France maintains one of the more structured commercial registration systems in continental Europe. The Registre du commerce et des sociétés (RCS) holds the foundational record for every registered legal entity. Control — who holds shares, who directs the company, and what constraints bind them — is the primary question this record addresses.
The record is not complete. The ceiling of what the sources allow is stated before payment, not after.
What the RCS showsLegal form, registered capital, directors, statutory managers, and filed documents including statutes and amendments. Source: Registre du commerce et des sociétés · verified 2026-09-01 Shareholder disclosureFor SA and SAS, named shareholders with share counts appear in filed documents when a statutory threshold is crossed or when statutes require disclosure. For SARL, the list of associés with quotas is filed and accessible. Source: Registre du commerce et des sociétés · verified 2026-09-01 Beneficial ownershipFrance maintains a Registre des bénéficiaires effectifs (RBE). Access for third parties is restricted following CJEU C-37/20; access conditions are subject to change and must be verified at the time of each request. Source: Institut national de la propriété industrielle / Infogreffe · verified 2026-09-01 Financial statementsSAs and larger SARLs are required to file annual accounts. Small companies may invoke confidentiality provisions under French commercial law; filed accounts may be absent or redacted for qualifying entities. Source: Registre du commerce et des sociétés · verified 2026-09-01 Insolvency proceedingsCollective proceedings (sauvegarde, redressement judiciaire, liquidation judiciaire) are recorded in the Bulletin officiel des annonces civiles et commerciales (BODACC). A negative result does not confirm the absence of a filed petition not yet published. Source: BODACC · verified 2026-09-01The RCS entry names the legal representatives — gérant, président, directeur général — and records their appointment dates and any limitations on their authority filed with the registry. For multi-layer structures, the named director may itself be a legal entity. In that case, the permanent representative of the legal-entity director is named in the filing.
Share capital and its division appear in the statutes and in subsequent amendments. For a SARL, the list of associés with their quota holdings is a filed document. For an SAS, the statutes govern the transfer conditions and governance rules; these are filed but may be drafted to restrict information available to third parties.
Pledges over shares (nantissement de parts sociales) are registered separately and appear in the RCS record when properly filed. An unpledged share transfer that has not yet been reflected in a filed amendment will not appear in the current record.
The RCS record reflects the state of filings, not the state of the company. A transfer executed but not yet registered creates a gap between legal reality and the public record.
Every appointment and every cessation of function must be filed with the greffe du tribunal de commerce. The RCS therefore provides a chronological record of who held authority and when. This includes:
The record does not show informal authority, side agreements on voting, or shareholders' agreements (pactes d'actionnaires) that have not been filed. Pactes d'actionnaires are private contracts in France; they bind the parties but are not publicly registered.
France created the Registre des bénéficiaires effectifs in 2017, implementing the EU Anti-Money Laundering Directives. The RBE is held at the greffe and contains the identity and ownership percentage of each beneficial owner holding more than 25% of capital or voting rights, or exercising control by other means.
Following the CJEU judgment in Joined Cases C-37/20 and C-601/21 (November 2022), public access to UBO registers across EU member states was suspended or restricted. France restricted third-party access to the RBE. Access is now limited to competent authorities, obliged entities under AML law, and persons demonstrating a legitimate interest.
The conditions for demonstrating legitimate interest, and the practical procedure for obtaining access, must be verified at the time of each request. The position is not static.
What this means for a counterparty review: the RBE layer may be accessible, may require a formal application, or may require judicial authorisation depending on the circumstances. The RCS layer — directors, capital, filed statutes — remains accessible without restriction.
French commercial law requires SAs, SASs above certain thresholds, and SARLs above certain thresholds to file annual accounts with the greffe. Filed accounts are accessible through Infogreffe and through the official data portal.
Two limitations apply.
First, small companies (petites entreprises) may file a confidentiality declaration under Article L. 232-25 of the Code de commerce. When this declaration is filed, the income statement is withheld from public access. The balance sheet remains accessible. Micro-enterprises may withhold both the income statement and the balance sheet from public access, retaining only the filing confirmation.
Second, filing compliance is imperfect. A company may be in arrears on its filing obligation. The absence of recent accounts in the registry does not confirm that accounts were not prepared; it confirms only that they were not filed or not yet processed.
The depth of financial information available therefore depends on the legal form, the size of the entity, and whether a confidentiality declaration has been filed. This is established before the report is delivered.
The Bulletin officiel des annonces civiles et commerciales publishes notices of collective proceedings, including the opening of sauvegarde, redressement judiciaire, and liquidation judiciaire. It also publishes notices of dissolution, merger, and certain other corporate events.
BODACC is searchable by company name and SIREN number. A search returns published notices; it does not return proceedings that have been filed but not yet published. The gap between filing and publication varies.
For a counterparty review, a BODACC search establishes the published insolvency record. It does not establish the absence of a pending petition.
Every French legal entity receives a SIREN number (9 digits) from INSEE at registration. Each establishment receives a SIRET number (14 digits). The NAF/APE code assigned by INSEE indicates the principal activity.
The SIREN is the key that links records across systems: RCS, BODACC, tax filings, and social security declarations. A counterparty review that does not begin with a verified SIREN risks conflating entities with similar names.
The INSEE SIRENE database is publicly accessible. It records the entity's status (active or ceased), its registered address, its legal form code, and its NAF code. It does not record ownership or financial information.
Three situations produce divergence between sources.
RCS versus SIRENE on address. The RCS registered address and the SIRENE address are updated independently. A company that has moved may show different addresses in the two systems during the period between filings.
RCS versus BODACC on corporate events. A merger or dissolution published in BODACC may not yet be reflected in the RCS entry if the greffe has not processed the update. The BODACC notice takes precedence as the publication of record.
Filed accounts versus current financial position. Filed accounts reflect a past period. For a company that has filed a confidentiality declaration, the most recent accessible balance sheet may be two or more years old. The gap between the filed record and the current position is not bridged by any public source.
The RCS, RBE, BODACC, and SIRENE together cover the formal corporate record. The following cannot be established from these sources:
The report states, at the point where the chain stops, which source was consulted, what it returned, and why the chain does not continue. A gap in the record is reported as a gap, not as a negative finding.
| Tier | Price | What is included | What is NOT included |
|---|---|---|---|
| Signal | €890 | RCS extract: legal form, capital, current directors, statutory managers, appointment dates. SIREN verification. BODACC search: published insolvency and dissolution notices. Summary of filed statutes. | RBE beneficial ownership layer. Financial statements. Former directors. Share pledge register. |
| Standard | €1,900 | All Signal content. Full document history from RCS: statutes, amendments, all filed documents. Filed financial accounts where accessible (subject to confidentiality declarations). Former directors and cessation dates. Share pledge (nantissement) search. | RBE beneficial ownership where access is restricted. Shareholders' agreements (private contracts, not filed). Current financial position beyond filed accounts. |
| Extended | €4,200 | All Standard content. RBE beneficial ownership layer: formal application with stated legitimate interest, including procedure and outcome. Multi-layer structure mapping where intermediate entities are identifiable from filed documents. Cross-reference of RCS, BODACC, SIRENE, and filed accounts for divergences. Written analysis of gaps and what each gap means for the record. | Shareholders' agreements and private arrangements. Pending insolvency petitions not yet published. Intra-group financial flows not reflected in filed accounts. |
What is the SIREN number and why does it matter for a counterparty review? The SIREN is the nine-digit national identifier assigned by INSEE to every French legal entity. It is the key that links the RCS entry, BODACC notices, filed accounts, and tax records. A review that begins without a verified SIREN risks conflating entities with similar names or missing a company that has changed its commercial name while retaining its SIREN.
Can the beneficial owner of a French company be identified from public sources? France maintains the Registre des bénéficiaires effectifs, which records beneficial owners holding more than 25% of capital or voting rights. Following the CJEU judgment of November 2022, third-party access is restricted. Access requires a formal application demonstrating legitimate interest. The outcome of that application cannot be guaranteed in advance. The Extended tier includes the application and its outcome.
What does it mean when a French company has not filed recent accounts? It may mean the company has filed a confidentiality declaration under Article L. 232-25 of the Code de commerce, which withholds the income statement or both statements from public access. It may also mean the company is in arrears on its filing obligation. The report distinguishes between these two situations where the record permits.
Does a BODACC search confirm that a company is not in insolvency? A BODACC search returns published notices. It does not return proceedings filed but not yet published. A negative BODACC result means no published insolvency notice was found on the date of the search. It does not confirm the absence of a pending petition.
What is the difference between a gérant and a président in a French company? A gérant is the statutory manager of a SARL or SNC. A président is the legal representative of an SAS or SA. Both are named in the RCS and both have authority to bind the company within the limits set by the statutes and the law. The RCS record shows the scope of their authority as filed; it does not show informal arrangements that restrict or extend that authority beyond what is filed.
How long does the report take? Signal: five to seven business days. Standard: ten to fourteen business days. Extended: fifteen to twenty business days, subject to the processing time of the RBE access application.
Sources: - Registre du commerce et des sociétés — https://www.infogreffe.fr — verified 2026-09-01 - Registre des bénéficiaires effectifs — held at the greffe du tribunal de commerce — verified 2026-09-01 - Bulletin officiel des annonces civiles et commerciales (BODACC) — https://www.bodacc.fr — verified 2026-09-01 - INSEE SIRENE — https://www.sirene.fr — verified 2026-09-01
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 Firm assumes no liability for actions taken or not taken based on this material. For advice regarding your particular situation, please contact info@vlolawfirm.com.
Author: Elena Moretti — Partner, Continental Europe, VLO Law Firm