The Registre du commerce et des sociétés (RCS) is the primary official source for board composition and control structure in French companies. Who holds a mandate, when it was granted, and what powers attach to it — these facts are on record. Who exercises control behind the registered layer is a separate question, with a different ceiling.
Control in France is not always visible at the board level. A gérant in a SARL and a président in a SAS carry different statutory powers. A directeur général may bind the company externally regardless of internal restrictions. The record shows the mandate; it does not show the instruction.
What the source showsNames and mandates of directors, gérants, présidents and statutory auditors, with appointment dates. Source: Registre du commerce et des sociétés · verified 2026-09-10 Shareholder visibilityFor SARLs, the associés list with shareholding percentages is filed and accessible. For SAS, shareholder identity is not systematically disclosed at the RCS. Source: Registre du commerce et des sociétés · verified 2026-09-10 Access conditionExtraits Kbis and filed documents are available through Infogreffe and the BODACC portal. Access does not require proof of legal interest for standard extracts. Source: Registre du commerce et des sociétés · verified 2026-09-10 What the source does not showBeneficial ownership beyond the registered layer; shareholder agreements; delegations of authority not filed with the greffe. Source: Registre du commerce et des sociétés · verified 2026-09-10Board structure and mandate types in French companies
French company law creates distinct mandate categories. Each carries a different scope of authority and a different disclosure obligation.
In a société à responsabilité limitée (SARL), the gérant is the sole statutory manager. The gérant's identity, appointment date and, where applicable, removal are filed with the greffe. Multiple gérants may be appointed; the record names each one.
In a société par actions simplifiée (SAS), the président holds the statutory representation mandate. The SAS form allows wide contractual freedom: a directeur général, a comité de direction or any other body may be created by the statuts. These bodies appear in the RCS only if the statuts filed there name them. Internal governance documents not filed with the greffe are outside the public record.
In a société anonyme (SA), the structure depends on whether the company uses a conseil d'administration (board of directors) with a président-directeur général or a two-tier directoire and conseil de surveillance. All members of these bodies are filed individually. The SA form is less common for closely held companies but remains standard for listed entities.
The extrait Kbis is the primary document. It lists current mandataires, their appointment dates and the registered seat. Historical mandates — former directors, removed gérants — appear in the chronological extract, not the standard Kbis.
Source: Registre du commerce et des sociétés · extracted 2026-09-10
Shareholder rights and what the record shows
Shareholder rights in France are governed by the Code de commerce and, for SAS, by the statuts. The statuts are a filed document. For SARLs, the statuts and any amendments are accessible at the greffe. For SAS, the statuts are filed but may be redacted in part where the company invokes confidentiality provisions.
The associés register in a SARL discloses each associate's name and percentage holding. Transfers of shares in a SARL require a formal act filed with the tax authorities and, in most cases, updated statuts filed with the greffe. The record therefore reflects ownership changes with a lag corresponding to the filing delay.
For SAS, there is no statutory obligation to file a shareholder register with the greffe. The RCS does not systematically show who holds shares in a SAS. This is a structural ceiling of the source, not a gap in a specific filing.
Shareholder agreements (pactes d'actionnaires) are private contracts. They are not filed with the greffe and do not appear in the public record. A pacte may restrict share transfers, grant pre-emption rights or regulate voting — none of this is visible from the RCS alone.
The Registre des bénéficiaires effectifs (RBE) was established under the 4th and 5th EU Anti-Money Laundering Directives. Following the CJEU ruling in joined cases C-37/20 and C-601/20, public access to UBO registers across EU member states was restricted. In France, access to the RBE is now limited to competent authorities, obligated entities under AML law, and persons demonstrating a legitimate interest. The standard of legitimate interest is assessed by the greffe. This is a legal access condition, not a technical one.
Source: Registre du commerce et des sociétés · extracted 2026-09-10
Control: what the registered layer shows and where it ends
The RCS shows formal control — the person with the statutory mandate to represent and bind the company. It does not show economic control, instructional control or the terms of any shareholders' agreement.
Several structures are commonly used in France to separate formal and economic control. A holding company (société holding) may be the registered associé of an operating entity. The holding's own ownership structure is a separate filing in a separate greffe. Tracing the chain requires a separate query at each level.
A société civile (SC) or société civile immobilière (SCI) may hold shares in an operating company. The SC/SCI is registered in the RCS but its associés list is not always current: there is no continuous filing obligation for transfers between existing associés in some SC forms.
Usufruit and nue-propriété arrangements split voting rights from economic rights. The RCS records the registered holder; it does not systematically record whether the holding is subject to a démembrement. This distinction matters for control analysis: the usufruitier typically votes at ordinary general meetings, the nu-propriétaire at extraordinary ones, under default statutory rules.
The analysis establishes the registered chain to the level the sources allow. At each point where the chain passes through a non-disclosed structure, the report names the structure and states why the record ends there.
Source: Registre du commerce et des sociétés · extracted 2026-09-10
The limit of what the sources allow
The RCS is a filing system, not a verification system. What appears there is what was filed. The greffe performs a formal review of documents; it does not verify the accuracy of the underlying facts.
Several ceilings apply specifically to French company records:
The SAS form does not require shareholder disclosure at the RCS. A buyer verifying a SAS counterparty cannot establish ownership from the public record alone.
The RBE is no longer publicly accessible following the CJEU ruling. Establishing beneficial ownership requires either a legitimate-interest access request to the greffe or reliance on documents obtained directly from the company.
Shareholder agreements are private. Their existence may be inferred from filed statuts that reference them, but their content is not on record.
Delegations of authority (délégations de pouvoirs) are internal documents. A person acting under a delegation may bind the company without appearing in the RCS. The Kbis does not show delegations.
Historical mandates require the chronological extract, not the standard Kbis. A director removed six months ago does not appear on the current Kbis.
The BODACC (Bulletin officiel des annonces civiles et commerciales) publishes notices of incorporation, modification and dissolution. It is a secondary source: it reflects what was filed, with a publication lag. Insolvency proceedings (procédures collectives) are published in the BODACC and in the Registre public des procédures collectives (RPPC). A negative result in the RPPC does not guarantee that no petition has been filed; it confirms that no published decision has been recorded.
The analysis names the level at which the chain ends and the reason it ends there. That statement is itself a result.
Source: Registre du commerce et des sociétés · extracted 2026-09-10
Source: BODACC · extracted 2026-09-10
Source: Registre public des procédures collectives · extracted 2026-09-10
Scope and fixed price
| Tier | Price | What is included | Not included |
|---|---|---|---|
| Signal | €1,350 | Current Kbis extract; current mandataires with appointment dates; BODACC search for modifications and dissolution notices; RPPC insolvency check; statement of the access ceiling for this entity type | Shareholder identity for SAS; RBE data; historical mandates prior to current extract; shareholder agreements; delegations of authority |
| Standard | €2,850 | Everything in Signal; chronological extract with historical mandates; statuts as filed with the greffe; associés list for SARL (where filed); holding company identification one level up; written statement of where the ownership chain ends and why | RBE data (legitimate-interest access not included); shareholder agreements; delegations of authority; second-level holding structure |
| Extended | €6,300 | Everything in Standard; multi-level holding chain traced to the point the sources allow, with a written statement at each break; RBE legitimate-interest access request filed and result reported; cross-check against BODACC and RPPC for all entities in the chain; filed financial statements where available; written summary of control structure and identified gaps | Shareholder agreements (private documents); delegations of authority (internal documents); facts not on record in any official source |
FAQ
What does the Kbis show about a board member in France? The extrait Kbis lists the current mandataires — gérant, président, directeur général, board members — with their appointment dates and the registered seat. It does not show historical mandates, delegations of authority or whether the mandate holder acts under instruction from a third party.
Can shareholder identity be established for a French SAS? Not from the RCS alone. The SAS form does not require a shareholder register to be filed with the greffe. Shareholder identity for a SAS must be obtained from the company directly or through other means outside the public record.
Is the French beneficial ownership register publicly accessible? No. Following the CJEU ruling in 2022, access to the Registre des bénéficiaires effectifs is restricted to competent authorities, AML-obligated entities and persons demonstrating a legitimate interest assessed by the greffe. Public access is no longer available as a matter of right.
What is the difference between a gérant and a président in France? A gérant is the statutory manager of a SARL. A président is the statutory representative of a SAS. Both bind the company externally. The SAS form allows additional management bodies created by the statuts; these appear in the RCS only if the filed statuts name them.
Does a negative insolvency search confirm the company is solvent? No. A negative result in the RPPC confirms that no published insolvency decision has been recorded. A petition may have been filed without a published decision yet. The RPPC is a record of published decisions, not a real-time insolvency monitor.
What is a pacte d'actionnaires and does it appear in the record? A pacte d'actionnaires is a private shareholders' agreement. It is not filed with the greffe and does not appear in the public record. Its existence may sometimes be inferred from references in filed statuts, but its content is not accessible through official sources.
Sources
- Registre du commerce et des sociétés (RCS) — via Infogreffe: https://www.infogreffe.fr — extracted 2026-09-10
- BODACC (Bulletin officiel des annonces civiles et commerciales) — https://www.bodacc.fr — extracted 2026-09-10
- Registre public des procédures collectives (RPPC) — https://www.registre-procedures-collectives.fr — extracted 2026-09-10
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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
