Electronic Invoice Export International: E-reporting and Obligations for Your Foreign Customers

The French electronic invoicing reform, which came into effect progressively from 2026, primarily concerns transactions between VAT-registered businesses established in France (domestic B2B flows). But what about French companies that invoice foreign customers — European Union or third countries? Many business leaders and finance directors are unaware: these transactions escape the obligation to issue through a Partner Digitalisation 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, data transmission deadlines, and best practices for integrating exports into your digitalised 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 issue and receipt of invoices via the public invoicing portal (PPF) or an approved PDP — applies only to transactions between VAT-registered businesses established in France. This strictly concerns domestic B2B transactions.

As soon as one of your customers is established abroad — whether situated 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 transmit the invoice via a PDP for validation. Conversely, this operation remains subject to the e-reporting obligation, which constitutes the international counterpart to the reform.

E-reporting: Definition and Export Field of Application

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

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

• Sales to foreign VAT-registered customers (exports, intra-Community supplies);

• Operations not subject to French VAT (export exemptions, Article 262 regime of the CGI).

The aim is to enable the DGFiP to reconstruct a near-exhaustive picture of VAT collected and deductible in the territory, even when operations are exempt or outside scope. For further detail on this mechanism, consult our complete guide to e-reporting.

What Distinguishes E-reporting and Electronic Invoicing

Data to Transmit in E-reporting for Your Exports

Content of Transaction Data

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

• The invoice issue date;

• The net amount (ex-VAT) of the transaction;

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

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

• The country of establishment of the customer;

• 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 regarding 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 Deadlines: Export E-reporting Periodicity

The implementing decree specifies three transmission frequencies depending on the size of the business and its VAT reporting frequency:

• Monthly: for businesses subject to the normal real VAT regime (monthly filing of the CA3) — transmission of data within 10 days following the end of the calendar month;

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

• Monthly option: businesses under the simplified regime may opt for monthly transmission.

These deadlines also apply 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 Structured Format Obligation for the Customer… But Best Practices

Since the structured format obligation (Factur-X, UBL 2.1, UN/CEFACT CII) applies only to domestic invoices passing through a PDP, you are in theory free to send a standard PDF to a German or American customer. However, several reasons argue for adopting a structured format now:

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

• Operational efficiency: a hybrid format such as Factur-X, the Franco-German standard, combines the readability of a PDF with XML data exploitable 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 Particular Case of Intra-Community Supplies (ICS)

Intra-Community supplies exempt from VAT (Article 262 ter of the CGI) warrant particular attention. Exemption is conditional on proof of supply 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.

As part of e-reporting, ICS 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 digitalisation 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), VAT exemption is based on Article 262 I of the CGI and requires customs evidence (DAU, EX1). These transactions must also appear in the e-reporting flow with the nature code "export". The DGFiP may cross-reference this data with declarations of goods exchanges (DEB/EMEBI) to detect inconsistencies.

Integrating Export into Your Electronic Invoicing System

Choosing a PDP That Manages the Export E-reporting Flow

Not all Partner Digitalisation Platforms 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 monitoring dashboard for transmissions 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, whilst the German subsidiary follows German rules, and so on. Intra-group cross-border invoicing flows (fee rebilling, shared service provisions) fall within the scope of e-reporting on the French side.

A centralised document governance — incorporating electronic signature for inter-company contracts and invoicing flow traceability — becomes essential to maintain a reliable audit trail.

Penalties for E-reporting Non-Compliance

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 cap may seem limited for large enterprises, but it applies per non-compliance — systematic late transmission or failure to transmit over several months can quickly generate significant penalties. To anticipate your exposure level, use our electronic invoicing diagnostic online.

Legal Framework Applicable to Export Electronic Invoicing and E-reporting

Founding Texts of the French Reform

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

• Ordinance No. 2021-1190 of 15 September 2021: authorises the government to implement the generalisation of electronic invoicing between VAT-registered businesses and e-reporting of transactions with non-registered businesses and international operations.

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

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

• Articles 262 and 262 ter of the CGI: foundations for VAT exemption on exports outside the EU and intra-Community supplies.

• Article 1737 of the CGI: financial penalties 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 basis of 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: makes electronic invoicing mandatory in European public contracts and defines the EN 16931 European standard for structured invoices — the technical basis of the CII format used in Factur-X.

• Commission Implementing Regulation (EU) No 282/2011: clarifies the rules for the place of taxation of services, essential for qualifying an export service subject or not to French VAT.

Law of Evidence 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 identity of the author can be duly identified and the integrity of the document is guaranteed — conditions that also apply to electronic invoices.

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

Data Protection

• Regulation GDPR 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. Conversely, retention of export invoices (legal deadline of 10 years under French commercial law — Article L. 123-22 of the Commercial Code) must comply with the principles of minimisation and data 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.

Usage Scenarios: Managing Export Electronic Invoicing in Practice

Scenario 1 — A SaaS Software Publisher Invoicing Customers in the EU and Outside the EU

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

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

Result: the processing time for export invoices has been reduced by 40% thanks to automation, and no e-reporting penalties have been noted in the first 12 months of deployment.

Scenario 2 — An SME Industrial Exporter to Non-EU Countries

An 80-employee SME 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 operations had to be declared 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 (DAU numbers) to ensure consistency of DEB/EMEBI declarations.

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

Scenario 3 — A Consulting Firm Invoicing Service Provision to European Customers

A strategy consulting firm of about twenty consultants delivers assignments for businesses 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 thus exempt from French VAT.

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

The adoption of an integrated PDP also allowed the firm to offer mission contracts generated and electronically signed to its foreign customers, with legal value recognised within the framework of the eIDAS regulation — reducing contractualisation timeframes across borders from several days to just a few hours.

Frequently Asked Questions

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

E-reporting export involves transmitting summarised 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 through an approved platform, e-reporting only covers a set of summarised data. The invoice itself can be sent directly to the customer in the format of your choice.

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

For each relevant transaction, you must transmit the date of issue, 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, as well as the nature of the transaction. No personal data of the foreign customer is required in this data flow, which limits constraints related to GDPR for data outside the European Union.

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

The deadline depends on your VAT regime. Businesses subject to the standard real-time VAT regime have ten days following the end of the calendar month. Those under the simplified regime must transmit their data within ten days following the end of each quarter, with the option to choose a monthly frequency. These deadlines apply regardless of the format used for the invoice provided to the foreign customer.

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

No. The obligation to transmit via a Partner Dematerialisation Platform or the public invoicing portal only applies to transactions between VAT-registered persons established in France. Once your customer is established in another Member State of the European Union, the invoice can be transmitted to them directly, without passing through a PDP. The transaction nevertheless remains subject to e-reporting to the DGFiP.

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

Yes, partially. It is not required to issue its invoices via an approved platform nor to receive structured invoices under the meaning of the domestic reform. However, it remains subject to the obligation of e-reporting for all its sales to foreign customers, whether these are exports outside the European Union or intra-community supplies exempt from French VAT.

Conclusion

Export electronic invoicing does not follow the same regime as domestic invoicing: it escapes the obligation to pass through a PDP, but fully integrates into the e-reporting mechanism. Your sales to foreign customers — intra-Community supplies, exports outside the EU, cross-border B2B service provisions — must be declared to the DGFiP via a structured data flow, under penalty of fines reaching €15,000 per year.

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

Certyneo supports you in achieving complete compliance — domestic and export flows. Discover our solutions adapted to exporting companies and consult our pricing, or start your electronic invoicing diagnostic to assess your readiness level in minutes.