France postpones VAT recodification to January 2027

France has postponed the entry into force of its recodified VAT legislation from September 1, 2026, to January 1, 2027. The delay does not change VAT obligations or the e-invoicing timetable, but gives businesses more time to adapt legal references and documentation.

France has postponed the main entry into force of its VAT recodification from September 1, 2026, to January 1, 2027. The change was introduced by Ordinance No. 2026-671 of July 27, 2026.

The recodification concerns the transfer of most French VAT provisions from the General Tax Code (Code général des impôts – CGI) to the Code of Taxes on Goods and Services (Code des impositions sur les biens et services – CIBS).

This is primarily a restructuring of the French VAT legal framework. It does not introduce a new VAT system and is not intended to change how businesses calculate VAT, when VAT becomes due, which transactions are taxable or which VAT rates apply.

Instead, the reform reorganizes the legal provisions and changes where businesses, tax advisers and software providers will find the relevant VAT rules. In practice, many provisions that are currently referred to by their CGI article number will eventually be cited under new CIBS article numbers.

The original plan was for the recodified VAT provisions to apply from September 1, 2026. However, this is also the first major implementation date for France’s mandatory electronic invoicing reform. From September 1, 2026, businesses falling within the French reform must be able to receive electronic invoices. Large companies and mid-sized companies must also start issuing electronic invoices and complying with the applicable e-reporting requirements from that date.Small and medium-sized enterprises and micro-enterprises will generally follow with their electronic invoice issuance and e-reporting obligations from September 1, 2027. Having the VAT recodification and the first major e-invoicing implementation phase enter into force on the same date was considered potentially confusing for businesses.

The French authorities therefore decided to separate the two changes. The e-invoicing reform remains on its existing timetable, while the main application date of the VAT recodification has been moved to January 1, 2027.

Businesses must therefore continue applying the existing VAT rules in the normal way. VAT rates, taxable transactions, exemptions, invoicing requirements and other substantive VAT obligations are not postponed because of this measure.The same applies to the French e-invoicing reform. Its implementation dates are separate from the VAT recodification and are not postponed by Ordinance No. 2026-671. For companies already preparing for the September 2026 e-invoicing deadline, this means that those projects should continue according to the existing schedule.

What does this mean for retailers and POS providers?

For retailers, POS providers and other retail technology companies, the change is mainly relevant from a legal-reference and documentation perspective. The postponement does not introduce a new POS transaction type, a new fiscalization process or a new VAT calculation method. Retailers do not need to change how standard sales, refunds or VAT calculations are processed simply because VAT provisions are being transferred from the CGI to the CIBS. The postponement therefore gives businesses more time to carry out this mapping without combining it with the most critical implementation phase of the French e-invoicing reform.

Implementation Impact and What the Business Should Do?

Businesses should not change their VAT calculation, POS or sales processes solely because of the VAT recodification. Instead, companies should identify French VAT references used across invoices, POS systems, ERP systems, contracts, tax procedures and technical documentation, and map existing CGI references to the corresponding CIBS provisions. Businesses should also keep the VAT recodification project separate from the mandatory e-invoicing project. The French e-invoicing timetable has not been postponed, and preparations for obligations applying from September 1, 2026 should continue.

The official source is Ordinance No. 2026-671 of July 27, 2026, concerning various adjustments to the code of taxation on goods and services. Source

Nikolina Basić, Senior Legal Consultant at Fiscal Solutions

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