France maintains two parallel public disclosure systems for corporate and judicial events: the tribunal commercial register and the Bulletin officiel des annonces civiles et commerciales (BODACC). Together they form the primary layer for establishing what has been filed, adjudicated, or published about a French entity. Neither system was designed to answer the question of who controls the company. That question requires a separate chain of sources.
The angle of control — who holds decision-making authority, what a shareholder can enforce, and where the formal record ends — runs through both systems in a specific way. BODACC publishes the event. The tribunal record holds the underlying document. The gap between the two is where the analysis begins.
What BODACC showsInsolvency proceedings (sauvegarde, redressement judiciaire, liquidation judiciaire), court-ordered modifications, and corporate events filed with the greffe. Source: BODACC — bodacc.fr · verified 2026-09-15 What the tribunal commercial record showsFiled statutes, amendments, annual accounts (where deposited), and judicial decisions affecting the entity. Source: Infogreffe / greffe du tribunal de commerce · verified 2026-09-15 Access conditionBODACC is free and publicly searchable without registration. Tribunal documents carry per-document fees set by the greffe; no registration is required to request them. What neither source showsBeneficial ownership, shareholder identity below the statutory disclosure threshold, and the content of shareholders' agreements.BODACC is the official gazette for civil and commercial announcements in France. It is published by the Direction de l'information légale et administrative (DILA) and is freely accessible without registration.
Every announcement in BODACC is a downstream publication of a filing made at the greffe du tribunal de commerce. The gazette does not generate information; it republishes what the greffe has received. This distinction matters for verification: if an announcement appears in BODACC but the underlying document at the greffe differs, the greffe document controls.
BODACC covers the following event categories:
For a buyer verifying a French counterparty, the insolvency section is the primary check. An absence of a BODACC entry does not certify that no proceeding has been opened; it certifies that no proceeding has been published as of the search date. A proceeding opened but not yet published — or published under a variant of the entity name — will not appear.
Source: BODACC — bodacc.fr · extracted 2026-09-15
The greffe du tribunal de commerce holds the physical and electronic record for each registered entity. Access to filed documents is available through Infogreffe, the national platform operated by the network of greffe offices.
The tribunal record contains:
The Kbis is the standard document requested in French commercial practice to verify the existence and current status of an entity. It names the current legal representative (gérant for SARL, président or directeur général for SAS/SA). It does not name shareholders.
Per-document fees apply to tribunal records. The fee schedule is set by the greffe and published on Infogreffe. No exact tariff is stated here because fees are subject to revision; the current schedule is available directly on the Infogreffe platform.
Source: Infogreffe — infogreffe.fr · extracted 2026-09-15
The question of control in a French entity breaks into three layers. The tribunal record addresses only the first.
Layer 1 — Named legal representative. The Kbis names the person authorised to bind the entity. For a SARL, this is the gérant. For a SAS, this is the président and any directeur général named in the statuts. This information is current as of the last filed modification.
Layer 2 — Shareholder identity. For a SARL, the statuts filed at the greffe must list the associés and their parts sociales at incorporation. Subsequent transfers are recorded in a registre des mouvements de titres held by the company, not at the greffe. The greffe record may therefore show the original shareholders but not the current ones if transfers have occurred without a statutory amendment.
For a SAS, the statuts need not list shareholders at all. The SAS is the dominant form for holding structures and venture-backed companies in France precisely because shareholder identity is not publicly disclosed through the greffe.
Layer 3 — Beneficial ownership. France implemented the EU beneficial ownership register under Article L. 561-46 of the Code monétaire et financier. The Registre des bénéficiaires effectifs (RBE) is held at the greffe. Following the CJEU judgment in C-37/20 (November 2022), public access to the RBE was suspended for natural persons. Access is now restricted to competent authorities, obligated entities under AML law, and persons demonstrating a legitimate interest. A cross-border buyer does not automatically qualify. The mechanism for demonstrating legitimate interest is defined by the greffe and subject to case-by-case assessment.
The chain therefore breaks at Layer 2 for SAS structures and at Layer 3 for all structures. The tribunal record establishes who signs for the company. It does not establish who owns it or who instructs the signatory.
An absence of a BODACC insolvency entry is not a clean bill of health. Three conditions limit what the absence proves:
Publication lag. A judgment opening a sauvegarde or redressement judiciaire is published in BODACC within a statutory period, but the period runs from the judgment, not from the filing of the petition. A petition filed and a hearing scheduled but not yet decided will not appear.
Name variants. BODACC is searchable by entity name and SIREN number. A search by name alone may miss entries filed under a slightly different commercial name or a previous name. A SIREN-based search is more reliable but requires knowing the correct SIREN.
Territorial scope. BODACC covers proceedings opened before French tribunaux de commerce and tribunaux judiciaires with commercial jurisdiction. A proceeding opened in another EU member state under the EU Insolvency Regulation (Regulation 2015/848) will appear in the European Insolvency Register, not in BODACC.
For a counterparty with operations in multiple jurisdictions, a BODACC search is a necessary but not sufficient step.
Source: BODACC — bodacc.fr · extracted 2026-09-15
French law requires deposit of annual accounts at the greffe for most commercial entities. The obligation applies to SA, SAS, and SARL above the micro-enterprise threshold. The accounts are publicly accessible through Infogreffe once filed.
Three limitations apply:
Filing delay. Accounts must be filed within one month of approval by the general meeting (or two months for electronic filing). Approval typically occurs within six months of the financial year end. A company with a December year-end may therefore file accounts up to eight months after the period closes. The most recent filed accounts may be eighteen months old at the time of a search.
Confidentiality option for small entities. Under Article L. 232-25 of the Code de commerce, small companies (petites entreprises as defined by the Code) may declare their accounts confidential. The filing is made but the accounts are not disclosed to the public; only competent authorities and certain professional categories may access them. A confidentiality declaration will appear in the greffe record; the accounts themselves will not.
Consolidated accounts. A French holding company that is itself a subsidiary of a foreign parent may file only its standalone accounts. The consolidated group accounts, if prepared at the parent level, are filed in the parent's jurisdiction.
Source: Infogreffe — infogreffe.fr · extracted 2026-09-15
The tribunal commercial record and BODACC together establish the following with a high degree of reliability: the entity exists, its legal form and registered address, the name of its current legal representative, the existence of any published insolvency proceeding, and the content of filed documents including accounts where not declared confidential.
The sources do not establish the following:
The analysis establishes the chain to the point where the source breaks and names the break. For a SAS holding structure, the chain from the legal representative to the shareholder is not established by the public record. That is a finding, not a gap in the analysis.
Two specific divergences arise regularly in French corporate records.
BODACC entry versus greffe document. BODACC publishes a summary of the event. The underlying document at the greffe may contain conditions, dates, or parties not reflected in the summary. Where the two differ, the greffe document is authoritative. A BODACC-only search is not a document-level search.
Kbis versus statuts. The Kbis reflects the current state of the registration as maintained by the greffe. The statuts on file reflect what was deposited at the last amendment. If a modification was registered but the statuts were not re-filed in full, the Kbis may show a change that the filed statuts do not yet reflect. Both documents are required for a complete picture.
Does a clean BODACC search confirm that a French company is not insolvent? A clean BODACC search confirms that no insolvency proceeding has been published as of the search date. It does not confirm that no petition has been filed or that no proceeding is pending before publication. It also does not cover proceedings opened in other EU jurisdictions.
Can the beneficial owners of a French SAS be identified from public records? Not as a general rule. The SAS form does not require shareholder disclosure in filed documents. The RBE holds beneficial ownership data, but public access was suspended following the CJEU judgment in C-37/20. Access requires demonstrating a legitimate interest to the greffe on a case-by-case basis.
What does the Kbis confirm about who controls a French company? The Kbis confirms the identity of the current legal representative — the person authorised to bind the entity in third-party dealings. It does not confirm who holds the shares, who appoints the legal representative, or what instructions the legal representative operates under.
Are annual accounts always available for French companies? No. Small companies may declare their accounts confidential under Article L. 232-25 of the Code de commerce. The filing is made but the accounts are withheld from public access. The confidentiality declaration itself is visible in the greffe record.
What is the difference between BODACC and the tribunal commercial record? BODACC is a downstream publication of events filed at the greffe. The tribunal commercial record is the primary source. BODACC is useful for event-level searches across the national database. The greffe record is required for document-level verification.
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