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France: DGFiP formalizes B2C e-reporting rules in new BOFiP doctrine

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Summary

French Tax Authority has published its first detailed Doctrine on e-reporting. For B2C sellers, it confirms that sales to consumers fall within transaction e-reporting and that data are reported as daily aggregates by transaction category and VAT rate, with separate payment reporting where VAT is cash-based.

Content

On September 30th, 2026, the French tax administration, DGFiP, published new official BOFiP guidance detailing the rules for both transaction e-reporting and payment e-reporting under France’s electronic invoicing reform.

The two key publications are BOI-TVA-DECLA-20-30-50, covering transaction e-reporting, and BOI-TVA-DECLA-20-30-60, covering payment e-reporting. The publication is particularly important for retailers and other B2C businesses because it gives an official administrative interpretation of how consumer transactions must be reported to the tax administration.

The obligations themselves are not new. They originate mainly from Articles 290 and 290 A of the French General Tax Code (CGI). However, the new BOFiP material provides a much stronger administrative reference for determining the scope, data requirements, aggregation rules and reporting frequencies.

B2C transactions are now formally confirmed as part of e-reporting:

The new doctrine clearly states that transaction e-reporting applies to transactions carried out with persons who are not subject to VAT, which includes ordinary private consumers.

For a taxable person established in France, this covers a broad range of B2C operations, including domestic sales of goods, services supplied to consumers and certain cross-border transactions. It can also include intra-EU distance sales and specific services supplied to consumers outside France, depending on where the transaction is considered to take place for VAT purposes.

Certain transactions remain outside the e-reporting obligation. In particular, BOFiP identifies transactions exempt from VAT and exempt from invoicing under Articles 261 to 261 E of the CGI, as well as several specific categories defined by law.

For retailers, an important distinction remains: B2C e-reporting is not the same as B2B electronic invoicing and thus is not handled in the same way as the other.

A retailer does not generally have to issue a structured electronic invoice through an approved platform when selling to an ordinary consumer. The existing customer-facing receipt or B2C invoice process can continue. Instead, the retailer must transmit prescribed information about those transactions separately to the tax administration through an approved platform – plateforme agréée. DGFiP guidance expressly confirms that businesses must use such platforms for transmitting transaction and payment data.

One of the most important confirmations for retail is how B2C information is aggregated.

BOFiP states that transaction information relating to non-taxable customers must be globalised by day. This means France is not requiring retailers to send every individual consumer receipt and consumer identity to DGFiP as a separate transaction record.  Instead, the required data include information such as the seller's SIREN, reporting period, transaction category, transaction date, taxable amount excluding VAT by VAT rate, corresponding VAT amount, currency and, where applicable, total French VAT due.  

DGFiP's practical guidance also explicitly explains that the data can come from the retailer's cash-register daily summary – the ticket Z. The cash-register system, POS software or another compatible solution can therefore become the upstream data source feeding the e-reporting process. The actual statutory transmission to DGFiP is then handled through an approved platform.  

This is particularly relevant to POS software providers because the POS may need to produce the correct daily VAT aggregation, transaction classifications and data structure even though the POS itself is not necessarily the entity directly communicating with the tax administration.

Daily aggregation does not mean daily submission of data.

Retailers should distinguish between the granularity of the data and the frequency at which those data are transmitted. B2C information is aggregated by day, yes, but the transmission frequency depends on the seller's VAT regime.

For businesses subject to the normal monthly VAT regime, transaction e-reporting is required three times per month, covering transactions performed from the 1st to the 10th, from the 11th to the 20th, and from the 21st to the end of the month. Each transmission must reach the administration within ten days after the end of the relevant period.  

Businesses under the normal quarterly regime and those currently under the simplified regime report transaction information monthly, while businesses benefiting from the VAT exemption threshold generally report every two calendar months.  

Therefore, for many large retailers using the normal monthly VAT regime, the practical model is:

individual POS transactions → daily VAT aggregation → three e-reporting transmissions per month through the approved platform.

Separate rules apply to payment e-reporting segment:

The second BOFiP publication, BOI-TVA-DECLA-20-30-60, deals with payment information.

Payment e-reporting is not a general requirement to report the payment method for every retail sale. It applies where VAT becomes chargeable when payment is actually collected. BOFiP specifically identifies services, advance payments and other transactions subject to VAT on collection.  

For B2C transactions falling within this requirement, payment data are also aggregated by day and VAT rate. The information includes the effective payment date and the amount collected by VAT rate.  

Consequently, a normal retail sale of goods that is paid for and supplied immediately will generally rely primarily on transaction e-reporting, because VAT on the goods is normally triggered by the supply rather than the collection of payment. Payment e-reporting becomes particularly important for retailers providing services or receiving advances before the underlying transaction is completed.  

When does the obligation apply?

BOFiP reconfirms again the before defined implementation dates:

  • 1 September 2026: large enterprises, intermediate-sized enterprises (ETIs) and VAT groups;
  • 1 September 2027: SMEs and micro-enterprises.  

This latest publication therefore does not postpone or restart the reform. For large companies and ETIs, the obligation has already legally started.

However, the French government has confirmed that the launch period is being handled under a tolerance approach and that no sanctions will be applied to companies during 2026 for difficulties implementing the reform. This is an enforcement tolerance rather than a change to the legal implementation date.  

From my point of view, the significance of the 30 September BOFiP publication is not that France suddenly introduced B2C e-reporting. That obligation was already established by law but the important change is that retailers now have a detailed and authoritative DGFiP guidance describing exactly how the administration interprets the obligation.

For retail, the strongest clarification is that the system is not designed as receipt-by-receipt consumer reporting. Instead, POS and retail systems must be capable of producing reliable daily aggregates by transaction category and VAT rate and transferring that information into the approved-platform reporting process.

This makes e-reporting a direct retail-system integration topic rather than simply an accounting or e-invoicing issue.

Implementation impact and what businesses in scope should do?

Large retailers and ETIs are already within the e-reporting obligation from this September. Their POS, e-commerce, ERP and accounting environments should be able to consolidate B2C transactions into the required daily VAT aggregates and make those data available to an approved platform.

Retailers should now verify that their implementation covers the correct transaction categories, VAT rates, daily aggregation, applicable reporting frequency and payment reporting for services or advance payments. POS providers should particularly review whether the daily Z-report/data export contains all information needed for the French e-reporting flow and how those data are transferred to the retailer's approved platform.

Primary official sources for these updates include the:  BOI-TVA-DECLA-20-30-50 — Transaction e-reporting as well as the BOI-TVA-DECLA-20-30-60 — Payment e-reporting , as published by the French Tax Authorities. Source Source

 

Tara Nedeljković, Team Lead of Legal Consultants at Fiscal Solutions

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