Electronic Invoice for International Export: e-reporting and Obligations for Your Foreign Clients

The French electronic invoicing reform, which came into force progressively starting in 2026, primarily concerns transactions between VAT-taxable entities established in France (domestic B2B flows). But what about French companies that invoice foreign clients — European Union or third countries? Many business leaders and financial directors are unaware: these transactions escape the obligation to issue through an Authorized Dematerialization Platform (PDP), but fall within the scope of the e-reporting mechanism. Understanding this distinction is crucial to avoid penalties and optimize your compliance.

This article details the rules applicable to invoices issued to clients established outside France, the recommended formats, data transmission deadlines, and best practices for integrating exports into your dematerialized invoicing strategy.

Why is export subject to e-reporting rather than mandatory electronic invoicing?

The scope of the electronic invoicing obligation

Ordinance No. 2021-1190 of September 15, 2021, and Decree No. 2022-1299 of October 7, 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 operations between VAT-taxable entities established in France. These are strictly domestic B2B transactions.

Once one of your clients is established abroad — whether located 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 through a PDP for validation. However, this operation remains subject to the e-reporting obligation, which constitutes the international counterpart of the reform.

E-reporting: definition and export scope

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

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

• Sales to foreign VAT-taxable clients (exports, intra-community deliveries);

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

The objective is to enable the DGFiP to reconstruct an almost exhaustive picture of VAT collected and deductible on the territory, even when operations are exempted or outside the scope. To learn more about the overall mechanism of this obligation, consult our complete 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 transits, e-reporting export concerns only a set of synthetic data per operation. Article 290 of the French Tax Code (CGI), as amended by the 2020 Finance Law and subsequent texts, defines the mandatory information to transmit:

• The invoice issue date;

• The net amount (excluding tax) of the operation;

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

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

• The country where the client is established;

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

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

Transmission deadlines: e-reporting export periodicity

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

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

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

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

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

Recommended invoice formats for your foreign clients

No mandatory format requirement for the client… but best practices

Since the mandatory structured format requirement (Factur-X, UBL 2.1, UN/CEFACT CII) applies only to domestic invoices transiting through a PDP, you remain theoretically free to send a standard PDF to a German or American client. However, several reasons argue for adopting a structured format now:

• Ongoing foreign regulations: Germany is rolling out its own mandatory electronic invoicing system (XRechnung / ZUGFeRD) since January 2025 for large companies. Invoicing a large 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 exploited by your foreign client's ERP system.

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

The specific case of intra-community deliveries (ICD)

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

In the context of e-reporting, ICDs must be declared with the appropriate nature code. A properly configured PDP can automate this qualification, reducing the risk of coding errors — see our comparison of signature and dematerialization 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 proof (SAD, EX1). These operations must also appear in the e-reporting flow with the "export" nature code. The DGFiP can cross-reference this data with goods exchange declarations (GED) to detect inconsistencies.

Integrating export into your electronic invoicing system

Choosing a PDP that manages the e-reporting export flow

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

• Supports automatic qualification of export vs. domestic operations;

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

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

• Offers a monitoring dashboard for transmissions with delivery receipts.

Our guide on approved PDP platforms helps you identify the determining 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. Intra-group cross-border flows (fee pass-throughs, shared services) fall within the scope of e-reporting on the French side.

Centralized document governance — incorporating electronic signatures 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 ceiling may seem limited for large companies, but it applies per violation — systematic late transmission or repeated non-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 export electronic 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 September 15, 2021: authorizes the government to implement the generalization of electronic invoicing between taxable persons and e-reporting of transactions with non-taxable persons and international operations.

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

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

• Article 262 and 262 ter of the CGI: basis for VAT exemption for exports outside the EU and intra-community deliveries.

• 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 authorizes 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 procurement and defines the EN 16931 standard for structured invoices — technical basis of the CII format used in Factur-X.

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

Law of evidence and legal value

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

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

Data protection

• GDPR Regulation No. 2016/679: applicable to personal data that may be contained in invoices (name of a self-employed person, contact details of an individual). For e-reporting flows, the DGFiP does not require personal data on foreign clients, which limits the GDPR exposure of these transmissions. However, the retention of export invoices (legal retention period of 10 years in French commercial law — article L. 123-22 of the French Commercial Code) must comply with data minimization and security principles.

Technical standards

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

Use cases: managing export electronic invoicing in practice

Scenario 1 — A software publisher SaaS billing clients in EU and non-EU zones

A French software company offering SaaS solutions generates 60% of its revenue internationally: clients 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 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 closure. For German clients, 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% through automation, and no e-reporting penalties have been recorded in the first 12 months of deployment.

Scenario 2 — A small industrial company exporting to non-EU countries

A 80-person SME specializing in mechanical component manufacturing 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. After 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 goods exchange declarations.

The estimated gain: a reduction of 3 days of accounting work per quarter, previously spent on manual reconciliation of export flows, and complete security against potential cross-checked tax audit between e-reporting and customs data.

Scenario 3 — A consulting firm billing service deliverables to European clients

A 20-consultant strategy consulting firm performs missions for companies established in Spain, Italy, and Switzerland. Its service deliverables are subject to the general rule of the place of the customer (article 44 of the VAT Directive): they are taxable in the client's country, and thus exempt from French VAT.

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

The adoption of an integrated PDP also enabled the firm to offer mission agreements generated and electronically signed to its foreign clients, with legal value recognized under the eIDAS regulation — reducing cross-border contracting time from several days to a few hours.

Frequently Asked Questions

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

E-reporting export consists of transmitting synthetic data to the DGFiP 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 covers only a summarized set of 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 the 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 stream, which limits the 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 VAT regime have ten days after the end of the calendar month. Those under the simplified regime transmit their data within ten days following the end of each quarter, with the option to opt for a monthly schedule. 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 go through a French PDP?

No. The obligation to transmit through a Partner Dematerialization Platform or the public invoicing portal only concerns transactions between businesses subject to VAT 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 going through a PDP. The transaction remains, however, 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 through an approved platform or to receive structured invoices under the domestic reform. However, it remains subject to the obligation of 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

Export electronic invoicing does not follow the same regime as domestic invoicing: it escapes the obligation to transit through a PDP, but is fully part of the e-reporting mechanism. Your sales to foreign clients — intra-community deliveries, exports outside the EU, cross-border B2B services — must be reported to the DGFiP via a structured data flow, on pain of fines reaching €15,000 per year.

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

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