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On 1 January 2027, the French Tax Code articles cited on your invoices are repealed and replaced by those of Book II of the Code of Taxes on Goods and Services. The old references remain accepted until 30 June 2028.
Our recommendation is not to replace the French Tax Code with the CIBS, but with the VAT Directive. The texts expressly allow it, including for the small-business exemption, and that reference will not move. The CIBS, by contrast, has already been renumbered before even taking effect.
Ordinance No. 2025-1247 of December 17, 2025, issued pursuant to Article 111(VII) of the 2024 Finance Act, transfers all legislative provisions relating to VAT from the General Tax Code to Book II of the Code of Taxes on Goods and Services.
Approximately 230 articles from the General Tax Code have been transformed into nearly 1,000 short, thematically organized articles.
The effective date was set for September 1, 2026, with a grace period allowing for continued reference to the old General Tax Code citations until December 31, 2027. The administration submitted its revised commentary for public consultation from February 18 to April 15, 2026 (BOI-RES-TVA-000253).
Ordinance No. 2026-671 of July 27, 2026, changed both dates: Article 17 postpones the transition to January 1, 2027, and extends the grace period until June 30, 2028.
The report to the President of the Republic acknowledges the reason: the coincidence of the initial date with the mandatory transition to electronic invoicing was seen as a source of confusion, and operators requested more time.
The second effect of this ordinance has received much less attention, yet it is the basis for our recommendation. It did not merely shift the schedule; it restructured Book II. Title II, which previously housed cross-cutting special regimes, has become the title dedicated to the right to deduct, while the special regimes have been moved to Title III.
Articles L. 22x-xx from the December 2025 version are now read as L. 23x-xx. The base exemption is the most visible example: the provision published under number L. 223-3 became L. 233-3 without ever having been applied for a single day.
The official concordance table published by Légifrance remains dated December 20, 2025, even though the new ordinance provides a transfer table for articles between the old and new Code of Taxes on Goods and Services.
In other words, a recodified text was renumbered before it even entered into force, and the official correspondence tool still reflects the abandoned numbering.
Commentaries published over the past year give the impression that every mention of VAT needs to be updated. This is inaccurate, and the reason lies in a previous reform.
Since 2024,Article 242 nonies A of Annex II to the General Tax Code no longer requires citing an article for self-assessment or margin schemes; it mandates standardized wording. Paragraph 13 requires the mention "Self-assessment," paragraph 14 "Self-billing," paragraph 15 "Special scheme - Travel agencies," and paragraph 16 "Special scheme - Second-hand goods," "Special scheme - Works of art," or "Special scheme - Collectors' items and antiques." None of these mentions contain a textual reference. All of them pass through the recodification without a single change.
Only two categories are affected. The first is exemptions, referred to in paragraph 12 of the same article. The second is the base exemption, governed by paragraph II of theArticle 293 E of the French General Tax Code (CGI). That’s it. In a standard billing configuration, this amounts to four to eight lines, not thirty.
An important detail: Article 242 nonies A is located in Annex II of the CGI, and regulatory annexes are not being recodified at this stage. The article listing mandatory invoice details therefore remains in the CGI, while the articles it refers to are moving to the CIBS.
Paragraph 12 of Article 242 nonies A offers three options: in the event of an exemption, the invoice must include a reference to the relevant provision of the General Tax Code, or to the corresponding provision of Directive 2006/112/EC, or any other mention indicating that the transaction is exempt.
The second option has been authorized from the start and remains unaffected by the recodification.
The most useful point concerns the most common mention of all.
Section II of Article 293 E stipulates that the invoice must state "VAT not applicable, Article 293 B of the CGI" or "VAT not applicable, Article 293 B bis of the CGI," or a reference to Article 284 of Directive 2006/112/EC.
The BOFiP (Official Bulletin of Public Finances) repeats these three options identically (BOI-TVA-DECLA-40-10-20).
A micro-entrepreneur, a lawyer, or a franchise consultant can therefore, starting today, use a mention that will remain accurate in 2027, 2028, and beyond, without ever having to choose between L. 223-3 and L. 233-3.
Note : Taken literally, after January 1, 2027, there will no longer be a "relevant provision of the General Tax Code" for a VAT exemption: it will be in the CIBS. The grace period until June 30, 2028, and the rule that references to repealed texts are understood to refer to the corresponding new provisions resolve the issue in practice. The fact remains that the only option under paragraph 12 whose wording remains accurate from start to finish, both before and after 2028, is the one referencing the directive.
All the reference materials for this article are gathered in the block below. The search field filters both tables simultaneously: enter a CGI article number, a VATEX code, or a keyword related to the transaction.
The first table lists the statements most commonly found in invoice templates.
The right-hand column provides the European statement written exactly as it should appear on the invoice : the reason in plain text, followed by the article of Directive 2006/112/EC, cited in full for each line.
Below that, where applicable, is the code to be entered in the structured field of the electronic invoice.
The second table addresses a much less discussed issue. As of September 1, 2026, the receipt of electronic invoices is mandatory for all taxable businesses, and large companies as well as mid-sized enterprises issue them via a platform. The exemption reason is no longer just a footer note on an invoice: it is structured data, carried by fields BT-120 and BT-121 of the EN 16931 standard, and the code must be selected from the VATEX list managed by the European Commission.
However, this list includes, alongside the VATEX-EU codes that refer to a directive article, twenty-six codes specific to France, twenty-four of which cite a CGI article. These articles will be repealed on January 1, 2027, while the codes themselves will remain in software and platform databases until the list is revised. Developments in AFNOR standards and guidance from the tax authorities must therefore be monitored.
There are three ways to interpret the first table.
For lines 3 to 5 and 11 to 12, the standardized wording is sufficient on its own, and the reference to the directive is redundant.
Lines 1, 2, and 6 to 9 are the ones that must actually be used.
Line 10 is where the French text itself already provides the European equivalent.
For the second table, the practical implication is clear. For transactions that have a European code, you should prefer this code over the French one: it refers to the directive and will remain valid after the recodification.
For others, the French code remains the only option available in the structured field, but there is nothing to stop you from adding the directive reference to the BT-120 text field now: the data will remain readable even after the CGI article it cites has been removed. The code will likely be updated by then.
Two rows in the second table deserve special attention because French law has no direct European basis for them: Article 261 A, for which no provision of the directive exactly matches its purpose, and Article 261(2)(3°), for which the exemption is not based on any specific article. These are the cases where the reference must remain national and will therefore need to be reconfigured on January 1, 2027.
Readability: A French client, their accountant, and, when the time comes, their auditor will read the CGI more readily than the directive.
An invoice bearing "Exemption — Article 138 of Directive 2006/112/EC" will sometimes be returned by an accounting department expecting "Art. 262 ter, I".
The answer is not to give in, but to supplement the reference: point 12 allows for "any other reference indicating that the transaction is exempt," so nothing prevents you from using "VAT exemption, intra-EU supply — Article 138 of Directive 2006/112/EC." The clear wording solves the readability issue, while the reference solves the legal one.
The directive is not immutable: It is amended regularly, and the ViDA package is the latest example. However, EU legislation is amended while keeping the same numbering: its articles are not renumbered in bulk. Articles 132, 135, 136, 138, 146, 284, 306, and 313 have contained the same rules since 2006.
Book II of the CIBS, on the other hand, changed its numbering in seven months.
An accurate reference does not constitute proof of substance: Citing Article 138 does not exempt you from holding proof of shipment, filing the recapitulative statement, or verifying the client's identification number.
The reference is a formal requirement; the exemption itself is earned elsewhere.
And the CIBS path remains open: Nothing forces you to use the directive: citing L. 233-3 starting January 1, 2027, is perfectly valid. Our reservation is one of method, not principle.
We do not recommend entering a reference into your settings that is taken from a concordance table not updated since the July 2026 renumbering, without first verifying it against the text currently in force.
The most exposed sectors are those whose invoicing relies on an exemption cited on every line:
At the other end of the spectrum, micro-entrepreneurs and liberal professionals under the franchise scheme only have one line to manage, but it is the one that appears on all their invoices.
Large companies and mid-sized enterprises face an additional constraint: as of September 1, 2026, their disclosures no longer live solely in a document template but within platform settings, where a correction is deployed less quickly than a change to a Word template.
No. Until December 31, 2026, the General Tax Code (CGI) remains the governing body for VAT rules, and the reference to it is the correct one. The transition takes place on January 1, 2027, and old references will remain accepted until June 30, 2028.
This is a matter of planning, not urgency.
By using the full formula each time: the reason, followed by the article, then the full title of the text. For example, "Exemption — Article 138 of Directive 2006/112/EC." Abbreviations such as "art. 138 VAT dir." should be avoided: the reference must unambiguously designate the relevant provision, including for a foreign reader.
Article L. 233-3 of the CIBS, following the renumbering carried out by the ordinance of July 27, 2026. One still encounters L. 223-3, which corresponds to the December 2025 version that never entered into force, and sometimes L. 233-1. This hesitation is an argument in itself: Section II of Article 293 E allows for citing Article 284 of the Directive, which settles the matter.
Yes. No text mandates a single reference, and point 12 of Article 242 nonies A allows for any mention indicating the exemption. However, a double citation should be monitored: a reference that has become incorrect is subject to penalties even if the other one is accurate.
No. These have been standardized labels since 2024, without textual reference. The recodification has no effect on them, and adding the directive article remains optional.
The fine under II of Article 1737 of the CGI: €15 per omission or inaccuracy, capped at one-quarter of the invoice amount. The unit amount is modest, but it multiplies by the number of invoices and mentions, making it a volume risk for automated invoicing systems.
It is conducted on a "constant law" basis, and for the most part, it remains unchanged.
However, the report to the President of the Republic accompanying the ordinance of December 17, 2025, notes some adjustments: codification of case law solutions, reclassifications between law and decree, and changes in terminology, where "intracommunity" becomes "intra-European" and travel agencies become travel operators.
Article L. 211-36, dedicated to leasing and lease-to-own agreements, is the clearest illustration of this: it incorporates into the law a jurisprudential criterion that administrative doctrine had never adopted. We analyze this in an op-ed published by Daf Magazine.
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