A French company leaves a documented trail across several official registers. Before a transaction closes, that trail can be read systematically. What it shows, what it conceals, and where the record stops — those boundaries are stated here, before any engagement begins.
Governance in France is split between the legal text of the statuts and the operational reality of who holds signing authority. Both layers are verifiable from official sources. The gap between them is what a pre-deal review is designed to locate.
What the record showsCorporate form, registered capital, registered office, date of incorporation, statutory purpose, names of dirigeants with signing authority. Source: Registre du commerce et des sociétés · verified 2026-09-15 Filed accountsAnnual financial statements filed with the greffe are accessible for most SA, SAS and SARL entities. Availability depends on entity type and filing compliance. Source: Registre du commerce et des sociétés · verified 2026-09-15 Insolvency statusProceedings opened before a tribunal de commerce are recorded in the Bodacc (Bulletin officiel des annonces civiles et commerciales). Source: Bodacc · verified 2026-09-15 Beneficial ownershipFrance maintains a Registre des bénéficiaires effectifs. Access by third parties is restricted following CJEU ruling C-37/20. The record exists; public access is not guaranteed. Source: Registre du commerce et des sociétés · verified 2026-09-15The Registre du commerce et des sociétés (RCS) is the primary source for French corporate data. It holds the immatriculation record, the statuts as filed, and all subsequent modifications — capital increases, changes of dirigeants, transfers of registered office.
For a société par actions simplifiée (SAS), governance rules are set by the statuts rather than by statute. The RCS holds the filed statuts, but the statuts of an SAS are not always filed in full. Amendments may be filed as extracts. What the RCS shows is the version on record; whether that version reflects the current operating agreement requires comparison with the company's own documentation.
For a société à responsabilité limitée (SARL), the gérant is named in the RCS extract. The gérant's powers are defined by statute and by the statuts. The RCS extract names the person; it does not reproduce the scope of authority in detail.
The Kbis extract is the standard output of the RCS. It names the entity, its legal form, its registered capital, its registered office, its statutory purpose, and the identity and functions of its dirigeants. A Kbis is a point-in-time document. It reflects the state of the register at the moment of extraction.
For a SARL, the associés and their respective parts sociales are recorded in the statuts filed with the RCS. Capital transfers must be recorded in a modified statuts or an acte de cession filed with the greffe. The record is therefore as current as the last filed document.
For an SAS, the identity of shareholders is not systematically disclosed in the RCS. The statuts may name founding shareholders; subsequent transfers may not appear unless the statuts are amended. An SAS with a single shareholder (SASU) discloses that shareholder in the RCS. An SAS with multiple shareholders does not necessarily disclose all of them through the public record.
For a société anonyme (SA), the identity of shareholders holding registered shares (actions nominatives) is recorded in the company's own registre des mouvements de titres. That register is held by the company or its agent, not by the RCS. It is not a public document.
The consequence: for an SAS or SA, the RCS establishes governance structure and the identity of dirigeants. It does not reliably establish the full shareholder composition. That layer requires direct access to company documentation or a separate legal process.
French law requires most commercial companies to file annual accounts with the greffe du tribunal de commerce. Filed accounts are accessible through the RCS and through the Infogreffe platform.
Filing compliance varies. A company that has not filed accounts for one or more years will show a gap in the record. The absence of a filing is itself a data point.
For micro-enterprises and certain small companies, a confidentiality option exists under French law. A company that has exercised this option files its accounts but restricts access to them. The Infogreffe record will show that accounts were filed; it will not show the figures. This restriction applies for the year of filing and may be renewed annually.
The consequence: the availability of financial data depends on entity size, filing history, and whether the confidentiality option has been exercised. A pre-deal review establishes which of these conditions applies before the review proceeds.
The Bodacc publishes notices of insolvency proceedings, including sauvegarde, redressement judiciaire, and liquidation judiciaire. It also publishes notices of amiable proceedings where disclosure is required, and notices of radiation from the RCS.
A search of the Bodacc against the company's SIREN number returns all published notices. A negative result means no notice has been published. It does not mean no proceeding has been initiated: a proceeding that has not yet reached the publication stage will not appear.
The Registre public des procédures collectives (RPPC) holds records of insolvency proceedings at the tribunal de commerce level. Cross-referencing the Bodacc against the RPPC provides a more complete picture than either source alone.
Enforcement actions against a company's assets — saisies, hypothèques judiciaires — are recorded at the level of the relevant conservation des hypothèques or service de publicité foncière, depending on the nature of the asset. These records are asset-specific and require a separate search by asset type and location.
France established a Registre des bénéficiaires effectifs (RBE) under the fourth Anti-Money Laundering Directive. The RBE is held within the RCS system. Entities are required to declare their beneficial owners — persons 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-601/20 (November 2022), public access to beneficial ownership registers across EU member states was suspended or restricted. In France, access to the RBE by third parties without a demonstrated legitimate interest is no longer automatic. The record exists and is maintained. Access by parties outside the company requires a formal request and a statement of legitimate interest.
The consequence: a pre-deal review can establish that a declaration has been filed and can identify the declared beneficial owner where access is granted. Where access is restricted, the review establishes the structure to the level that the RCS discloses and identifies the point at which the chain stops.
The RCS establishes legal form, registered capital, registered office, statutory purpose, and the identity of persons with signing authority. It does not establish the full shareholder composition of an SAS or SA. It does not establish the beneficial owner where RBE access is restricted. It does not establish the terms of any shareholders' agreement, which is a private document and not filed.
Filed accounts establish the financial position as reported. They do not establish the accuracy of that reporting. A confidentiality election removes the figures from public access entirely.
The Bodacc establishes published insolvency notices. It does not establish proceedings that have been initiated but not yet published.
The RBE establishes the declared beneficial owner. It does not establish whether the declaration is accurate or current. A declaration filed at incorporation may not reflect subsequent changes if the company has not updated its filing.
These are the structural limits of the French public record. They are not limitations of the review methodology. They are the ceiling of what the sources allow, stated before any engagement begins.
A Kbis extract and a filed set of statuts may show different information about the scope of a dirigeant's authority. The Kbis names the function; the statuts define the powers. Where the statuts have been amended and the amendment has not been reflected in the Kbis, a discrepancy exists.
Filed accounts and the RCS capital record may diverge where a capital increase has been registered but the accounts predate it, or where accounts have not been filed for the relevant period.
The Bodacc record and the RPPC record may diverge in timing. A proceeding appears in the RPPC before it appears in the Bodacc. Relying on the Bodacc alone introduces a lag.
Where sources disagree, the review identifies the discrepancy and states which source is more recent and which is more authoritative for the specific data point. The discrepancy itself is a result.
| Tier | Price | What is included | What is NOT included |
|---|---|---|---|
| Signal | €1,350 | Kbis extract with current dirigeants and registered capital; Bodacc insolvency search; confirmation of RBE filing status; summary of source gaps | Filed accounts; statuts analysis; shareholders' agreement review; RBE access request |
| Standard | €2,850 | All Signal items; filed accounts for available years; statuts as filed with analysis of governance provisions; RBE access request with legitimate interest statement; discrepancy report across sources | Shareholders' agreement (private document); enforcement search by asset; legal qualification of findings |
| Extended | €6,300 | All Standard items; enforcement search across relevant asset registries; cross-reference of Bodacc and RPPC; analysis of capital history and modification filings; structured discrepancy report with source-by-source comparison | Legal advice; representation; any document not held in a public register |
What does the RCS show for an SAS? The RCS shows the legal form, registered capital, registered office, statutory purpose, and the identity of the président and any other dirigeants named in the statuts. For an SAS, the shareholder composition is not systematically disclosed unless the statuts name all shareholders and have been filed in full. Subsequent share transfers may not appear in the public record.
Can the beneficial owner of a French company be established from public sources? A declaration of beneficial ownership is required to be filed with the RCS. Following the CJEU judgment of November 2022, access by third parties is no longer automatic. A formal request with a statement of legitimate interest is required. The review establishes whether a declaration has been filed and pursues access through the available legal mechanism. Where access is refused, the review states that result and identifies the declared structure to the level that the RCS discloses.
Are filed accounts always available? No. Availability depends on entity type, filing compliance, and whether the company has exercised the confidentiality option available to qualifying small companies. A review establishes which condition applies before the accounts layer is assessed.
What is the Bodacc and what does it cover? The Bodacc (Bulletin officiel des annonces civiles et commerciales) is the official gazette for civil and commercial announcements. It publishes notices of insolvency proceedings, radiation from the RCS, and certain other corporate events. A Bodacc search returns all published notices against a company's SIREN number. It does not capture proceedings that have been initiated but not yet published.
What is not covered by any of the three tiers? No tier covers legal advice, legal qualification of findings, or representation. No tier covers documents that are not held in a public register — including shareholders' agreements, private share transfer agreements, and internal governance documents. The Extended tier covers the widest range of public sources; it does not extend beyond them.
Sources
Registre du commerce et des sociétés — https://www.infogreffe.fr — verified 2026-09-15
Bodacc (Bulletin officiel des annonces civiles et commerciales) — https://www.bodacc.fr — verified 2026-09-15
Registre des bénéficiaires effectifs (held within RCS) — https://www.infogreffe.fr — verified 2026-09-15
Registre public des procédures collectives — https://www.bodacc.fr — verified 2026-09-15
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