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

The French electronic invoicing reform, which has been progressively coming into force since 2026, primarily concerns transactions between VAT-registered entities established in France (domestic B2B flows). But what about French companies that invoice foreign customers — whether in the European Union or third countries? Many business leaders and financial directors are unaware of this: these transactions escape the obligation to issue via a Partner 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 customers 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 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 foundation 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-registered entities established in France. This strictly covers domestic B2B transactions.

As soon as one of your customers is established abroad — whether 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. However, this operation remains subject to the e-reporting obligation, which constitutes the international counterpart to the reform.

E-reporting: definition and export scope of application

E-reporting refers to the transmission to the French tax administration (DGFiP) of transaction data (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, regime under article 262 of the French Tax Code).

The objective is to enable the DGFiP to reconstruct a quasi-exhaustive picture of VAT collected and deductible on the territory, even when operations are exempted or fall outside the scope. To deepen your understanding of this global obligation mechanism, consult our complete guide to e-reporting.

What distinguishes e-reporting from 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 covers only a set of synthetic data per operation. Article 290 of the French Tax Code (CGI), amended by the 2020 Finance Act and subsequent texts, defines the mandatory information to transmit:

• The invoice issuance date;

• The pre-tax amount (HT) of the operation;

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

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

• The customer's country of establishment;

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

No personal data relating to the foreign customer (name, address, intra-community VAT number) should 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 reporting frequency:

• Monthly: for companies subject to the normal VAT standard 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 reporting.

These deadlines apply equally 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 obligation for structured format on the customer side… 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 remain theoretically free to send an ordinary PDF to a German or American customer. However, several reasons support adopting a structured format now:

• Foreign regulatory reforms underway: Germany is rolling out its own mandatory electronic invoicing system (XRechnung / ZUGFeRD) from January 2025 for large enterprises. Invoicing a large German group in PDF can 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 processed by your foreign customer's ERP system.

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

The special case of intra-community supplies (ICS)

Intra-community supplies 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 communication of the customer's intra-community VAT number. If these conditions are not met, the transaction becomes taxable in France.

Within the e-reporting framework, intra-community supplies 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 (DEB/EMEBI) to detect inconsistencies.

Integrating export into your electronic invoicing system

Choosing a PDP that handles export e-reporting flow

Not all Partner Dematerialization 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 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 rate);

• Provides a monitoring dashboard for transmissions with delivery confirmations.

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. Cross-border intra-group invoicing flows (re-invoicing of costs, 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 failure to comply with e-reporting

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 absence of 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 electronic invoice for export 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: 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 7 October 2022: specifies the conditions for deployment, the permitted formats (Factur-X, UBL 2.1, CII) and the operating procedures of the PPF and PDPs.

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

• Articles 262 and 262 ter of the CGI: foundations of VAT exemption for 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, €15,000/year cap).

European VAT law

• Directive 2006/112/EC of the Council (the "VAT Directive"): common foundation of invoicing rules in Europe. Its article 218 allows Member States to accept electronic documents as invoices. Its article 219 bis determines the territorial rules for invoicing.

• Directive 2014/55/EU: makes electronic invoicing mandatory in European public procurement and defines the EN 16931 technical standard for structured invoices — the technical basis of the CII format used in Factur-X.

• Implementing Regulation (EU) No. 282/2011 of the Council: clarifies the rules for determining 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 French 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 affix enhanced probative value to electronically signed invoices, particularly in cross-border exchanges within the EU.

Data protection

• GDPR Regulation No. 2016/679: applicable to personal data possibly contained in invoices (name of a sole trader, contact information of a representative). For e-reporting flows, the DGFiP does not require personal data on foreign customers, which limits the GDPR exposure of these transmissions. However, retention of export invoices (statutory retention period of 10 years under 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 timestamping and integrity of electronic invoices in a cross-border transmission context.

Use cases: managing electronic invoice for export in practice

Scenario 1 — A SaaS software publisher invoicing customers in the EU zone and outside the EU

A French SaaS solution company generates 60% of its revenue 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 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 closing. For German customers, the PDP also produces a ZUGFeRD/Factur-X file to meet local requirements.

Result: the processing time for export invoices was reduced by 40% through automation, and no e-reporting penalties were incurred during the first 12 months of deployment.

Scenario 2 — An SME industrial exporter to countries outside the EU

An 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. 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 (SAD numbers) to ensure consistency of DEB/EMEBI declarations.

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

Scenario 3 — A consulting firm invoicing service provision to European customers

A strategy consulting firm with around twenty consultants performs assignments for companies established in Spain, Italy and Switzerland. Its service provision is subject to the general rule of the place of the customer (article 44 of the VAT Directive): it is taxable in the customer's country and therefore exempt from French VAT.

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

Adoption of an integrated PDP also enabled the firm to offer electronically generated and signed engagement letters to its foreign customers, with legal value recognized under the eIDAS regulation — reducing contractualization lead times from several days to a few hours.

Frequently Asked Questions

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

E-reporting for exports consists of transmitting summary data to the DGFiP regarding your transactions with foreign customers or customers not subject to VAT in France. Unlike mandatory electronic invoicing, which requires issuing and receiving structured invoices through an approved platform, e-reporting only concerns a set of summarized data. The invoice itself can be sent directly to the customer in a 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 tax, the VAT amount or the reason for exemption, the currency and exchange rate used, the country of establishment of the customer, and the nature of the transaction. No personal data of the foreign customer is required in this flow, 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 VAT regime have ten days after the end of the calendar month. Those falling under the simplified regime transmit their data within ten days following the end of each quarter, with the possibility to opt for a monthly frequency. These deadlines apply regardless of the format used for the invoice delivered to the foreign customer.

Must an invoice addressed to a customer established in the European Union go through a French EDI platform?

No. The obligation to transmit through an Electronic Data Interchange Platform or the public invoicing portal concerns only transactions between VAT-registered businesses established in France. Since your customer is established in another Member State of the European Union, the invoice can be transmitted to them directly, without going through an EDI platform. 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 through an approved platform nor to receive structured invoices within the meaning of 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

Electronic invoicing for export does not follow the same regime as domestic invoicing: it escapes the obligation to transit through a PDP, but is fully inscribed in the e-reporting mechanism. Your sales to foreign customers — intra-community supplies, exports outside the EU, cross-border B2B services — must be declared to the DGFiP via a structured data flow, under penalty of fines that can reach €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 the invoicing reforms currently underway in partner countries.

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