The French reporting calendar for a payment firm
France splits reporting across more counterparties than most markets, and the split does not follow the licence. A payment firm operating in France answers to the prudential supervisor, the central bank, the financial intelligence unit and the tax administration — and at least one of those obligations is triggered by serving French residents rather than by having any establishment in France at all. Building the calendar means testing the perimeter per return.
1. Who collects what
| Counterparty | What it collects |
|---|---|
| ACPR | Prudential and financial reporting, and the conduct and complaints layer |
| Banque de France | Payment-means security and fraud data through the Observatory, and external-sector statistics |
| TRACFIN | Suspicion reporting and the systematic-communication regime |
| DGFiP (tax administration) | The account register and the tax information returns |
| AMF | Where the firm also holds an investment-services permission |
2. The recurring obligations
Grouped by counterparty, with links to the detail covered elsewhere on this site:
| Obligation | To | Nature |
|---|---|---|
| SURFI | ACPR | Periodic supervisory and financial returns |
| FICOBA | DGFiP | Event-driven: account opening, modification, closure |
| Payment fraud data | Banque de France | Aggregated fraud statistics via the Observatory |
| Déclaration de soupçon | TRACFIN | Event-driven suspicion reporting |
| COSI | TRACFIN | Systematic communications |
| Conduct and complaints | ACPR | Periodic conduct reporting |
| MiFIR transaction reporting | AMF | Daily, where investment services are provided |
| CESOP | DGFiP | Quarterly cross-border payment data |
3. The perimeter tests
Three questions decide most of the calendar, and they give different answers:
- Do you have a French establishment? Drives the prudential and financial returns to the ACPR, which attach to the supervised entity in France.
- Do you serve French residents? Drives FICOBA through the Article 1649 A limb covering operations with French residents, regardless of establishment.
- What do you actually do? Drives the instrument-specific collections. The Observatory’s scope names credit transfers, direct debits, cards, cheques, commercial paper, electronic money and the transmission of funds — so a product set with no cards is still inside it.
4. Building and maintaining it
Facts: an EMI authorised in another member state passports into France under the freedom to provide services, with no branch, and offers accounts and transfers to French consumers.
What the analysis produces: the absence of an establishment removes some ACPR periodic reporting but does not remove the account-register obligation, which is framed around operations with French residents. The instrument scope of the fraud collection covers transfers and e-money. AML obligations follow the host-state framework as applied to the passporting model.
What the practitioner does: builds the calendar as four columns — obligation, legal trigger, perimeter test met, channel — and re-tests only the third column when the business changes. The returns are stable; what moves is whether you are inside them.
One planning note specific to France: several obligations are event-driven rather than periodic — the account register and suspicion reporting among them. Event-driven obligations do not appear on a calendar at all, which is precisely why they are the ones that get missed. They belong on the same register as the periodic returns, with a named owner and a monitoring control, even though they have no due date.
The monitoring control for an event-driven obligation is different in kind from a due-date reminder, and it is worth stating what it looks like. For the account register, the control is a periodic reconciliation between the account population in the core ledger and the population declared — differences in either direction are the finding. For suspicion reporting, the control is not a count of reports but evidence that the assessments behind them are being recorded, including the negative ones.
5. Language and channel
Two practical constraints shape French filings more than they shape most markets. Documentation and correspondence with the French authorities generally proceed in French, which is a resourcing question for a foreign-headquartered team rather than a legal obstacle, but it belongs in the plan rather than in the first week of a first submission.
Most Banque de France and ACPR collections arrive through a single window, ONEGATE, but each counterparty operates its own channel with its own enrolment. As in Spain, channel onboarding is a critical-path item: the ability to file is not a by-product of being authorised, and the lead time to obtain access, certificates and test credentials is frequently longer than the time needed to build the file itself.
6. The calendar, return by return
France spreads the work across four collectors, and the split between the supervisor and the central bank is the part newcomers get wrong. The deadline column gives the operating rule; the instrument is in the linked article.
| Collector | Return | Cadence | Deadline rule |
|---|---|---|---|
| TRACFIN | ERMES — déclaration de soupçon | Event-driven | Without delay |
| COSI — systematic reporting | Systematic, on the defined criteria | Per the criteria | |
| ACPR | SURFI supervisory reporting | Periodic | Per the collection calendar |
| Carte de Visite Fonctionnelle | Annual | Defines which collections apply to you | |
| Conduct and complaints reporting | Annual | Conduct reporting | |
| Banque de France | OSCAMPS fraude | Half-yearly | Fraud on payment instruments |
| OSCAMPS cartographie | Periodic | Mapping of payment instruments | |
| RPC, CRT and CRC | Monthly and quarterly by collection | Per collection | |
| FICP — credit incidents | Event-driven | On incident | |
| FCC and FNCI — cheque registers | Event-driven | On incident | |
| DGFiP | FICOBA — account register | On account opening, change and closure | Event-driven |
| CESOP cross-border payment data | Quarterly | End of the month following the quarter | |
| CRS / DAC2 | Annual — new for e-money from the 2026 data | 15 July of the following year | |
| Branch obligations | Head-office annual accounts to the register | Annual | A standard branch duty |
The row that decides the others is the annual functional declaration to the supervisor. It is not a data return — it is the statement of what your firm does, and the collections you are then expected to file are derived from it. Get it wrong and you will either be chased for returns you do not owe or, worse, not chased for ones you do.
7. The row that is new: CRS/DAC2 to the DGFiP
Council Directive (EU) 2023/2226 extends the Common Reporting Standard to specified electronic money products from 1 January 2026, first exchange 2027. France collects it as a technical file rather than a form, and the specification is versioned per campaign.
- Deadline: 15 July of the year following the year in which the income was received or the balances closed, set by decree — six weeks later than the Spanish window, which is a trap for a group filing in both.
- Specification: a cahier des charges reissued each campaign with a version number. Building to last year’s version is a structural rejection.
- Limits: the deposited file may not exceed 100 megabytes before compression, and one message may not exceed 32,000 account reports — so the export has to be splittable by construction.
- Channel: encrypted XML through the third-party declarant deposit route. A firm already filing another French return this way may have the enrolment it needs.
Worked example. A group with a French and a Spanish branch builds one CRS programme against a single July milestone. Rule: two administrations, two deadlines, two formats — and the Spanish window closes on 31 May. What the practitioner does: builds one reportable-account population from the 31 December snapshot, then renders and submits it twice on two calendars. Outcome: the expensive half of the work is done once, and neither deadline is missed.
FAQ
Which French obligations apply without a branch?
Those framed around operations with French residents rather than around establishment — the account register under Article 1649 A of the CGI is the clearest example.
Does the fraud collection apply to a firm with no cards?
Yes. The Observatory’s instrument scope expressly includes electronic money and the transmission of funds alongside cards, transfers, direct debits, cheques and commercial paper.
What is easiest to miss?
Event-driven obligations. They never appear on a due-date calendar, so they need a named owner and a monitoring control rather than a diary entry.
8. What to do, today
- Write the calendar down as a table with an owner per row, not as a set of diary entries. A row with no name against it is the one that is missed.
- Record the channel and the enrolment beside each return. Enrolment, certificates and access are the long pole on almost every one of these, and they expire.
- Add the CRS/DAC2 row now if it is not there. The 2026 data is being generated already, whatever year the first filing falls in.
- Run a coverage query on tax residence and foreign tax identification numbers against the existing book before year end, and let the result decide whether year one is a negative return or a full build.
- Check which returns require a nil or negative filing. Several here do, and “nothing to report” is not the same as nothing to file.
- Diarise the head-office annual accounts. It is a branch duty with no owner in most operating models.
- Re-derive the calendar whenever the product set changes. A new product does not announce itself to the reporting function.
Related: SURFI · The Spanish reporting calendar · What is supervisory reporting · OSCAMPS Cartographie · Carte de Visite Fonctionnelle · FCC and FNCI — the French cheque registers · FICP — the French credit-incident register · ERMES — the TRACFIN declaration de soupcon · CRS/DAC2 filing in France · QLB — the annual AML questionnaire and its deadlines · SIREN, SIRET and the French RNE · Rapport de contrôle interne LCB-FT — the ACPR’s 30 April report
