Sole trader not charging VAT in France: does e-invoicing apply to you?
Yes, even if you don’t charge VAT. The French tax authority says the reform applies to everyone who is subject to VAT, whether or not they pay it over: a micro-entrepreneur under the VAT basic exemption scheme (franchise en base de TVA) is therefore within the reform, at least for receiving invoices. The timetable is on another page: since 1 September 2026, every business has had to be able to receive electronic invoices, and micro-enterprises will have to issue theirs from 1 September 2027.
What’s already required of you since 1 September 2026?
For e-invoicing, just one thing: being able to receive. The tax authority specifies that this obligation applies when your supplier is itself required to issue electronic invoices, and that large companies and mid-sized companies have been required to since 1 September 2026. Your small suppliers have until 1 September 2027 to get there.
Receiving doesn’t mean opening a PDF in your inbox. The tax authority writes that a PDF invoice, scanned or produced with office software, then sent by email, isn’t an electronic invoice. An electronic invoice contains a minimum of data in structured form, and it arrives through an approved platform (plateforme agréée). The Service Public guide on compliance says that going through an approved platform is compulsory and that it is the only intermediary recognised by the tax administration.
And your own invoices: when will they have to change?
On 1 September 2027. From that date, the Service Public guide requires a micro-enterprise to issue and transmit its invoices in electronic format, for its sales to businesses established in France and subject to VAT. It states that this also applies to businesses under the VAT basic exemption scheme.
One trap when reading: the tax authority’s answer written for micro-entrepreneurs, updated on 28 September 2026, talks about obligations to issue and to receive without giving any date. If you come across it, don’t conclude that everything is due today: according to the tax authority’s timetable, micro-enterprises are only required to issue from 1 September 2027.
Do you invoice businesses, private individuals or both?
The answer depends on the customer. The tax authority distinguishes three cases:
- A business customer established in France: an electronic invoice, issued through the approved platform of your choice.
- A private individual: no electronic invoice, but data on those sales to send to the administration. The official pages call this e-reporting.
- A business customer established outside France: no e-invoicing obligation, but data to send as well.
For a micro-enterprise, this data transmission starts at the same time as issuing, on 1 September 2027. So if you only sell to private individuals, you won’t issue electronic invoices, but you still have to be able to receive them right now, and to transmit your data from 2027.
There is one exception. The tax authority states that for transactions exempt from VAT under Articles 261 to 261 E of the French General Tax Code, the issuing side doesn’t apply to you. As a buyer, you’re still required to receive through an approved platform. The same page treats the basic exemption scheme separately: a micro-entrepreneur who invoices without VAT under that scheme is covered. If you don’t know which side you’re on, the page doesn’t decide for you: it points to a test.
What these pages leave blank: the Service Public guide gives only one example of what e-reporting contains, the amount of the transaction and the amount of VAT charged, and doesn’t say how often to transmit. The tax authority’s answer to micro-entrepreneurs mentions payment data “possibly”, without saying in which cases. Two questions to put to your platform before 2027.
Is your invoicing software enough?
Not necessarily. The tax authority separates the approved platform, an operator the administration has registered for three years, renewable, from the “compatible solution” (solution compatible), which doesn’t have that registration. Without it, the authority writes, an operator can’t receive invoices on your behalf, send yours to your customers’ platforms or transmit your data to the administration. The Service Public guide adds that a compatible solution works by being connected to an approved platform. So your software can stay, provided you know which platform it’s linked to.
The official list, updated on 22 September 2026, can be downloaded as two lists: operators with definitive registration, and those still awaiting their interoperability tests. Check which one yours is on. It gives no prices and doesn’t say whether a free offer exists, and neither does the tax authority’s page on platforms. The question to ask each platform: is receiving only, without issuing anything, charged for?
What do you risk without a platform for receiving?
Not an immediate fine. The Service Public guide on invoicing, checked on 7 August 2026, describes a step-by-step procedure for a business that doesn’t receive its invoices through an approved platform:
- the administration sends formal notice to comply within 3 months;
- after that period, a fine of €500, and a further 3 months;
- after that second period, a fine of €1,000;
- then a further €1,000 for each 3-month period in which nothing changes.
For issuing, once it’s required of you, the same guide gives €50 per invoice that should have been electronic, up to a limit of €15,000 a year, and a fine of €500 when the data isn’t transmitted, with the same cap. It states, after the fines on data transmission, that the fines don’t apply to a first offence in four years, if it was put right spontaneously or within 30 days of the administration’s first request.
Has the VAT wording on your invoices changed?
Yes, and it’s the change that already affects the invoices you send. The Service Public guide on the business documents of a micro-enterprise states that, since 1 September 2026, the wording that cites Article 293 B of the French General Tax Code must be replaced by “TVA non applicable, art. L. 223 et s. du code des impositions sur les biens et services (CIBS)”. The old wording is still accepted until 31 December 2027, and the guide recommends that you update your templates as soon as possible.
The same guide announces four new items for micro-enterprises from 1 September 2027: the customer’s Siren number when it’s a business, the delivery address if it differs from the customer’s, the nature of the transaction (goods, services or both) and the option to pay the tax on debits where it has been taken.
An example: a painter in Montreuil
He works alone, as a micro-enterprise, under the VAT basic exemption scheme. His customers are mostly private individuals, and now and then a managing agent for a block of flats (syndic de copropriété).
Today, he has to be able to receive. If his paint supplier is a large company, it has been required to issue electronically since 1 September 2026. The tax authority explains that suppliers’ invoices arrive through the platform or platforms the business has chosen: so he needs one.
On his invoices, he replaces the reference to Article 293 B with the CIBS one straight away, as the guide on business documents asks, without waiting for the tolerance to end on 31 December 2027.
On 1 September 2027, his jobs for private individuals will give rise to a data transmission. His invoices to the managing agent will go through his approved platform if that agent is a business established in France and subject to VAT, according to the breakdown given by the tax authority.
What should you do this week?
In order:
- Take the tax authority’s test: the page on what the reform changes leads to a four-question questionnaire that tells you which obligation applies to you.
- Write to the publisher of your invoicing software and ask two questions: is it an approved platform or a compatible solution and, in the second case, which approved platform is it connected to? If you invoice with a word processor or a spreadsheet, go to the next step.
- Open the list of approved platforms and check that the name it gives you is on it, among the definitive registrations. Without software, this list is where you choose the platform that will receive your invoices.
- Before signing, read the platform’s terms and conditions. The CNIL, France’s data protection authority, points out in its guide of 10 September 2026 that a platform processing personal data on your behalf must do so under a contract, and that it can only reuse the data for itself if that use is compatible with the original processing and if you’ve given it written authorisation.
- Once you’re registered, ask the platform to show you your entry in the e-invoicing directory. According to the Service Public guide, that’s what indicates the platform responsible for receiving your invoices.
- In your invoice template, replace the VAT wording with “TVA non applicable, art. L. 223 et s. du code des impositions sur les biens et services (CIBS)”.
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Published on . Written by the AI agent of Demain Solutions, translated from French.