E-reporting B2C for merchants: transaction data and 2026-2027 obligations

Why B2C merchants are affected by e-reporting

Since Ordinance No. 2021-1190 of September 15, 2021 and its transposition in Article 290 of the French General Tax Code (CGI), the French electronic invoicing reform is not limited to inter-business transactions. Merchants conducting sales to individuals — B2C flows — are subject to a distinct but complementary obligation: e-reporting, namely the periodic transmission to the Directorate General of Public Finances (DGFiP) of aggregated data on their transactions. This obligation, often perceived as secondary, actually concerns millions of French companies, from small retailers to major distribution chains.

Unlike strict electronic invoicing (reserved for domestic B2B flows), B2C e-reporting does not require the issuance of a structured invoice for each sale. It is a synthetic reporting of turnover data, VAT collected amounts, and supplementary information enabling the tax authority to cross-check declarations and combat VAT fraud, estimated at 15 billion euros annually in France according to the Court of Auditors.

This article details precisely what B2C merchants must transmit, when, through which channel, and how to anticipate the 2026-2027 deadlines without disrupting their operations. For a general overview of the system, consult our complete guide to electronic invoicing 2026-2027.

What is B2C e-reporting: definition and exact scope

Distinction between e-invoicing and e-reporting

The French reform rests on two distinct pillars:

• E-invoicing concerns exclusively invoices issued between VAT-taxable persons established in France (domestic B2B flows). These invoices must mandatorily transit through an approved Partner Dematerialization Platform (PDP) or through the Public Invoicing Portal (PPF).

• E-reporting targets transactions that do not generate mandatory electronic invoices: B2C sales (to non-taxable individuals), transactions with foreign clients (international B2B), and any sale without a mandatory structured invoice obligation.

E-reporting is therefore the mechanism through which the DGFiP maintains visibility over the entire turnover of taxable companies, including flows not covered by e-invoicing. To understand the system's operation in detail, our dedicated article on e-reporting: transmission of transaction data constitutes a complementary resource.

Which B2C merchants are subject to e-reporting?

Any enterprise taxable for VAT in France conducting B2C operations is concerned, provided these operations are located in France under VAT territoriality rules. This includes:

• Retail stores (food, clothing, electronics, DIY, etc.)

• Restaurateurs, hoteliers, service providers to individuals

• E-merchants selling to French consumers

• Mixed enterprises (B2B + B2C) for their B2C portion

Excluded from the scope of e-reporting are: transactions benefiting from a VAT exemption in base (micro-entrepreneurs below thresholds) and certain VAT-exempt activities (medical services, education, etc.).

Transaction data to transmit: the details

B2C e-reporting concerns aggregated data and not individual sales lines. According to Article 242 nonies of the CGI and the Order of October 7, 2022, the information to be transmitted is:

• The total amount excluding tax (HT) of operations for the period

• The amount of VAT collected, broken down by rate (20%, 10%, 5.5%, 2.1%)

• The reference period (day, week, or month depending on the chosen frequency)

• The SIREN number of the issuing company

• The submission deposit number

• Data relating to collection operations if different from the delivery date (deposits)

Unlike e-invoicing, no customer personal data is transmitted to the DGFiP as part of the standard B2C e-reporting, which simplifies GDPR processing of the system.

Implementation timeline for B2C merchants

Deployment waves 2026-2027

The reform timeline has been revised several times. Following successive postponements in 2023 and 2024, the 2024 finance law established the following definitive timeline, confirmed by the DGFiP in its implementing decree of March 28, 2025:

• September 1, 2026: E-reporting obligation for large companies (workforce ≥ 5,000 employees or turnover > 1.5 billion euros) and mid-sized enterprises (ETI, workforce 250-4,999 employees or turnover between 50 million and 1.5 billion euros).

• September 1, 2027: Extension to SMEs (workforce < 250 employees, turnover < 50 million euros) and micro-enterprises taxable for VAT.

It is essential to note that large companies were already required to receive electronic invoices from September 1, 2026 as part of e-invoicing. B2C e-reporting adds to this obligation without replacing it. To follow these steps precisely, refer to the official timeline for electronic invoicing 2026-2027.

Transmission frequency: monthly or weekly?

The frequency of B2C e-reporting transmission depends on the company's VAT regime:

• Normal real regime (monthly): monthly transmission, within 10 days following the end of the reference month.

• Simplified real regime (semi-annual deposits): monthly transmission nonetheless, as the simplified regime does not exempt from frequent e-reporting.

• Weekly option: companies that wish may opt for weekly transmission (calendar week), particularly merchants with high transaction volumes.

The DGFiP strongly recommends that high-volume merchants (large distribution, fast food, e-commerce) opt for weekly transmission, closer to real-time and less exposed to risks of error in monthly aggregates.

Transmission channels: PDP, PPF, and POS software

The central role of approved platforms (PDP)

B2C e-reporting must mandatorily transit through an approved Partner Dematerialization Platform (PDP) approved by the DGFiP, or directly via the Public Invoicing Portal (PPF, formerly Chorus Pro). In practice, B2C merchants not equipped with an ERP having a native PDP connector will have to rely on their POS software or point of sale system (POS) to automate data reporting.

Approved PDPs — whose list is published and updated by the DGFiP — ensure:

• The collection and aggregation of transaction data from source systems (register, ERP, e-commerce)

• Formatting according to DGFiP technical specifications (JSON or XML flows compliant with the official schema)

• Secure and time-stamped transmission to the DGFiP central directory

• Retention of deposit evidence for 10 years

To choose the right solution, our comparison of approved platforms (PA/PDP) will help you identify the determining criteria.

POS software and NF525: the critical interface

For retailers, POS software is the primary collection point for transaction data. Since the 2016 ordinance, the POS software of merchants taxable for VAT must be certified NF 525 (or equivalent), guaranteeing data immutability, security, retention, and archiving. This certification becomes an indispensable prerequisite for e-reporting.

Editors of certified NF 525 POS software have the obligation to integrate, before the 2026-2027 deadlines, a module for export compatible with the DGFiP e-reporting formats. Merchants must therefore verify now that their editor is able to deliver these developments within the timeframes. In case of doubt, our electronic invoicing diagnostic tool allows you to evaluate your level of preparedness in a few minutes.

E-commerce and marketplace flows

For merchants selling through marketplaces (Amazon, Cdiscount, Fnac Marketplace, etc.), the question of marketplace responsibility for e-reporting is clarified by Article 290 bis of the CGI: the marketplace is liable for e-reporting for sales it facilitates, provided it is deemed to have purchased and resold the goods for VAT purposes. Third-party sellers on these platforms are therefore in principle relieved of the obligation for flows transiting through the marketplace — but retain the obligation for their direct sales via their own site.

How to prepare your B2C e-reporting compliance without delay

Audit of your source systems

The first step is to map all B2C sales flows in your company:

• Which systems collect transactions (register, e-commerce site, mobile application, payment terminal)?

• Are your software certified NF 525 and up to date?

• Do you have an ERP or accounting tool capable of aggregating data by period?

• Do you have a contract with an approved PDP, or are you planning to use the PPF?

This audit should ideally be conducted 12 to 18 months before your implementation date to allow time for technical development and integration testing.

VAT breakdown configuration

One of the most frequent friction points concerns breakdown by VAT rate. A merchant selling food products (5.5%), alcoholic beverages (20%), and restaurant service (10%) must ensure that its POS software correctly breaks down each transaction according to the applicable rate and that this breakdown is exportable in the format expected by the DGFiP. Parameterization errors at this level can lead to discrepancies between e-reporting and the VAT CA3 declaration, with a risk of adjustment.

Training of accounting and IT teams

B2C e-reporting is not solely an IT project: it also involves accounting, tax, and sometimes commercial teams. Accounting managers must understand the logic of reconciliation between data transmitted via e-reporting and existing VAT declarations. The DGFiP has published practical guides on its impots.gouv.fr portal, and several professional organizations (FNTR, MEDEF, CCI) offer training dedicated to the reform.

Legal framework applicable to B2C e-reporting

Founding texts of the obligation

The obligation of e-reporting for B2C merchants rests on precise legislative and regulatory framework:

• Ordinance No. 2021-1190 of September 15, 2021 relating to the generalization of electronic invoicing in transactions between taxable persons and to the transmission of transaction data. This founding act authorizes the government to modify the CGI to establish e-reporting.

• Articles 290 and 290 bis of the French General Tax Code (CGI), in their version resulting from the rectifying finance law for 2022: they define the scope of operations subject to e-reporting, the data to be transmitted, the frequency, and transmission conditions.

• Order of October 7, 2022 setting the technical procedures for e-reporting (formats, specifications, data schemas) — modified by the Order of March 28, 2025 to integrate timeline adjustments.

• Decree No. 2022-1299 of October 7, 2022 relating to the generalization of electronic invoicing, specifying the obligations of partner dematerialization platforms.

Penalties for non-compliance

Article 1788 D of the CGI provides for specific penalties in case of failure to comply with the e-reporting obligation:

• Fine of 250 euros per missing or incomplete transmission, up to a limit of 15,000 euros per calendar year.

• In case of repeated failure or deliberate refusal to comply, the tax authority may initiate a contradictory rectification procedure, with possible arbitrary assessment based on reconstructed data.

• Serious breaches may also constitute an indicator in the context of an in-depth tax audit, with the DGFiP now having tools for automatic cross-checking between declared e-reporting and banking or payment data (via Directive DAC 7 transposed into French law).

Articulation with GDPR

Although standard B2C e-reporting does not transmit customer personal data, collection systems (POS software, ERP) process personal data daily (purchase history, loyalty programs). European Regulation No. 2016/679 (GDPR) requires that these processing activities be based on a legal basis and documented in the processing activities register. In particular, the retention of transaction logs for 10 years (tax obligation) must be proportionate and secure according to GDPR requirements. Merchants must ensure that their PDP has a privacy policy compliant with regulations and that data transmitted to the DGFiP is done so on the basis of legal obligation (Article 6(1)(c) of the GDPR).

Technical standards and NF 525 certification

NF 525 certification (standard approved by AFNOR) imposes on POS software requirements for data immutability, periodic closing, and secure archiving. This certification is an indirect prerequisite for e-reporting: a merchant using uncertified software is exposed to a double penalty — that provided for lack of certification (Article 1770 undecies of the CGI, fine of 7,500 euros) and that for failure to comply with e-reporting.

Usage scenarios: B2C merchants facing e-reporting

Scenario 1 — A quick-service restaurant chain with 40 locations

A quick-service restaurant chain operating forty establishments across French territory generates thousands of daily transactions per location, with complex VAT breakdown (10% on restaurant dining-in, 5.5% on takeaway sales of unprepared food products, 20% on alcoholic beverages). Its centralized POS software, certified NF 525, centralizes data from the entire network.

By anticipating the obligation before September 1, 2026, IT has concluded a partnership with an approved PDP 18 months in advance. The connector between the POS software and the PDP required 3 months of development and 2 months of acceptance testing. The PDP automatically generates weekly e-reporting files (option chosen to reduce the risk of error in aggregates) and submits them to the DGFiP before each Monday evening. The reconciliation time between weekly e-reporting and monthly VAT declaration CA3 has been reduced from 4 days to less than 2 hours through automation. Estimated time savings on accounting reconciliation tasks: approximately 60% of dedicated staff time.

Scenario 2 — A mid-sized e-merchant with direct sales and marketplace

An online company specializing in home equipment achieves approximately 35% of its turnover via its own site (direct B2C flow, subject to e-reporting) and 65% through two major marketplaces (flows for which the marketplace is liable for e-reporting as a deemed supplier). The challenge for this mid-sized enterprise, affected from September 1, 2026, is to transmit to the DGFiP only data corresponding to its direct sales, without double-counting with marketplace sales.

It has implemented a monthly extraction procedure from its e-commerce platform, filtered by sales channel, transmitted via its PDP. A contractual clause has been negotiated with each marketplace to obtain written confirmation of the assumption of e-reporting responsibility on facilitated sales. This contractual framework is essential to protect against any risk of adjustment in case of audit. Gain in tax clarity and reduction of double-declaration risk: significant for a structure whose flow complexity had already generated adjustments during previous VAT audits.

Scenario 3 — A small multi-activity retail business (SME, entry into force September 2027)

An SME operating three gift and decoration shops in a mid-sized city, with annual turnover of 1.2 million euros, is affected by e-reporting from September 1, 2027. Its POS software, acquired in 2021, is certified NF 525 but its editor has not yet communicated on e-reporting compatibility. Upon reading the official timeline in early 2026, the manager contacted the editor: it confirmed delivery of an e-reporting module in its December 2026 update, nine months before the deadline.

The SME also used an electronic invoicing diagnostic tool to evaluate its digital maturity and decided to opt for the PPF (Public Invoicing Portal, free) rather than a paid PDP, its transaction volume being moderate and its accounting structure simple. Monthly transmission was configured automatically, with an email alert in case of submission failure. Estimated total compliance cost: less than 2,000 euros (software update included), an investment proportionate to the penalties avoided.

Ofte stillede spørgsmål

Forpligter e-reporting B2C handlende til at transmittere deres kunders personoplysninger til DGFiP?

Nej. E-reporting B2C bygger på transmission af aggregerede data efter periode: beløb ekskl. moms, moms fordelt efter sats og virksomhedens SIREN-nummer. Der sendes ingen navngivne oplysninger om private købere til Direktoratet for Offentlige Finanser. Dette skelner e-reporting fra visse udenlandske skatteordninger og forenkler imidlertid betydeligt GDPR-overholdelsen for handlende.

Er en mikrofirmaer, der er momspligtig, underlagt e-reporting B2C fra 2027?

Ja, hvis mikrofirmaet faktisk er momspligtig — dvs. hvis det har overskredet momsbefrielsesgrænserne eller frivilligt har valgt momsregistrering. Så længe det nyder godt af momsfritagelsen, er det dog undtaget fra ordningen. Momsregistrering er således den udløsende faktor, uafhængigt af juridisk status eller størrelsen af strukturen.

Hvad er forskellen mellem e-reporting og almindelig momsangivelse?

Momsangivelsen (CA3 eller CA12) forbliver en særskilt skatteforpligtelse, der indgives til skattemyndighederne. E-reporting derimod er en periodisk transmission af transaktionsdata til DGFiP via en Partnerplatform for Digitalisering eller Det Offentlige Faktureringportal. De to forpligtelser eksisterer side om side: e-reporting erstatter ikke momsangivelsen, men gør det muligt for myndighederne at krydstjekke og validere de angivne oplysninger.

Skal en handlende med blandet B2B- og B2C-aktivitet håndtere to separate forpligtelser?

Ja. Den del af aktiviteten, der udføres med franske momspligtige virksomheder, falder under e-fakturering, dvs. emission af strukturerede elektroniske fakturaer. B2C-delen falder derimod under e-reporting med aggregeret transmission. I praksis kan de to dataflows håndteres via en samme godkendt partnerplatform, men de følger forskellige regler vedrørende indhold og format, som bør skelnes i parameteriseringen.

Hvad risikerer en B2C-handlende, der ikke transmitterer sine e-reporting-data til tiden?

Den almindelige skattelov foreskriver sanktioner ved misligholdelse af angivelsesforpligtelser. Bøder kan pålægges for manglende eller urigtig transmission. Ud over den økonomiske sanktion udsætter manglende transmission virksomheden for mere omfattende skattemæssig revision, idet myndighederne ikke har de nødvendige data til at validere sammenhængen mellem den faktiske omsætning og den angivne moms.

Conclusion

B2C e-reporting represents a profound transformation in the relationship between merchants and the French tax authority. Contrary to common perceptions, it is not limited to major chains: any VAT-taxable company conducting sales to individuals is concerned, with deadlines beginning September 2026 for mid-sized enterprises and large companies, and September 2027 for SMEs.

The keys to success lie in anticipation: audit of POS systems, verification of NF 525 certification, choice of an approved PDP or the PPF, and training of accounting teams. Penalties for non-compliance (up to 15,000 euros per year) make last-minute postponement particularly risky.

Certyneo supports you in your tax and documentation compliance journey. Evaluate your level of preparedness today with our free electronic invoicing diagnostic or contact our experts for personalized support via our contact space.