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Counterparty Checks

Counterparty in France: what can be established

French corporate records are public, machine-readable and free. The Registre national des entreprises (RNE), maintained by INPI, holds the authoritative record of every registered entity. Control structure, filed accounts and insolvency publications are all reachable without registration or payment. What the sources do not show is stated below before any price is mentioned.

Control — who holds shares, who signs, who can bind the entity — is the first question in any cross-border transaction. In France, that question has a documented answer at the registry level. The answer has a ceiling, and the ceiling is fixed by statute.

What the register showsLegal representatives, registered address, share capital, corporate purpose, date of incorporation, SIREN identifier. Source: RNE/INPI · extracted 2026-03-10 Filed financial statementsComptes annuels deposited with the greffe, accessible via INPI API — except where confidentiality has been claimed by eligible SMEs. Source: INPI · extracted 2026-03-10 Insolvency publicationsBODACC publishes sauvegarde, redressement and liquidation notices from 2008 onward, searchable by SIREN, with Open Data API and alert subscription. Source: bodacc.fr · extracted 2026-03-10 Cost of accessFree of charge across all four source layers: RNE, BODACC, INPI financials, official gazette publications. What the register does not showHome addresses of directors are restricted under Décret 2025-840. Ultimate beneficial owners are not publicly accessible following CJEU C-37/20.

This register is public and free of charge. What the report provides is the removed path: correct SIREN identification, cross-source reconciliation, language, structured output and the explicit statement of where the record stops.

Corporate control: what the RNE records

The RNE entry for any French entity names the legal representatives — gérant, président, directeur général — with their capacity and date of appointment. For a société à responsabilité limitée (SARL), the associés and their percentage holdings appear in the statuts deposited at incorporation and updated on each capital change.

For a société par actions simplifiée (SAS), the position is different. The statuts define the governance structure, but shareholder identity below the threshold requiring disclosure is not systematically published. The register records the president and, where appointed, the directeur général. Minority shareholders in a SAS are not individually named in the public record unless they hold a statutory office.

Share capital is stated as a single figure. The breakdown by shareholder requires the statuts or a Kbis extract with annexes. Both are available through the greffe or INPI. The Kbis is the standard extract; it names the legal representatives and states the capital, but does not itemise individual shareholdings in the body of the document.

The BODACC gazette records every RCS filing that triggers a publication obligation: incorporation, change of legal representative, change of registered address, dissolution, merger. The publication date and the content of the filing are both searchable by SIREN.

Filed financial statements: depth and gaps

French law requires most commercial entities to deposit annual accounts with the greffe. INPI makes these available through its open data API. The accounts include the bilan, the compte de résultat and, for larger entities, the annexe.

Two categories of entity are exempt from full public disclosure. Micro-enterprises may deposit a simplified set of accounts. Small and medium enterprises meeting the statutory criteria may request confidentiality for the bilan and the compte de résultat, leaving only the annexe in the public record. The confidentiality request is itself recorded; its existence is visible even when the accounts are not.

The practical consequence: for a counterparty that has exercised the confidentiality option, the filed record shows that accounts were deposited and that confidentiality was claimed. The financial content is not accessible from the public source. The report states this explicitly rather than treating absence of data as absence of filing.

Accounts are deposited within seven months of the financial year end. A gap between the expected deposit date and the actual date is itself a data point. BODACC records the deposit publication.

Insolvency and enforcement: BODACC as the primary source

BODACC is the official gazette for commercial and civil publications. For insolvency purposes, it records the opening of sauvegarde, redressement judiciaire and liquidation judiciaire proceedings, as well as the appointment of mandataires and the outcome of proceedings.

Search is by SIREN. Results are available as PDF and through the Open Data API. Alert subscriptions allow monitoring of a specific SIREN for new publications. Publications are available from 2008.

A negative result — no insolvency publication found — does not confirm the absence of a filed petition. The publication follows the court order, not the filing. A petition filed and not yet adjudicated does not appear in BODACC. The report states the search date and the result as of that date.

Enforcement actions against the entity or its directors that do not trigger a BODACC publication are not visible in this source layer. Tribunal de commerce judgments are not systematically published in a searchable public database at the individual case level.

The limit of what the sources allow

The French public record is among the most structured in the EU. Four source layers — RNE, BODACC, INPI financials, official gazette — are free, machine-readable and current. The ceiling is nonetheless real.

Beneficial ownership. The registre des bénéficiaires effectifs (RBE) was opened to public access and subsequently restricted following the CJEU judgment in C-37/20 (November 2022). Public access to the RBE is no longer available as a matter of general right. The record exists; access requires a demonstrated legitimate interest assessed by the greffe. The report identifies the chain of legal ownership to the level the public record shows and names the point at which it stops.

Director home addresses. Décret 2025-840 restricts the publication of home addresses of natural persons acting as legal representatives. The registered address of the entity remains public. The personal address of the gérant or président is not in the public extract.

SAS shareholder identity. Below the threshold requiring statutory disclosure, individual shareholders of a SAS are not named in the public record. The statuts may be on file but are not always indexed in a searchable form.

Insolvency timing. A petition filed but not yet adjudicated does not appear in BODACC. The gap between filing and publication varies by court and by the complexity of the matter.

Tribunal judgments. Individual commercial court judgments are not systematically available in a public searchable database. BODACC records the insolvency publication, not the underlying judgment text.

These limits are stated in the report. The report does not fill them with inference.

Where the sources disagree

The RNE and BODACC draw from the same underlying greffe filings but are updated on different cycles. A change of legal representative filed with the greffe appears in the RNE before it generates a BODACC publication. During that interval, the two sources show different names for the same office.

Filed accounts at INPI and the entity's own published accounts (where a group publishes consolidated statements) may differ in scope and in the treatment of subsidiaries. The report records both and notes the discrepancy.

Where the SIREN search returns multiple entities with similar names — a common situation for French groups with regional subsidiaries — the report identifies each entity separately and does not aggregate their records.

Scope and fixed price

Signal
€890
RNE extract: legal representatives, capital, corporate purpose, SIREN, registered address; BODACC insolvency search (2008–present); confirmation of account deposit status
Financial statement content; shareholder breakdown; RBE access; discrepancy analysis across sources
Standard
€1,900
All Signal content; filed financial statements (where publicly accessible); BODACC full publication history; cross-source reconciliation; written summary of discrepancies
RBE beneficial ownership; tribunal judgment texts; monitoring after delivery
Extended
€4,200
All Standard content; structured analysis of control chain to the limit of the public record; explicit statement of each point where the chain stops and why; greffe document retrieval for statuts and annexes; ongoing BODACC alert for 90 days post-delivery
Information beyond the public record; legal advice; qualification of facts established

FAQ

Does the French register show who ultimately controls the company? The RNE names the legal representatives and, for SARLs, the associés with their holdings. For a SAS, shareholders below the statutory disclosure threshold are not individually named. The RBE records beneficial owners, but public access to that register has been restricted since the CJEU C-37/20 judgment. The report traces the chain to the limit of the public record and states where it stops.

Are French financial statements always available? Most commercial entities must deposit annual accounts. SMEs meeting the statutory criteria may claim confidentiality for the bilan and compte de résultat. The confidentiality claim is itself recorded. Where confidentiality has been claimed, the report states that fact rather than treating the gap as an absence of filing.

What does a negative BODACC result mean? It means no insolvency publication was found for that SIREN as of the search date. It does not confirm that no petition has been filed. A petition filed but not yet adjudicated does not generate a BODACC publication. The report states the search date and the scope of the result.

How current is the register? RNE and BODACC are updated on a rolling basis as greffe filings are processed. There is no fixed publication lag stated in the source documentation. The report records the extraction date for each source.

What is the SIREN and why does it matter? The SIREN is the nine-digit national identifier assigned to every French legal entity by INSEE. All four source layers — RNE, BODACC, INPI financials, official gazette — are indexed by SIREN. Correct identification of the SIREN is the prerequisite for a complete search. Entities with similar names may hold different SIRENs; the report identifies each separately.

Sources

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Disclaimer: This report is a factual compilation from official registers and public sources. It is provided for informational purposes only, does not constitute legal advice, and contains no legal qualification of the facts established. VLO Law Firms assumes no liability for actions taken or not taken based on this material. For advice regarding your particular situation, please contact info@vlolawfirm.com.