FICOBA — France’s account register, and who must file
FICOBA is the French register of bank and similar accounts, and the obligation to feed it is older and broader than most foreign firms assume. Article 1649 A of the Code général des impôts requires a defined set of bodies to declare to the tax administration the opening and closing of accounts of any kind, along with the renting of safe-deposit boxes. The arrêté of 14 June 1982, codified at Articles 164 FB to 164 FF of Annex IV to the CGI, extended the FICOBA procedure to the whole population of declarants and remains the operative instrument.
1. Who must declare
Article 1649 A names four categories, and the third is the one that reaches passporting firms:
| Category | Note |
|---|---|
| Public administrations | — |
| Establishments or bodies subject to the control of the administrative authority | The broad supervisory limb |
| Establishments benefiting from Articles L. 511-22 and L. 511-23 of the Code monétaire et financier, for their operations with French residents | The cross-border limb — operations with French residents are the trigger |
| All persons who habitually receive on deposit securities, titles or funds | A functional catch-all |
2. Three events, not one
FICOBA is an event-driven register rather than a periodic return, and it captures three lifecycle events:
- Opening of an account of any kind;
- Modification — a change to the declared characteristics of an existing account, including to the identification of the holder;
- Closure.
The modification limb is where most data-quality debt accumulates. Openings and closures are discrete events that a system naturally emits; modifications require the firm to detect that something in an already-declared record has changed and to emit a corresponding update. A pipeline built only around account creation and closure will drift from the register silently, and the drift is invisible until a query returns a stale holder.
3. The FICOBA 3 format
Declarations are made in a defined XML format, specified in the DGFiP’s cahier des charges for FICOBA 3, which is accompanied by a migration guide for financial institutions moving from the earlier format. Two consequences follow for the build:
- The specification is versioned. The cahier des charges carries a version number, and the version in force is what your file is validated against — the same discipline that applies to any taxonomy-based return.
- Identification data is the payload. A FICOBA declaration is fundamentally an identity record attached to an account, so the quality bar sits on the holder’s identification data rather than on amounts. There are no balances to reconcile and no arithmetic to check — which removes one class of error and concentrates everything in another.
4. How the declaration is created
Facts: an EU credit institution operating in France under the freedom to provide services opens accounts for French residents from its head office, with no French branch.
What the rule says: Article 1649 A reaches establishments benefiting from Articles L. 511-22 and L. 511-23 of the Code monétaire et financier for their operations with French residents. The passporting route does not remove the obligation; the residence of the customer engages it.
What the practitioner does: makes French residence a maintained customer attribute, then builds three event feeds — open, modify, close — from the account lifecycle rather than from a periodic snapshot. The modification feed needs an explicit list of which declared fields are change-relevant, because “the customer record changed” is far broader than “a declared characteristic changed”, and emitting on the former produces noise while emitting on neither produces drift.
The access side is worth knowing even though it is not a reporting duty: access to the information held in FICOBA is regulated by Article 5 of the amended arrêté of 14 June 1982, which is the provision to cite when asked who can see what you have declared.
FAQ
Does a passporting institution have to feed FICOBA?
Article 1649 A covers establishments benefiting from Articles L. 511-22 and L. 511-23 of the Code monétaire et financier in respect of their operations with French residents, so the cross-border route is expressly contemplated.
Is FICOBA a periodic return?
No. It is event-driven — opening, modification and closure of accounts of any kind, plus the renting of safe-deposit boxes.
What is the technical format?
A versioned XML declaration specified in the DGFiP’s FICOBA 3 cahier des charges, with a separate migration guide for institutions moving from the earlier format.
Who bears the obligation in an outsourced setup?
The declarations fall on the establishments that manage the accounts and maintain them in their books. Operational execution can be delegated; the obligation does not move.
Related: The French reporting calendar · Issuing French IBANs · The French AML framework
