France operates a beneficial ownership register embedded in the national trade register. Who controls a French company — and what a shareholder can enforce — depends on what that register discloses and to whom. Since November 2022, the answer has changed materially.
The register names the individuals who ultimately control a French legal entity. It records the nature and extent of that control. It does not, however, show the full ownership chain in every case, and public access to the data has been curtailed by court order. Control is the central question this register was designed to answer; the sources now answer it only partially, and only for certain categories of requester.
What the register showsThe identity of beneficial owners (individuals holding more than 25% of capital or voting rights, or exercising control by other means), with the nature and percentage of their interest. Source: Registre des bénéficiaires effectifs (RBE), held within the Registre du Commerce et des Sociétés (RCS) · verified 2026-09-01 Access after CJEU C-37/20Following the Court of Justice of the EU ruling of 22 November 2022, general public access to UBO registers across EU member states was suspended. France restricted access accordingly: the register is no longer open to the general public without demonstrated legitimate interest. Verified 2026-09-01 Who retains accessCompetent authorities (AML supervisors, prosecutors, tax administration), obliged entities conducting customer due diligence under AML obligations, and persons or organisations demonstrating a legitimate interest. The definition of legitimate interest is applied by the registrar on a case-by-case basis. Verified 2026-09-01 What the register does not showIntermediate holding layers above the 25% threshold that fall below it; nominee arrangements not disclosed to the registrar; trust structures where the trustee is the registered shareholder; and the full corporate chain where ownership passes through non-French entities.The Registre des bénéficiaires effectifs (RBE) was established under French law transposing the Fourth EU Anti-Money Laundering Directive. It is maintained by the clerks of the commercial courts (greffes des tribunaux de commerce) and forms part of the broader RCS.
Every legal entity registered in France must file a declaration identifying its beneficial owners. The declaration covers individuals who hold, directly or indirectly, more than 25% of the capital or voting rights, or who exercise control through other means — including the right to appoint or remove a majority of the board.
The filed declaration includes: full name, date and place of birth, nationality, country of residence, and the nature and percentage of the interest held. The address of the beneficial owner is not part of the public-facing record.
Entities subject to the obligation include commercial companies (SA, SAS, SARL, SNC), economic interest groupings, and certain other legal persons. Associations and foundations follow a separate regime.
The declaration must be updated within 30 days of any change in beneficial ownership. Failure to file or to update is a criminal offence under French law.
The RBE is designed to answer one question: who ultimately controls this entity? For straightforward structures — a French SARL with two individual shareholders — the register answers that question directly. The names, percentages, and nature of control are on file.
For layered structures, the answer is less complete. Where a French company is owned by another French company, the chain must be traced through successive RBE filings. Where a French company is owned by a foreign entity, the chain stops at the French level. The foreign entity's beneficial ownership is governed by the law of its own jurisdiction.
The register records what was declared. It does not independently verify the accuracy of declarations. A discrepancy between the RBE filing and the actual ownership structure is possible; the register does not flag it.
Voting agreements, shareholders' agreements, and contractual control arrangements are not captured in the RBE. A shareholder holding 20% of capital but exercising de facto control through a shareholders' agreement will not appear in the register on that basis alone — unless the agreement grants rights that meet the statutory definition of control.
The CJEU ruling in Joined Cases C-37/20 and C-601/20 (22 November 2022) held that general public access to UBO registers was incompatible with the right to privacy under the EU Charter of Fundamental Rights. France suspended unrestricted public access following that ruling.
The current French access regime operates on three tiers:
| Category of requester | Access granted |
|---|---|
| Competent authorities (AML, tax, prosecution) | Full access, no condition |
| Obliged entities (banks, notaries, lawyers, auditors) conducting CDD | Access for the purpose of the specific due diligence obligation |
| Persons or organisations with a demonstrated legitimate interest | Access subject to assessment by the registrar |
The third category is the operative one for most cross-border verification requests. The concept of legitimate interest is not defined exhaustively in French law. The registrar applies it on a case-by-case basis. Journalists, civil society organisations, and persons with a direct connection to the entity have been recognised in guidance as potential legitimate interest holders. A foreign buyer conducting pre-acquisition due diligence may qualify; the outcome depends on the specific circumstances presented.
A request that does not establish legitimate interest will be refused. The refusal can be challenged, but the challenge adds time to the process.
The RBE shows the declared beneficial owner at the time of the last filed update. It does not show:
Where a French company is held through a chain of foreign entities, the RBE identifies the French entity's declared beneficial owner. Whether that person is the ultimate beneficial owner of the chain as a whole cannot be established from the RBE alone.
The register does not show whether a beneficial ownership declaration has been challenged or is under investigation. A filing that appears complete and current may be the subject of a pending enforcement action that is not visible in the register.
For structures involving trusts, the RBE does not capture the trust itself as a beneficial owner. Where a trustee holds shares in a French company, the trustee appears as the shareholder; the beneficiaries of the trust do not appear in the RBE unless they independently meet the statutory threshold.
The ceiling of what the sources allow is stated before any engagement. Where the chain breaks, the break is identified and its cause is named.
The RBE filing and the company's statuts (articles of association) can diverge. The statuts record the legal ownership structure; the RBE records the declared beneficial ownership. Where the two are inconsistent — for example, where the statuts show a corporate shareholder but the RBE names an individual who does not appear in the statuts — the discrepancy is itself a finding.
The RBE and the Infogreffe commercial register data can also diverge on the identity of directors and legal representatives. The RBE covers beneficial owners; the RCS covers legal representatives and registered capital. A person named as beneficial owner in the RBE may not appear as a director in the RCS, and vice versa. Both layers are necessary to map control fully.
Where the sources disagree, the disagreement is reported as a finding, not resolved by inference.
A report on beneficial ownership in France draws on the following sources:
The report maps what each source shows, what it does not show, and where the chain stops. It does not qualify the legal significance of the findings. That function belongs to a separate legal opinion.
Does France have a public beneficial ownership register? France maintains the RBE, but it is no longer publicly accessible without restriction. Following the CJEU ruling of November 2022, access requires either a professional AML obligation or a demonstrated legitimate interest. The register exists; general public access does not.
What does the 25% threshold mean in practice? An individual holding more than 25% of capital or voting rights must be declared. An individual holding exactly 25% or less is not captured by the threshold unless they exercise control by other means. A structure designed to keep all individual holdings at or below 25% may result in no individual appearing in the RBE, even where effective control is concentrated.
Can a foreign buyer access the RBE for due diligence purposes? A foreign buyer may qualify as a person with a legitimate interest, but access is not automatic. The request must demonstrate the connection between the requester and the entity, and the purpose of the enquiry. The registrar assesses each request individually.
What happens if the RBE filing is out of date? The obligation to update within 30 days of a change is a legal requirement. Non-compliance is a criminal offence. However, the register does not flag stale filings automatically. A filing that has not been updated will appear current in the register. Cross-referencing with other sources — BODACC announcements, filed accounts, statuts amendments — can indicate whether a filing is likely to be current.
Does the RBE show the full ownership chain for a French subsidiary of a foreign group? No. The RBE shows the declared beneficial owner of the French entity. If the French entity is owned by a foreign parent, the chain above the French level is governed by the law of the parent's jurisdiction. The RBE does not capture that layer.
What is BODACC and why does it matter? BODACC is the official gazette for civil and commercial announcements. It records incorporations, capital changes, mergers, insolvency proceedings, and dissolutions. It is a public source. Cross-referencing the RBE with BODACC can reveal corporate events that post-date the last RBE update and may affect the accuracy of the current filing.
Sources:
Registre des bénéficiaires effectifs (RBE) — held within the Registre du Commerce et des Sociétés, administered by the greffes des tribunaux de commerce — https://www.infogreffe.fr — verified 2026-09-01
BODACC (Bulletin officiel des annonces civiles et commerciales) — https://www.bodacc.fr — verified 2026-09-01
Pappers (aggregated RCS and BODACC data) — https://www.pappers.fr — verified 2026-09-01
CJEU, Joined Cases C-37/20 and C-601/20, judgment of 22 November 2022 — verified 2026-09-01
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