Carte de Visite Fonctionnelle — your ACPR reporting scope

Most French reporting teams believe their filing scope is something they worked out from the regulations. It is not. For institutions reporting to the ACPR, the authoritative list of what you owe is a document the ACPR generates and publishes to you on ONEGATE: the Carte de Visite Fonctionnelle. And it is generated from a form you filled in yourself — the fiche déclarative. Get that form wrong and the CVF is wrong, which means the portal expects returns you do not owe and stays silent about ones you do. This piece explains the chain, why it is a control rather than a formality, and how to work it.

1. What the CVF is

The ACPR’s own description is exact and worth reading literally: from the data in a fiche déclarative completed by each reporter on the ONEGATE portal, the ACPR generates for each of those reporters a Carte de Visite Fonctionnelle listing the reports to be submitted.

Three things follow from that single sentence, and each one changes how a reporting function should behave.

• The CVF is derived, not authored. It is an output of your own declaration. It is not a supervisory determination handed down independently of anything you said.
• It is per reporter. Two institutions with similar business models will hold different cards if they described themselves differently.
• It lists reports, not rules. It resolves the abstract question “which returns apply to an institution like us?” into a concrete enumeration for you, at a version, on a date.

The practical effect is that the CVF is the specification the collection infrastructure works from. Documentation for banking-sector collections, including the CVF release notes, is published on the ACPR’s dedicated eSurfi site rather than inside the portal.

2. The fiche déclarative, and why it is not admin

The fiche déclarative is itself a report submitted through ONEGATE, and the ACPR publishes a user guide for completing and depositing it. Its stated purpose is to collect the activities carried on within the institution and the contacts who may be approached by the ACPR. The ACPR asks reporters to keep it systematically updated whenever contacts change.

That is two payloads in one form, and they fail in different ways. The activities half feeds scope: it is what the CVF is computed from. The contacts half feeds correspondence: it determines who receives the queries, the late-filing chases and the collection notices. A firm can therefore be simultaneously in-scope for a return it does not know about and unreachable at the address the supervisor is writing to.

3. The CVF is versioned, and the versions are events

The ACPR does not publish the CVF once. It reissues it on the portal whenever the reporting landscape shifts, and it publishes what changed. The public release history makes the pattern clear:

Read the effective-date column rather than the publication column. Several releases carry a lag — published in February, effective at the end of March; published in September, effective in mid-October — and one of them, the CRD VI / CRR3 step, changed a deadline rather than a list of tables. A reporting calendar that tracks only regulatory instruments and not CVF releases will miss that class of change entirely.

4. How the CVF behaves in the channel

On ONEGATE, rights are granted per collection and déclarant pair, periods carry a life cycle and a state, and each delivery is processed in steps with a status. The CVF sits upstream of all of that: it is what determines which reports appear for your institution in the first place, and therefore which periods can open and which submissions the platform will accept as expected.

The two failure directions are asymmetric, and only one of them is loud.

• The CVF says you owe something you do not. This is the loud failure. Periods open, reminders fire, and the collection manager asks where the return is. Unpleasant, but self-announcing.
• The CVF is silent about something you do owe. This is the quiet failure, and the dangerous one. Nothing opens, nothing chases, and the institution reads the silence as confirmation that the return does not apply — until a supervisory review reconstructs the obligation from the regulation rather than from the card.

The asymmetry is the reason to reconcile in both directions rather than treating the CVF as a to-do list. The card tells you what the infrastructure expects. The regulation tells you what you owe. Compliance means the two agree.

5. Three scenarios

Scenario 1 — the new activity that reported nothing. An institution adds a payment service line mid-year. The product, legal and prudential workstreams all complete; nobody updates the fiche déclarative. Facts to rule: the CVF is generated from the fiche, and it is what causes reports to appear for the reporter. What the reporting lead does: add “update the fiche déclarative and re-check the CVF” as a named gate in the product-launch checklist, alongside the supervisory notification. Outcome: the new returns appear before the first reference date. The failure mode is a clean ONEGATE account with nothing overdue on it and a return that was owed for two quarters.

Scenario 2 — the framework upgrade nobody scheduled. A CVF release introduces a new EBA framework version. The institution’s reporting tool is on the previous taxonomy. Facts to rule: CVF releases carry their own effective dates, and some of them change the tables expected rather than only the labels. What the team does: subscribe to the eSurfi publication alerts, treat each CVF release note as a change request against the reporting tool, and test the new expectation in the ONEGATE homologation environment before the effective date. Outcome: the first submission on the new framework is a rehearsal, not a discovery. The failure mode is meeting a new taxonomy for the first time on a filing day.

Scenario 3 — the contact who left. The named contact on the fiche déclarative moves on. Collection notices and queries continue to be addressed to them. Facts to rule: the fiche collects the contacts the ACPR may approach, and the ACPR explicitly asks for systematic updating when contacts change. What the compliance officer does: attach fiche maintenance to the joiners-movers-leavers process rather than to the annual reporting review, and name a role rather than only a person where the form allows it. Outcome: correspondence lands. The failure mode is a supervisory query that goes unanswered because it went to a disabled mailbox — which reads externally as non-response, not as a directory problem.

6. How to operate it

The workable pattern is a small, dull, quarterly routine rather than a project.

• Pull the current CVF from ONEGATE and store it with a date. It is a point-in-time artefact and you will need last quarter’s version to explain a change.
• Reconcile it against your own obligations register — the list you maintain from the regulations, not from the portal. Investigate differences in both directions.
• Re-read the fiche déclarative against the actual business: services provided, activities carried on, contacts.
• Check the eSurfi release history for CVF versions published since the last review, and read their effective dates.

Fifteen minutes a quarter, and it removes the single most common cause of a French return being missed — which is not a data problem, a calendar problem or a system problem, but a scope problem nobody owned.

7. What to do, today

• Find out who in your organisation last completed the fiche déclarative, and when. If nobody knows, that is the finding.
• Download the current CVF and reconcile it line by line against your own obligations register, investigating gaps in both directions.
• Add “update the fiche déclarative” as an explicit gate in the launch checklist for any new activity or service.
• Subscribe to eSurfi publication alerts and treat each CVF release note as a change request with an effective date.
• Wire the fiche’s contact section into joiners-movers-leavers, not into the annual review.
• Archive each CVF version with its date, so a change in expected reports can be explained rather than rediscovered.

Related: ONEGATE — the Banque de France reporting channel · SURFI — French supervisory reporting · The French reporting calendar for a payment firm · Testing a new return before first submission