Key facts
1 September 2026: invoice receipt within the French scope.
1 September 2027: issuing and e-reporting for French SMEs and micro-enterprises.
Transactions and payments: two separate datasets.
« The first mistake to avoid is assuming the software covers every flow without listing the sales sources. »
Sébastien Doat, CFO · Quote translated from French
Which transactions fall within e-reporting?
For a business established in France, certain consumer sales and international transactions may fall under e-reporting, subject to conditions. An entity-level matrix should distinguish domestic B2B, B2C and international flows. A France-Spain group cannot automatically apply French rules to every subsidiary.
How do transaction and payment data differ?
Transaction data describes operations; payment data tracks receipts where required. For services, examine the VAT tax point. Exceptions involving the debit option and reverse charge must not obscure special cases, including advances. Validate the matrix rather than infer a rule from software alone.
How do you reconcile sales, VAT and receipts?
Accounting revenue, submitted totals and payment-provider settlements are not automatically equal. Build a reconciliation bridge for net and gross amounts, VAT, timing, refunds, credit notes and provider fees. An explained difference is better than a forced equality.
Teaching example: a tax-inclusive sale may be collected later and settled net of fees. A reconciliation bridge links sale, VAT, payment and fee through retained references. We explain amount and timing differences before treating an anomaly.
We recommend a reconciliation bridge by entity and source. The starting point specifies whether sales exclude or include VAT. The bridge isolates VAT, refunds, fees and settlement timing. Each explanatory line retains a reference and period: a justified difference should not be turned into an artificial correction.
Completeness checks compare expected sources with files actually received. Duplicate checks ensure one sale is not picked up by two integrations. Period checks review dates, cancellations and partial payments. We separate these controls so a coherent total cannot hide missing and duplicate lines that cancel out.
How do you collect data and correct an anomaly?
Identify the owner of each source: shop, checkout, ERP, payment provider and accounting. Ask the vendor which flows are covered, what data is missing and how errors are returned. Test for duplicate reporting and retain correction evidence. Check statutory frequency for your regime and add it to the control calendar.
What belongs in the e-reporting matrix?
The e-reporting matrix links each sales category to an entity, source and tax treatment. We list channels before configuration: store, till, invoicing software, ERP and payment provider. One business can produce several datasets. The control should explain which are submitted and which are already covered by another process.
We distinguish sale date, invoice date, receipt date and reporting period. The four dates need not coincide. A later refund or credit note may affect a different period from the original sale. Retain the reference allowing reconstruction without reconciling only monthly totals.
The accountant classifies the VAT regime for specific cases. We then translate the validated matrix into collection rules, a calendar and tests. Operational controls must remain readable to finance. A tax regime should not be inferred from the software name or the appearance of a bank payment.
Which process connects sales, payments, PA and accounting?
The e-reporting process connects sales and payment sources to the approved platform, with independent accounting reconciliation. PA is the current term for plateforme agréée; the former PDP meant plateforme de dématérialisation partenaire. The public invoicing portal (PPF) concentrates data for the administration. We document interfaces, exports and error responses.
Ask the vendor to show a successful submission and a rejected one. The response should identify the source to correct and whether a new submission replaces or supplements the previous one. Retain the acknowledgement and data version. Automation that sends without an actionable outcome leaves a control task unresolved.
The operating calendar must match the frequency and deadlines applicable to the entity’s regime. We recommend owners for collection and reconciliation and an escalation route. Absences and technical incidents should be anticipated. Manage this calendar alongside closing and filing obligations instead of checking sources on the final day.
« Electronic invoicing does not create disorder; it makes it visible and obstructive. »
Sébastien Doat, CFO · Quote translated from French
How do you test B2C sales, credit notes and refunds?
A useful test follows a transaction from sale through submission and reconciliation. Teaching example: an online store makes a sale and later a partial refund after payment-provider settlement. The test retains the original sale, refund, fee and relevant periods. Expected results distinguish revenue, VAT and cash.
We then check that no second source reports the same sale. If a B2C order produces an invoice in another tool, the matrix must explain how the transaction remains unique. The owner retains the deduplication rule and test. Unrecorded manual deletion is not a reproducible process for future periods.
For a France-Spain group, testing starts with the selling entity. A shared platform does not make obligations identical. The French company follows its French scope; the Spanish subsidiary follows Spanish systems. The map retains country, entity and identifiers before calculating group totals. Intragroup flows are also identified separately.
How do you retain evidence of a submission and correction?
Submission evidence connects a period, source and data version to an outcome. We recommend retaining the prepared file, completed checks and response. The record also identifies who validated anomalies. A sending date alone does not demonstrate source completeness, acceptance or accounting consistency. Keep a clear distinction between preparation, submission and the returned result so the finance team can locate the precise stage requiring further action.
When a correction occurs, we retain the original data and the reason for changing it. New processing should link back to the previous submission, following platform rules. Staff check that correction does not reintroduce duplication. Traceability allows totals to be understood without relying on the operator’s memory. Use the same reference in the anomaly record, correction record and accounting bridge wherever possible; request vendor confirmation of the resubmission behaviour.
Periodic controls compare expected submissions with actually processed submissions. A missing source, incomplete period and rejection are different alerts. We recommend tracking them separately with owners and actions. Keep the accounting bridge alongside the record: it explains legitimate timing, tax and settlement differences without imposing artificial equality. Reviewing these items before the reporting deadline makes the unresolved work visible and preserves the evidence needed for the following period’s reconciliation.
Frequently asked questions
When must an SME issue electronic invoices?
1 September 2027 for SMEs and micro-enterprises within the French scope. Receipt has been required since 1 September 2026 for relevant VAT-taxable businesses. Large and intermediate-sized businesses follow the 2026 issuing deadline.
Does e-reporting replace the VAT return?
No, e-reporting submits transaction and payment data; VAT returns remain due. Reconciliation checks differences in basis, timing and tax point. Keep separate schedules for submission and filing.
Must every payment be submitted?
No, payment data follows VAT tax-point conditions and exceptions. Services, deposits, the debit option and reverse charge must be distinguished. The tax matrix then determines configuration.
Must e-reporting totals equal payment-provider settlements?
No, direct equality can be wrong. VAT, fees, refunds and timing explain differences. A reconciliation bridge documents them without forcing totals to match.
How do you avoid duplicate B2C submissions?
Identify the reporting source for each transaction. An order and its invoice may appear in two tools: the rule must preserve one transaction. Test refunds and retain references.
Does the French reform apply to a Spanish subsidiary?
No, not automatically: establishment and transactions determine scope. The subsidiary also follows Spanish rules, including RRSIF and B2B invoicing under Crea y Crece, which are separate systems. An entity-level matrix avoids applying French dates to the whole group.
