French VAT Recodification: Transfer to the CIBS Postponed until 1 January 2027

By Ordinance No. 2026-671 of 27 July 2026, published in the Official Journal on 28 July 2026, the French Government has postponed until 1 January 2027 the entry into force of the transfer of French VAT provisions to the French Tax Code for Goods and Services (Code des impositions sur les biens et services – CIBS).

This long-awaited decision gives businesses, software providers and tax advisers an additional four months to update their documentation, contracts, internal procedures and IT systems to reflect the new statutory references.

Despite its title, the Ordinance introduces virtually no substantive changes to French VAT law. Its primary purpose is to revise the implementation timetable for the recodification while making a number of technical adjustments intended to improve the legal consistency of the future Code.

A Reform Announced at the Council of Ministers on 27 July 2026

The Ordinance was presented at the French Council of Ministers on 27 July 2026.

According to the report submitted to the President of the Republic, the postponement is mainly justified by:

• comments received during the public consultation on the draft recodification;
• the need to allow businesses more time to become familiar with the new CIBS references;
• the intention to avoid introducing two major regulatory changes on 1 September 2026, the date chosen for the rollout of mandatory electronic invoicing in France.

The objective is therefore purely organisational: to facilitate the transition without altering the applicable VAT rules.

What is the CIBS?

Created by Ordinance No. 2021-1843 of 22 December 2021, the Code des impositions sur les biens et services (CIBS) is intended to progressively consolidate all French indirect taxes within a single legislative code.

It already incorporates excise duties, several sector-specific taxes and various indirect taxes that were previously scattered across the French General Tax Code (Code général des impôts), the Customs Code and other legislative texts.

Until now, however, French VAT had not yet been incorporated into the CIBS.

This major step was initiated by Ordinance No. 2025-1247 of 17 December 2025, which provides for the transfer, without any change to the substantive law, of all French VAT provisions currently contained in the French General Tax Code.

The future Book II of the CIBS will bring together all substantive VAT rules, including the scope of VAT, place of supply rules, exemptions, taxable amount, VAT rates, input VAT recovery and taxpayers’ obligations.

Tax procedural rules—including tax audits, penalties, limitation periods and document retention requirements—will continue to be governed by the French Tax Procedures Code (Livre des procédures fiscales – LPF).

The purpose of this reform is therefore to modernise and simplify the structure of French tax legislation without changing the VAT rules applicable to businesses.

A New Timetable for the French VAT Recodification

The Ordinance of 27 July 2026 revises the original implementation timetable.

Milestone	Original timetable	New timetable
Entry into force of Book II of the CIBS relating to VAT	1 September 2026	1 January 2027
VAT provisions remain in the French General Tax Code	Until 31 August 2026	Until 31 December 2026
New CIBS statutory references become applicable	1 September 2026	1 January 2027
End of the transitional period allowing the use of former General Tax Code references	31 December 2027	30 June 2028

In practical terms:

• the current provisions of the French General Tax Code will remain the legal basis for French VAT until 31 December 2026;
• the new CIBS references will apply from 1 January 2027;
• existing references to the General Tax Code may continue to be used until 30 June 2028 in contracts, invoices, certificates, internal procedures and document templates without affecting their legal validity.

This transitional period will allow businesses to update their legal documentation and information systems progressively.

Other Changes Introduced by the Ordinance

Beyond postponing the implementation timetable, the Ordinance mainly introduces a number of technical amendments.

The principal changes include:

• reorganising the future Book II of the CIBS by bringing together all provisions relating to input VAT recovery within a dedicated title;
• incorporating measures introduced by the French Finance Act for 2026, including certain reduced VAT rates and various legislative coordination measures;
• correcting a number of drafting errors and cross-references identified during the public consultation;
• updating references to the new French Customs Code;
• refining certain provisions to better reflect existing case law.

The French Government reiterates that this recodification is carried out without altering the substantive law. Beyond simply postponing the implementation timetable, the Ordinance also strengthens legal certainty by expressly confirming that the French administrative guidance published in the Official Public Finance Bulletin (BOFiP) will remain binding on the tax authorities after the CIBS enters into force.

However, not all VAT-related provisions will be transferred to the CIBS. Tax procedural rules will continue to be governed by the French Tax Procedures Code (Livre des procédures fiscales – LPF), which is itself currently undergoing significant legislative changes.

The New Retention Period for Tax Documents Will Continue to Be Governed by the French Tax Procedures Code

Although the future Book II of the CIBS includes a chapter dealing with VAT audits, collection procedures and tax litigation, it is essentially limited to coordination provisions and cross-references to the French Tax Procedures Code (LPF).

The procedural rules themselves – including document retention periods, tax audit procedures, limitation periods and penalties – will continue to be governed by the LPF.

This is notably the case for the new general retention period for tax records, introduced by Article 36 of Law No. 2026-534 of 25 June 2026 on combating social security and tax fraud, which amends Article L.102 B of the French Tax Procedures Code.

From 1 January 2027, the statutory retention period will increase from 6 years to 10 years for the principal records that may be requested by the French tax authorities during a tax audit, including:

• sales and purchase invoices (including electronic invoices);
• accounting books and statutory records;
• tax returns and supporting documentation;
• evidence supporting input VAT recovery;
• documentation forming part of the reliable audit trail (piste d’audit fiable).

The legislation provides that the new retention period will apply to documents whose existing six-year retention period expires after 1 January 2027.

In practice, this should cover documents whose statutory retention period has not yet expired on that date, although further clarification from the French tax authorities is still expected.

The requirements governing the storage of electronic invoices—including authenticity, integrity, legibility and availability—will continue to be governed by Articles L.102 B and L.102 B bis of the French Tax Procedures Code.

What Does This Mean for Businesses?

For most businesses, the Ordinance of 27 July 2026 should primarily be viewed as a measure aimed at facilitating compliance.

It provides several additional months to:

• update contracts, invoice templates and terms and conditions;
• adapt ERP systems and accounting software to the new CIBS references;
• review internal procedures and tax documentation;
• train finance, tax and legal teams.

The Ordinance does not introduce any changes to VAT rates, input VAT recovery rules or VAT reporting obligations. Its principal effect is therefore the postponement of the VAT recodification timetable, giving businesses additional time to prepare for this legislative transition under optimal conditions.

How BtoBnice Can Help

BtoBnice supports both French and international businesses with:

• securing input VAT recovery, helping to minimise the risk of adjustments during a tax audit;
• implementing and documenting a reliable audit trail in accordance with French VAT requirements;
• reviewing international business flows to ensure the correct VAT treatment of cross-border transactions;
• identifying and meeting international indirect tax compliance obligations, including VAT registrations, VAT reporting requirements and documentary compliance;
• delivering tailored VAT training programmes for finance and accounting teams.

By combining legal expertise, operational tax audits and practical support for finance departments, BtoBnice helps businesses anticipate regulatory changes, strengthen their VAT compliance and reduce indirect tax risks over the long term.