Most coverage of the French reform is written for a business that invoices other businesses and nothing else. Send a structured invoice, done. That leaves out a large group: the shop, the cafe, the restaurant, the petrol station, the print shop. Businesses whose customers are mostly consumers, but not always.
If that is you, there is a piece of guidance from mid-September that changes how your counter works.
What changed
Guidance published on 14 September clarified how a meal or a counter sale fits into the reform. The answer is that your customer decides, at the moment of the sale.
If the customer does not identify a business as the purchaser, the transaction stays in B2C e-reporting. You report the data to the tax authority through your platform, and no structured invoice is needed.
If the customer identifies their employer or their own company as the purchaser, it becomes a B2B transaction. That needs a structured e-invoice routed through your approved platform, with everything the law requires on it.
The 150 euro excluding VAT restaurant invoice simplification has not been touched. That part is unchanged.
So far this is simple. The difficulty is the sale that changes category after it has happened.
Someone eats lunch, pays at the counter, and the sale is rung up and reported as B2C. Two days later they come back and ask for an invoice made out to their company, because they want to claim it. If you issue that invoice and do nothing else, the tax authority now has the same meal twice. Once in your e-reporting as a consumer sale, once as a B2B e-invoice.
That is not an automatic fine. It is a discrepancy between your e-reporting and your VAT return, and a discrepancy is what invites a question from the tax office. The worst time to discover it is at year end, when nobody remembers the lunch.
What to do this week
- Tell whoever works the till to ask, before ringing up, whether the purchase is for a business. It takes one sentence and it prevents the whole problem.
- Write down one agreed process for the after-the-fact invoice request, so two people do not handle it two different ways.
- Ask your approved platform or your accountant how to cancel or adjust a B2C e-report, and get the answer in writing before you need it.
- Reconcile your e-reporting totals against your VAT return once this month. Not at year end. Once, early, while the volume is small enough to fix by hand.
A note on timing
If you are a small or micro business, your own obligation to issue e-invoices and send e-reporting data starts on 1 September 2027, not 2026. But you have had to be able to receive structured e-invoices since 1 September 2026. The classification question becomes yours the moment your issuing obligation starts, and the till habit is easier to build now than in a rush next August.
This is general information about published guidance, not legal or tax advice. Check your own position with your accountant.