Direct ownership in France is recorded at the Registre du commerce et des sociétés (RCS). The record names shareholders, states their holdings, and fixes the date of each change. Control — who holds it, how it is distributed, and what a shareholder can enforce — is the question this report addresses.
The RCS is a public register. Access is not restricted to French nationals or licensed practitioners. What the register shows, however, is not the same as what a buyer needs to establish. The gap between those two things is the subject of this page.
What the record showsNamed shareholders with percentage holdings and dates of entry. Source: Registre du commerce et des sociétés · verified 2026-09-01 Access conditionPublic access without registration requirement. Source: Registre du commerce et des sociétés · verified 2026-09-01 Document languageFrench only. Certified translation is not provided by the registry. Source: Registre du commerce et des sociétés · verified 2026-09-01 What the record does not showBeneficial owners above the statutory threshold are held in a separate register with restricted access. The RCS shareholder list does not identify the natural person in control where ownership passes through an intermediate holding company. Source: Registre du commerce et des sociétés · verified 2026-09-01This register is public. What the report provides is the removed path: identification of the correct national identifier, navigation of the French-language interface, extraction of the relevant filing sequence, and assembly of the ownership chain across multiple filings into a single structured document.
French commercial law requires every société à responsabilité limitée (SARL) and société par actions simplifiée (SAS) to file a list of shareholders — the liste des associés or liste des actionnaires — with the RCS at incorporation and on each subsequent change. The filed document names each shareholder, states the number and percentage of shares held, and records the date of the filing.
For a SARL, the shareholder list is a statutory document filed with the greffe du tribunal de commerce. For an SAS, the articles of association and any amendments are the primary filed instruments. The SAS structure permits significant flexibility in how voting rights and control are allocated — a point that the shareholder list alone does not resolve.
The RCS record establishes the direct ownership layer. It does not, by itself, establish who exercises control where voting rights are separated from economic rights, where shareholders' agreements exist, or where the direct shareholder is itself a legal entity.
Source: Registre du commerce et des sociétés · extracted 2026-09-01
The greffe holds the following categories of document for each registered entity:
The filing sequence matters. A shareholder list filed at incorporation may have been superseded by a later amendment. Establishing the current position requires reading the full chronological sequence, not only the most recent document.
Source: Registre du commerce et des sociétés · extracted 2026-09-01
France implemented the EU beneficial ownership register under Article L. 561-46 of the Code monétaire et financier. The déclaration de bénéficiaires effectifs (DBE) is filed with the greffe and held as part of the RCS record.
Following the Court of Justice of the European Union judgment in joined cases C-37/20 and C-601/20 (November 2022), public access to beneficial ownership data was suspended in several EU member states. In France, access to the DBE is restricted. The current access regime requires a demonstration of legitimate interest. The conditions under which that demonstration is assessed are set by the greffe and are subject to change.
The consequence for a cross-border buyer: the beneficial owner declaration may not be accessible through a standard public search. The report states what was accessible at the date of extraction and identifies the point at which the chain stops.
Source: Registre du commerce et des sociétés · extracted 2026-09-01
Filing obligations for annual accounts depend on entity type and size thresholds. A SARL is generally required to file. An SAS may qualify for a confidentiality option under Article L. 232-25 of the Code de commerce, which permits small companies to request that their accounts not be made public.
Where accounts are filed and public, the report extracts the most recent three financial years. Where a confidentiality request has been granted, the report records that fact and states the year from which accounts are unavailable.
The absence of filed accounts is itself a finding. It is recorded as such, not treated as a gap in the report.
Source: Registre du commerce et des sociétés · extracted 2026-09-01
The RCS records the identity of the gérant (for a SARL) or the président and any directeurs généraux (for an SAS), together with their dates of appointment and, where applicable, cessation. Statutory auditors (commissaires aux comptes) are recorded separately where the entity is subject to the audit obligation.
The filed record establishes who holds signatory authority at the date of filing. It does not record the internal limits on that authority set by shareholders' agreements or board resolutions that are not filed with the greffe.
Source: Registre du commerce et des sociétés · extracted 2026-09-01
The RCS record and the annual accounts sometimes present inconsistent ownership figures. A shareholder list filed at a share transfer may show a different percentage than the equity section of the most recent balance sheet. This is not always an error: timing differences between the filing of a transfer and the closing of an accounting period produce legitimate discrepancies.
The report identifies every discrepancy between the shareholder list, the articles of association, and the filed accounts. Each discrepancy is stated as a finding. No legal qualification is attached to the finding.
The RCS record is the authoritative public source for direct ownership in France. Its ceiling is fixed by what has been filed and what is accessible.
The record does not show:
The report states, at the point of delivery, which of these ceilings applied to the specific entity examined. A ceiling is a finding. It is not a failure of the report.
| Tier | Price | What is included | Not included |
|---|---|---|---|
| Signal | €890 | Current shareholder list with percentages; director and officer register; entity status and registration history; identification of filing gaps | Annual accounts extraction; beneficial owner declaration search; shareholders' agreement cross-reference; translation |
| Standard | €1,900 | Everything in Signal, plus: three-year annual accounts extraction; beneficial owner declaration search (access conditions permitting); chronological filing sequence review; discrepancy report between shareholder list and accounts | Shareholders' agreements not filed with the greffe; legal qualification of findings; representation before the greffe |
| Extended | €4,200 | Everything in Standard, plus: full document set extraction across the filing history; cross-reference of French entity against intermediate holding companies in available registries; structured ownership chain diagram to the point the record allows; written summary of each ceiling encountered | Natural persons behind foreign intermediate holders where those registries do not disclose; legal advice; court filings or enforcement action |
What does the RCS record show for an SAS with complex voting rights? The RCS records the shareholders named in the articles of association and any filed amendments. It records economic ownership percentages. Voting rights that differ from economic ownership — double voting rights, preference shares, or contractual arrangements — appear only where they are written into the filed statuts. Arrangements set out in a shareholders' agreement that is not filed with the greffe are not visible in the RCS record. The Signal tier identifies whether the filed statuts contain voting rights provisions. The Standard and Extended tiers cross-reference those provisions against the filed accounts.
Is the beneficial owner declaration always accessible? No. Since the CJEU judgment of November 2022, access to beneficial owner declarations in France requires a demonstration of legitimate interest. The greffe assesses that demonstration. The outcome is not guaranteed. The report records whether the declaration was accessible at the date of extraction and, if not, states the access condition that applied.
What if the company has not filed annual accounts? Failure to file is itself a finding. The report records the years for which accounts are absent, distinguishes between a confidentiality option exercised under Article L. 232-25 and a simple non-filing, and notes the date of the last filed document. No inference about the company's financial position is drawn from the absence.
Can the report establish who controls the company if the direct shareholder is a foreign entity? The RCS record identifies the direct shareholder. Where that shareholder is a foreign legal entity, the chain continues into the foreign entity's home registry. The Extended tier includes a cross-reference against available registries for intermediate holding companies. The report states, at each link in the chain, whether the registry of that jurisdiction discloses further ownership data and where the chain stops.
How long does extraction take? The Signal tier is delivered within five business days of confirmation. The Standard tier within ten business days. The Extended tier within fifteen business days. Timelines assume that the relevant filings are accessible at the date of the request. Restricted access to beneficial owner declarations or foreign registry delays may extend the timeline; any such extension is communicated before delivery.
Sources:
Registre du commerce et des sociétés — https://www.infogreffe.fr — extracted 2026-09-01
Bodacc (Bulletin officiel des annonces civiles et commerciales) — https://www.bodacc.fr — extracted 2026-09-01
Registre des bénéficiaires effectifs (held at greffe du tribunal de commerce) — access via Infogreffe — extracted 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