Every company registered with France’s Registre du commerce et des sociétés (RCS) must declare its ultimate beneficial owner (UBO, or bénéficiaire effectif): the natural person who ultimately owns or controls the entity. Older guidance is now wrong on two counts. Filing moved to the INPI Guichet unique in 2023, and open public access ended with a 2022 EU court ruling.
This guide gives the current rules. A UBO is a natural person holding more than 25% of capital or voting rights, or exercising control by other means, under Article R.561-1 of the Code monétaire et financier (CMF), the French monetary and financial code.
What Are the UBO Filing Requirements in France?
Every RCS-registered legal entity in France must declare the natural person holding more than 25% of its capital or voting rights, or controlling it by other means. Declarations go through the INPI Guichet unique at registration, with updates within 30 days of any change. Non-compliance now reaches €200,000 for individuals under the 2026 reform.
Table 1: UBO filing requirements at a glance
| Requirement | Rule | Legal source |
|---|---|---|
| Who files | All RCS-registered legal entities, including French branches of foreign firms | Art. L.561-46 CMF (Legifrance) |
| Threshold | Natural person with more than 25% of capital or voting rights, or control by other means | Art. R.561-1 CMF (Legifrance) |
| Where | INPI Guichet unique (procedures.inpi.fr), sole channel since 1 January 2023 | INPI |
| When | At registration, then updates within 30 days of any change | Art. R.561-55 CMF (Legifrance) |
| Penalty | Up to €200,000 (individuals), €1,000,000 (entities), 15-year management ban | Art. L.574-5 CMF, Loi n° 2026-403 |
What Is an Ultimate Beneficial Owner (UBO) Under French Law?
A UBO is a natural person who holds, directly or indirectly, more than 25% of a company’s capital or more than 25% of its voting rights, or who exercises control by other means over its management or general meeting. The threshold is strictly more than 25%, per Article L.561-2-2 CMF and Art. R.561-1 CMF.
There is no 10% rule in the standard French regime. If three shareholders each hold 30% of a company, all three are UBOs, because each exceeds the 25% threshold set by Art. R.561-1 CMF. Ownership is traced through intermediate entities, so a person controlling a parent is a UBO of the subsidiary too.
What Happens If No One Owns More Than 25%?
When no natural person meets the ownership or control tests, the company’s legal representative is declared as the UBO of last resort under Articles R.561-1 to R.561-3 CMF. That is the gérant for a SARL and the président for a SAS. Every RCS-registered company therefore always has a UBO to declare, even widely-held ones. This fallback is the point most guides miss.
Who Must File a UBO Declaration in France?
All legal entities registered with the RCS must file, including French branches of foreign companies, under Art. L.561-46 CMF. Companies listed on a regulated market with equivalent disclosure are exempt, and associations not registered with the RCS fall outside the regime. The table below sets out the common forms.
Table 2: entity types in scope vs exempt
| Entity type | In scope? | Source |
|---|---|---|
| SARL / EURL (private limited, single-member variant) | Yes | Art. L.561-46 CMF |
| SAS / SASU (simplified joint-stock, single-member variant) | Yes | Art. L.561-46 CMF |
| SA (public limited company) | Yes | Art. L.561-46 CMF |
| SNC (société en nom collectif) | Yes | Art. L.561-46 CMF |
| SCS / SCA (partnerships limited by shares) | Yes | Art. L.561-46 CMF |
| SCI (société civile immobilière) | Yes | Art. L.561-46 CMF |
| GIE (economic interest grouping) | Yes | Art. L.561-46 CMF |
| Foreign branch (succursale) registered in France | Yes | INPI |
| RCS-registered associations | Yes | Art. L.561-46 CMF |
| Listed companies on a regulated market | Exempt | Art. L.561-46 CMF |
| Associations not registered with the RCS | Out of scope | INPI |
Do SARL and SAS Companies Have to File a UBO Declaration?
Yes, both the SARL and the SAS must file, as must their single-member variants, the EURL and the SASU. Where no shareholder crosses 25%, the fallback UBO is the gérant for a SARL or the président for a SAS, under Articles R.561-1 to R.561-3 CMF. These are the forms most foreign founders use for a French subsidiary.
Does a Foreign Branch in France Need to File?
Yes. A foreign company with a branch (succursale) or establishment registered in France must declare the UBOs of the foreign parent to the French register, per INPI guidance. Tracing runs up the ownership chain to the ultimate natural person. Registration extracts for the foreign parent, the equivalent of a French Kbis, evidence the chain and are often translated or apostilled.
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What Is the French Beneficial Ownership Law?
France’s beneficial ownership regime sits in the Code monétaire et financier and transposes EU directives. Directive (EU) 2015/849, the Fourth Anti-Money Laundering Directive (AMLD4), created UBO registers and was adopted on 20 May 2015. France transposed it through Ordonnance n° 2016-1635 of 1 December 2016, with the declaration duty applying from 1 August 2017. The table citations below are the operative articles.
| Area | Citation |
|---|---|
| Definition of beneficial owner | Art. L.561-2-2 CMF (Legifrance) |
| Ownership and control criteria, fallback rule | Art. R.561-1 to R.561-3 CMF (Legifrance) |
| Duty to declare and register access | Art. L.561-46 to L.561-50 CMF (Legifrance) |
| Criminal penalties | Art. L.574-5 CMF (Legifrance) |
| International standard | FATF Recommendation 24, tightened March 2022 |
The register, the Registre des bénéficiaires effectifs (RBE), is maintained by INPI (Institut national de la propriété industrielle) and consolidated into the Registre national des entreprises (RNE) since 1 January 2023.
What Documents Are Required for UBO Filing in France?
Each UBO declaration records full name, date and place of birth, nationality, residential address, and the nature and extent of control held. You also give the company’s registration number and, for owned structures, proof of the parent’s registration such as a Kbis extract. The supporting form depends on when the company was created, per INPI.
Table 3: required document by company creation date
| Company creation date | Required document | Source |
|---|---|---|
| Before January 2021 | DBE-S-1 (Document relatif au bénéficiaire effectif) | INPI |
| January 2021 to January 2023 | Cerfa 16062*01 (Déclaration relative au(x) bénéficiaire(s) effectif(s)) | INPI (legacy) |
| After January 2023 | Copie intégrale des informations déclarées, filed via the Guichet unique | INPI |
Is the Cerfa 16062 Form Still Used for UBO Declarations?
The paper Cerfa 16062*01 is legacy. It covered companies created between January 2021 and January 2023, before the online portal went live. Since the INPI Guichet unique became the sole channel on 1 January 2023, declarations are made online rather than on the paper form, per INPI. New filers never use the Cerfa; it survives only as the historical record for that cohort.
How Do You File a UBO Declaration in France Step by Step?
File online through the INPI Guichet unique at procedures.inpi.fr, the single mandatory portal since 1 January 2023. The former Infogreffe and greffe route no longer applies. The five steps are below.
- Identify the UBOs. Apply the more-than-25% capital test, the more-than-25% voting-rights test, and the control-by-other-means test. Use the legal-representative fallback if none applies.
- Gather documentation. Collect UBO identity documents, articles of association, cap tables, and parent-entity registration extracts for owned structures.
- Complete the online declaration. Enter each UBO’s details and the nature and extent of control.
- Submit via the Guichet unique. The legal representative or an authorized agent files at procedures.inpi.fr.
- Keep the register current. Update within 30 days of any change in ownership or control.
What Are the UBO Filing Deadlines in France?
File the initial declaration at company registration with the RCS, so beneficial ownership is on record from the outset. After that, file a corrective or supplementary declaration within 30 days of any event that makes the recorded information inaccurate or incomplete, under Article R.561-55 CMF. The accuracy duty is continuous, not a one-off.
Triggering events include a share transfer, a funding round that pushes a holder above 25%, a founder buyout, a parent restructuring, a change of legal representative under the fallback rule, or even a UBO moving house, since an address change counts.
What Are the Penalties for UBO Non-Compliance in France?
Penalties rose sharply in 2026. Under Article L.574-5 CMF as amended by Loi n° 2026-403 of 26 May 2026, failing to declare or filing inaccurate information exposes an individual to a fine up to €200,000 and a legal entity up to €1,000,000, in force since 28 May 2026. The former six-month prison term was removed.
Table 4: penalties for UBO non-compliance
| Penalty | Applies to | Maximum | Source |
|---|---|---|---|
| Fine (current) | Individual (legal representative) | €200,000 | Art. L.574-5 CMF, Loi n° 2026-403, from 28 May 2026 |
| Fine (current) | Legal entity | €1,000,000 | Art. L.574-5 CMF, Loi n° 2026-403, from 28 May 2026 |
| Management ban | Director | Up to 15 years | Art. L.574-5 CMF, Loi n° 2026-403 |
| Fine plus prison (former regime) | Individual | €7,500 and 6 months, pre-28 May 2026 | Art. L.574-5 CMF (prior text) |
| Fine (former regime) | Legal entity | €37,500, pre-28 May 2026 | Art. L.574-5 CMF (prior text) |
| Dissolution, judicial supervision, establishment closure, public-tender exclusion | Legal entity | Up to 5 years where time-limited | Art. 131-39 Penal Code |
| Registration denial for a new entity | Non-filing company | Blocked RCS formality | INPI / greffe practice |
How Do You Avoid UBO Filing Penalties in France?
File the declaration at registration, then calendar the 30-day update rule for every ownership change. Re-check UBOs after any share transfer, funding round, or restructuring. Remember the legal-representative fallback so widely-held entities still declare. Retain supporting documents, including cap tables and parent extracts, so the recorded chain stays defensible if a registrar or bank asks.
How Does UBO Filing Work for Foreign-Owned Companies in France?
Trace ownership up the chain to the ultimate natural person, applying France’s more-than-25% test at the top. If Company A in France is 100% owned by Company B abroad, and Mr. X owns 30% of Company B, then Mr. X indirectly controls A and is a UBO of A, because 30% exceeds the Art. R.561-1 CMF threshold.
Use the French 25% figure, not another regime’s. The AMLD4 standard in Directive (EU) 2015/849 treats more than 25% as the ownership indicator, while some sector-specific or FATF and US contexts cite 10%. Applying the wrong threshold is a common foreign-parent error. Foreign parent registration extracts evidence each tier of the chain.
Is the France UBO Register Public?
No. The France UBO register is no longer open to the general public. The Court of Justice of the European Union (CJEU) ruled on 22 November 2022, in Joined Cases C-37/20 and C-601/20, that blanket public access breaches Articles 7 and 8 of the EU Charter of Fundamental Rights. France then restricted access accordingly.
Since 31 July 2024, under the French Ministry of the Economy’s revised access rules, consultation is limited to competent authorities, AML-obligated entities performing know-your-customer (KYC) checks, and persons showing a legitimate interest, such as journalists, researchers, and civil society. At-risk UBOs can request restriction of their data. This regime is still moving.
What Is Changing Under the 2024 EU AML Package?
The EU’s 2024 anti-money-laundering (AML) package reshapes the regime from 2027. Regulation (EU) 2024/1624 sets a single rulebook, Directive (EU) 2024/1640 (AMLD6) updates register rules, and a further regulation creates the EU Anti-Money Laundering Authority (AMLA) in Frankfurt. Application is phased mostly from 2027, with harmonized legitimate-interest access and stricter verification of beneficial ownership data.
The trend is clear across four markers. France transposed AMLD4 in 2017. The CJEU closed open public access in 2022. INPI centralized filing in 2023. The EU AML package lands from 2027. Expect tighter verification, so keep ownership records clean now.
How We Help With UBO Filing in France
Commenda’s entity management platform prepares and submits UBO declarations through the INPI Guichet unique, tracks the 30-day update obligation, and keeps ownership records current across every jurisdiction you operate in. It gives controllers certainty of compliance: if a French UBO filing is required, it is tracked, and if it is tracked, it is handled.
Pair it with the Commenda compliance calendar to diarize filing deadlines by entity, so a funding round or share transfer never slips past the 30-day window. For cross-border groups, global tax ID verification confirms the registration details behind each tier of the ownership chain.
Book a demo to get a compliance check on your French entity’s UBO filings.
About the author
Logan leads Commenda’s Services and Operations team, helping controllers, heads of tax, and finance leaders navigate international expansion. He built a global expert network across 70 countries and previously worked in management consulting across the Middle East and Southeast Asia.
Disclaimer: Commenda and its affiliates do not provide tax, accounting, or legal advice. This material has been prepared for informational purposes only, and is not intended to provide or be relied on for tax, accounting, or legal advice. You should consult your own tax, accounting, and legal advisors before engaging in any related activities or transactions.
