intra-Community acquisitions in France, and purchases of goods or services taxable in France from a non-established supplier, where the company is liable for the VAT under the reverse charge.

The data are aggregated per day for sales to non-taxable persons, and those of an e-invoice, with your foreign identifier in place of the SIREN, for business transactions; payment data are added where VAT is due on payment, as for services. The frequency depends on your VAT regime (Annex II CGI, Articles 242 nonies O and P, as amended by Decree 2026-677 of 27 July 2026): from three transmissions per month under the normal regime with monthly returns to one per two calendar months under the VAT exemption scheme; no transaction data is due for a period without a relevant transaction. The mechanics are in E-reporting in France: what data you send, and how often.

The EU's ViDA package adds its own digital reporting on a separate timeline: EU ViDA and e-invoicing: the timeline for businesses.

What to do first

1. Settle your establishment status in writing with your tax adviser. With a permanent establishment, follow the full French timeline.
2. List your transactions located in France. Separate the sales on which you are liable for French VAT, the purchases on which you self-assess it (in scope from 1 September 2027), and the flows outside e-reporting: exports, intra-Community supplies, One Stop Shop transactions.
3. Fix your size category with worldwide figures as at 1 January 2025, to know whether your e-reporting as seller started in 2026 or starts in 2027.
4. Choose an approved platform before your date, with your fiscal representative or accountant, and check that your software can export the data.
5. Put the calendar in your closing process: who extracts and sends the data, at which frequency, and who keeps the proof.

FAQ

My company appears in the French directory. Does that mean I must e-invoice?

No. The DGFiP states that being in the directory does not make a non-established foreign company subject to e-invoicing: it does not have to choose a receiving platform, but may still be subject to e-reporting.

A French customer asks me for an e-invoice through a platform. Am I obliged?

Not under Article 289 bis CGI, which applies only between taxable persons established in France; your customer reports the purchase through its own e-reporting. Agree the invoice data it needs, in particular identifiers and VAT treatment.

What happens if a non-established company misses an e-reporting transmission?

Article 1788 D CGI sets a fine of EUR 500 per transmission, capped at EUR 15,000 per calendar year, waived for a first breach in the current calendar year and the three preceding years if corrected spontaneously or within thirty days of the administration's first request. Légifrance shows Articles 289 bis and 290 as repealed from 1 January 2027 by Ordinance 2025-1247 of 17 December 2025, which moves VAT into the Code des impositions sur les biens et services, some provisions staying in force until implementing regulations take them over; this version of Article 1788 D also ends on that date. Check the texts in force on the date of the breach.