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 implementation in Article 290 of the French General Tax Code (CGI), the French electronic invoicing reform is not limited to inter-business exchanges. Merchants making sales to individuals — B2C flows — are subject to a distinct but complementary obligation: e-reporting, that is, the periodic transmission to the General Directorate of Public Finances (DGFiP) of aggregated data on their transactions. This obligation, often perceived as secondary, actually affects millions of French companies, from small retailers to large 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 reporting 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 merchants must transmit, when, through which channel, and how to anticipate the 2026-2027 deadlines without disrupting their operations. For an overview of the system, consult our comprehensive 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-registered entities established in France (domestic B2B flows). These invoices must necessarily pass through an approved Partner Dematerialization Platform (PDP) or through the Public Invoicing Portal (PPF).

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

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

Which B2C Merchants Are Subject to E-reporting?

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

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

• Restaurants, hotels, service providers to individuals

• E-commerce merchants selling to French consumers

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

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

Transaction Data to Submit: 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 transmit includes:

• 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 frequency chosen)

• The SIREN number of the issuing enterprise

• The submission deposit number

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

Unlike e-invoicing, no customer personal data is transmitted to the DGFiP under 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. After successive postponements in 2023 and 2024, the Finance Act for 2024 set the following final timeline, confirmed by the DGFiP in its implementing decree of March 28, 2025:

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

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

It is essential to note that large enterprises were already required to receive electronic invoices as of September 1, 2026 under e-invoicing. B2C e-reporting adds to this obligation without replacing it. To track 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 enterprise's VAT regime:

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

• Simplified real regime (biannual advance payments): monthly transmission nonetheless, as the simplified regime does not exempt from frequent e-reporting.

• Weekly option: enterprises may opt for weekly transmission (calendar week) if desired, particularly merchants with high transaction volumes.

The DGFiP strongly recommends enterprises with high volumes (large retail distribution, quick-service restaurants, 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 Point-of-Sale Software

The Central Role of Approved Platforms (PDP)

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

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

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

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

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

• Preservation 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.

Point-of-Sale Software and NF525: The Critical Interface

For retail merchants, the point-of-sale software is the primary collection point for transaction data. Since the 2016 ordinance, point-of-sale software for VAT-registered merchants must be certified NF 525 (or equivalent) guaranteeing data unalterability, security, retention, and archiving. This certification becomes the essential prerequisite for e-reporting.

Certified NF 525 point-of-sale software publishers are required to integrate, before the 2026-2027 deadlines, an export module compatible with the DGFiP's e-reporting formats. Merchants must verify now that their publisher is able to deliver these enhancements within the timelines. In case of doubt, our electronic invoicing diagnostic tool allows you to assess your level of preparation in minutes.

E-commerce and Marketplace Flows

For merchants selling through marketplaces (Amazon, Cdiscount, Fnac Marketplace, etc.), responsibility for e-reporting is clarified by Article 290 bis of the CGI: the marketplace is liable for e-reporting for the sales it facilitates, provided it is deemed to have acquired and resold the goods under VAT rules. Third-party sellers on these platforms are thus in principle relieved of the obligation for flows passing through the marketplace — but retain the obligation for their direct sales through 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 within your enterprise:

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

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

• Do you have an ERP or accounting tool able to aggregate 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.

Configuration of VAT Rate Breakdown

One of the most frequent friction points concerns breakdown by VAT rate. A merchant selling food products (5.5%), alcoholic beverages (20%), and table service dining (10%) must ensure their point-of-sale software correctly breaks down each transaction according to the applicable rate and that this breakdown is exportable in the format expected by the DGFiP. Configuration errors at this level can lead to discrepancies between e-reporting and VAT return declaration, with 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 reconciliation logic 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

Foundational Legal Texts for the Obligation

The obligation for B2C merchants to conduct e-reporting rests on a precise corpus of legislative and regulatory texts:

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

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

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

• 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 specific sanctions for failure to meet the e-reporting obligation:

• Penalty of €250 per missing or incomplete transmission, up to €15,000 per calendar year.

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

• Serious failures may also constitute an indicator in the context of an in-depth tax audit, the DGFiP now having tools for automatic cross-checking 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 (point-of-sale software, ERP) daily process personal data (purchase histories, loyalty programs). The European Regulation No. 2016/679 (GDPR) requires that these processing activities rest on a legal basis and be 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 their PDP has a compliant privacy policy and that data transmitted to the DGFiP is done so 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 point-of-sale software requirements for data unalterability, periodic closure, and secure archiving. This certification is an indirect prerequisite for e-reporting: a merchant using non-certified software is exposed to dual penalty — that provided for certification failure (Article 1770 undecies of the CGI, €7,500 penalty) and that for e-reporting failure.

Usage Scenarios: B2C Merchants Facing E-reporting

Scenario 1 — A Quick-Service Restaurant Network with 40 Points of Sale

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

Anticipating the obligation for September 1, 2026, the IT department concluded a partnership with an approved PDP 18 months in advance. The connector between the point-of-sale 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 on aggregates) and submits them to the DGFiP before each Monday evening. The reconciliation period between weekly e-reporting and monthly VAT return declaration has been 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-Sized E-commerce Company with Direct Sales and Marketplace

An online home equipment retailer realizes approximately 35% of its 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 SME, affected starting 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 was negotiated with each marketplace to obtain written confirmation of responsibility for e-reporting on facilitated sales. This contractual framework is essential to protect against audit risk in case of tax examination. Clarity gain and reduction in double-declaration risk: significant for a structure whose flow complexity had already generated adjustments in previous VAT audits.

Scenario 3 — A Multi-Activity Local Store (SME, Implementation September 2027)

An SME operating three gift and decoration shops in a mid-sized town, with annual revenue of €1.2 million, is affected by e-reporting starting September 1, 2027. Its point-of-sale software, purchased in 2021, is certified NF 525 but its publisher has not yet communicated on e-reporting compatibility. Upon reading the official timeline in early 2026, the manager contacted the publisher: 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 assess its digital maturity and decided to opt for the PPF (Public Invoicing Portal, free) rather than a paid PDP, given its moderate transaction volume and simple accounting structure. Monthly transmission was configured automatically, with email alert in case of submission failure. Estimated total cost for compliance: under €2,000 (software update included), representing a proportionate investment relative to avoided penalties.

Frequently Asked Questions

Does B2C e-reporting require merchants to transmit their customers' personal data to the French Tax Authority (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 Direction Générale des Finances Publiques. This distinguishes e-reporting from certain foreign tax systems and significantly simplifies GDPR compliance for merchants.

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

Yes, if the micro-entrepreneur is actually subject 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 system. 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 standard VAT return filing?

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 an Approved Dematerialization Platform or the Public Invoicing Portal. Both obligations coexist: e-reporting does not replace VAT return filing; rather, it allows the tax administration to cross-check and verify the information declared.

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

Yes. The portion of activity conducted with French businesses subject to VAT falls under e-invoicing, meaning the issuance of structured electronic invoices. The B2C portion, on the other hand, 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 must be distinguished in your system configuration.

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

The French Tax Code provides for penalties in case of failure to comply with reporting obligations. Fines may be imposed for each missing or incorrect transmission. Beyond the financial penalty, failure to transmit exposes the business to more thorough tax audits, since the tax administration lacks the data needed to verify consistency between actual turnover and declared VAT.

Conclusion

B2C e-reporting represents a profound transformation in the relationship between merchants and the French tax authority. Contrary to common misconception, it is not limited to large retailers: any enterprise registered for VAT conducting sales to individuals is affected, with deadlines starting September 2026 for SMEs and large enterprises, and September 2027 for smaller companies.

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

Certyneo supports you in your fiscal and documentary compliance effort. Assess your level of preparation today with our free electronic invoicing diagnostic or contact our experts for personalized support via our contact area.