Understanding
the reform

Your company's size is assessed as at 1 January 2025, based on the last financial year closed before that date. That is what determines your deadline. The measure used is the legal unit, identified by its SIREN number.

It all depends on what it actually does:

• a passive holding company (an asset-holding vehicle), which merely holds shareholdings and receives dividends, is not VAT-registered: it falls outside the scope of the reform;
• an active holding company, which invoices services to its subsidiaries, is VAT-registered and is treated like any other business for electronic invoicing and e-reporting.

Same reasoning: VAT registration is what settles it. An SCI that invoices rent subject to VAT falls within the scope; an SCI whose rent is VAT-exempt does not. If you use DigiPA for an asset-holding structure, the dedicated guide covers invoicing your leases.

Personal care services are VAT-exempt (article 261, 4, 1° of the French tax code): they therefore fall outside the scope. But the distinction matters:

• locum work: the locum collects payment in the name and on behalf of the practice holder, who then pays them a share of the fees. As the invoice still relates to care services, no electronic invoice is required;
• associate practice: the associate collects payment on their own account and pays the practice holder a fee, in the nature of rent. This is a transaction between two VAT-registered parties: an electronic invoice is mandatory for that fee.

Transactions with a VAT-registered customer in Guadeloupe, Martinique or Réunion fall under electronic invoicing. Those with customers in French Guiana or Mayotte, where VAT does not apply, fall under e-reporting.

In short: a sale to a French business falls under electronic invoicing; a sale to a private individual or abroad falls under e-reporting. The matching exercise in the previous step lets you check it has sunk in.

Yes, but differently: there is no electronic invoice to issue. You report the total amount of transactions per day, over a given period — that is transaction e-reporting.

It depends on your VAT scheme, not on a single rule:

• small-business VAT exemption: every two months;
• standard monthly VAT scheme: three times a month for transaction data, once a month for payment data.

Payment data concerns supplies of services only.

No. A supplier cannot impose an exchange format on you, and you are the one who chooses your receiving platform. Accredited platforms offer a common set of formats that guarantees exchanges remain interoperable.

The invoice is made out in your name but can be addressed to your provider through an “INVOICEE” block designed for this. You have access to the invoice and its data on the same footing as your provider.

Note: a first breach carries no penalty if it is put right voluntarily or within thirty days of a request from the tax authorities. The fine for having no platform, for its part, only applies after a formal notice has gone unanswered.

The real problem lies elsewhere: without a receiving platform, your supplier invoices no longer reach you. That means disruption in your commercial dealings, late payments, and VAT returns that are no longer pre-filled correctly.

Extencia takes care of it for you. We offer to make the designation on your behalf: all you need to do is agree, then sign an electronic mandate from within your software. Nothing to print, nothing to post.

If you already have an accredited platform, let us know: we will take it into account.

That is anticipated. Extencia handles designating the platform, and most of it happens inside the software you already use. The Academy guides walk you through step by step, and your adviser remains available.

Setting up takes a few minutes to sign the mandate. After that, electronic invoicing tends to save time: invoices arrive on their own, there is less data entry, and payment chasing relies on dependable statuses.