What E-reporting Really Changes for the Group CFO
This article applies exclusively to companies subject to French tax law.
Since 1 September 2026, large companies and mid-sized enterprises (ETI) have been transmitting their transaction data to the DGFiP (French tax authority) via their Approved Platform (Plateforme Agréée — PA). SMEs will join them from 1 September 2027. But behind the technical obligation lies a deeper shift that many have yet to fully grasp: the administration now has an automated reconciliation tool covering three dimensions of a company's activity — invoices transmitted by platforms, VAT returns (CA3 or CA12), and the Statutory Accounting File (FEC).
In practice, this means that any inconsistency between what is reported in e-reporting, what appears in the accounts, and what is declared for VAT is now visible to the DGFiP — without waiting for a traditional tax audit. The good news is that this reconciliation is also a discipline that CFOs can take ownership of, and when done well, it becomes the best way to stay above reproach.
Understanding What E-reporting Covers — and What It Doesn't
E-reporting is not a duplicate of the electronic invoice. The two obligations are complementary and cover distinct perimeters. Electronic invoicing (e-invoicing) covers domestic B2B transactions between French VAT-registered companies. E-reporting covers everything that electronic invoicing does not capture: B2C sales, international transactions (exports, intra-community acquisitions), and receipts from services.
For each period, the entity subject to the obligation transmits aggregated data — net amounts, VAT broken down by rate, customer country, tax identifier — via its Approved Platform, which then forwards them to the PPF (Public Invoicing Portal) before transmission to the DGFiP. E-reporting does not replace the VAT return: it coexists with the CA3 or CA12, and it is precisely from this coexistence that the risk of discrepancies arises.
The Reconciliation Method: Three Levels, by Entity
In a multi-entity group, it is not enough to verify that flows are being sent. You must ensure, entity by entity, that the transmitted data is consistent with two reference points: the accounting records (FEC) and the VAT returns. Here are the three control levels to implement.
First level — e-reporting × CA3 reconciliation. For each entity and each reporting period, the aggregated amounts transmitted in e-reporting (net, VAT, gross by rate) must match the corresponding VAT return. Any discrepancy between the total VAT collected declared in the CA3 and that reported in e-reporting is an immediate red flag. The most common causes: a VAT rate incorrectly coded in the ERP, an intra-community transaction wrongly classified as domestic B2B, or a receipt not allocated to the correct period.
Second level — e-reporting × FEC reconciliation. E-reporting flows must exactly mirror the accounting entries. The Statutory Accounting File must reflect the same flows as those transmitted to the DGFiP. A discrepancy between the two reveals either an incorrect accounting entry or incomplete e-reporting data. This control level is particularly sensitive for B2C sales and service receipts, which are often processed in aggregated mode with a higher risk of period slippage.
Third level — transmission status monitoring. The Approved Platform returns a status for each submission: accepted, rejected, or pending. A rejected flow has not entered the system — there is nothing to correct for the period, but the anomaly must be fixed and resubmitted before the period closes. An unread rejection automatically becomes a missing transmission, triggering the corresponding penalty. Article 1788 D of the French Tax Code (CGI) sets the penalty at €500 per missing or inaccurate transmission, capped at €15,000 per calendar year.
The Five Most Common Anomalies Observed Since September 2026
Since the reform came into force, field feedback has identified five recurring types of discrepancy that the group CFO must keep front of mind.
The first is a missing flow from a secondary entity. In a group, smaller entities — a distribution subsidiary, an operating holding company — may be connected to the main PA but poorly configured for e-reporting. Flows are sent for the parent company's transactions but not for those of the subsidiary.
The second is a B2B / B2C classification error. A sale to a foreign professional client not established in France falls under e-reporting, not e-invoicing. If misclassified, it is neither electronically invoiced nor declared in e-reporting — it simply disappears from the radar.
The third is a period mismatch on receipts. For companies on a cash-accounting basis for VAT, the date of payment data transmission must correspond to the actual receipt date, not the invoice date. A systematic mismatch creates a cumulative discrepancy between the CA3 and e-reporting.
The fourth is an incorrect or missing SIREN reference. Accurate mapping of reference data — SIREN, intra-community VAT numbers — is essential to avoid technical rejections. In groups that have rationalised their IT systems after an acquisition, old SIREN numbers may still be circulating in flows.
The fifth is an undetected rejection. Without active monitoring of acknowledgements returned by the PA, a rejection may go unnoticed for several weeks. In groups where the PA is managed centrally but local entities are poorly trained, this risk is particularly high.
What the DGFiP Looks At — and How to Stay Ahead
The doctrine published in the BOFiP on 30 September 2026 (ACTU-2026-00145) sets out the framework. The administration has automated cross-referencing between invoices transmitted via PAs, CA3 returns, and FEC files. It is not looking for isolated anomalies — it is looking for systemic coherence. A one-off discrepancy, documented and corrected, is manageable. A recurring inconsistency between e-reporting and CA3 over several periods becomes a strong signal.
The best line of defence is proactive consistency: implementing a monthly control, by entity, before the CA3 is filed. If a discrepancy is identified internally before the DGFiP spots it, there is still time to correct — a rejected submission that is corrected and resubmitted within the deadline counts as a valid transmission, with no penalty.
In the event of a temporary difficulty — a technical incident, a configuration delay — the DGFiP's position is clear: secure the source data, document the incident, transmit what can be transmitted, and regularise without sending uncontrolled data in bulk. A temporary e-reporting difficulty does not affect the validity of invoices or payments.
Setting Up the Monthly Control: The Framework to Follow
For a group looking to secure its e-reporting flows on a lasting basis, the monthly control is structured around four actions.
The first is to retrieve acknowledgements and statuses from the PA for all entities before each period closes. Any rejection identified must be addressed immediately.
The second is to reconcile e-reporting data with the CA3 for each entity, line by line: B2C VAT collected, VAT on intra-community acquisitions, VAT on receipts. Any difference of more than a few euros deserves a documented explanation.
The third is to cross-reference with the FEC for entities with significant B2C or international flows. The FEC × e-reporting reconciliation is the ultimate test: if the two are consistent, the entity's position in the event of an audit is solid.
The fourth is to maintain the evidence file for each period: list of transactions covered, transmission acknowledgements, processed rejections, final reconciliation. This file is the first thing the administration requests in a tax audit.
How Trevys Supports Group Finance Teams
At Trevys, we support group finance functions across the entire e-reporting cycle: flow configuration with the Approved Platform, implementation of the monthly control by entity, and quarterly coherence review across e-reporting, accounting, and VAT.
This is not purely a technical subject — it is simultaneously accounting, tax, and organisational. That is precisely where a firm that combines accounting expertise with IT transformation consulting delivers the most value.
Book a meeting with a Trevys partner
Sources: BOFiP ACTU-2026-00145 of 30/09/2026 — Article 1788 D CGI — Articles 290 and 290 A CGI — DGFiP, practical start-up guide (July 2026)