E-reporting B2C for Retailers: Transaction Data and Obligations 2026-2027

Why B2C retailers are affected by e-reporting

Since Ordinance No. 2021-1190 of 15 September 2021 and its transposition into Article 290 of the French General Tax Code (CGI), the French electronic invoicing reform is not limited to business-to-business transactions. Retailers making sales to individuals — B2C flows — are subject to a distinct but complementary obligation: e-reporting, that is, the periodic transmission to the Directorate General of Public Finances (DGFiP) of aggregated transaction data. This obligation, often perceived as secondary, actually affects 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. Instead, it is a synthetic upload of revenue data, VAT collected amounts, and supplementary information allowing the tax authority to cross-check declarations and combat VAT fraud, estimated at €15 billion per year in France according to the Court of Auditors.

This article details precisely what B2C retailers must transmit, when, through which channel, and how to anticipate the 2026-2027 deadlines without disrupting their operations. For a general overview of the framework, consult our comprehensive guide on 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-registered entities 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-VAT-registered individuals), operations with foreign clients (international B2B), and any sale without obligation for a structured invoice.

E-reporting is therefore the mechanism by which the DGFiP maintains visibility over the total revenue of registered entities, including flows not covered by e-invoicing. To understand the framework in detail, our dedicated article on e-reporting: transmission of transaction data is a complementary resource.

Which B2C retailers are subject to e-reporting?

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

• Retail shops (food, clothing, electronics, hardware, etc.)

• Restaurants, hotels, service providers to individuals

• E-commerce retailers selling to French consumers

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

Excluded from e-reporting: operations benefiting from a VAT exemption (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 includes:

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

• The VAT collected amount, 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 entity

• The submission receipt number

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

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

Timeline for implementation for B2C retailers

Deployment phases 2026-2027

The reform timeline 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 application decree of 28 March 2025:

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

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

It is essential to note that large enterprises were already required to receive electronic invoices from 1 September 2026 under 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 transmission frequency for B2C e-reporting depends on the company's VAT scheme:

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

• Simplified real scheme (semi-annual instalments): monthly transmission nevertheless, as the simplified scheme does not exempt from frequent e-reporting.

• Weekly option: companies wishing to do so may opt for weekly transmission (calendar week), particularly retailers with high transaction volumes.

The DGFiP strongly recommends that high-volume retailers (major distribution, quick-service restaurants, e-commerce) choose weekly transmission, closer to real-time and less exposed to risks of error in monthly aggregates.

Transmission channels: PDP, PPF and till software

The central role of approved platforms (PDP)

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

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

• Collection and aggregation of transaction data from source systems (till, ERP, e-commerce)

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

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

• Retention of proof of submission 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 NF525: the critical interface

For retailers, till software is the primary collection point for transaction data. Since the 2016 ordinance, till software for entities registered for 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 are obligated to integrate, before the 2026-2027 deadlines, an export module compatible with the DGFiP's e-reporting formats. Retailers must therefore verify now that their editor can deliver these developments within the timeframes. In case of doubt, our electronic invoicing diagnostic tool allows you to assess your preparedness level in minutes.

E-commerce flows and marketplaces

For retailers selling through marketplaces (Amazon, Cdiscount, Fnac Marketplace, etc.), the question of e-reporting responsibility 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 acquired and resold the goods under VAT law. 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 of your enterprise:

• Which systems collect transactions (till, e-commerce site, mobile app, card reader)?

• 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 do you plan 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 rate breakdown configuration

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

Training for accounting and IT teams

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

Legal framework applicable to B2C e-reporting

Foundational texts of the obligation

The e-reporting obligation for B2C retailers 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 registered entities and the transmission of transaction data. This foundational act authorises the government to amend the CGI to establish e-reporting.

• Articles 290 and 290 bis of the French General Tax Code (CGI), as amended by the Supplementary 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 fixing the technical modalities of e-reporting (formats, specifications, data schemas) — amended by the Order of 28 March 2025 to incorporate calendar adjustments.

• Decree No. 2022-1299 of 7 October 2022 on the generalisation of electronic invoicing, clarifying the obligations of partner dematerialisation 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 per missing or incomplete submission, up to €15,000 per calendar year.

• In case of repeated breach or deliberate refusal to comply, the tax authority may initiate a contradictory adjustment procedure, with possible full assessment on the basis of reconstructed data.

• Serious breaches may also constitute an indicator within the framework of a detailed tax audit, with the DGFiP now having automatic cross-checking tools between declared e-reporting and bank 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 (till software, ERP) daily process personal data (purchase histories, loyalty programmes). Regulation (EU) 2016/679 (GDPR) requires these processing activities to rest on a legal basis and be documented in the processing activities register. In particular, retention of transaction logs for 10 years (tax obligation) must be proportionate and secured according to GDPR requirements. Retailers must ensure their PDP has a GDPR-compliant privacy policy and that data transmitted to the DGFiP is 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 faces a double penalty — that provided for certification failure (Article 1770 undecies of the CGI, €7,500 fine) and that for e-reporting breach.

Use cases: B2C retailers facing e-reporting

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

A quick-service restaurant chain operating forty establishments across France generates thousands of daily transactions per outlet, with complex VAT breakdown (10% on dine-in meals, 5.5% on takeaway sales of unprepared food products, 20% on alcoholic beverages). Its central till software, NF 525-certified, centralises data from the entire network.

Anticipating the obligation by 1 September 2026, IT partnered 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 acceptance testing. The PDP automatically generates weekly e-reporting files (option chosen to reduce risk of error in aggregates) and submits them to the DGFiP before each Monday evening. The reconciliation delay between weekly e-reporting and the monthly VAT return CA3 was reduced from 4 days to less than 2 hours through automation. Estimated savings on accounting reconciliation tasks: approximately 60% of dedicated staff time.

Scenario 2 — A mid-market e-commerce business with direct sales and marketplace

An online equipment retailer generates approximately 35% of revenue through 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 MTE, concerned from 1 September 2026, is to transmit to the DGFiP only data corresponding to direct sales, without double-counting with marketplace sales.

It 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 assumption of e-reporting responsibility for facilitated sales. This contractual framework is essential to guard against adjustment risk in case of audit. Benefit of clarity and reduced double-reporting risk: significant for a structure whose flow complexity had already generated adjustments in previous VAT audits.

Scenario 3 — A multi-activity neighbourhood store (SME, implementation September 2027)

An SME operating three gift and decoration shops in a medium-sized town, with annual turnover of €1.2 million, is affected by e-reporting from 1 September 2027. Its till software, purchased in 2021, is NF 525-certified but its editor has not yet communicated on e-reporting compatibility. Upon reading the official timeline in early 2026, the manager contacted the editor: confirmation was given that an e-reporting module would be delivered in the December 2026 update, nine months before the deadline.

The SME also used an electronic invoicing diagnostic tool to assess digital maturity and decided to opt for the PPF (Public Invoicing Portal, free) rather than a paid PDP, as transaction volume was moderate and accounting structure simple. Monthly transmission was configured automatically, with e-mail alert in case of submission failure. Total estimated compliance cost: under €2,000 (software update included), representing proportionate investment relative to avoided penalties.

Frequently Asked Questions

Does B2C e-reporting require merchants to transmit their customers' personal data to the DGFiP?

No. B2C e-reporting is based on the transmission of aggregated data by period: amounts excluding tax, VAT broken down by rate, and the company's SIREN number. No personal information about individual buyers is sent to the Directorate General of Public Finances. This distinguishes e-reporting from certain foreign tax arrangements and considerably simplifies RGPD compliance for merchants.

Is a micro-entrepreneur subject to VAT required to comply with B2C e-reporting from 2027 onwards?

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

What is the difference between e-reporting and a 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 DGFiP via a Partner Dematerialisation Platform or the Public Invoicing Portal. Both obligations coexist: e-reporting does not replace the VAT return; it allows the administration to cross-reference and validate the information declared.

Must a merchant operating in both B2B and B2C manage two separate obligations?

Yes. The portion of their activity conducted with French VAT-registered enterprises falls under e-invoicing, which means the issuing of structured electronic invoices. The B2C portion falls under e-reporting with aggregated data transmission. In practice, both flows can be managed through the same approved partner platform, but they are subject to different content and format rules that should be distinguished in your system settings.

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

The General Tax Code provides for penalties in the event of failure to comply with reporting obligations. Fines may be imposed for each missing or incorrect transmission. Beyond the financial penalty, failure to submit data exposes the business to more thorough tax scrutiny, as the administration will not have the data needed to verify the consistency between actual turnover and declared VAT.

Conclusion

B2C e-reporting represents a profound transformation in the relationship between retailers and the French tax authority. Contrary to common misconceptions, it is not limited to large chains: any VAT-registered entity conducting sales to individuals is concerned, with deadlines from September 2026 for MTEs and large enterprises, and September 2027 for SMEs.

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 accounting teams. Penalties for non-compliance (up to €15,000 per year) make leaving implementation to the last moment particularly risky.

Certyneo supports you in your tax and document compliance journey. Assess your preparedness level today with our free electronic invoicing diagnostic or contact our experts for personalised support via our contact page.