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

Why B2C retailers are affected by e-reporting

Since the ordinance no. 2021-1190 of 15 September 2021 and its transposition in article 290 of the French General Tax Code (CGI), the French electronic invoicing reform is not limited to inter-company exchanges. Retailers making sales to individuals — B2C flows — are subject to a distinct but complementary obligation: e-reporting, namely the periodic transmission to the French Tax Authority (DGFiP) of aggregated data on their transactions. This obligation, often perceived as secondary, actually concerns millions of French companies, from small retailers to major retail 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 transmission of turnover data, VAT collected amounts and complementary information allowing the tax authority to cross-check returns and combat VAT fraud, estimated at 15 billion euros annually in France according to the French Court of Auditors.

This article details precisely what B2C retailers must transmit, when, via which channel, and how to anticipate the 2026-2027 deadlines without disrupting their business. For a general overview of the scheme, 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 obligatorily pass through an approved Partner Dematerialisation Platform (PDP) or through the Public Invoicing Portal (PPF).

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

E-reporting is therefore the mechanism by which the DGFiP maintains visibility over all the turnover of taxable companies, including flows not covered by e-invoicing. To understand in detail how the scheme works, our dedicated article on e-reporting: transmission of transaction data is a complementary resource.

Which B2C retailers are subject to e-reporting?

Any company subject to VAT in France carrying out B2C operations is concerned, provided that these operations are located in France under VAT territoriality rules. This includes:

• Retail shops (food, clothing, electronics, home improvement, etc.)

• Restaurateurs, hoteliers, service providers to individuals

• E-commerce retailers selling to French consumers

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

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

Transaction data to be transmitted: the details

B2C e-reporting covers aggregated data and not individual sales lines. According to article 242 nonies of the CGI and the order of 7 October 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 deposit number of the transmission

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

Unlike e-invoicing, no customer personal data is transmitted to the DGFiP in the context of standard B2C e-reporting, which simplifies GDPR processing of the scheme.

Timeline for entry into force for B2C retailers

Deployment waves 2026-2027

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

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

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

It is essential to note that large companies already had to receive electronic invoices as of 1 September 2026 under e-invoicing. B2C e-reporting is added 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 scheme:

• Normal standard VAT system (monthly): monthly transmission, within 10 days following the end of the reference month.

• Simplified standard VAT system (half-yearly deposits): monthly transmission nonetheless, as the simplified system does not exempt from frequent e-reporting.

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

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

Transmission channels: PDP, PPF and till systems

The central role of approved platforms (PDP)

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

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

• Collection and aggregation of transaction data from source systems (till, 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 proof of deposit for 10 years

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

Till software and NF 525: the critical interface

For retail shops, till software is the primary collection point for transaction data. Since the 2016 ordinance, till software of companies subject to VAT must be certified NF 525 (or equivalent) guaranteeing data immutability, security, retention and archiving. This certification becomes the indispensable prerequisite for e-reporting.

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

E-commerce and marketplace flows

For retailers selling via marketplaces (Amazon, Cdiscount, Fnac Marketplace, etc.), the question of responsibility for e-reporting is clarified by article 290 bis of the CGI: the marketplace is liable for e-reporting for sales it facilitates, insofar as it is deemed to have acquired and resold the goods under VAT rules. Third-party sellers on these platforms are therefore in principle relieved of the obligation for flows passing 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 (till, e-commerce site, mobile application, card 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 carried out 12 to 18 months before your entry into force date to allow time for technical developments and integration testing.

VAT breakdown configuration

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

Training of finance and IT teams

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

Legal framework applicable to B2C e-reporting

Founding texts of the obligation

The obligation for B2C retailers to provide e-reporting rests on a precise legislative and regulatory corpus:

• Ordinance no. 2021-1190 of 15 September 2021 on the generalisation of electronic invoicing in transactions between taxable persons and on the transmission of transaction data. This founding act empowers the government to amend 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 act for 2022: they define the scope of operations subject to e-reporting, the data to be transmitted, frequency and transmission conditions.

• Order of 7 October 2022 setting the technical modalities of e-reporting (formats, specifications, data schemas) — amended by the order of 28 March 2025 to incorporate the timeline adjustments.

• Decree no. 2022-1299 of 7 October 2022 on the generalisation of electronic invoicing, specifying the obligations of partner dematerialisation platforms.

Penalties for non-compliance

Article 1788 D of the CGI provides for specific penalties in case of breach of the e-reporting obligation:

• Fine of 250 euros per missing or incomplete transmission, capped at 15,000 euros per calendar year.

• In the case of repeated breach or deliberate refusal to comply, the tax authority may initiate adversarial rectification proceedings, with possible assessment on the basis of reconstructed data.

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

Articulation with GDPR

Although standard B2C e-reporting does not transmit customer personal data, collection systems (till software, ERP) daily process personal data (purchase history, loyalty programmes). The European regulation no. 2016/679 (GDPR) requires these processing activities to be based on a legal basis and documented in the record of processing activities. In particular, the retention of transaction logs for 10 years (tax obligation) must be proportionate and secured according to GDPR requirements. Retailers must ensure that their PDP has a privacy policy compliant and that data transmitted to the DGFiP is done on the basis of legal obligation (article 6(1)(c) of GDPR).

Technical standards and NF 525 certification

NF 525 certification (standard approved by AFNOR) imposes on till software requirements for data immutability, periodic closure and secure archiving. This certification is an indirect prerequisite for e-reporting: a retailer using non-certified software is exposed to double penalty — that provided for failure to certify (article 1770 undecies of the CGI, fine of 7,500 euros) and that for breach of e-reporting.

Use cases: B2C retailers facing e-reporting

Scenario 1 — A fast food chain with 40 outlets

A fast food franchise operating forty establishments across French territory generates thousands of daily transactions per outlet, with complex VAT breakdown (10% on on-premise catering, 5.5% on take-away sales of unprepared food products, 20% on alcoholic beverages). Its central till software, certified NF 525, centralises data from the entire network.

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

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

An online company specialising in home equipment realises about 35% of its turnover via its own site (direct B2C flow, subject to e-reporting) and 65% via two major marketplaces (flows for which the marketplace is liable for e-reporting as a deemed supplier). The challenge for this SME, concerned as of 1 September 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 was negotiated with each marketplace to obtain written confirmation of the undertaking of e-reporting on facilitated sales. This contractual framework is essential to protect against any risk of adjustment in the event of inspection. Gain in tax clarity and reduction in the risk of double reporting: significant for a structure whose flow complexity had already generated adjustments in previous VAT inspections.

Scenario 3 — A multi-activity neighbourhood shop (SME, entry into force September 2027)

An SME operating three gift and decoration shops in a small town, with annual turnover of 1.2 million euros, is concerned by e-reporting from 1 September 2027. Its till 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 owner contacted his editor: the latter confirmed the 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 assess 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 the event of deposit failure. Total estimated compliance cost: less than 2,000 euros (software update included), an investment proportionate to the penalties avoided.

Frequently Asked Questions

Does B2C e-reporting require retailers to transmit their customers' personal data to the French tax authority?

No. B2C e-reporting is based on the transmission of aggregated data by period: amounts excluding VAT, VAT broken down by rate, and the company's SIREN number. No personal information about individual buyers is sent to the Direction Générale des Finances Publiques. This distinguishes e-reporting from certain foreign tax systems and significantly simplifies GDPR compliance for retailers.

Is a micro-entrepreneur liable to VAT subject to B2C e-reporting from 2027 onwards?

Yes, if the micro-entrepreneur is actually liable to VAT — that is, if they have exceeded the VAT exemption thresholds or have voluntarily opted for VAT. However, as long as they benefit from the VAT exemption, they are excluded from the scheme. VAT liability is therefore the triggering criterion, regardless of legal status or the size of the business.

What is the difference between e-reporting and the standard VAT return?

The VAT return (CA3 or CA12) remains a separate tax obligation, filed with the tax authorities. E-reporting, on the other hand, is a periodic transmission of transaction data to the French tax authority via an Accredited Dematerialisation Platform or the Public Billing Portal. The two obligations coexist: e-reporting does not replace the VAT return; it allows the tax authority to cross-check and validate the information declared.

Must a retailer with both B2B and B2C activities manage two separate obligations?

Yes. The part of their activity conducted with French businesses liable to VAT falls under e-invoicing, namely the issue of structured electronic invoices. The B2C part, on the other hand, falls under e-reporting with aggregated data transmission. In practice, the two flows can be managed via a single approved partner platform, but they are subject to different content and format rules that should be distinguished in the system settings.

What are the risks for a B2C retailer who fails to transmit their e-reporting data on time?

The French tax code provides for penalties in the event of non-compliance with reporting obligations. Fines may be imposed for each missing or incorrect transmission. Beyond the financial penalty, failure to transmit exposes the company to a more thorough tax audit, as the tax authority lacks the necessary data to verify the consistency between actual turnover and declared VAT.

Conclusion

B2C e-reporting represents a profound transformation of the relationship between retailers and the French tax authority. Contrary to popular belief, it is not limited to major chains: any company subject to VAT making sales to individuals is concerned, with deadlines starting September 2026 for SMEs and large companies, and September 2027 for smaller enterprises.

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

Certyneo accompanies you in your fiscal and documentary compliance approach. Assess your level of preparedness today with our free electronic invoicing diagnostic or contact our experts for personalised support via our contact space.