Obligation to transmit transaction data: which companies are affected?

The dematerialization of invoices, with their mandatory receipt and transmission via a public or private platform certified by the State, is about to be implemented for exchanges between professionals. Fortunately, a staggered timetable, defined by the amended Finance Act for 2022, allows businesses to get organized. Between July 2024 and January 2026, e-invoicing will be phased in for all businesses. At the same time, companies will be required to transmit their transaction data. But what exactly is involved, and which companies are affected?

Which companies are affected by the obligation to transmit transaction data?

The electronic billing system is complemented by e-reporting, which involves the transmission of transaction and payment data.

All VAT-registered companies, including micro-businesses, established in France, are concerned by e-reporting when they carry out BtoC (business-to-consumer) operations or transactions with foreign European or non-European companies.

In other words, any tax-liable business meeting one of these conditions will have to send the tax authorities a daily summary of transactions by payment method (similar to a till receipt), without transferring this information to their customers. This obligation applies to small retailers and craftsmen who sell goods or services to private individuals.

On the other hand, for companies operating in the international B2B sector (purchases or sales), and who generally issue or receive invoices, e-reporting will follow the same process as e-invoicing. The data, which is identical, will be transmitted via either a public or an approved private platform. The only difference lies in the supplier or customer identification number, which will not be a SIREN but an intra-Community VAT number for EU companies, and a national register number for those from other countries.

As the government is unable to impose its national policy of dematerializing invoices on foreign companies, e-reporting has been provided for transactions with players not based in France.

If a company has both business and private customers, it is concerned by both e-invoicing and e-reporting. It is important to note that transactions that fall outside the scope of VAT are not subject to the obligation to transmit information to the tax authorities.

How is data transmitted and what information is required?

Data must be transmitted via the chosen platform, which, if private, will transfer it to the administration. Data can be entered directly on the portal or transmitted as a computer file. Data will include, among other things, transaction amounts, VAT rates and amounts, and dates of collection.

Several transmission modes and formats are possible. New cash register software is already equipped to enable the dematerialized transmission of daily transaction summaries. If a company supplies invoices, even to private individuals or entities not subject to VAT, such as associations, it can submit them directly to a platform. Only the necessary data will be extracted. Finally, for very small businesses that have no software or invoicing, they will be asked to enter their total sales per day, as well as any VAT collected. No customer data should be transmitted.

The e-reporting process is designed to enable companies of all sizes to transmit data quickly and efficiently. It will be necessary to take into account the configuration of management and accounting systems so that they can automatically extract information in real time or at regular intervals.

The frequency with which data is sent depends on the tax regime. Companies subject to the standard tax system must send a weekly report within 4 days. For companies benefiting from a special tax regime, such as micro-enterprises, the deadline is 7 days from the end of the month.