RPC, CRT and CRC: French balance-of-payments returns

French balance-of-payments reporting is not one return, and the return most payment firms owe is not the one they have heard of. The Banque de France’s Direction de la Balance des paiements runs three collections a payment or e-money institution can fall into — RPC for customer cross-border payments, CRT for the firm’s own cross-border transactions, CRC for cross-border card activity. Different populations, different thresholds, different deadlines, and only one publishes a list of who is in scope.

1. What the Banque de France is collecting

France’s balance of payments and its position extérieure — the international investment position — rest on instruments each collection notice cites by name: Regulation (EC) No 184/2005 on Community statistics concerning balance of payments, international trade in services and foreign direct investment, as amended; the European Central Bank Guideline of 9 December 2011 on external statistics; Article L.141-6 of the Code monétaire et financier; Loi n° 51-711 of 7 June 1951; and the Bank’s own Décision du Comité monétaire du Conseil général n° 2007-01, amended by the Décision du gouverneur 2024-01 of 8 February 2024.

Two things follow. The obligation is statistical, not prudential — it does not sit with the ACPR returns. And the scoping documents are technical notices, notes techniques DGS (now DGSEI), not regulation text, updated on their own cadence: the CRT notice, n° 15-02, was last updated in March 2026. All three collections are delivered through OneGate, the Bank’s single collection window, each as its own domaine.

2. Three returns, three populations

The fastest way to scope the obligation is to ask whose money moved. Customer money is RPC. The firm’s own money is CRT. Card money is CRC.

Note what that does to a typical e-money business: a firm whose product is a card and an account owes CRC on the card leg and RPC on the transfer leg, and may owe nothing on CRT — because CRT is about the firm’s own income and expenditure with non-residents, not its customers’ payments.

3. RPC — the return most payment firms hit first

Defined by note technique DGS n° 16-02, the RPC picks up transfers and direct debits made by resident businesses and households with non-resident counterparties. Responsibility falls on the intermediary that holds the account of the resident client who is the originator or final beneficiary — whatever the instrument, system or currency. That test catches passported firms: if the French customer’s account sits with you, the return is yours.

• Volet 1 — businesses, SEPA counterparties. Payments to or from a resident business with a counterparty in the SEPA area outside France, where the euro equivalent exceeds €50,000, in any settlement currency. Keyed on declarant, month, client SIREN, direction, currency and country; the economic code is a fixed value so the layout matches volet 2.
• Volet 2 — businesses, non-SEPA counterparties. Same €50,000 threshold, broken down by a simplified nomenclature running E01 to E15 — goods, transport, IT and communication services, construction, royalties and licence fees, tourism-related services, other services, investment income, current transfers, intra-group investment and disinvestment, real-estate operations, debt securities and shares, derivatives, non-group loans and borrowings. The notice is explicit that these are declared on the basis of the coding elements communicated by the resident business. The bank does not guess the purpose; the customer supplies it.
• Volet 3 — households. All cross-border payments for resident households, with no amount threshold, aggregated without netting and coded into bands: ME1 under €500, ME2 €500 to under €5,000, ME3 €5,000 to under €10,000, ME4 €10,000 to under €50,000, ME5 €50,000 and above. ME1 is not compulsory. Households carry the generic SIREN 888 888 888.

Amounts convert to euro at the payment-day rate, or failing that the monthly average, and are declared in thousands without decimals.

4. CRT — where thresholds decide everything

CRT records the firm’s own cross-border operations against balance-of-payments headings: financial and non-financial services, income and current transfers in the current account; debt forgiveness towards non-residents in the capital account; direct investment and derivative transactions in the financial account. It splits across three OneGate domains, and a firm can be a monthly reporter on one and an annual reporter on another.

• HPD (form HPDRES) — services, income, capital. Monthly filing is triggered where exports or imports of financial and non-financial services with non-residents reach, over a year, more than €30 million of income or more than €50 million of charges; 18 working days after month end. Below the threshold, intermediaries may be polled annually instead and are told bilaterally, at 40 working days after year end.
• PFD — derivatives. Monthly flow reporting where fair-valued derivative assets or liabilities against non-residents exceed €200 million at 31 December of year N-1. Any monthly PFD reporter also owes a quarterly stock return covering resident and non-resident counterparties, 28 working days after quarter end.
• SFP — direct-investment stocks. An annual state of holdings in foreign branches, subsidiaries and participations, owed by any resident intermediary holding at least 10% of the share capital of a non-resident undertaking at the reference date. Sampled by the Bank; 40 working days after year end.

Separately, any cross-border share-capital operation or property investment above €15 million must be reported — and that route changed. The FID remittance covering forms A1, A2, B1 and B2 was withdrawn from OneGate in January 2026; those reports now go to the Bank by email. A team that automated FID into its OneGate pipeline has a dead branch to remove.

The Bank publishes the list of monthly HPD and PFD reporters annually, grouped by category — credit institutions, investment firms, portfolio management companies, financing companies and, on the 2026 list, two payment institutions. Everyone else may face an annual survey of the year’s flows outside derivatives and a triennial survey for derivatives, notified bilaterally — absence from the list is not the same as being out of scope. Reporters must also archive the last three rolling years and be able to return all or part of them within two weeks.

5. CRC — the card return

CRC is the narrowest of the three. Defined by note technique DGS n° 16-01 and giving effect to Décision n° 2010-03, it estimates travel-services exports and imports: what non-resident visitors spend in France, what residents spend abroad.

It captures card settlements at the point of sale, all cash withdrawals whether at an ATM or over the counter, and all remote transactions. It does not cover funds transfers made by card. Operations sit in the month of the transaction, and commissions and cancellations are not treated as operations at all. Four economic codes carry the breakdown: C for face-to-face settlements with the cardholder physically present, R for cash withdrawals, D for remote transactions, and Z — a grouping of C and R — used only for the number of cards.

Residence is determined in a way that catches issuers out: the cardholder’s status comes from the country of issue, meaning the location of the entity that manages the account the card is attached to, while the counterparty country comes from the beneficiary’s location or from where the cash was withdrawn. Data are aggregated with no threshold and no netting, keyed on declarant SIREN, remitter SIREN, ISO 3166 country, economic code, amount in thousands of euros truncated, transaction count, card count for code Z, direction — credit 1 for French receipts, debit 2 for French expenditure — and reference month and year.

6. Residence, and the Monaco trap

All three returns turn on residence, and residence here is economic rather than a matter of nationality or tax. A resident is a French or foreign legal person in respect of its establishments in France, diplomatic and consular missions excepted, and a natural person of any nationality whose principal centre of interest is in France. French officials posted abroad stay residents; French nationals become non-resident on settling abroad.

“France” covers metropolitan France and the overseas departments, plus Mayotte, Saint-Barthélemy, Saint-Martin and Saint-Pierre-et-Miquelon, and includes Monaco. The notices differ on how Monaco is coded: CRT folds it into the territory identified under code FR, while RPC identifies it separately under MC. One mapping table serving both returns is exactly how you get a validation failure on one collection and silence on the other. Country codes are ISO 3166, currencies ISO 4217; CRT restricts currencies to a named family with a catch-all code and dropped the Bulgarian lev when Bulgaria joined the euro area on 1 January 2026. International organisations carry their own counterparty code — the European Central Bank is 4F, not DE.

7. Three scenarios

The branch that scoped only CRT. A passported e-money institution opens a French branch, issues IBANs and cards, checks the published CRT list, finds itself absent and concludes it has no obligation. Facts to rule: the list covers only monthly HPD and PFD reporters; RPC has no list and no institution-level threshold, and the test is simply who holds the resident client’s account. What the team does: scope RPC and CRC first, then re-test CRT annually against the €30m / €50m services test.

The €120,000 supplier payment. A French business customer instructs €120,000 to a supplier in the United States. Facts to rule: non-SEPA counterparty, so volet 2; above €50,000; volet 2 needs an E01–E15 code that comes from the business, not the bank. What the analyst does: make sure payment initiation collects a purpose code for non-SEPA business payments above the threshold, mapped to the fifteen codes rather than an internal taxonomy. The failure mode is silent — the payment goes out fine, and the return is built months later from a field nobody captured.

The card spend reported twice. A firm builds one cross-border payments dataset and feeds both RPC and CRC. Facts to rule: RPC excludes cards and cheques; CRC excludes funds transfers made by card, and excludes commissions and cancellations. What the reporting owner does: split the source at instrument level before aggregation and add a reconciliation proving the two returns are disjoint.

8. Filing for someone else

All three notices let a resident intermediary remit on behalf of other resident intermediaries, and all three make it conditional. The Direction de la Balance des paiements must give explicit prior agreement; every resident–non-resident operation must be captured without netting; and CRC adds that the remitter must give the Bank the list of institutions it files for and distinguish each declarant’s data inside the file. The division of responsibility is stated in the same words across the notices and belongs in any outsourcing schedule: the remettant produces and transmits the data, the déclarant remains responsible for the data itself. Appointing a group filing team does not move the obligation.

9. What to do, today

• Scope by whose money moved: customer transfers to RPC, own-account flows to CRT, cards to CRC.
• Apply the RPC responsibility test to your account structure — if the resident client’s account sits with you, the return is yours regardless of where the platform runs.
• Re-test the CRT thresholds annually against last year’s services income and charges with non-residents, rather than treating absence from the published list as an exemption.
• Fix the household population before mapping volets: sole traders and partnerships without legal personality belong in volet 3.
• Capture the E01–E15 economic code at payment initiation for non-SEPA business payments above €50,000. It cannot be reconstructed later.
• Keep one mapping table per collection — Monaco alone is coded differently between CRT and RPC.
• Put the three-year archive and two-week restitution window into records retention, and set OneGate accreditation up per collection before the first period closes.

Related: External-sector reporting compared across the EU · ONEGATE — the Banque de France reporting channel · SURFI — French supervisory reporting · How to issue French IBANs