France UBO Register: New Access Rules Explained

France has updated the rules governing access to its Beneficial Ownership Register (RBE). Following a landmark ruling by the Court of Justice of the European Union and the subsequent transposition of Directive (EU) 2024/1640, France has replaced open public access with a structured legitimate-interest access model. Companies with French entities need to understand what this means for their compliance processes.

What Is France’s Beneficial Ownership Register?

France’s Registre des Bénéficiaires Effectifs (RBE) — the Beneficial Ownership Register — is administered by the Institut National de la Propriété Industrielle (INPI). It holds information on the ultimate beneficial owners (UBOs) of legal entities registered in France.

All legal entities incorporated in France must identify their beneficial owners and file that information with the RBE. The register records the following details for each UBO:

• Full name and any usage name or pseudonym
• First names
• Month and year of birth
• Country of residence
• Nationality
• Nature and extent of the beneficial ownership interest

The obligation applies to commercial companies, including SAS, SARL, SA, and SNC structures, as well as associations and other legal entities.

What Changed and Why?

Until recently, the RBE was publicly accessible to anyone. That model was designed to promote corporate transparency and combat money laundering.

However, in November 2022, the Court of Justice of the European Union ruled that unrestricted public access to beneficial ownership registers violates Articles 7 and 8 of the EU Charter of Fundamental Rights, which protect private and family life and personal data. As a result, France restricted access from 31 July 2024.

The EU then codified this approach through Directive (EU) 2024/1640 of 31 May 2024. France transposed it via Law No. 2025-391 of 30 April 2025 (the DDADUE5 law) and implemented the operational details through Decree No. 2026-310 of 24 April 2026.

Together, these two instruments establish a clear, tiered system for who can access the RBE and under what conditions.

Who Can Now Access the RBE?

Access to the RBE is no longer open to the public. Instead, it is limited to two groups: authorised entities and persons with a legitimate interest.

Authorised entities with automatic access

The following categories can access the RBE without needing to justify a specific reason:

• Competent authorities and professionals subject to AML/CFT obligations (such as banks, notaries, and auditors)
• Journalists, researchers, and civil society organisations working on financial transparency
• The Agence française anticorruption
• Authorised officials of the Directorate-General of the Treasury and customs officials (when applying EU restrictive measures)
• The European Public Prosecutor’s Office (EPPO)
• The European Anti-Fraud Office (OLAF)
• Europol and Eurojust (when supporting national authorities)
• The European Anti-Money Laundering Authority (AMLA)
• Equivalent authorities of other EU Member States
• The High Authority for Transparency in Public Life
• The National Sanctions Commission
• State agents responsible for protecting France’s economic, industrial, and scientific interests
• Labour inspectorate and social security oversight officers
• The Court of Auditors and regional chambers of auditors

Persons with a legitimate interest

Other parties — including businesses conducting due diligence on potential counterparties — may access the RBE after demonstrating a legitimate interest. In practice, this means showing a relevant connection to AML compliance or business risk, such as verifying the ownership of a future commercial partner.

How to Request Access

Persons with a legitimate interest must submit a request to the INPI or to the competent court clerk.

The process works as follows:

1. Complete the INPI request form for access to beneficial ownership data
2. Attach supporting documents that justify the legitimate interest
3. Submit to INPI or the competent court clerk

Once a legitimate interest is recognised, the INPI or clerk issues an access certificate valid for three years. This certificate enables faster subsequent access without needing to re-justify the interest each time.

From 10 November 2026, the INPI and court clerks will have 12 days to rule on requests. Until that date, a two-month silence from the administration constitutes acceptance.

A Note on Deregistered Companies

The Decree of 24 April 2026 also introduced a regularisation mechanism for companies that were automatically removed from the Trade and Companies Register (RCS) due to incomplete or non-compliant beneficial ownership filings.

Such companies can now apply to the court clerk to have the cancellation reversed, provided they first bring their UBO data into compliance. The clerk has 15 days to respond. If the clerk refuses or fails to reply, the company may appeal to the President of the Court within a further 15 days.

This measure is particularly relevant for companies that received automatic cancellation notices and were unaware of the UBO filing gap.

What This Means for Compliance Teams

For multinationals managing French entities, the shift to legitimate-interest access has two main implications.

First, third parties can no longer freely look up your entities’ UBO data. Access is now gated. In practice, this means that counterparties conducting due diligence on your French subsidiaries will need to request access formally. You may receive more requests for UBO documentation directly from business partners.

Second, your own ability to look up other companies’ UBO data has changed. If your compliance team relies on the RBE as part of counterparty due diligence, you will need to either request access through the legitimate-interest route or confirm that your organisation qualifies as an authorised entity under the new rules.

Importantly, the obligation to register and keep UBO data accurate and current has not changed. All French entities must continue to file and update their beneficial ownership information. Failure to do so can result in automatic removal from the RCS — and, as of the April 2026 decree, a formal regularisation process is now required to reverse that.

What Companies Should Do Now

Given the current transition, compliance teams responsible for French entities should take the following steps:

• Verify that UBO filings for all French entities are complete, accurate, and up to date in the RBE
• Confirm that your organisation’s access rights are correctly classified — whether as an authorised entity or through the legitimate-interest route
• Prepare for counterparty access requests and build the documentation needed to support them
• Act before 10 November 2026, when the 12-day ruling period for access requests comes into force and the process becomes more formal

What’s Next?

France’s move to a legitimate-interest access model reflects a broader shift across the EU. Several Member States have introduced similar restrictions following the 2022 CJEU ruling, and the 6th Anti-Money Laundering Directive requires all Member States to align their UBO register access rules by 10 July 2026.

For more context on the EU-wide picture, read our article France UBO Enforcement Tightened Since June 2025.

Klea supports businesses with centralised governance tools, automated compliance tracking, and secure documentation workflows across jurisdictions. Companies looking to manage French UBO obligations efficiently can:

• Request a Demo – See Klea in action for your organisation.
• Start a Trial – Experience firsthand how automation reduces workload and improves efficiency.
• Talk to Our Experts – Get tailored recommendations based on your entity management needs.

Company secretarial software plays a vital role in maintaining structured governance and consistent compliance. With Klea, organisations can keep regulatory change manageable, transparent, and under control.

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