What the record showsRegistered legal form, directors, statutory seat, and filed constitutional documents. Source: Registre du commerce et des sociétés (RCS) · verified 2026-09-10
Shareholder layerFor SA and SAS, shareholder lists are not filed with the RCS as a matter of routine. Associé names in SARL are disclosed in the statuts deposited at formation and on subsequent amendments. Source: RCS · verified 2026-09-10
Beneficial ownershipFrance maintains a Registre des bénéficiaires effectifs (RBE). Access conditions following CJEU C-37/20 are restricted; access is not open to the general public without a demonstrated legitimate interest. Source: INPI / RBE · verified 2026-09-10
Cost of registry accessThe RCS is accessible via the INPI data platform.
France operates a civil-law corporate system anchored in the Code de commerce. Control questions — who directs the company and what a shareholder can enforce — turn on the legal form chosen and on what the filed record actually contains. The RCS is the primary public register. It records the legal existence of commercial entities, their officers, and their constitutional documents. What it does not record is equally important: the RCS does not systematically capture the full ownership chain above the registered entity, and it does not resolve nominee arrangements.
The angle here is control: who holds decision-making authority, what the shareholder can enforce, and where the documentary chain ends. That question is answered at three levels — the registered layer, the statutory layer, and the beneficial-ownership layer — and each level has a different depth and a different access condition.
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## What the Registre du commerce et des sociétés records
The RCS is maintained by the clerks of the commercial courts (greffes des tribunaux de commerce) and is now centralised through the INPI national platform. Every commercial entity incorporated in France receives a SIREN number (nine digits) and a SIRET number (fourteen digits, adding the establishment code). These identifiers are the entry point for any documentary search.
The RCS records the following for each entity:
- Legal form (SARL, SAS, SA, SNC, and others)
- Registered name and statutory seat
- Date of incorporation and duration
- Identity of legal representatives (gérant, président, directeur général, membres du conseil)
- Registered capital amount
- Filed statuts (articles of association) and subsequent amendments
- Dissolution, liquidation, or strike-off proceedings
The INPI platform provides free access to basic identification data and to filed documents in PDF form. Certified extracts (extrait Kbis) carry an official fee set by the greffes. The Kbis is the standard proof of legal existence requested in commercial transactions.
> Source: **Registre du commerce et des sociétés / INPI** · verified 2026-09-10
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## Shareholder composition: what the record discloses by legal form
The depth of shareholder disclosure depends entirely on the legal form of the entity. This is not a gap in the system; it is a deliberate structural feature of French company law.
| Legal form | Shareholder disclosure in RCS | Basis |
|---|---|---|
| SARL | Associés named in statuts filed at formation and on each amendment | Code de commerce art. L. 223-1 et seq. |
| SAS | No routine shareholder list filed; statuts may or may not name shareholders | Code de commerce art. L. 227-1 et seq. |
| SA (listed) | AMF disclosures apply above statutory thresholds | Code monétaire et financier |
| SA (unlisted) | Shareholder register held by the company; not filed with RCS | Code de commerce art. L. 228-1 |
| SNC | Associés named in statuts | Code de commerce art. L. 221-1 et seq. |
For a SARL, the statuts on file at the greffe will name the associés and their respective parts sociales at the time of the last filed amendment. If the company has not filed an amendment following a share transfer, the RCS record will not reflect the current ownership. The gap between the filed record and the actual ownership position is a known feature of the system, not an anomaly.
For an SAS — the most common form for holding structures and for venture-backed companies — the statuts filed at the RCS may contain no shareholder list at all. The SAS is designed for contractual flexibility; its statuts are often minimal. The shareholder register is a private document held by the company.
> Source: **Registre du commerce et des sociétés / INPI** · verified 2026-09-10
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## Beneficial ownership: the Registre des bénéficiaires effectifs
France transposed the EU Anti-Money Laundering Directives through the creation of the Registre des bénéficiaires effectifs (RBE). Every commercial entity is required to file a declaration identifying the natural persons who ultimately own or control it, applying a threshold of 25 % of capital or voting rights, or effective control by other means.
The RBE is held by the greffes and is accessible through the INPI platform. However, access conditions changed materially following the CJEU judgment of 22 November 2022 (joined cases C-37/20 and C-601/21). The Court held that unrestricted public access to beneficial ownership information is incompatible with the Charter of Fundamental Rights. France, in line with the majority of EU member states, restricted public access. Access without demonstrated legitimate interest is no longer available as a matter of course.
Entities with a legitimate interest — including journalists, civil society organisations, and professionals subject to AML obligations — may apply for access. The procedure and the standard of proof required to establish legitimate interest are defined by national implementing measures. For a foreign buyer conducting pre-acquisition due diligence, the question of whether that purpose qualifies as a legitimate interest under French implementing rules is a legal question, not a registry question.
The practical consequence: the RBE filing exists, but reading it requires satisfying an access condition that a foreign applicant cannot resolve unilaterally.
> Source: **INPI / Registre des bénéficiaires effectifs** · verified 2026-09-10
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## Insolvency and enforcement proceedings
French insolvency proceedings are recorded in two places. The Bodacc (Bulletin officiel des annonces civiles et commerciales) publishes notices of sauvegarde, redressement judiciaire, and liquidation judiciaire. The Registre public des procédures collectives (RPPC) held by the INPI provides a searchable record of collective proceedings.
A negative result in these registers does not certify the absence of a filed petition. The gap between filing and publication is a structural feature of the system. A petition filed but not yet published will not appear in a search conducted on the day of the search.
Enforcement records — saisies, hypothèques judiciaires — are held at the service de la publicité foncière for real property and at the greffe for commercial pledges (nantissements). These are separate searches from the RCS search.
> Source: **Bodacc / INPI / RPPC** · verified 2026-09-10
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## Filed financial statements
French commercial entities are required to file annual accounts with the greffe. The obligation applies to SA, SAS, and SARL above certain size thresholds. Small companies may elect confidentiality for their income statement under conditions set by the Code de commerce. The balance sheet remains accessible even where the income statement is withheld.
Filed accounts are accessible through the INPI platform. The depth of what is available depends on the size category of the entity and on whether a confidentiality election has been made. For a holding company with minimal operational activity, the filed accounts may show little beyond the balance sheet structure.
> Source: **Registre du commerce et des sociétés / INPI** · verified 2026-09-10
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## The limit of what the sources allow
The RCS and the INPI platform together provide a reliable record of legal existence, officer identity, registered capital, and filed constitutional documents. That record has four structural limits that apply regardless of the quality of the search.
**First: the SAS shareholder gap.** For an SAS, the RCS does not contain a shareholder list. The shareholder register is a private document. The record establishes who manages the company; it does not establish who owns it.
**Second: the amendment lag.** For a SARL, the filed statuts reflect ownership at the time of the last filed amendment. A share transfer that has not been followed by a filed amendment will not appear. The record is accurate as of its last update, not as of today.
**Third: the RBE access condition.** The beneficial ownership declaration exists. Reading it requires satisfying a legitimate-interest condition under post-CJEU French implementing rules. A foreign buyer cannot resolve that condition unilaterally. The chain from the registered entity to the natural person behind it may be established only to the level the RCS discloses directly.
**Fourth: the insolvency publication gap.** A petition filed but not yet published in the Bodacc will not appear in a register search. The absence of a record is not a guarantee of the absence of a proceeding.
These are not failures of the search. They are the ceiling of what the sources allow. The report states, at each point, which level has been reached and where the chain stops.
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## Where the sources disagree
Two situations produce a discrepancy between sources that is itself a finding.
The first is a mismatch between the gérant or président named in the RCS and the signatory on filed documents or contracts. This may reflect an undisclosed change of management, a de facto director arrangement, or a filing delay. The discrepancy is recorded; its legal significance is not assessed in this report.
The second is a mismatch between the capital structure shown in the filed statuts and the capital structure implied by the filed accounts. For an SAS with multiple share classes, the statuts may have been amended without a corresponding update to the accounts, or vice versa. The discrepancy is noted and the two sources are presented side by side.
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## Scope and fixed price
| Tier | Price | What is included | Not included |
|---|---|---|---|
| Signal | €440 | RCS extract (Kbis equivalent), legal form, registered officers, statutory seat, SIREN/SIRET, incorporation date, registered capital | Statuts, shareholder layer, RBE, financial statements, insolvency search |
| Standard | €890 | All Signal items plus filed statuts and amendments, shareholder layer to the extent disclosed by legal form, Bodacc insolvency search, RPPC check | RBE access (subject to legitimate-interest condition), enforcement records, financial statements |
| Extended | €1800 | All Standard items plus filed financial statements (last three available years), enforcement and pledge search at greffe, documented statement of the point at which the ownership chain stops and why | RBE access where legitimate-interest condition is not met; identification of natural persons behind nominee or trust arrangements |
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## FAQ
**What is the difference between a SIREN and a SIRET number?**
The SIREN is a nine-digit identifier assigned to the legal entity. The SIRET adds a five-digit establishment code, making fourteen digits in total. The SIREN is the identifier used in RCS searches and in cross-border verification. The SIRET identifies a specific place of business of the same entity.
**Does the RCS show who owns an SAS?**
Not as a matter of routine. The SAS is designed for contractual flexibility. Its statuts filed at the RCS may contain no shareholder list. The shareholder register is a private document held by the company. The RCS shows who manages the SAS, not who owns it.
**Is the Registre des bénéficiaires effectifs accessible to a foreign buyer?**
Access requires demonstrating a legitimate interest under French implementing rules following the CJEU judgment of November 2022. Whether pre-acquisition due diligence by a foreign buyer qualifies is a legal question. The report documents the access condition and the point at which the chain stops.
**What does a negative insolvency search result mean?**
It means no published proceeding was found at the time of the search. A petition filed but not yet published in the Bodacc will not appear. The absence of a record is not a guarantee of the absence of a proceeding.
**Can financial statements be withheld in France?**
Small companies may elect confidentiality for their income statement under conditions set by the Code de commerce. The balance sheet remains accessible. The report notes where a confidentiality election has been made and what remains available.
**What legal forms are most common in holding structures?**
The SAS is the predominant form for holding structures and for multi-layer ownership chains in France. Its flexibility on governance and its limited shareholder disclosure requirements make it the standard vehicle. The SARL remains common for smaller operational entities.
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**Sources:**
Registre du commerce et des sociétés / INPI — https://www.inpi.fr — verified 2026-09-10
Bodacc (Bulletin officiel des annonces civiles et commerciales) — https://www.bodacc.fr — verified 2026-09-10
Registre public des procédures collectives / INPI — https://www.inpi.fr — verified 2026-09-10
Registre des bénéficiaires effectifs / INPI — https://www.inpi.fr — verified 2026-09-10
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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 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