Control in a French company is distributed across three layers: the registered shareholders list, the statutory documents, and the beneficial ownership declaration. Each layer sits in a different register. Each register has its own access condition. A foreign requester who approaches only one layer will miss the other two.
This page maps what each layer shows, where the chain breaks, and what the fixed-price report establishes before a shareholders agreement is signed.
What the sources showRegistered shareholders, share capital, statutory documents, and beneficial ownership declarations — across three distinct French registers. Verified against Registre du commerce et des sociétés (RCS), Registre des bénéficiaires effectifs (RBE), and BODACC. Verified: 06.10.2026. Access conditionRBE access for third parties requires a declaration of legitimate interest since the CJEU ruling of November 2022. Without that declaration, the beneficial ownership layer is not retrievable. Verified: 06.10.2026. What the sources do not showNominee arrangements, undisclosed shareholder agreements, and economic rights transferred outside the register. The chain stops at the declared layer. Verified: 06.10.2026. Coverage levelLevel A — statutory and registered ownership layer fully retrievable. Beneficial ownership layer subject to access condition. Verified: 06.10.2026.What the French register shows about ownership
The Registre du commerce et des sociétés (RCS) is the primary source for corporate identity in France. It records the company's legal form, registered capital, statutory seat, and the identity of legal representatives — gérant, président, or directeur général depending on the form.
For SAS (société par actions simplifiée) and SA (société anonyme), the RCS does not publish the full shareholders list as a matter of public record. The statuts (articles of association) filed at incorporation may name founding shareholders, but subsequent transfers are not automatically reflected in the public file.
For SARL (société à responsabilité limitée), the Acte de cession de parts must be filed with the greffe (commercial court registry). This makes the ownership chain more traceable at the RCS level than for share-based forms.
The BODACC (Bulletin officiel des annonces civiles et commerciales) publishes notices of incorporation, capital changes, and dissolution. It is the audit trail for structural events. It does not publish the underlying documents.
| Register | What it shows | Access condition | What it does not show |
|---|---|---|---|
| RCS (greffe) | Legal form, capital, statutory seat, legal representatives, filed statuts | Public; electronic access via Infogreffe | Full shareholder list for SAS/SA; transfers post-incorporation |
| RBE | Declared beneficial owners with identity and ownership percentage | Declaration of legitimate interest required since Nov 2022 | Undisclosed economic arrangements; nominees |
| BODACC | Notices of capital events, incorporations, dissolutions | Public and free | Underlying transaction documents |
| Greffe (SARL) | Filed share transfer deeds (actes de cession) | Public; per-document retrieval | Transfers not yet filed |
The beneficial ownership layer and the access condition that stops most foreign requesters
France implemented the EU beneficial ownership register under the 5th Anti-Money Laundering Directive. The Registre des bénéficiaires effectifs (RBE) is maintained by the greffe of each commercial court and accessible through Infogreffe.
Following the CJEU judgment in Joined Cases C-37/20 and C-601/20 (November 2022), unrestricted public access to beneficial ownership registers was held incompatible with fundamental rights under EU law. France responded by restricting third-party access to the RBE. A requester must now demonstrate a legitimate interest to obtain the beneficial ownership declaration.
For a foreign requester without a French legal identifier, without a registered address in France, and without a pre-established relationship to the target company, demonstrating legitimate interest is the step that fails in practice. The form exists. The legal basis exists. The path requires preparation that most foreign requesters have not completed before they approach the register.
The report prepares and submits that declaration on the requester's behalf, using the documented purpose of pre-contractual due diligence as the stated legitimate interest.
Control: what the statutory documents establish
The statuts of a French company are filed at incorporation and at each subsequent amendment. For SAS, the statuts define the governance structure in detail: who holds veto rights, how decisions are made, what thresholds trigger consent requirements. These provisions are not summarised in the RCS extract. They are in the filed document.
A shareholders agreement (pacte d'actionnaires) is a private contract. It is not filed with any register. It does not appear in any public source. Its existence may be disclosed in the statuts by reference, or it may be entirely invisible to the register.
This is the structural limit of what official sources allow. The report establishes what is in the public record. It identifies where the public record ends and where a private contractual layer may exist. It does not retrieve private agreements.
Control, in the sense of who can block a decision or force a transfer, may rest entirely in a pacte d'actionnaires that no register holds. The report names that gap explicitly.
Step-by-step: what the report retrieves and in what order
Step 1 — RCS extract (Kbis) The Kbis is the official extract from the RCS. It names the legal representatives, the registered capital, the legal form, and the statutory seat. It is the starting point for every subsequent step.
Step 2 — Filed statuts and amendments The greffe holds the filed statuts and all subsequent amendments. For SAS, these documents define governance rights. For SARL, they define the share structure and transfer restrictions. Retrieval is per-document.
Step 3 — BODACC audit trail BODACC is searched for all notices relating to the target company: capital increases, reductions, mergers, partial asset transfers, and dissolution proceedings. The timeline of structural events is mapped.
Step 4 — RBE declaration and retrieval The legitimate interest declaration is prepared and submitted. The beneficial ownership declaration names the declared ultimate beneficial owner(s), their identity, and their declared ownership percentage and nature of control.
Step 5 — Insolvency and enforcement check The Registre du commerce et des sociétés includes entries for judicial reorganisation (redressement judiciaire) and liquidation (liquidation judiciaire). The Bulletin officiel des annonces civiles et commerciales publishes insolvency notices. Both are searched.
Step 6 — Cross-reference and gap identification The report cross-references the ownership layer (RCS/statuts) against the beneficial ownership layer (RBE). Where they diverge, the divergence is stated. Where the chain stops — at a holding company, a trust, or an undisclosed arrangement — the stopping point is named.
The limit of what the sources allow
The French register system is among the more complete in the EU for corporate transparency. It is not complete.
The RBE shows the declared beneficial owner. It does not verify the declaration. A company is required to file an accurate declaration; the register does not independently audit it. A discrepancy between the declared beneficial owner and the actual economic beneficiary will not appear in any public source.
The statuts show the governance structure as filed. A shareholders agreement that modifies governance rights in practice is not filed anywhere. Its existence is not detectable from public sources unless the statuts reference it.
For SAS and SA, the full shareholder register is not a public document. The report retrieves what is filed. Shareholders who hold interests through a holding company registered outside France will appear in the French register only at the level of that holding company. The chain above that level requires a separate report in the holding company's jurisdiction.
The report states, at the point of delivery, exactly where the chain ends and why. That statement is part of the deliverable, not a qualification added after the fact.
Where the sources disagree
A divergence between the RCS extract and the RBE declaration is itself a finding. It may indicate a recent transfer not yet reflected in one register, a filing delay, or a structural arrangement that produces different answers at different layers.
When the declared beneficial owner in the RBE holds less than 25% of capital but the statuts grant that person a veto right or a casting vote, the control picture differs from the ownership picture. The report maps both and states the difference.
When BODACC shows a capital event that is not reflected in the current Kbis extract, the gap is noted and the relevant BODACC notice is cited.
Scope and fixed price
| Tier | Price | What is included | What is NOT included |
|---|---|---|---|
| Signal | €890 | Kbis extract, BODACC audit trail, insolvency check, gap identification report | RBE beneficial ownership retrieval; statuts and amendments; cross-reference analysis |
| Standard | €1,900 | All Signal items, plus: filed statuts and amendments, RBE legitimate interest declaration and retrieval, cross-reference of ownership and beneficial ownership layers | Shareholders above the French holding company level; private shareholders agreements; legal qualification of findings |
| Extended | €4,200 | All Standard items, plus: holding company chain analysis (up to two additional jurisdictions), timeline of structural events, written gap analysis with source citations | Jurisdictions beyond the two included; legal advice; enforcement strategy |
FAQ
What is the difference between the RCS extract and the beneficial ownership register? The RCS extract (Kbis) records the legal representatives and the registered capital. It does not name the ultimate beneficial owner for most company forms. The RBE is a separate register that records the declared beneficial owner — the natural person who ultimately owns or controls the company. Since November 2022, access to the RBE requires a declaration of legitimate interest from the requester.
Can a foreign requester access the French beneficial ownership register directly? Access is legally available to any person who can demonstrate legitimate interest. In practice, the declaration must be prepared in French, reference a specific legal basis, and identify the purpose of the request. A foreign requester without prior experience of the French greffe system will typically encounter delays or rejection at this step.
Does the report retrieve private shareholders agreements? No. A pacte d'actionnaires is a private contract. It is not filed with any French register and does not appear in any public source. The report identifies whether the statuts reference such an agreement and states that the agreement itself is outside the scope of public record retrieval.
What does the report deliver if the beneficial ownership chain leads outside France? The Standard tier establishes the chain to the level of the French entity. Where the chain continues through a foreign holding company, the report names that company and its jurisdiction. The Extended tier includes analysis of up to two additional jurisdictions. Further jurisdictions require a separate engagement.
How long does retrieval take? The RCS extract and BODACC search are typically completed within two to three business days. The RBE retrieval, which requires the legitimate interest declaration, adds two to five business days depending on the greffe's processing time. The full Standard report is typically delivered within seven business days of instruction.
Sources:
Registre du commerce et des sociétés (RCS) / Infogreffe — https://www.infogreffe.fr — verified 06.10.2026
Registre des bénéficiaires effectifs (RBE) — maintained by the greffes of the tribunaux de commerce — verified 06.10.2026
BODACC (Bulletin officiel des annonces civiles et commerciales) — https://www.bodacc.fr — verified 06.10.2026
CJEU, Joined Cases C-37/20 and C-601/20, judgment of 22 November 2022 — access restriction basis for RBE — verified 06.10.2026
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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
