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.
And 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.
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.
Related: SURFI · The Spanish reporting calendar · What is supervisory reporting
