International electronic invoicing export: e-reporting and obligations for your foreign customers

The French electronic invoicing reform, which came into force progressively from 2026, primarily concerns transactions between VAT taxpayers established in France (domestic B2B flows). But what about French businesses that invoice foreign customers — those in the European Union or third countries? Many executives and finance directors are unaware: these transactions escape the obligation to issue invoices via an Approved Dematerialisation Platform (PDP), but fall within the scope of the e-reporting mechanism. Understanding this distinction is crucial to avoid penalties and optimise your compliance.

This article details the rules applicable to invoices issued to customers established outside France, the recommended formats, the timelines for transmitting data, and best practices for integrating exports into your dematerialised invoicing strategy.

Why is export subject to e-reporting and not mandatory electronic invoicing?

The scope of the electronic invoicing obligation

Ordinance No. 2021-1190 of 15 September 2021 and Decree No. 2022-1299 of 7 October 2022 laid the foundations for the reform. Mandatory electronic invoicing — that is, the issuance and receipt of invoices via the public invoicing portal (PPF) or an approved PDP — applies only to transactions between VAT taxpayers established in France. These are strictly domestic B2B transactions.

Once one of your customers is established abroad — whether in Germany, Morocco, the United States or Singapore — the transaction falls outside the scope of electronic invoicing in the strict sense. You are not required to submit the invoice through a PDP for validation. However, this transaction remains subject to the e-reporting obligation, which constitutes the international counterpart of the reform.

E-reporting: definition and export scope of application

E-reporting refers to the transmission to the French tax administration (DGFiP) of transaction data (and not complete invoices) relating to:

• Sales of goods and services to customers who are not VAT taxpayers in France (B2C), regardless of their location;

• Sales to foreign VAT-liable customers (exports, intra-community supplies);

• Transactions not subject to French VAT (export exemptions, regime under Article 262 of the General Tax Code).

The objective is to enable the DGFiP to reconstruct a quasi-exhaustive picture of VAT collected and deductible on French territory, even when transactions are exempt or outside the scope. To deepen understanding of the overall mechanism of this obligation, consult our comprehensive guide to e-reporting.

What distinguishes e-reporting from electronic invoicing

Data to transmit in e-reporting for your exports

Transaction data content

Unlike domestic electronic invoicing where the entire invoice is transmitted, export e-reporting covers only a set of synthetic data per transaction. Article 290 of the General Tax Code (CGI), amended by the 2020 Finance Law and subsequent texts, defines the mandatory information to be transmitted:

• The invoice issue date;

• The net amount (excluding VAT) of the transaction;

• The applicable VAT amount (or the statement of exemption and its legal basis);

• The currency and, where applicable, the exchange rate used;

• The customer's country of establishment;

• The nature of the transaction (supply of goods, provision of services, export outside the EU, intra-community supply exempt from VAT, etc.).

No personal data relating to the foreign customer (name, address, intra-community VAT number) must be transmitted in this flow — which simplifies GDPR compliance for data outside the EU.

Transmission timelines: periodic e-reporting export

The implementing decree specifies three transmission schedules depending on company size and VAT declaration frequency:

• Monthly: for companies subject to the normal VAT regime (monthly filing of the sales return) — transmission of data within 10 days following the end of the calendar month;

• Quarterly: for companies in the simplified regime — transmission within 10 days following the end of the quarter;

• Monthly option: companies in the simplified regime may opt for monthly submission.

These timelines apply equally to export flows, even if the invoice has already been issued directly to the foreign customer in PDF or paper format. E-reporting is independent of the format of the invoice sent to the customer.

Recommended invoice formats for your foreign customers

No obligation for structured format on the customer side... but best practices

Since the obligation for structured format (Factur-X, UBL 2.1, UN/CEFACT CII) applies only to domestic invoices transmitted via a PDP, you theoretically remain free to send an ordinary PDF to a German or American customer. However, several reasons argue in favour of adopting a structured format now:

• Ongoing foreign regulatory changes: Germany is rolling out its own mandatory electronic invoicing system (XRechnung / ZUGFeRD) from January 2025 for large enterprises. Invoicing a major German group in PDF could become an operational obstacle.

• Operational efficiency: a hybrid format like Factur-X, the Franco-German standard, combines the readability of a PDF with XML data that can be processed by your foreign customer's ERP system.

• Traceability for e-reporting: a structured file facilitates automatic extraction of data to be transmitted to the DGFiP.

The specific case of intra-community supplies (ICS)

Intra-community supplies exempt from VAT (Article 262 ter of the CGI) merit particular attention. The exemption is conditional on proof of delivery in another Member State and communication of the customer's intra-community VAT number. If these conditions are not met, the transaction becomes taxable in France.

Within the framework of e-reporting, intra-community supplies must be declared with the appropriate nature code. A properly configured PDP can automate this classification, reducing the risk of coding errors — see our comparison of signature and dematerialisation solutions to evaluate platforms integrating this module.

Exports outside the EU: VAT exemption and e-reporting

For exports to third countries (outside the European Union), the VAT exemption is based on Article 262 I of the CGI and requires customs proof (SAD, EX1). These transactions must also appear in the e-reporting flow with the "export" nature code. The DGFiP can cross-reference this data with intra-community trade declarations (ITS/INTRASTAT) to detect inconsistencies.

Integrating exports into your electronic invoicing system

Choosing a PDP that manages the export e-reporting flow

Not all PDPs approved by the DGFiP offer the same level of service for export e-reporting flows. When evaluating a PDP, verify that the platform:

• Supports automatic classification of export vs. domestic transactions;

• Generates the e-reporting file in the API format expected by the DGFiP;

• Manages foreign currencies and exchange rates (ECB or contractual rate);

• Offers a tracking dashboard for submissions with acknowledgments of receipt.

Our guide on approved PDP platforms helps you identify the key criteria for your choice.

Case of groups with foreign subsidiaries

For groups with subsidiaries established in other Member States, the situation becomes more complex: the French subsidiary is subject to the French reform, while the German subsidiary follows German rules, and so on. Cross-border intra-group flows (fee re-invoicing, shared service provisions) fall within the scope of e-reporting on the French side.

Centralised document governance — integrating electronic signatures for inter-company contracts and traceability of invoicing flows — becomes essential to maintain a reliable audit trail.

Sanctions for failure to comply with e-reporting

Article 1737 of the CGI provides for a fine of €250 per invoice whose data has not been transmitted, capped at €15,000 per calendar year. This ceiling may seem limited for large companies, but it applies per breach — a systematic late submission or absence of transmission over several months can quickly generate significant penalties. To anticipate your level of exposure, use our online electronic invoicing diagnostic.

Legal framework applicable to electronic export invoicing and e-reporting

Founding texts of the French reform

The electronic invoicing reform is based on several texts of domestic and European law that overlap:

• Ordinance No. 2021-1190 of 15 September 2021: empowers the government to implement the generalisation of electronic invoicing between taxpayers and e-reporting of transactions with non-taxpayers and international transactions.

• Decree No. 2022-1299 of 7 October 2022: specifies the conditions for deployment, the permitted formats (Factur-X, UBL 2.1, CII) and the operating procedures of the PPF and PDPs.

• Articles 289 bis, 290 and 290 A of the General Tax Code (CGI): respectively define the domestic electronic invoicing obligation, e-reporting of B2C and international transactions, and applicable sanctions.

• Articles 262 and 262 ter of the CGI: legal basis for VAT exemption for exports outside the EU and intra-community supplies.

• Article 1737 of the CGI: financial sanctions for failure or delay in transmitting e-reporting data (€250 per invoice, cap €15,000/year).

European VAT law

• Council Directive 2006/112/EC (the "VAT Directive"): common foundation for invoicing rules in Europe. Its Article 218 authorises Member States to accept electronic documents as invoices. Its Article 219 bis determines the territoriality rules for invoicing.

• Directive 2014/55/EU: imposes electronic invoicing in European public procurement and defines the European standard EN 16931 for structured invoices — the technical basis for the CII format used in Factur-X.

• Commission Implementing Regulation (EU) No. 282/2011: clarifies the rules on the place of taxation of services, essential for determining whether a service is subject to French VAT or not.

Evidence law and legal value

• Articles 1366 and 1367 of the Civil Code: establish the principle of equivalence between electronic writing and paper writing, provided that the author's identity can be properly identified and the document's integrity is guaranteed — conditions that also apply to electronic invoices.

• Regulation eIDAS No. 910/2014: provides the framework for qualified electronic signatures that can confer enhanced probative value on electronically signed invoices, particularly in cross-border exchanges within the EU.

Data protection

• GDPR Regulation No. 2016/679: applicable to personal data possibly contained in invoices (name of a sole trader, contact details of an intermediary). For e-reporting flows, the DGFiP does not require personal data on foreign customers, which limits the GDPR exposure of these transmissions. However, the retention of export invoices (legal retention period of 10 years under French commercial law — Article L. 123-22 of the Commercial Code) must comply with the principles of data minimisation and security.

Technical standards

• ETSI EN 319 132: standard governing advanced electronic signatures in XAdES format, usable for timestamping and integrity of electronic invoices in a cross-border transmission context.

Use cases: managing electronic export invoicing in practice

Scenario 1 — A SaaS software publisher invoicing customers in the EU zone and outside the EU

A French software solutions publisher generates 60% of its turnover internationally: customers in Germany, the Netherlands, the United Kingdom post-Brexit and North America. Before the reform, invoices were issued in PDF via its ERP, without a structured process.

With compliance implementation, the company configured its PDP to automatically distinguish between domestic flows (mandatory electronic invoicing) and export flows (e-reporting only). The system generates transaction data in DGFiP API format monthly, within 10 days of closure. For German customers, the PDP also produces a ZUGFeRD/Factur-X file to satisfy local requirements.

Result: the processing time for export invoices in accounting was reduced by 40% thanks to automation, and no e-reporting penalties were recorded over the first 12 months of deployment.

Scenario 2 — An SME industrial exporter to non-EU countries

An SME of 80 employees specialising in the manufacture of mechanical components regularly ships goods to Morocco, Tunisia and Canada. Its exports, exempt from VAT under Article 262 I of the CGI, represent approximately 300 invoices per year.

The SME was initially unaware that these exempt transactions had to be reported in e-reporting with the "export" nature code. Following a compliance audit, it integrated an e-reporting module into its ERP. Monthly data transmission is now automated, with automatic reconciliation with customs data (SAD numbers) to ensure consistency of intra-community trade declarations/INTRASTAT.

Estimated gain: a reduction of 3 working days per quarter in accounting, previously devoted to manual reconciliation of export flows, and complete security against potential cross-checked tax audits between e-reporting and customs data.

Scenario 3 — A consulting firm invoicing service provisions to European customers

A strategy consulting firm of about twenty consultants carries out projects for companies established in Spain, Italy and Switzerland. Its service provisions are subject to the general rule of the place of the customer (Article 44 of the VAT Directive): they are taxable in the customer's country and therefore exempt from French VAT.

These transactions must nevertheless appear in the e-reporting flow with the nature code "intra-community B2B service provision" or "non-EU service". The firm configured its invoicing platform to automatically apply the legal statement "Reverse charge / Self-assessment" on invoices for EU customers, and to include these transactions in the monthly e-reporting report.

Adoption of an integrated PDP also enabled the firm to offer engagement letters generated and signed electronically to its foreign customers, with legal value recognised under the eIDAS regulation — reducing the time taken for cross-border contracting from several days to just a few hours.

Frequently Asked Questions

What is e-reporting for exports and how does it differ from mandatory electronic invoicing?

E-reporting for exports involves submitting summary data to the DGFiP (French tax authority) regarding your transactions with foreign customers or those not subject to VAT in France. Unlike mandatory electronic invoicing, which requires you to issue and receive structured invoices via an approved platform, e-reporting concerns only a set of summarised data. The invoice itself may be sent directly to the customer in the format of your choice.

What information must be submitted to the DGFiP for an invoice sent to a foreign customer?

For each relevant transaction, you must submit the issue date, the amount excluding VAT, the VAT amount or the reason for exemption, the currency and exchange rate used, the country where the customer is established, and the nature of the transaction. No personal data relating to the foreign customer is required in this data stream, which limits GDPR-related constraints for data outside the European Union.

What are the deadlines for submitting e-reporting data on export sales?

The deadline depends on your VAT scheme. Businesses subject to the standard real VAT scheme have ten days after the end of the calendar month. Those under the simplified scheme submit their data within ten days following the end of each quarter, with the possibility of opting for a monthly reporting frequency. These deadlines apply regardless of the format used for the invoice delivered to the foreign customer.

Must an invoice addressed to a customer established in the European Union pass through a French EDI platform?

No. The obligation to transmit via an EDI Platform (Plateforme de Dématérialisation Partenaire) or the public invoicing portal applies only to transactions between VAT-registered persons established in France. Where your customer is established in another Member State of the European Union, the invoice may be transmitted to them directly, without going through an EDI platform. The transaction remains, however, subject to e-reporting to the DGFiP.

Is a French company with only foreign customers affected by the electronic invoicing reform?

Yes, partially. It is not required to issue its invoices via an approved platform or to receive structured invoices within the meaning of the domestic reform. However, it remains subject to the obligation to submit e-reporting for all of its sales to foreign customers, whether these are exports outside the European Union or intra-Community supplies exempt from French VAT.

Conclusion

Electronic invoicing for exports does not follow the same regime as domestic invoicing: it escapes the obligation to transit via a PDP, but is fully part of the e-reporting mechanism. Your sales to foreign customers — intra-community supplies, exports outside the EU, cross-border B2B service provisions — must be reported to the DGFiP via a structured data flow, or risk fines that could reach €15,000 per year.

Anticipating this obligation involves choosing a PDP capable of automatically classifying and transmitting these export flows, and adopting structured formats compatible with invoicing reforms currently underway in partner countries.

Certyneo supports you in full compliance implementation — both domestic and export flows. Discover our offers tailored to exporting companies and consult our pricing, or start your electronic invoicing diagnostic to assess your level of readiness in just a few minutes.