France maintains two distinct public layers for corporate control: the commercial register and the beneficial ownership register. Both are accessible to third parties. Both have structural limits that matter before a cross-border transaction closes.
The question of control — who directs the company and who ultimately owns it — runs through both layers. The appointed director appears in the Registre du commerce et des sociétés (RCS). The declared beneficial owner appears in the Registre des bénéficiaires effectifs (RBE), which is held by the same registry body, the Greffe du tribunal de commerce. What each layer discloses, and where each stops, is stated below before any payment is made.
Director disclosureFull name, date and place of birth, nationality, and address of the appointed director(s) — filed at the Greffe du tribunal de commerce. Source: Registre du commerce et des sociétés · verified 2026-09-01 Beneficial owner disclosureFull name, date and place of birth, nationality, country of residence, and the nature and extent of the beneficial interest — filed under Article L. 561-46 of the Code monétaire et financier. Source: Registre des bénéficiaires effectifs · verified 2026-09-01 Access conditionThird-party access to the RBE requires a declaration of legitimate interest following the CJEU ruling C-37/20; unrestricted public access was suspended. Access to the RCS director record remains open. Source: Greffe du tribunal de commerce · verified 2026-09-01 What neither register showsNeither register discloses nominee arrangements, side agreements between shareholders, or the economic terms of any shareholders' agreement (pacte d'actionnaires).What the commercial register discloses about directors
The RCS records every person holding a mandate as gérant, président, directeur général, or member of the conseil d'administration or conseil de surveillance. For each mandataire, the register shows full name, date and place of birth, nationality, and the registered address used for service.
The register also records the date of appointment and, where applicable, the date of cessation of mandate. A historical extract (extrait Kbis historique) shows all mandates since incorporation, including those that have ended. This is the primary instrument for establishing the continuity of control over time.
Amendments to the mandate — a change of director, a new appointment, a resignation — must be filed within one month of the event. The register reflects the filed position, not the operational reality on any given day. A gap between the two is possible and is noted in the analysis.
Source: Registre du commerce et des sociétés (Greffe du tribunal de commerce) · verified 2026-09-01
What the beneficial ownership register discloses
The RBE was established by Ordonnance n° 2016-1635 of 1 December 2016, transposing the Fourth Anti-Money Laundering Directive. Every French legal entity subject to registration at the RCS must file a declaration identifying each natural person who ultimately holds, directly or indirectly, more than 25% of the capital or voting rights, or who exercises control by other means.
The filed declaration states: full name, date and place of birth, nationality, country of residence, and the nature and extent of the beneficial interest (percentage of capital, percentage of voting rights, or description of the control mechanism).
Following the CJEU judgment of 22 November 2022 in Joined Cases C-37/20 and C-601/21, France suspended unrestricted public access to the RBE. Access is now conditional on demonstrating a legitimate interest. The categories of persons who may access the register without that condition — competent authorities, obliged entities under AML law, journalists — are defined in Article L. 561-46 CMF as amended.
A professional acting under a mandate from a party with a documented legitimate interest may obtain the declaration. The analysis states the access pathway used and the date of extraction.
Source: Registre des bénéficiaires effectifs (Greffe du tribunal de commerce) · verified 2026-09-01
Corporate structure and shareholding
For a société à responsabilité limitée (SARL), the list of associés with their respective shares (parts sociales) is filed at the RCS and is accessible in the company's statuts and any subsequent actes modificatifs. For a société par actions simplifiée (SAS) or société anonyme (SA), the register of shareholders (registre des mouvements de titres) is held internally by the company and is not filed at the Greffe. It is not accessible through the RCS.
This distinction is material. An SAS — the dominant form for holding structures and venture-backed companies in France — does not disclose its shareholders through the commercial register. The RBE declaration covers the beneficial owner above the 25% threshold; it does not reproduce the full cap table.
For listed companies, the Autorité des marchés financiers (AMF) requires disclosure of shareholdings above 5% thresholds. That layer is separate from the RCS and the RBE and is covered in the Extended tier.
Source: Registre du commerce et des sociétés · verified 2026-09-01
Financial statements and accounts
French companies are required to file annual accounts at the Greffe. The filed accounts are accessible through the RCS and through the INPI data platform (data.inpi.fr). The depth of disclosure depends on company size.
Micro-enterprises and small companies may elect confidentiality under Article L. 232-25 of the Code de commerce. Where confidentiality is elected, the income statement is not disclosed to the public; only the balance sheet is available. The analysis records whether confidentiality has been elected and what is therefore accessible.
Medium and large companies file full accounts without a confidentiality option. The filed accounts show total assets, equity, turnover (where not subject to confidentiality), and the statutory auditor's report where one is required.
Source: INPI / data.inpi.fr · Greffe du tribunal de commerce · verified 2026-09-01
Insolvency and judicial proceedings
Proceedings under the Code de commerce — sauvegarde, redressement judiciaire, liquidation judiciaire — are recorded in the Bulletin officiel des annonces civiles et commerciales (BODACC) and reflected in the RCS. The Registre public des procédures collectives (RPPC) held by the Conseil national des greffiers des tribunaux de commerce provides a searchable index.
A negative result in these registers does not exclude the existence of a filed petition that has not yet been published. The analysis states the date of the search and the scope of the registers checked.
Source: BODACC · Registre public des procédures collectives · verified 2026-09-01
The limit of what the sources allow
The RCS and RBE together establish the declared control structure. They do not establish the actual control structure where it diverges from the declared one.
Specific limits:
- The RBE declaration reflects what was filed. It is not independently verified by the Greffe at the time of filing. A declaration that understates the beneficial interest, or that names a nominee rather than the true beneficial owner, will appear in the register without correction.
- For an SAS, the full shareholder list is not in the public record. The analysis establishes the declared beneficial owner above 25%; it does not reconstruct the full cap table from public sources.
- A pacte d'actionnaires — a shareholders' agreement governing voting rights, pre-emption, drag-along, or tag-along — is a private document. It is not filed at the Greffe and does not appear in any public register. Its existence may be inferred from the statuts if it is referenced there, but its terms are not disclosed.
- Director liability and the enforceability of shareholder rights are legal questions. This analysis establishes the factual record; it does not qualify the legal consequences of what the record shows.
- The RBE access pathway post-CJEU C-37/20 requires a declaration of legitimate interest. Where access is refused or delayed, the analysis records that outcome and states the reason given.
The ceiling of what the sources allow is stated before payment.
Where the sources disagree
Where the declared beneficial owner in the RBE and the shareholding structure inferable from the statuts or filed accounts point to different persons or percentages, the analysis records both data points and identifies the discrepancy explicitly.
A discrepancy between the filed director mandate and the signatory on filed documents — for example, a person signing company filings who does not appear as a mandataire in the RCS — is noted as a factual finding. The analysis does not qualify its legal significance; it records it.
Where the most recent filed accounts and the RBE declaration carry different dates, and where a corporate event (capital increase, transfer of shares, change of control) falls between those dates, the analysis identifies the gap and states what cannot be confirmed from the record as it stands.
What is included at each tier
| Tier | Price | What is included | Not included |
|---|---|---|---|
| Signal | €1,350 | Current director(s) from RCS: name, mandate dates, address. Current RBE declaration: beneficial owner name, interest type and percentage. BODACC insolvency check. Summary of access conditions applied. | Historical mandates. Full account analysis. Shareholder list for SAS. AMF threshold disclosures. Cross-border chain tracing. |
| Standard | €2,850 | Everything in Signal, plus: historical Kbis extract covering all mandates since incorporation. Filed accounts for the last three available years, with confidentiality status noted. Registre public des procédures collectives search. Identification of any discrepancy between RBE and statuts. | AMF threshold disclosures. Cross-border chain tracing beyond French entities. Legal qualification of findings. |
| Extended | €6,300 | Everything in Standard, plus: AMF shareholding threshold disclosures where applicable. Cross-border chain tracing through intermediate holding entities in other jurisdictions covered by the VLO registry network. Analysis of any pacte d'actionnaires references in filed documents. Identification of gaps between declared and inferable control. Written summary of the point at which the record stops and what remains unverifiable. | Legal advice. Qualification of director liability. Enforcement strategy. |
FAQ
Does the RBE show the full ownership chain for a French holding company? The RBE shows the natural person(s) who ultimately hold more than 25% of capital or voting rights, or who exercise control by other means. It does not reproduce the intermediate chain of entities. Where the holding structure passes through one or more intermediate companies — French or foreign — the register names the end beneficial owner and states the nature of the interest, but does not map each intermediate layer. The Extended tier traces the intermediate chain through available registry sources.
Is the RBE accessible to a foreign buyer conducting due diligence? Following CJEU C-37/20, access requires a declaration of legitimate interest. A party to a contemplated transaction — acquisition, joint venture, financing — generally qualifies. The access pathway is documented in the analysis. Where access is refused, the refusal and its stated basis are recorded.
What does the RCS show for a société par actions simplifiée? For an SAS, the RCS shows the président and, where appointed, the directeur général and members of any supervisory body. It does not show the list of shareholders (associés). The statuts filed at incorporation may name the founding shareholders, but subsequent transfers of shares are not filed at the Greffe and do not appear in the public record.
Can a pacte d'actionnaires be identified from public sources? The existence of a pacte d'actionnaires may be referenced in the statuts or in a filing at the Greffe, but its terms are not disclosed. The analysis identifies any such reference. The content of the agreement is not accessible through public registers.
What is the difference between the Signal and Standard tiers for a French target? Signal establishes the current declared position: who the director is today, who the declared beneficial owner is today, and whether insolvency proceedings are recorded. Standard adds the historical mandate record, three years of filed accounts, and a cross-check between the RBE declaration and the shareholding structure inferable from filed documents. The discrepancy analysis in Standard is the layer most relevant to a buyer who has already reviewed the current position and needs to understand how it was reached.
Sources: - Registre du commerce et des sociétés (Greffe du tribunal de commerce) — https://www.infogreffe.fr — verified 2026-09-01 - Registre des bénéficiaires effectifs — held by Greffe du tribunal de commerce — verified 2026-09-01 - INPI data platform — https://data.inpi.fr — verified 2026-09-01 - Bulletin officiel des annonces civiles et commerciales (BODACC) — https://www.bodacc.fr — verified 2026-09-01 - Registre public des procédures collectives — https://www.registre-procedures-collectives.fr — verified 2026-09-01 - Autorité des marchés financiers (AMF) — https://www.amf-france.org — verified 2026-09-01
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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
