FICP — declaring credit incidents to Banque de France

The FICP is the Banque de France register of credit repayment incidents, and since the March 2026 specification it has two new credit codes that exist specifically for split payments and mini-credit. Payment institutions and e-money institutions are declaring institutions in their own right, and the clock they work to is four business days. This is what counts as a declarable incident, what the new codes cover, and how the files move.

1. What the FICP is, and who feeds it

The Fichier national des Incidents de remboursement des Crédits aux Particuliers records payment incidents on credit granted to natural persons for non-professional needs, plus information on the handling of over-indebtedness. Articles L. 751-1 to L. 752-3 of the Code de la consommation entrust its management to the Banque de France and define its content and purpose; the arrêté of 26 October 2010, published in the Journal officiel of 30 October 2010, sets out how it is collected, recorded, retained and consulted.

The declaring population is wider than “banks”, and this is the part firms new to the French market read past. Incidents are observed and declared by credit institutions and financing companies under Article L. 511-1 of the Code monétaire et financier, payment institutions under Article L. 522-1, e-money institutions under Article L. 526-1, and the bodies listed at points 5 and 8 of Article L. 511-6. Over-indebtedness files are recorded by the secretariats of the over-indebtedness commissions, not by the institutions.

Consultation runs on a separate track. Those same three categories may query the register before granting any form of credit — including an authorised overdraft — and before issuing a means of payment such as a card or chequebook. The purpose limitation is real: the FICP may not be consulted to check the financial situation of a job candidate, including for a role inside the institution itself.

2. What counts as a declarable incident

The arrêté defines an incident de paiement caractérisé in three limbs and adds one discretion. None of it is internal risk policy: the trigger is fixed, and a firm applying its own arrears threshold declares either too early or too late.

Three rules then govern how many declarations you send. An incident concerns one person and one credit, assessed credit by credit. Where an agreement was taken out by several people, there are as many declarations as defaulting debtors. And once an incident is registered against a credit, no further declaration is made for it if other incidents follow, or the déchéance du terme is pronounced, or proceedings begin — the one exception being incidents arising on that credit inside an over-indebtedness plan.

3. The new codes: split payments and mini-credit

Each declared incident carries a two-character code. The first is the incident type — 0 for a standard default, 1 for a default on a claim inside an over-indebtedness measure. The second identifies the nature of the credit, and it is here that the current specification has moved.

Code 4, “personal loan and permanent credit”, has been unused since 25 June 2011, although incidents already recorded under it stay there until removed. The consequence of P and M is that the products a payments firm is most likely to offer — pay-in-three at checkout, a deferred debit at 30 days, a small short-term advance — now have their own reporting identity in a national register. A firm mapping them to 6 “miscellaneous” because that is what an older build did is mis-declaring.

4. Worked example — a pay-in-three default

Facts: a French branch of an EU e-money institution offers pay-in-three at merchant checkout. A customer takes EUR 240 over three monthly instalments, pays the first, and misses the second and third.

Which rule applies: a credit with monthly instalments, so the trigger is the sum of the last two instalments due — met exactly when the third goes unpaid. Nature of credit P, because the facility is tied to a specific purchase and repayable in several instalments; incident type 0. The EUR 150 discretion does not help: the cumulated unpaid amount is EUR 160.

What the practitioner does: records a reference date equal to the day the incident became declarable — the due date of the third instalment, not the day the collections queue picked it up — and declares by the fourth business day after it. The build requirement is that the reference date comes from the schedule, not from an operator’s action, because the retention clock and the automatic removal date are both computed from it.

Outcome: the incident sits in the register for five years from that date unless the customer pays in full, in which case it is removed the day the full-payment declaration is recorded.

5. The clock, and how records leave the register

Four operations exist — registration, removal following full payment, cancellation where the original declaration was wrong, and modification of an incident already declared — and all four run to the same deadline.

• Registration: the fourth business day at the latest following the date the incident became declarable.
• Removal on full payment: same deadline, counted from the date of full payment. The firm’s declaration is the trigger, not the customer’s payment.
• Cancellation and modification: same terms, as soon as the declaring institution finds an anomaly in the original declaration, and recorded on receipt.
• Automatic purge: incidents are retained five years from the reference date and purged automatically at the end of the legal period, on a removal date the system calculates.

Over-indebtedness files are retained for the duration of the measures. Early removal is handled by the Banque de France, either when the debtor evidences full repayment to all creditors named in the plan with a payment attestation from each, or when the measures have run five years without incident.

6. Worked example — the over-indebtedness blackout

Facts: a customer with an unpaid revolving facility files an over-indebtedness application and the commission declares it admissible. Two weeks later the firm’s collections engine hits its normal trigger and queues a FICP declaration.

Which rule applies: no payment incident may be declared against a debtor between the date the over-indebtedness file is declared admissible and 60 days after the measures take effect — or, where the file closes without measures, until the instruction recording that closure ends. A declaration inside that window is not a late filing; it is a filing that should not exist.

What the practitioner does: treats admissibility as a state on the customer record that suppresses declaration, sourced from the notice received rather than from the arrears data. After the plan is in place the position inverts: if the claim is included in the plan and a new incident occurs after the plan starts, that incident must be registered — with incident type 1. A standard incident and an on-measure incident can legitimately coexist against the same credit reference.

Outcome: nothing is declared during the blackout, and declaration resumes afterwards with the correct incident type. One flag, correctly sourced, prevents both errors.

7. Identity is the failure mode

Records are indexed on a “clé BDF” built from the six digits of the date of birth and the first five letters of the family name. Around it the institution supplies family name, marital name, forenames in civil-status order, date and place of birth — département and INSEE geographic code for those born in France, ISO country code and locality for those born abroad — and sex.

The Banque de France verifies this against the RNIPP, the national register of natural persons managed by INSEE, and is authorised to do so for that purpose. It may correct data that appears incomplete or erroneous, and informs declarants of the corrections. Where a civil-status record cannot be identified, it issues an enquiry to the institution that created the entry; the institution completes and returns it, and must also fix its own reference data to match.

Following orientations agreed at the CFONB between the Banque de France and industry representatives, rejected declarations are billed — rejected detail records only, invoiced half-yearly in the month after the half-year closes, itemised by rejects per movement type per institution. Data quality has a line item.

8. How the files actually move

File exchange requires the Banque de France’s prior agreement, formalised in a FICP subscription agreement, and prior testing is mandatory. Each declarant is identified by a code regroupement FICP: its own interbank (CIB) code where it declares for itself, or an alphanumeric grouping code allocated by the Banque de France where several institutions in one group share IT resources and declare together.

• Two channels. File teletransmission over IP using the PESIT hors SIT protocol, or the Banque de France’s Portail Bancaire Internet (POBI). The internet route complements teletransmission rather than replacing it.
• OpenPGP throughout. Exchanges are secured with software conforming to the open OpenPGP standard and the Banque de France’s OpenPGP convention, acquired at the institution’s own cost. Signature, encryption, compression and transcoding are all in scope; the public application key must carry a valid signature from the organisation’s master key, and keys are renewed periodically.
• Deposit window. For same-day processing, files must arrive between 07:30 and 21:15, Monday to Friday on business days. Files received between 00:00 and 07:30 are processed the evening of receipt; those received between 21:16 and midnight, the following evening.
• Acknowledgement. The processing report including rejects is sent on the evening of processing, from 21:30. If it does not arrive, the institution must ask the Banque de France to re-issue it.
• Sender retention. The remitter keeps a copy of the original file until the processing report and rejects come back.

Accreditation, key exchange, file structure and retrieval of the processing report are four separate failure modes, and a successful connection tests none of them. Firms that instrument only the send discover their rejects on the invoice.

FAQ

What to do, today

• Product owner: assign every French credit-like product a credit-nature code. Anything pay-in-three, deferred or short-term small-ticket not mapped to P or M is today’s finding.
• Reporting engineer: derive the reference date from the repayment schedule, and alert on the four-business-day deadline rather than on transmission.
• Compliance officer: confirm an admissibility notice suppresses declaration for the whole blackout period, and that the suppression is sourced from the notice.
• Operations lead: put the reject invoice in front of the team that owns identity data, and check no civil-status enquiry was ever answered by removing and re-declaring.

Related: FCC and FNCI — the Banque de France cheque registers · FICOBA — the French account register · France reporting calendar for payment institutions · CIRBE — the Spanish credit register