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The simplified VAT regime (RSI) will be abolished on January 1, 2027. Businesses currently under this regime will automatically transition to the standard actual regime.
As a result, semi-annual installments and the annual CA12 return will be replaced by quarterly CA3 returns, or monthly returns if your turnover (including acquisitions for which the taxable person is liable for VAT) exceeds one million euros.
This transition will not require any specific action on your part: the tax authorities will handle the change of regime automatically.
At first glance, the reform might seem to simply mean new reporting obligations and increased pressure on business cash flow. However, its consequences deserve a more nuanced analysis.
Since the simplified regime is already reserved for businesses whose annual VAT liability does not exceed €15,000, the reform will not fundamentally change the total amount of VAT payable over the year.
Its main impact will be on the schedule: for filings, payments, and, starting in September 2027, e-reporting obligations.
What will the concrete changes be for the affected businesses? How will the transition be managed? What will the real impact on cash flow be, and how will these new obligations align with the electronic invoicing reform?
This article breaks down the provisions set out in the legislation, presents the implementation timeline, and illustrates the financial and operational consequences of the end of the RSI with supporting figures.
However, this does not replace a personalized analysis of your situation, which our firm can provide as part of an audit of your VAT practices.
The elimination of the simplified VAT tax regime is no longer a prospect: it has been written into law since February 2025. Its application is automatic, with no option for opt-outs or exemptions. Only the closing date of the accounting period determines the transition schedule applicable to each company.
Article 38 of Finance Act No. 2025-127 of February 14, 2025, rewrites paragraphs 2, 3, and 3 bis of Article 287 of the General Tax Code (CGI). As of January 1, 2027, the CA3 return, filed monthly or quarterly, will replace the current system of two semi-annual installments followed by an annual adjustment.
This reform is a choice made by the French legislature, not a European requirement. Article 252 of the VAT Directive allows member states to set tax periods of one, two, or three months, or even longer periods up to one year. France has therefore chosen to eliminate the annual periodicity of the simplified regime in favor of a quarterly or monthly return, depending on the company.
Note: on January 1, 2027, VAT will move from the General Tax Code to Book II of the Code of Taxes on Goods and Services (CIBS). However, Article 287 is exempt from this transfer. The administration classifies it among the provisions downgraded to the regulatory level, which remain temporarily in force until they are incorporated into the implementing texts of the CIBS (Ordinance No. 2025-1247 of December 17, 2025, art. 15; BOI-RES-TVA-000253).
As long as these texts are not published, the reference remains Article 287 of the CGI.
For the effects of the recodification on your invoices, see our article on VAT disclosures.
For companies whose fiscal year coincides with the calendar year, the new regime will apply to VAT due from January 1, 2027. The first CA3 return will therefore cover January or the first quarter of 2027, depending on the applicable frequency. The final annual CA12 return, relating to 2026, must be filed no later than May 4, 2027.
For companies with a split fiscal year, the transition will occur at the end of the fiscal year that includes December 31, 2026. Thus, a company closing its accounts on June 30 will switch to the new regime on July 1, 2027. It must file its final CA12E return within three months following that closing.
Two categories of companies are exempt from this reform: those benefiting from the VAT exemption threshold, which are not required to file periodic returns (see the current exemption thresholds), and agricultural operators under the simplified agricultural regime, which is maintained by Article 298 bis of the CGI.
Table 1: What is changing, and when
| Situation | Rule | Basis | Status |
|---|---|---|---|
| Business under the simplified regime, calendar year | CA3 returns from January 2027 VAT; last CA12 return by 4 May 2027 | 2025 Finance Act, Art. 38; FTC, Art. 287 | From 1 January 2027 |
| Business under the simplified regime, non-calendar year | CA3 returns after the close of the financial year that includes 31 December 2026; CA12E within 3 months | 2025 Finance Act, Art. 38, VI | At the 2026/2027 year-end |
| July 2027 instalment | Due only if the financial year ends between July and November 2027 and the previous year's VAT exceeds €1,000 | DGFiP news release of 22 September 2026 | July 2027 |
| December 2027 instalment | Never due | DGFiP news release of 22 September 2026 | December 2027 |
| Business already filing monthly, previous year's turnover up to €1,000,000 | May request quarterly filing | FTC, Art. 287(3); DGFiP news release | From 1 January 2027 |
| E-reporting for SMEs | Transmission of transaction and payment data | FTC, Art. 290 and 290 A | From 1 September 2027 |
The new text establishes a clear rule: VAT returns are to be filed quarterly when the adjusted turnover does not exceed €1,000,000 for the previous calendar year and €1,100,000 for the current year. Exceeding these thresholds triggers a switch to monthly filing. These amounts will be updated every three years based on inflation.
For the 2027 transition, the tax authorities will base their assessment on the turnover indicated in the most recent annual VAT return. If no return has been filed, the quarterly frequency will be applied by default.
The vast majority of companies currently under the simplified regime should therefore fall under the quarterly regime. Indeed, the simplified tax regime (RSI) was reserved for companies whose annual VAT due did not exceed €15,000 and whose turnover in 2026 remained below €945,000 for sales activities and €286,000 for service provision (BOI-BAREME-000036).
An exception, however, applies to trading companies close to the one-million-euro threshold. Exceeding the standard RSI threshold does not result in its immediate termination as long as the turnover does not exceed €1,040,000 (CIBS, art. L. 162-5). A company with a turnover between €1,000,000 and €1,040,000 may therefore still qualify for the simplified regime in 2026, only to be subject to mandatory monthly filing starting in 2027.
The turnover used to determine the frequency of VAT returns is not limited to the sales and services provided by the company.
The text uses the turnover defined for the VAT base franchise (CGI, art. 293 D) as a starting point, to which it adds the pre-tax amount of certain operations subject to self-assessment. This primarily concerns services provided by suppliers established outside of France, subcontracting in the construction sector, other operations referred to in Article 283, 2 to 2 decies of the CGI, as well as self-assessed imports and exits from suspensive regimes.
These operations, for which the company itself is liable for VAT, can therefore cause the company to cross the threshold for monthly filing, even when its commercial turnover remains below one million euros.
These are, for the most part, operations to be declared in box A3 of the CA3 return.
To find out which side of the threshold you fall on, enter your figures in the calculator below.
A company eligible for quarterly filing may nevertheless opt for monthly filing. The option is exercised with the business tax office (SIE) via the secure messaging system in your professional account. It takes effect on the first day of the following calendar quarter and commits the company for at least four quarters. After this period, it may be revoked under the same terms regarding effective dates.
In our view, this option is primarily of interest to companies that are structurally in a VAT credit position: exporters, companies making significant investments, or businesses whose purchases consistently precede their sales. Monthly filing allows them to obtain refunds for their VAT credits more quickly.
For other companies, the benefit is less obvious. Switching to a monthly schedule effectively means paying VAT one month in advance, on average, while tripling the frequency of filings and transaction data transmissions (e-reporting).
One argument, however, may favor the monthly schedule: it enforces greater rigor in bookkeeping and limits the accumulation of pending entries. This benefit is real, but it can be achieved without giving up quarterly filing by simply adopting monthly accounting monitoring.
This is one of the least discussed effects of the reform: some companies that currently file their VAT monthly will be able to switch to a quarterly schedule starting in 2027.
Until now, a company whose annual VAT exceeded €15,000 could no longer benefit from the simplified regime and was, in principle, required to file VAT monthly, even with modest turnover. Under the standard real regime, quarterly filing was effectively reserved for companies whose annual VAT payable did not exceed €4,000.
The same constraint applied to companies under the simplified regime that carried out intra-community acquisitions or imports. They were required to file monthly CA3 returns, unless their annual VAT remained below €4,000 (CGI, art. 287, 3 ter, as worded prior to 2027).
As of January 1, 2027, these limits based on the VAT amount will disappear. The frequency will now depend on the adjusted turnover. Companies that do not exceed the new thresholds will therefore be able to file their VAT quarterly, regardless of the amount of VAT paid over the year.
The transition will not be the same for everyone, however. Companies currently under the simplified regime will need to verify the frequency assigned to them and request a correction if necessary. Those already under the standard monthly real regime will need to explicitly request their switch to quarterly filing from their tax office. This change will not be automatic.
The cash flow impact is tangible. Take a trading company that pays €36,000 in VAT per year, or €3,000 per month on average. By switching from a monthly to a quarterly filing, it could permanently retain about €3,000 in additional cash flowthanks to the deferral of payment deadlines.
This switch to quarterly filing does not reduce the VAT owed, but it does change the disbursement schedule. It therefore serves as a cash flow lever to be examined on a case-by-case basis, taking into account filing constraints and the company's financing needs.
This is precisely the type of trade-off we calculate with our clientsto determine if switching to quarterly filing offers a real advantage for their business.
The switch to a monthly schedule can also occur during the year. The text provides for an immediate switch, but limits its retroactive effect.
In this case, the monthly reporting period applies from the first day of the month in which the threshold is exceeded. However, the text limits the retroactive effect of this switch: the first monthly return includes all transactions carried out since the beginning of the current calendar quarter, without going back to previous quarters.
Example: A company crosses the €1,100,000 threshold on May 12, 2027. Its first monthly return, filed in June, covers transactions carried out in April and May. From June onwards, it then declares its VAT each month according to the usual schedule.
This limitation on the retroactive effect is a significant step forward.
Starting in 2027, regularization will be limited to the current calendar quarter. Companies will therefore no longer have to reconstruct several months of returns from the beginning of the year.
It is still necessary to anticipate crossing the threshold. For companies experiencing strong growth or dealing with an exceptional order, monthly monitoring of cumulative turnover—including self-assessed transactions—becomes essential. This will allow for timely identification of the change in reporting frequency and help avoid any filing delays.
Under the simplified regime, you paid a 55% VAT installment of the previous year's VAT in July, followed by 40% in December, calculated before deducting VAT on capital assets (CGI, art. 287, 3, in its current wording). The balance was settled with the CA12 return the following spring. From now on, you pay the VAT actually due for the past quarter with each CA3 return.
The impact depends on your trajectory. For a stable company, the quarterly system is neutral or even favorable: the fourth-quarter VAT is only paid in January, whereas the December installment previously brought payments to 95% of the year's total. For a growing company, it is the opposite. The installments, calculated on a less profitable year, provided a cash flow advantage that the reform eliminates. The scale remains limited, as the simplified regime was capped at €15,000 of VAT per year.
A company in decline, however, gains little. It could already reduce its installments when the VAT actually due was at least 10% lower than their amount, by simple declaration to the public accountant (same article). The new regime primarily offers simplicity.
For a calendar year, no installments are due in 2027. The same applies to financial years ending between January and June 2027. The December 2027 installment is not due from anyone.
Under the simplified regime, a VAT credit was only refunded once a year, with the annual return, except for purchases of capital assets.
Under the standard real regime, you can request a refund at the end of each quarter, or each month if you file monthly, as soon as the credit reaches €760 (CGI, Annex II, art. 242-0 A and 242-0 C).
For a company that invests, the advance payment made to the Treasury is now measured in weeks.
Context. A communications agency with four employees is under the simplified regime, operating on a calendar year basis. Its net VAT due amounts to €8,000 in 2025 and €14,000 in 2026. It remains under the simplified regime in 2026, as its 2025 VAT does not exceed €15,000. It forecasts €18,000 in VAT for 2027, spread equally over the four quarters.
Initial situation. In 2026, the agency paid two installments calculated based on 2025 VAT: €4,400 in July (55%) and €3,200 in December (40%), totaling €7,600. The 2026 balance therefore amounts to €6,400, payable with the final CA12 return by May 4, 2027, at the latest.
Applying the rule. Under the new system, it pays €4,500 in April for the first quarter, €6,400 in May for the 2026 balance, then €4,500 in July and €4,500 in October.
The fourth quarter is settled in January 2028. If the simplified system had been maintained, it would have paid €6,400 in May, then €7,700 in July and €5,600 in December, based on 2026 VAT.
Table 2: Cumulative VAT cash outflows in 2027
| End of month | Old regime, had it continued | New quarterly regime | Difference |
|---|---|---|---|
| April | €0 | €4,500 | +€4,500 |
| May | €6,400 | €10,900 | +€4,500 |
| July | €14,100 | €15,400 | +€1,300 |
| October | €14,100 | €19,900 | +€5,800 |
| December | €19,700 | €19,900 | +€200 |
Financial impact. Over the year, the difference is only €200. However, from April to November, the agency advances up to €5,800 more than under the old system, peaking in October and November. This is a temporary cash flow requirement, not a new expense.
Conversely, a stable company with €14,000 in VAT in 2025, 2026, and 2027 would reduce its 2027 cash outflows by €2,800, since its fourth quarter shifts to January 2028.
Conclusion. For the agency, the decision is simple: incorporate these dates into the 2027 cash flow forecast and do not opt for monthly payments, which would advance payments by another month.
As of September 1, 2027, SMEs will be required to issue their electronic invoices and transmit two categories of data to the tax authorities via their approved platform:
The abolition of the simplified VAT regime will therefore precede the entry into force of these obligations by eight months. However, the frequency of VAT returns will also determine the frequency of transaction data transmission.
The transition to the standard actual regime will therefore not only change the schedule for VAT returns and payments: it will also set the pace for future e-reporting obligations starting in 2027.
The comments published by the tax authorities on September 30, 2026 (BOI-TVA-DECLA-20-30-50-30, § 50 to 100) confirm that the frequency of transaction data transmission depends on the VAT reporting regime.
Under the monthly standard actual regime, data must be transmitted three times a month, in ten-day periods: from the 1st to the 10th, from the 11th to the 20th, and then from the 21st to the last day of the month. Under the quarterly standard actual regime, only one monthly transmission is required. In both cases, companies have ten days after the end of each period to transmit their data.
By comparison, the simplified regime offers a longer deadline, until the end of the month following the period concerned.
For payment data, however, the frequency is identical for the monthly and quarterly standard actual regimes: it must be transmitted each month, no later than the 10th of the following month (official table of transmission frequencies and deadlines).
Companies with a non-calendar fiscal year that are still under the simplified regime as of September 1, 2027, will therefore temporarily follow the deadlines specific to that regime. They will then adopt the standard actual regime's schedule at the end of their fiscal year.
The choice between monthly and quarterly reporting has a direct operational consequence: it determines whether the company must transmit its transaction data twelve or thirty-six times per year.
A company subject to quarterly reporting will have already transmitted three months of transaction and payment data by the time it files its CA3. This information must be consistent with the amounts declared for the quarter.
The tax authorities will thus have data allowing them to reconcile the transactions transmitted by certified platforms with VAT returns. This cross-referencing capability addresses two stated objectives of the reform: strengthening the fight against fraud and, eventually, enabling the pre-filling of tax returns.
In practice, the quarterly VAT closing must be based on the same data as that transmitted by the certified platform. Any discrepancies must be identifiable and justifiable, particularly when they result from differences in scope or tax point rules.
An unexplained discrepancy between e-reporting data and the CA3 may attract the attention of the tax authorities and lead to requests for clarification or even an audit.
Your certified platform does not automatically determine your VAT status. The tax authorities therefore explicitly ask companies leaving the simplified regime to communicate their new status to their platform, so that it can apply the correct data transmission frequency.
This configuration must be verified as soon as the switch occurs, to avoid any errors in the transmission schedule.
The reform does not change the applicable penalties, but it increases the opportunities to incur them. Companies will now have to file four to twelve VAT returns per year, compared to just one under the simplified regime, to which up to forty-eight annual transmissions of transaction and payment data may be added.
The increase in deadlines thus raises the risk of oversight, delay, or error, even when obligations are automated.
Table 3: Breaches, regulations, and penalties
| Breach | Legal basis | Penalty |
|---|---|---|
| Late filing of the CA3 return (deadline between the 15th and the 24th of the following month) | FTC, Art. 287; Annex IV, Art. 39 | Late-payment interest of 0.20% a month (Art. 1727) and a 10% surcharge, rising to 40% if not filed within 30 days of a formal notice (Art. 1728) |
| Late payment of VAT, the CA3 return having been filed on time | FTC, Art. 287 | 5% surcharge (Art. 1731) and late-payment interest |
| Staying on quarterly filing after exceeding €1,100,000 | FTC, Art. 287(3) | The same penalties for each monthly return not filed |
| Late or missing transmission of transaction and payment data | FTC, Art. 290 and 290 A; Annex IV, Art. 41 septies M | €500 per missing filing, capped at €15,000 a year per obligation; a first breach remedied is not penalised (Art. 1788 D) |
In 2027, the primary risk will be a scheduling error. CA3 returns must be filed between the 15th and 24th of the month following the period in question, with the specific deadline depending on factors such as the company's legal structure and the location of its registered office. The exact date can be found in your professional account on impots.gouv.fr.
Late filing exposes the company to a 10% surcharge and, where applicable, late payment interest. Errors regarding declared amounts can be corrected according to standard procedures within the usual statute of limitations and claim periods.
Failing to notice that the €1,100,000 threshold has been exceeded can lead to several missed monthly returns, which will then need to be regularized.
The risk is particularly high for companies that make significant purchases subject to the reverse charge mechanism. These transactions are included in the calculation of the adjusted turnover and can trigger a change in filing frequency, even when the company's sales remain below the threshold.
Monthly monitoring of the adjusted turnover allows you to anticipate this shift and avoid late regularization.
Opting for monthly filing commits the company for at least four quarters. It accelerates VAT cash outflows and triples the frequency of transaction data submissions.
For a company that is not structurally in a VAT credit position, the additional constraints may outweigh the benefits. Before opting in, it is essential to assess the impact on cash flow and reporting obligations.
Only if you are liable for VAT. If you benefit from the VAT exemption threshold, you do not file periodic VAT returns, and the reform does not apply to you.
However, if you have exceeded the exemption thresholds and are currently under the simplified regime, you will transition to the standard real regime. In the vast majority of cases, you will file your VAT returns quarterly (CGI, art. 287, 3).
No, the transition to the standard real regime is automatic. The tax authorities will determine your new filing frequency based on the turnover reported in your last annual VAT return (impots.gouv.fr news update from September 22, 2026).
However, you will need to take action if you wish to opt for monthly filing while currently on a quarterly schedule, or conversely, if you wish to switch to quarterly filing while already on the standard monthly regime.
October 1, 2027. You will remain under the simplified regime until the end of the financial year that includes December 31, 2026 (Finance Act for 2025, art. 38, VI).
You will therefore still need to pay the July 2027 installment if the VAT due for the previous financial year exceeds €1,000.
Your final annual CA12E return must be filed within three months of the closing date, i.e., no later than December 31, 2027. Your first CA3 return will cover October or the fourth quarter of 2027, depending on your new filing frequency.
Yes, provided your VAT credit reaches €150. You can request a refund directly on your final annual CA12 return (CGI, Annex II, art. 242-0 A).
We recommend that you submit this request without waiting for the transition to the standard regime, to avoid having an outstanding VAT credit at the time of the switch.
Nothing. The simplified agricultural regime remains in place. Provided for in Article 298 bis of the CGI, it is not affected by the reform.
You will therefore continue to file an annual VAT return and pay quarterly installments when the VAT due for the previous year exceeds €1,000 (impots.gouv.fr news update of September 22, 2026).
For e-reporting, from September 1, 2027, you will transmit your transaction data monthly, between the 25th and the end of the following month (BOI-TVA-DECLA-20-30-50-30).
From the Finance Act for 2025. Article 38 of Law No. 2025-127 of February 14, 2025, amended Article 287 of the CGI and set the effective date of the reform for January 1, 2027.
This is also the text referenced by the tax authorities in their news update of September 22, 2026.
Between the 15th and the 24th of the month following the end of the quarterdepending on your company's legal structure and the location of its registered office (CGI, Annex IV, art. 39). Your exact deadline can be found in your professional account on impots.gouv.fr.
Therefore, your CA3 for the first quarter of 2027 must be filed in April 2027, before the filing deadline for your final annual CA12 return for 2026.
Late filing may result in a 10% surcharge on the duties owed, increased to 40% if the return is not filed within 30 days of a formal notice (CGI, art. 1728).
Late payment interest of 0.20% per month may also apply to sums paid late (CGI, art. 1727).
If the return is filed on time but the VAT is paid late, a 5% surcharge generally applies (CGI, art. 1731).
No. The reform concerns VAT exclusively. The simplified tax regime for industrial and commercial profits (BIC) remains in place, with its own conditions and thresholds.
The Government expressly confirmed this distinction during the presentation of the reform (amendment no. I-3668 to the 2025 Finance Bill).
The abolition of the simplified VAT regime is primarily a reform of the reporting and payment schedule, rather than the amount of tax itself. While it requires adopting new habits, it also opens up favorable prospects: a transition without retroactive adjustments for the entire year, potentially faster VAT credit refunds, and, for some companies, the possibility of switching from monthly to quarterly reporting.
The key is therefore to anticipate the reform rather than be caught off guard by it. Starting this autumn, reviewing your situation with your accountant and your approved platform will allow you to identify the most suitable filing frequency, assess its impact on your cash flow, and prepare for your new reporting obligations.
To review your situation and the opportunities offered by the reform, book an appointment with our firm.
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