VAT recodification CGI to CIBS: impact on certified cash register software
France is recodifying its VAT rules from the CGI into the CIBS. The transfer takes effect on 1 January 2027. It is a recodification "à droit constant", meaning the substance of the rules does not change, only where they live in the legal code. For fiscalization obligations there is nothing to do. The only point to note is the new legal reference: cash register software editors should now pinpoint the new article in their own documents and in those shared with their customers. References to the old CGI articles stay valid in parallel until 30 June 2028, so there is no urgency.
What is happening
Ordonnance n° 2025-1247 of 17 December 2025 transfers France's VAT provisions from the Code général des impôts (CGI) into the Code des impositions sur les biens et services (CIBS). A second text, the recent Ordonnance n° 2026-671 of 27 July 2026, set the entry into force at 1 January 2027 (initially planned for 1 September 2026) and integrated the VAT measures adopted since December 2025, including those from the loi de finances 2026.
The move is part of a wider project, running since 2021 and 2022, to gather France's indirect tax rules, previously spread across the CGI, the customs code and others, into a single Code des impositions sur les biens et services. VAT is one of the last major blocks to be transferred, which is why the change is significant on paper even though it leaves the rules themselves untouched.
What the recodification does not change
| Element | Status | | ------------------------------------------------------------------------- | --------- | | The fiscalization obligation | Unchanged | | ISCA requirements (inaltérabilité, sécurisation, conservation, archivage) | Unchanged | | B2B exclusion | Unchanged | | €7,500 sanction per non-compliant software | Unchanged | | fiskaly product and integration | No change |
What actually changes
Only the legal citation. The obligation moves from CGI art. 286, I, 3° bis to CIBS art. L. 216-48 (scope: L. 216-38 and L. 216-39). This is the kind of reference that appears in your contracts, your self-attestation and maybe your commercial documents.
What this means for you in practice
- Nothing changes in your integration or setup: no migration, no new configuration, no re-certification.
- Existing contracts and documents that cite the CGI article stay valid on their own. The CGI to CIBS substitution operates automatically, by law, for existing legislative and regulatory texts, administrative acts, invoices and contracts. There is nothing to reissue.
- When you next update or issue contracts, your attestation individuelle de l'éditeur or other commercial documents, you can use the CIBS reference. You have until 30 June 2028 to make the switch, and the CGI reference is admitted in the meantime.
Not to be confused with e-invoicing
This recodification concerns the anti-fraud obligation for certified cash and POS software. It is separate from the e-invoicing generalisation. The two run on comparable timelines, and the VAT transfer was in fact postponed to 1 January 2027 precisely to avoid clashing with the e-invoicing rollout of 1 September 2026.
fiskaly is tracking the recodification and will reflect the updated references in its documentation. If the scope or the applicable dates change again, we will let you know.
Questions? Contact us to talk to our team.
