The European Commission has issued a reasoned opinion to France after finding that it has not provided all the IT functionalities required under Directive (EU) 2020/285 to support the exchange of information between Member States for the special VAT scheme for small enterprises.
France has received a reasoned opinion from the European Commission, as outlined in its July 2026 infringements package published on 7 July 2026, for failing to fulfil its obligations to provide all the IT functionalities required to enable the exchange of information between Member States from 1 January 2025 under Directive (EU) 2020/285 on the special VAT scheme for small enterprises.
Commission calls on France to fully transpose the new EU VAT rules for the special SMEs scheme
The European Commission decided to send a reasoned opinion to France (INFR(2025)2150) for failing to meet its obligations to provide all the IT functionalities necessary to ensure the exchange of information between Member States as from 1 January 2025, as requested by Directive (EU) 2020/285 on the special scheme for small enterprises.
The Directive allows small enterprises to sell goods and services without charging VAT and alleviates their VAT compliance obligations. Moreover, small enterprises established in a Member State may get a VAT exemption when they sell in another Member State, just like small businesses based in that country. To facilitate this across the EU, IT systems should permit the exchange of information between Member States.
According to the information at the disposal of the Commission, the French IT system does not currently provide all the functionalities needed to ensure the exchange of information necessary for the correct operation of this special scheme. In October 2025, the Commission sent a letter of formal notice to the Member State for failing to fully implement the rules of the Directive.
Therefore, the Commission has decided to issue a reasoned opinion to France, which now has two months to respond and take the necessary measures. Otherwise, the Commission may decide to refer the case to the Court of Justice of the European Union.
