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 transposition in Article 290 of the French General Tax Code (CGI), the French electronic invoicing reform is not limited to inter-business transactions. Merchants conducting sales to individuals—B2C flows—are subject to a distinct but complementary obligation: e-reporting, namely the periodic transmission to the Directorate General of Public Finance (DGFiP) of aggregated transaction data. This obligation, often perceived as secondary, actually affects millions of French companies, from small retailers to large 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 involves a synthetic reporting of revenue, VAT collected, and supplementary information enabling the tax authority to cross-check declarations and fight VAT fraud, estimated at 15 billion euros annually 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 operations. For a general 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-taxable persons established in France (domestic B2B flows). These invoices must obligatorily pass through an accredited Partner Dematerialization Platform (PDP) or through the Public Invoice Portal (PPF).

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

E-reporting is therefore the mechanism by which the DGFiP maintains visibility over the entirety of revenue of taxable businesses, including flows not covered by e-invoicing. To understand the system in detail, our dedicated article on e-reporting: transmission of transaction data serves as a complementary resource.

Which B2C Merchants Are Subject to E-reporting?

Any business subject to VAT in France conducting B2C operations is affected, provided those operations are located in France under VAT territoriality rules. This includes:

• Retail stores (food, apparel, electronics, DIY, etc.)

• Restaurateurs, hoteliers, service providers to consumers

• E-commerce merchants selling to French consumers

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

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

Transaction Data to Report: 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 frequency chosen)

• The SIREN number of the reporting business

• The submission reference number

• Data relating to collection operations if different from delivery date (deposits)

Unlike e-invoicing, no customer personal data is transmitted to the DGFiP under standard B2C e-reporting, which simplifies GDPR compliance for the system.

Timeline for Entry into Force for B2C Merchants

The 2026-2027 Rollout Waves

The reform timeline has been revised several times. After successive postponements in 2023 and 2024, the 2024 Finance Law established the following definitive schedule, confirmed by the DGFiP in its implementing decree of March 28, 2025:

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

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

It is essential to note that large enterprises were already required to receive electronic invoices as of September 1, 2026 as part of e-invoicing. B2C e-reporting adds to this obligation without replacing it. To track these steps precisely, refer to the official timeline of electronic invoicing 2026-2027.

Transmission Frequency: Monthly or Weekly?

The frequency of B2C e-reporting transmission depends on the business's VAT regime:

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

• Simplified real regime (semi-annual deposits): monthly transmission nonetheless, as the simplified regime does not exempt from frequent e-reporting.

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

The DGFiP strongly recommends to high-volume merchants (large retail, fast food, e-commerce) opting for weekly transmission, closer to real-time and less exposed to aggregation error risks on monthly figures.

Transmission Channels: PDP, PPF, and POS Software

The Central Role of Accredited Platforms (PDP)

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

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

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

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

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

• Proof retention for 10 years

To choose the right solution, our comparison of accredited platforms (PA/PDP) will help you identify determining criteria.

POS Software and NF525: The Critical Interface

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

Editors of NF 525-certified POS software have the obligation to integrate, before the 2026-2027 deadlines, an export module compatible with the DGFiP's e-reporting formats. Merchants should verify now that their editor is able to deliver these updates within the timeframes. In case of doubt, our electronic invoicing diagnostic tool allows you to assess your level of readiness in minutes.

E-commerce and Marketplace Flows

For merchants selling via 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 for VAT purposes. Third-party sellers on these platforms are therefore in principle discharged from the obligation for flows transiting 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 business:

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

• 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 accredited PDP, or do you plan to use the PPF?

This audit should ideally be conducted 12 to 18 months before your entry into force 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 merchant selling food products (5.5%), alcoholic beverages (20%), and on-premise dining (10%) must ensure that their POS software correctly allocates each transaction by applicable rate and that this allocation is exportable in the format expected by the DGFiP. Configuration errors at this level can cause discrepancies between e-reporting and the VAT CA3 return, with a 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 returns. 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 Legislation of the Obligation

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

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

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

• Order of October 7, 2022 setting the technical modalities of e-reporting (formats, specifications, data schemas)—amended by the order of March 28, 2025 to integrate calendar adjustments.

• Decree No. 2022-1299 of October 7, 2022 on the generalization of electronic invoicing, specifying obligations of partner dematerialization platforms.

Penalties for Non-compliance

Article 1788 D of the CGI provides for specific sanctions in case of failure to comply with the e-reporting obligation:

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

• In case of repeated breach or deliberate refusal to comply, the tax administration may initiate a disputed correction procedure, with possible summary assessment based on reconstructed data.

• Serious breaches may also constitute evidence in the context of thorough tax audit, the DGFiP now having automated cross-checking tools between declared e-reporting and banking 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 (POS software, ERP) handle personal data daily (purchase histories, loyalty programs). 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 under GDPR requirements. Merchants must ensure that 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 the GDPR).

Technical Standards and NF 525 Certification

NF 525 certification (standard approved by AFNOR) imposes requirements on POS software for data immutability, periodic closure, and secure archiving. This certification is an indirect prerequisite for e-reporting: a merchant using non-certified software faces double jeopardy—sanction for certification failure (Article 1770 undecies of the CGI, €7,500 fine) and that for e-reporting breach.

Usage Scenarios: B2C Merchants Facing E-reporting

Scenario 1 — A Fast-Food Chain with 40 Locations

A fast-food chain operating forty establishments across France generates thousands of daily transactions per location, with complex VAT breakdown (10% on in-restaurant dining, 5.5% on takeaway food sales of non-prepared products, 20% on alcoholic beverages). Its centralized POS software, NF 525-certified, centralizes data from all network locations.

In anticipating the obligation by September 1, 2026, IT partnered with an accredited PDP 18 months in advance. The connector between the POS software and the PDP required 3 months of development and 2 months of testing. The PDP automatically generates weekly e-reporting files (option chosen to reduce aggregation error risk) and submits them to the DGFiP before each Monday evening. Reconciliation time between weekly e-reporting and monthly VAT CA3 return was reduced from 4 days to under 2 hours through automation. Estimated time savings on accounting reconciliation tasks: approximately 60%.

Scenario 2 — A Mid-Sized E-Commerce Company with Direct and Marketplace Sales

An online equipment retailer generates roughly 35% of revenue via its own site (direct B2C flow, subject to e-reporting) and 65% via two large marketplaces (flows for which the marketplace is liable for e-reporting as a deemed supplier). The challenge for this mid-sized enterprise, affected as of September 1, 2026, is to report to the DGFiP only data corresponding to direct sales, without double-counting 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 e-reporting responsibility for facilitated sales. This contractual framework is essential to guard against adjustment risk during audit. Gain in tax clarity and reduction of double-reporting risk: significant for a structure whose flow complexity previously generated adjustments during VAT audits.

Scenario 3 — A Multi-Activity Local Store (SME, Entry into Force September 2027)

An SME operating three gift and decoration boutiques in a mid-sized town, with annual revenue of €1.2 million, is affected by e-reporting as of September 1, 2027. Its POS software, purchased in 2021, is NF 525-certified but its editor had not yet communicated on e-reporting compatibility. Upon reading the official timeline in early 2026, the manager contacted the editor: confirmation was given of an e-reporting module delivery 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 Invoice Portal, free) rather than a paid PDP, given its moderate transaction volume and simple accounting structure. Monthly transmission was configured automatically, with email alert on deposit failure. Estimated total compliance cost: under €2,000 (software update included), representing proportionate investment against avoided sanctions.

Frequently Asked Questions

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

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 arrangements and significantly simplifies GDPR compliance for merchants.

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

Yes, if the sole trader is actually subject to VAT — that is, if he or she has exceeded the turnover thresholds for VAT exemption or has voluntarily opted for VAT. However, as long as he or she benefits from the VAT exemption, he or she is excluded from the scheme. VAT liability is therefore the triggering criterion, regardless of legal status or the size of the business.

What is the difference between e-reporting and standard VAT returns?

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 French tax authority via a Partner Dematerialization Platform or the Public Invoicing Portal. The two obligations coexist: e-reporting does not replace the VAT return; rather, it allows the tax authority to cross-check and verify the declared information.

Must a merchant with mixed B2B and B2C activity manage two separate obligations?

Yes. The part of its activity conducted with French VAT-registered businesses falls under e-invoicing, namely the issuing of structured electronic invoices. The B2C part, meanwhile, falls under e-reporting with aggregated data transmission. In practice, the two flows can be managed through a single approved partner platform, but they are subject to different content and format rules that should be distinguished in the system settings.

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

The French 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 transmit exposes the business to a more thorough tax audit, as the tax authority will not have 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 misconceptions, it is not limited to large chains: any VAT-taxable business conducting sales to individuals is affected, with deadlines starting September 2026 for mid-sized enterprises and large companies, and September 2027 for SMEs.

Keys to success lie in anticipation: audit of POS systems, verification of NF 525 certification, choice of an accredited PDP or the PPF, and training of accounting teams. Penalties for non-compliance (up to €15,000 per year) make last-minute postponement particularly risky.

Certyneo supports you in your compliance journey. Assess your readiness level today with our free electronic invoicing diagnostic or contact our experts for personalized support via our contact page.