The short answer
Yes, you are concerned, but not necessarily in the same way as other businesses. The French reform distinguishes three things: receiving e-invoices, issuing e-invoices and reporting data to the tax authority (e-reporting). The first applies to everyone; the other two depend on your activity and your clients.
| Your situation | Receive (since 1/09/2026) | Issue (by 1/09/2027) | E-reporting (by 1/09/2027) |
|---|---|---|---|
| VAT-exempt care for patients (physio, doctor, nurse, osteopath…) | Yes | No | No |
| Taxable work for a French business (study, expert opinion, consulting) | Yes | Yes | Payment data if VAT is due on receipt |
| Lawyer, architect, consultant: French business client | Yes | Yes | Payment data if VAT is due on receipt |
| Lawyer, architect, consultant: private client | Yes | No | Yes: daily total and receipts |
| Client established abroad | Yes | No | Yes: invoice by invoice |
Exempt healthcare: no e-invoice, no e-reporting
Article 261, 4, 1° of the CGI (Code général des impôts, the French tax code) exempts from VAT the care provided to people by members of the regulated medical and paramedical professions.
These operations are outside the scope of the reform. The DGFiP (French tax authority) states in its FAQ that only operations within the scope of VAT and not exempt under articles 261 to 261 E of the CGI are subject to e-invoicing or data reporting.
In practice, nothing changes in your relationship with your patients: your fee notes and care forms stay as they are, and you will not report your daily consultations to the tax authority.
Locum and associate arrangements
- Locum (remplacement libéral): the locum collects fees in the name of the practice holder, who then pays the locum a share of the fees. According to the DGFiP, since the invoice remains linked to acts of care, there is no obligation to issue an e-invoice.
- Associate (collaboration libérale): the associate collects their own fees and pays the holder a monthly fee that contributes to practice costs. For the DGFiP, this is a transaction between two VAT-registered professionals: that fee requires an e-invoice.
Receiving e-invoices is mandatory for everyone
A doctor, physio or osteopath whose entire activity is exempt is still a taxable person for VAT. They must therefore be able to receive their suppliers' e-invoices. The DGFiP uses exactly this example: a general practitioner or an osteopath must have chosen a plateforme agréée (approved platform, accredited by the French tax authority) by 1 September 2026, to receive invoices from their energy or internet providers.
This covers your suppliers of medical equipment, practice software, telephony, your landlord if they charge you VAT… The choice of platform is free, can be made through your software or your accountant, and you can change at any time. If you have not chosen yet, read how to choose an approved platform.
Having no platform for receiving invoices exposes you, after a formal notice from the tax authority left unanswered for three months, to a €500 fine, then €1,000 for each further three-month period (article 1737 of the CGI).
When a healthcare professional has a taxable activity
The exemption covers care, not everything the professional does. The DGFiP gives the example of a GP who consults at their practice, exempt from invoicing for that care, but who also carries out a study for a pharmaceutical group: that consulting work is subject to VAT, and they must issue an e-invoice to the laboratory.
The same logic applies to an expert opinion, training or consulting invoiced to a business, if it is subject to VAT. If this is your case, check the exact treatment of each activity with your accountant, then prepare to issue e-invoices by 1 September 2027 at the latest.
Lawyers, architects, consultants: the normal rules
Liberal professions whose activity is subject to VAT (lawyers, chartered accountants, architects, surveyors, consultants, commercial agents…) follow the same rules as other businesses:
- Business client established in France: e-invoice through an approved platform, by 1 September 2027 at the latest for a practice that is an SME, TPE (very small business) or micro-business.
- Private client: no e-invoice, but the total amount of sales per day is reported (transaction e-reporting).
- Payment data: services are, in principle, taxed on receipt. You will therefore report your receipts by setting the status "Encaissée" (collected) on your e-invoices, unless you opted to pay VAT on invoicing (option pour les débits).
A lawyer under franchise en base (the French VAT exemption scheme for small businesses) is still concerned. The threshold is specific: €50,000 of turnover the previous year, or €55,000 in the current year, for regulated legal work. Invoices bear the mention "TVA non applicable, article 293 B du CGI" and e-reporting data is sent every two months. See also our article on e-invoicing for micro-entrepreneurs.
Practising from abroad with no establishment in France? The DGFiP states that e-invoicing does not apply to foreign businesses without a French establishment, but e-reporting may, for operations located in France on which they owe French VAT.
What to do now
- Choose an approved platform for receiving invoices, if not done yet.
- List your activities: exempt care on one side, taxable work on the other (expert opinions, consulting, training, associate fees).
- If you do taxable work for businesses, check that your software can issue e-invoices before 1 September 2027, and collect those clients' SIREN (9-digit French company ID).
- If you charge VAT to private clients, check with your platform how e-reporting data will be collected.
Our test gives you your obligations in a few questions.
Frequently asked questions
Does a physiotherapist report sessions through e-reporting?
No. Care provided by regulated paramedical professions is VAT-exempt (article 261, 4, 1° of the CGI), and e-reporting only covers operations not exempt under articles 261 to 261 E. The physio must, however, be able to receive suppliers' e-invoices since 1 September 2026.
Must a doctor choose an approved platform?
Yes. The DGFiP says so explicitly: a GP or an osteopath must have chosen an approved platform by 1 September 2026 to receive invoices from suppliers, for example energy or internet providers.
Will my fee notes to patients change?
No, for exempt care. They are not e-invoices and give rise to no data reporting under the reform.
Is a lawyer advising private individuals concerned?
Yes, through e-reporting: from their start date, their platform will report the daily total of their sales to individuals and their receipts. For French business clients, they will issue e-invoices.
What about fees passed on to a locum?
According to the DGFiP, since they remain linked to acts of care, they do not require an e-invoice. The fee paid under an associate arrangement (collaboration libérale), on the other hand, does require an e-invoice.
Sources
- DGFiP — FAQ "Je découvre la facturation électronique" (version of 01/09/2026, question 1.2) (impots.gouv.fr)
- DGFiP — FAQ "J'approfondis la facturation électronique" (version of 01/09/2026, questions 1.6, 2.10 and 3.1) (impots.gouv.fr)
- DGFiP — Fiche 2: "Mon entreprise sera-t-elle obligée de facturer électroniquement ?" (will my business have to e-invoice?, October 2026) (impots.gouv.fr)
- impots.gouv.fr — E-reporting requirements for foreign companies without a permanent establishment in France (impots.gouv.fr)
- Légifrance — CGI, articles 261 to 263 (exempt operations) (legifrance.gouv.fr)
- Entreprendre.Service-Public.fr — Franchise en base de TVA (VAT exemption scheme, 2026 thresholds) (entreprendre.service-public.gouv.fr)
- Entreprendre.Service-Public.fr — E-invoicing: sanctions are evolving (20/02/2026) (entreprendre.service-public.gouv.fr)
- impots.gouv.fr — "La facturation électronique, qu'est-ce que ça change pour moi ?" (what changes for me, questionnaire) (impots.gouv.fr)
This article summarises the official texts to help you get organised. It is not a substitute for personalised advice from your accountant.