Control in a French company is not a single-source question. The Registre du commerce et des sociétés records the legal structure. The Registre des bénéficiaires effectifs holds the declared beneficial owner. The Greffe du tribunal de commerce holds filed accounts and constitutional documents. Each source answers a different part of the control question — and each has a ceiling that the others cannot raise.
Before signing a shareholders agreement, the relevant question is not merely who appears on the cap table. It is who can block a resolution, who holds a casting vote, and what the articles say about transfer restrictions. The sources below establish the first layer. The limit section states where that layer ends.
Legal shareholders and share capitalRecorded in the Registre du commerce et des sociétés (RCS) via Infogreffe and the Guichet unique. Verified: 09.09.2026. Declared beneficial ownerRegistre des bénéficiaires effectifs (RBE), held at the Greffe. Access conditions have changed following CJEU C-37/20; current public access is restricted. Verified: 09.09.2026. Filed accounts and statutsDeposited at the Greffe du tribunal de commerce. Availability varies by legal form and company size. Verified: 09.09.2026. Access conditionNo single identifier retrieves all three sources simultaneously. Each requires a separate query with the SIREN number.What the RCS shows — and what it does not
The Registre du commerce et des sociétés records the legal form, the registered capital, the names of managers (gérants, directeurs généraux, présidents), and — for SARLs — the names of associés with their share counts. For SASs, the RCS records the president and, where applicable, the directeur général. It does not record the full list of shareholders of an SAS unless those shareholders are themselves registered entities with a mandatory filing obligation.
This distinction matters before signing. An SAS is the dominant form for venture-backed and family-controlled structures in France. Its shareholders are not publicly listed in the RCS. The articles (statuts) govern transfer restrictions, approval clauses (clauses d'agrément), and pre-emption rights — but the statuts are filed at the Greffe, not automatically surfaced in a standard RCS extract.
A standard Kbis extract confirms the legal existence of the entity, its registered address, its SIREN, and its current managers. It does not confirm the shareholder structure of an SAS, the existence of a shareholders agreement (pacte d'associés), or any off-register pledge over shares.
The Registre des bénéficiaires effectifs
France implemented the EU beneficial ownership register under the 5th Anti-Money Laundering Directive. The RBE is held at each Greffe and records the natural person(s) who ultimately own or control more than 25% of the capital or voting rights, or who exercise control by other means.
Following the CJEU judgment in Joined Cases C-37/20 and C-601/20 (November 2022), unrestricted public access to beneficial ownership registers across EU member states was suspended. French law was amended accordingly. As of the verification date, access to the RBE for persons without a demonstrated legitimate interest is restricted. The mechanism for establishing legitimate interest and the procedural steps required are subject to ongoing regulatory interpretation.
[СВЕРИТЬ местным консультантом до публикации] The current access regime for the French RBE, including the documentary requirements for a foreign entity claiming legitimate interest, should be confirmed with a French-qualified practitioner before any filing or formal request is submitted.
What the RBE contains when accessible: the declared identity of the beneficial owner, the nature and extent of the interest held, and the date of declaration. It does not contain the underlying contractual arrangements that produce that control — shareholders agreements, voting trusts, or irrevocable proxies are not filed here.
Filed accounts and constitutional documents
French companies above certain size thresholds are required to file annual accounts at the Greffe. Smaller entities and SASs below the micro-enterprise threshold may file confidentially, restricting access to tax authorities and certain public bodies. The confidential filing option means that a significant proportion of French SASs do not have publicly accessible accounts.
The statuts — the constitutional document — are filed at the Greffe on incorporation and on each amendment. Amendments to the statuts that affect share capital, transfer restrictions, or governance rights trigger a new filing obligation. A review of the statuts establishes the formal governance architecture: quorum requirements, majority thresholds for ordinary and extraordinary decisions, approval clauses for share transfers, and the scope of the president's authority.
The statuts do not contain the pacte d'associés. A shareholders agreement in France is a private contract between the parties. It is not filed, not registered, and not publicly accessible. Its existence may be inferred from cross-references in the statuts or from representations in a due diligence process, but it cannot be retrieved from any official source.
Where the sources disagree
| Source | What it records | Known gap |
|---|---|---|
| RCS / Kbis | Managers, legal form, capital | SAS shareholders not listed |
| RBE | Declared beneficial owner (>25%) | Access restricted post-CJEU; declaration may lag structural changes |
| Greffe — statuts | Formal governance rules | Pacte d'associés not filed; amendments may not yet be registered |
| Greffe — accounts | Financial position | Confidential filing available; micro-entities may not disclose |
| BODACC | Insolvency and enforcement notices | Publication lag; not a real-time source |
When the RCS shows one manager and the RBE shows a different natural person as beneficial owner, the divergence is itself a finding. The report records both, states the source of each, and identifies the gap between declared control and formal authority.
The limit of what the sources allow
The French official sources establish the declared layer of ownership and control. They do not establish:
- The existence or content of any shareholders agreement (pacte d'associés)
- Voting arrangements, irrevocable proxies, or usufruct structures over shares
- Pledges (nantissements) over shares not yet enforced and not yet appearing in the RCS
- Beneficial ownership chains above the 25% threshold where the structure is held through multiple tiers of non-French entities
- Amendments to the statuts filed within the last few days and not yet processed by the Greffe
The RBE records a declaration. It does not verify the accuracy of that declaration against the underlying contractual structure. A beneficial owner who holds control through a chain of entities each below the 25% threshold may not appear in the RBE at all.
For an SAS, the combination of a non-public shareholder list and a private shareholders agreement means that the official sources can confirm the legal existence of the entity, its managers, and its declared beneficial owner — but cannot confirm who holds blocking rights on a resolution or what transfer restrictions apply to the shares being acquired.
The report states, at each point, which source produced the finding and where the chain ends.
Scope and fixed price
| Tier | Price | What is included | What is NOT included |
|---|---|---|---|
| Signal | €890 | RCS extract (Kbis), SIREN verification, manager and legal form confirmation, BODACC insolvency check, written summary of findings with source citations | RBE access, statuts review, accounts analysis, shareholders agreement review |
| Standard | €1,900 | All Signal content, plus: Greffe statuts retrieval and review, filed accounts (where publicly accessible), RBE query (subject to access conditions), written report identifying divergences between sources | Pacte d'associés (not publicly accessible), share pledge verification, non-French entity chain analysis |
| Extended | €4,200 | All Standard content, plus: multi-tier ownership chain analysis across non-French holding entities, cross-referencing of RBE declaration against corporate structure, identification of gaps in the declared chain, written report with annotated source map | Legal qualification of findings, advice on negotiating position, review of draft shareholders agreement |
FAQ
What does the RCS show for an SAS before a shareholders agreement is signed? The RCS records the legal form, registered capital, SIREN, registered address, and the identity of the president and any directeur général. For an SAS, it does not list the shareholders. The shareholder list for an SAS is maintained by the company itself and is not a public document.
Is the French beneficial ownership register publicly accessible? Following the CJEU judgment of November 2022, unrestricted public access was suspended. Access now requires a demonstrated legitimate interest. The procedural requirements for a foreign entity are subject to ongoing regulatory interpretation and should be confirmed with a French-qualified practitioner before a formal request is submitted.
Can a shareholders agreement be found in official French sources? No. A pacte d'associés is a private contract. It is not filed with the Greffe, not registered in the RCS, and not accessible through any official source. Its existence may be referenced in the statuts, but its content is not publicly available.
What does a nantissement de parts sociales mean for a buyer? A pledge over shares (nantissement) is registered in the RCS for SARLs. For SASs, the registration mechanism differs. A registered pledge gives the pledgee priority rights in enforcement. The report identifies registered pledges where they appear in the RCS; it does not identify unregistered or informal arrangements.
What is BODACC and what does it show? The Bulletin officiel des annonces civiles et commerciales publishes insolvency proceedings, judicial liquidations, and certain enforcement notices. It is a publication-lag source: proceedings may be opened before they appear. A negative result confirms no published notice as of the extraction date, not the absence of any proceeding.
How long does the report take? The Signal tier is produced within three to five business days of the request. Standard and Extended tiers depend on Greffe processing times and RBE access conditions, which vary. An indicative timeline is provided at the time of the request.
Sources:
Infogreffe — Registre du commerce et des sociétés — https://www.infogreffe.fr — extracted 09.09.2026
Guichet unique des formalités des entreprises — https://www.guichet-entreprises.fr — extracted 09.09.2026
Greffe du tribunal de commerce de Paris — Registre des bénéficiaires effectifs — extracted 09.09.2026
BODACC — Bulletin officiel des annonces civiles et commerciales — https://www.bodacc.fr — extracted 09.09.2026
CJEU, Joined Cases C-37/20 and C-601/20, judgment of 22 November 2022 — referenced for RBE access regime
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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
