Who controls a French company is a question the Registre du commerce et des sociétés (RCS) answers in part — and only in part. The authorised representative on record is the person the company has declared to the registry as holding power to bind it. That declaration is a legal act. It is also a starting point, not a conclusion.
The angle of control runs through the representative layer before it reaches the shareholder layer. An international buyer verifying a French object needs to know what the RCS shows about the representative, what it does not show, and where the chain of authority stops being visible in official sources.
What the source showsIdentity, title and appointment date of the gérant, président, directeur général or other authorised representative, as filed with the RCS. Source: Registre du commerce et des sociétés · verified 2026-09-20 Access conditionThe RCS is accessible via Infogreffe and the Guichet des formalités des entreprises. No registration is required for basic extracts; certified extracts (Kbis) carry a fee set by the registry. What the source does not showThe scope of internal authority delegated beyond the statutory minimum, side agreements restricting the representative's powers, and any undisclosed mandate given to a third party. Coverage levelLevel A — representative identity and appointment are on record. Beneficial ownership sits at a separate layer with separate access conditions.What the RCS records about the authorised representative
The RCS is the primary public register for French commercial entities. Every société (SAS, SARL, SA and others) must file the identity of its legal representative at incorporation and update that filing on any change.
The extract most commonly used for verification is the extrait Kbis. It states the representative's full name, date of birth, nationality, and the capacity in which they act — gérant for a SARL, président or directeur général for an SAS or SA. The Kbis also records the date of appointment and, where applicable, the date of cessation.
For an SAS, the statuts filed with the RCS define the scope of the président's authority. Those statuts are a filed document, not a confidential one. They can be retrieved from the greffe of the competent Tribunal de commerce. The scope of authority written into the statuts is therefore verifiable — but only if the statuts have been updated each time the authority was modified.
For a SARL, the gérant's authority is defined partly by statute (Code de commerce) and partly by the statuts. The statutory floor is broad: the gérant binds the company in dealings with third parties acting in good faith, regardless of any internal restriction. That internal restriction, if it exists, is not visible in the Kbis.
Source: Registre du commerce et des sociétés (RCS) · verified 2026-09-20
The shareholder layer and what it shows about control
The identity of shareholders in a SARL is recorded in the Registre des bénéficiaires effectifs (RBE) and, for SARLs, in the Acte de cession de parts filed with the greffe when shares change hands. The RBE records beneficial owners holding more than 25% of capital or voting rights, or exercising control by other means.
Access to the RBE changed following the CJEU judgment in joined cases C-37/20 and C-601/20 (November 2022). France restricted public access to the RBE as a consequence. Access now requires demonstration of a legitimate interest. The mechanism for establishing that interest is defined by the Décret n° 2023-1013 and subsequent administrative guidance. The practical path for a foreign buyer without a French national identifier involves filing a written request to the greffe with supporting documentation.
For an SA, the identity of shareholders holding registered shares (actions nominatives) is recorded in the registre des mouvements de titres, which is an internal document held by the company or its agent — not a public registry filing. Shareholders holding bearer shares (actions au porteur) are identified through the intermediary holding the account, not through any public source.
The shareholder register of an SAS is not a public document. The statuts may name founding shareholders, but subsequent transfers are not required to be filed publicly unless the statuts themselves require it.
Source: Registre des bénéficiaires effectifs (RBE) / Greffe du Tribunal de commerce · verified 2026-09-20
Filed financial statements and what they show about the structure
French companies above certain thresholds are required to file annual accounts with the greffe. Those accounts are public. They include the bilan (balance sheet), the compte de résultat (income statement), and the annexe, which may contain notes on related-party transactions, group structure and significant shareholding changes.
Small companies (petites entreprises) may file simplified accounts and, since the Loi Pacte (2019), may opt for confidentiality of the income statement. That confidentiality option means the compte de résultat is not accessible to third parties, including buyers conducting verification. The bilan remains public.
The consolidation perimeter — which entities are included in a group — is visible in consolidated accounts where filing is required. For a French holding company with subsidiaries in other jurisdictions, the consolidated accounts filed in France show the perimeter as declared by the group. They do not independently verify the structure of each subsidiary.
Source: Greffe du Tribunal de commerce / Infogreffe · verified 2026-09-20
Insolvency and enforcement records
Proceedings under the Code de commerce (sauvegarde, redressement judiciaire, liquidation judiciaire) are recorded in the Bulletin officiel des annonces civiles et commerciales (BODACC) and in the RCS itself. A judgment opening proceedings is published in BODACC and noted on the Kbis.
The Fichier national des interdits de gérer (FNIG) records individuals subject to a prohibition on managing companies. Access to the FNIG is restricted: it is not a public search tool. Verification of whether a specific individual is subject to a prohibition requires a formal request through the competent authority.
A negative result in BODACC does not confirm the absence of a filed petition. The period between filing and publication can create a gap. For time-sensitive transactions, the greffe can be queried directly.
Source: BODACC / Greffe du Tribunal de commerce · verified 2026-09-20
The limit of what the sources allow
The RCS shows who the company has declared as its authorised representative. It does not show the internal delegation of authority beyond what is written in filed statuts. It does not show whether the representative acts under instruction from an undisclosed principal.
The RBE shows beneficial owners above the 25% threshold as declared by the company. It does not independently verify that declaration. Access for a foreign buyer requires a demonstrated legitimate interest; the path is procedural and takes time.
The shareholder register of an SAS is not public. The registre des mouvements de titres of an SA is internal. Bearer shares in an SA are identified through the account intermediary, not through any registry.
Filed accounts show the structure as declared. Where the income statement is confidential under the Loi Pacte option, the revenue and cost structure is not visible to third parties.
The FNIG is not a public search tool. A prohibition on a specific individual cannot be confirmed or excluded without a formal request.
The chain of authority from the authorised representative back to the ultimate controlling person is not fully visible in any single public source. The report establishes what each source shows, names the point at which the chain becomes opaque, and states the access condition that cannot be cleared remotely.
Where the sources disagree
The Kbis and the statuts may show different things about the scope of authority. The Kbis records the title and appointment. The statuts define the powers. If the statuts have not been updated after an internal restructuring, the Kbis shows a current representative whose actual authority has been modified — but the modification is not reflected in the extract a third party would first retrieve.
The RBE declaration and the actual shareholding structure may diverge where the company has not updated its filing following a transfer. The obligation to update exists; the enforcement of that obligation is not automatic.
Filed accounts and the RBE may show different pictures of control where a shareholder holds exactly 25% — below the RBE threshold — but exercises de facto control through a shareholders' agreement not filed with any public registry.
These divergences are not anomalies. They are structural features of the French disclosure framework. Identifying them is part of what the report does.
What is included at each tier
| Tier | Price | What is included | Not included |
|---|---|---|---|
| Signal | €1,350 | Kbis extract with representative identity and appointment; BODACC insolvency check; confirmation of legal form and registered address; identification of filed statuts | Retrieval and analysis of statuts content; RBE access request; financial statement analysis; shareholder register review |
| Standard | €2,850 | Everything in Signal; retrieval and analysis of filed statuts; RBE access request with legitimate interest filing; review of filed annual accounts (bilan and available annexe); identification of divergences between Kbis and statuts | FNIG prohibition check; review of consolidated accounts; analysis of group structure beyond the French entity; legal qualification of findings |
| Extended | €6,300 | Everything in Standard; FNIG prohibition check via formal request; consolidated accounts analysis where filed; group structure mapping to the extent visible in French public sources; written analysis of divergences across all sources; identification of the point at which the authority chain becomes opaque | Independent verification of facts declared in the RBE; access to internal shareholder registers; legal advice on transaction implications |
FAQ
What does the Kbis show about the authorised representative? The Kbis states the representative's name, date of birth, nationality, title and appointment date. It does not state the scope of authority beyond the title. For an SAS, the scope is in the statuts. For a SARL, the statutory floor applies to third parties regardless of internal restrictions.
Is the beneficial ownership register in France publicly accessible? Following the CJEU judgment of November 2022, France restricted public access to the RBE. Access requires demonstration of a legitimate interest. A foreign buyer without a French national identifier must file a written request to the greffe with supporting documentation. The report includes that request at Standard and Extended tiers.
Can the income statement of a French company be retrieved? Small companies may opt for confidentiality of the income statement under the Loi Pacte. Where that option has been exercised, the compte de résultat is not accessible to third parties. The bilan remains public. The report identifies which documents are available before the order is confirmed.
What is the gap between a BODACC publication and a filed insolvency petition? There is a period between the filing of a petition and its publication in BODACC. A negative BODACC result does not confirm the absence of a filed petition. For time-sensitive matters, the greffe can be queried directly; this is included in the Standard and Extended tiers.
Does the report provide legal advice on the findings? No. The report is a factual compilation from official sources. It establishes what each source shows, identifies divergences, and names the point at which the chain of authority becomes opaque. Legal qualification of those findings is a separate engagement.
Sources
- Registre du commerce et des sociétés (RCS) — https://www.infogreffe.fr — verified 2026-09-20
- Registre des bénéficiaires effectifs (RBE) — accessible via the greffe of the competent Tribunal de commerce — verified 2026-09-20
- Bulletin officiel des annonces civiles et commerciales (BODACC) — https://www.bodacc.fr — verified 2026-09-20
- Guichet des formalités des entreprises — https://formalites.entreprises.gouv.fr — verified 2026-09-20
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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
