FCC and FNCI — the Banque de France cheque registers

The FCC and the FNCI are the two Banque de France registers that decide, in France, whether a person may write a cheque and whether a merchant will accept one. They are fed by the institutions that carry the accounts and issue the cards, on deadlines counted in business days, through a file channel that predates every modern reporting portal and still works exactly as specified. This is what they hold, who declares what, on what clock, and how the files move.

1. Two registers, two audiences

The Fichier central des chèques (FCC) is a register of people. It records those barred from issuing cheques after an unregularised unfunded cheque, those whose payment card the issuer withdrew following an incident in its use, and those under a judicial ban. It is fed by the institutions, managed by the Banque de France, and consulted by institutions — not by the public.

The Fichier national des chèques irréguliers (FNCI) is a register of accounts and cheque forms. Under Articles L. 131-84 and L. 131-86 and Articles R. 131-5 and following of the Code monétaire et financier, it centralises the bank details of closed accounts, the accounts of people barred from issuing cheques, stop instructions for lost or stolen cheques, and the identifying characteristics of forged cheques. It is consulted by cheque beneficiaries — in practice retailers — through a Banque de France subscription answering with a colour code, not data.

2. The declaration clock

Every duty here is expressed in business days, and every deadline runs from an event the institution itself creates. These are the ones a payments or banking operation has to instrument.

The durations on the other side are asymmetric, and front-line staff guess at them. A cheque incident is erased automatically five years after registration if never regularised; a card withdrawal, two years after the decision; a judicial ban runs for at most five years. Regularisation shortens none of these by itself — it obliges the institution to ask for removal, and the request is what clears the record.

3. Worked example — a card withdrawal

Facts: a French branch of an EU e-money institution issues cards on the domestic scheme. A customer runs a sequence of card transactions the available balance and authorised overdraft cannot cover, and the risk team decides to withdraw the card.

What the rule says: before declaring the customer to the FCC, the institution must inform them of the amount of the incident found, of their possibilities for regularisation, of the fact that the registration is maintained for two years absent regularisation, and of their right to present observations. If the customer does not regularise in time, the institution has them registered for a maximum of two years. The customer keeps the right to issue cheques throughout — a card withdrawal and a cheque ban are separate measures.

What the practitioner does: treats the pre-registration letter as a controlled document rather than free text. The ACPR’s survey found most card-related letters incomplete, and found institutions telling customers to regularise “on receipt” without stating a date they could work to. The fix is a template carrying all four mandatory elements and a concrete deadline, generated from the incident record so the amount cannot drift, and archived so the institution can evidence it when removal is later disputed.

4. What the merchant sees

The FNCI is consulted through the Banque de France’s Vérifiance-FNCI subscription, and the answer is deliberately thin: a colour, never a name and never a reason.

Alongside the colour, the service returns consultation counters — enquiries on that account today and over two longer trailing windows — and the two digits of the magnetic line recomposition key. The counters are the anti-fraud signal: an account being checked repeatedly across merchants in a short window is a different proposition from the same colour on a first enquiry.

5. Worked example — a bank identifier change

Facts: two French operations merge, the accounts move to a new interbank code, and some of the renumbered accounts belong to customers already barred from issuing cheques.

What the rule says: a ban attaches to the person across every account they hold. The institution declaring a first cheque incident to the FCC on one set of bank details must, in parallel, declare a banking ban to the FNCI on the other set. Where cheques drawn on the old details are still paid, both sets carry the declaration; where they are not, the old details go to the FNCI as a closed account.

What the practitioner does: builds the migration as a double-declaration exercise rather than a data update, and does not remove the FNCI entry until the notice lifting the ban arrives from the reconciliation against the national account register. The removal trigger is an inbound notice, not the firm’s own view that the customer has paid.

6. How the files actually move

The FCC update channel is a specified file exchange, not a portal, and access is subject to the Banque de France’s agreement in the light of the declarant’s average daily volume. Two roles are separated in the specification and confusing them is the classic onboarding error: the remettant transmits the physical file and may carry several declarants inside it, while the déclarant is the account-holding institution whose logical file sits within it. Each pairing must be declared in advance. Every item below is a build requirement:

• Transfer protocol PESIT hors SIT over IP, with sender and receiver access points allocated by the Banque de France. A successful deposit returns protocol code zero; anything else is the remettant’s to diagnose and re-send.
• Security by OpenPGP, the institution buying its own software and generating and storing its own keys. The key identifier follows a fixed nomenclature with a T., P. or S. prefix for test, production and backup, and must carry the interbank code — keys are per remettant, not per group.
• Files in UTF-8, fixed-length records of 560 bytes, all characters upper case, numeric fields right-aligned and zero-filled, alphanumeric fields left-aligned and blank-filled.
• Ten record types, from the type 0 header to the type 9 trailer: type 1 cheque incidents, type 2 account-holder descriptions, type 3 card withdrawals, types 4 to 8 modifications, deletions, early removals and global deletions.
• A daily file, Monday to Friday, between 08:00 and 21:00; anything later is processed the next business day. An empty file with only a header and a trailer is valid, and is how a quiet day is declared.
• A creation date usable only once per logical file — reusable the next day if the file was rejected.

Testing before go-live is not advisory: the specification makes prior tests mandatory, organised with the Banque de France’s FCC support unit — the same discipline the ONEGATE collections apply, and for the same reason. Accreditation, keys, format and acknowledgement retrieval are four separate failure modes, and a successful connection tests none of them.

7. Worked example — reading the acknowledgement

Facts: a declarant sends its daily FCC file at 17:00 on a Tuesday, carrying fourteen incidents and their holder descriptions. The next morning the compliance analyst wants to know they landed.

What comes back: a processing report, transmitted the same day the file is received, at around 23:00, secured with OpenPGP, in fixed-length records of 575 bytes. It carries up to five rejection reasons per record, each keeping its original sequence number, and a trailer numbered 99999 counting records received, processed and rejected by type. It is held for five business days and can be re-sent on request; where transmission fails, a paper state is posted as a degraded procedure.

What the practitioner does: reads the trailer counts, not the absence of an error alert. Two coupling rules make partial acceptance normal: an anomaly on a type 1 or type 3 record automatically rejects the type 2 descriptions attached to it, and an anomaly on a description rejects the incident or card withdrawal it belongs to — a clean dependent record comes back with a distinct code so it can be identified. A structural anomaly rejects the whole logical file, and nothing is recorded. The specification is blunt: rejections must be recycled as quickly as possible, and delay may engage the declaring institution’s liability.

One category never lands automatically: declarations concerning legal persons without a national business identifier, companies registered abroad, and limited-liability sole traders are keyed by hand from the day after receipt, and if the data is incomplete a paper state comes back by post as a rejection to be corrected and returned. A firm with a cross-border customer base should staff that queue in advance.

8. What the supervisor looks at

The ACPR has surveyed how ten institutions actually operate these registers, and the findings read as a checklist of what goes wrong.

• Consultation is mandatory before a first chequebook. Article R. 131-44 of the Code monétaire et financier requires the FCC to be consulted before the first delivery of a chequebook and the answers kept for two years. Several could not reconstruct why a consultation had been made; one queried its own internal records instead, which by construction excluded the card data.
• Removal has a deadline too: on regularisation, within two days — and attestations must say whether the incidents concerned cheques or cards, because the two carry different durations.
• Account closure is a warning event. Seven of the ten did not warn customers of the FCC risk when closing an account — and refusals to deliver a chequebook must be motivated in writing on every channel.

Identity theft is the one place where doing the work yourself is wrong. Where an institution learns that an account on its books was opened fraudulently in someone else’s name, it must ask the Banque de France by letter, with supporting documents, to attach the “usurped identity” marker — never carry that marker itself inside the update file. Once attached, every incident and card withdrawal on that account links to it automatically.

FAQ

What to do, today

• Compliance officer: confirm in writing which register your French product line engages, and on which of the six events in the clock table your systems currently emit nothing.
• Operations lead: check that the pre-registration letter for card withdrawals carries all four mandatory elements and a concrete regularisation date — the ACPR found this the most common gap.
• Reporting engineer: instrument the acknowledgement, not the send — alert on the trailer counts of the 23:00 report and on the five-business-day retention window.
• Product owner: if cheque forms are in scope, complete the transcoding rule before launch — without it every cheque you issue answers WHITE.

Related: FICOBA — the French account register · ONEGATE — the Banque de France reporting channel · Account registers compared across the EU · Card fraud typologies in PSD2 reporting