The French reform on electronic invoicing is often reduced to one issue: B2B e-invoicing. For many companies, e-reporting is by far the greater operational challenge – and the most frequently underestimated part of the reform.

Two obligations – staggered deadlines

The reform will be phased in. From September 1, 2026, the obligation to receive electronic reports will apply to all companies based in France, as well as the outbound and e-reporting obligations for large companies and ETIs (Exchange Traded Institutions). For SMEs, TPEs (Exchange Traded Institutions), and micro-enterprises, the outbound and e-reporting obligations will begin on September 1, 2027.

E-Invoicing → for domestic B2B transactions between VAT-registered companies based in France
E-Reporting → for certain transactions outside the e-invoicing scope, in particular B2C sales, relevant cross-border B2B transactions, and payment data for services where VAT is incurred upon payment

From September 1, 2027, SMEs, TPEs (Technical Product Authorities), and micro-enterprises will be required to issue electronic invoices and use e-reporting. However, starting September 1, 2026, all companies established in France – regardless of size – must be able to receive electronic invoices and select a Plateforme Agréée (Approved Platform) for this purpose.

Who is affected by e-reporting?

This does not only affect companies based in France. Foreign companies with French VAT ties may also be subject to e-reporting requirements if, for example:

generate taxable B2C sales in France,
Conduct cross-border B2B transactions with French tax implications,
or, as a company not established in France, generate sales for which they owe French VAT.

For companies not established in France, the scope will be further extended from 1 September 2027 to include certain acquisition and supply cases where the recipient of the service owes French VAT by way of reverse charge or self-assessment.

And what applies to supplier invoices?

Credit invoices should not be automatically equated with e-reporting. The supplier's origin and the VAT classification of the transaction are crucial. Equally important: The buyer is not required to report the payment of an incoming invoice as a payment e-report.

Invoices from French suppliers: For domestic B2B transactions, they are received as electronic incoming invoices via a Plateforme Agréée (Approved Platform). The French buyer does not need to report the supplier's invoice or its payment separately as an e-report. The invoice data is transmitted within the e-invoicing process; any payment data is reported by the supplier if applicable.
Invoices from foreign suppliers: These are not received via the French e-invoicing network. However, for companies established in France, intra-Community acquisitions, purchases of goods taxable in France with reverse charge, and relevant services received from foreign suppliers fall within the scope of transaction e-reporting. The tax-relevant transaction data is reported – not the payment of the supplier's invoice. Pure goods imports are excluded from transaction e-reporting. For companies not established in France, the extension to acquisitions and services where they, as the recipient of the goods or services, are liable for French VAT, generally applies from September 1, 2027.

Specifically excluded from e-reporting are sales outside the scope of VAT, certain sales exempt from VAT and invoicing according to Articles 261 to 261 E CGI, and security-related special cases. This distinction should be explicitly considered in the SAP scope.

For SAP projects, this means that in addition to customer documents, vendor processes must also be analyzed – not because every incoming invoice or its payment needs to be reported, but so that French domestic invoices are received correctly and relevant cross-border acquisition and reverse charge cases are reliably classified and reported on a transaction-related basis.

The technical infrastructure: PA and PPF

France relies on a decentralized but strictly regulated ecosystem. E-invoices and e-reporting data are transmitted via a state-accredited private platform – the so-called Plateforme Agréée (PA), formerly known as PDP. Direct operational transmission to the tax authorities without the PA is not permitted.

The PPF (Portail Public de Facturation) functions in particular as:

central company directory for invoice addressing,
Data concentrator for forwarding the reporting data to the DGFiP.

Supported structured invoice formats include, in particular, Factur-X, UBL, and CII. Specific format and process support depends on the chosen PA (Process Automation) and the connected solution.

The real challenge: Data from SAP

In B2B e-invoicing, reporting data is generated from the structured invoice flow. In contrast, with e-reporting, relevant processes must be identified, processed, and transmitted in a structured manner separately. In practice, this means:

Classification of each receipt: domestic B2B, B2C, cross-border or relevant acquisition case?
Separation of accounts receivable and accounts payable processes and clear determination of reporting responsibilities
Complete extraction of all tax-relevant fields from SAP – including received payment data on the sales side for services and advance payments with tax liability arising after payment; not for reverse charge transactions, for the option of taxation based on agreed consideration, and not for the payment of vendor invoices.
Preparation in the prescribed reporting format of the DGFiP
Timely connection to a Plateforme Agréée – transmission occurs periodically depending on the VAT regime; international B2B data is generally reported at the individual transaction level within the reporting period, while B2C data is reported in daily aggregated form.

This is precisely where the biggest gaps become apparent in practice: in data quality, process logic, and technical integration. Those who only check whether SAP has correctly populated all relevant fields and classified document types just before the deadline often experience unpleasant surprises.

GOpus® eTax: SAP-like solution for e-reporting

GOpus® eTax works directly at the data source – in SAP – and supports the entire process chain:

✅ Extraction of tax-relevant transaction data and – if necessary – the received payment data on the sales side from SAP
✅ Inclusion of relevant customer and vendor documents in the scope check
✅ Preparation in the reporting formats required by the DGFiP
✅ Technical connection to your chosen Agréée platform
✅ Integration into existing SAP processes – without cloud migration and without system change
✅ Support for international reporting formats for cross-border requirements

The solution is designed as an SAP add-on and is compatible with SAP ECC and SAP S/4HANA. The choice of PA provider remains flexible.

Act now – before the deadline becomes a bottleneck

Early testing saves valuable time for bug fixes before live operation begins. Experience from comparable international compliance projects shows that coordination requirements, project volume, and lead times increase significantly shortly before legal deadlines.

Three concrete first steps:

Clarify the scope – Which outgoing and incoming processes fall under e-invoicing or e-reporting?
Check data quality – Are all tax-relevant fields in SAP completely and correctly filled?
Define your platform strategy – Which PA suits your infrastructure and process requirements?

👉 Contact us – We analyze your scope and show you the way to compliance with GOpus® eTax.

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