RUBA: ACPR unified reporting for PIs and EMIs in France
RUBA, the Reporting Unifié des Banques et Assimilés, is the national return that French payment institutions and e-money institutions file with the ACPR and the Banque de France, and its table set is narrower and more mechanical than most project plans assume. RUBA took over from SURFI with the reference date of 31 January 2022. The background is in our SURFI and RUBA overview; this piece covers which states a PI or EMI owes, on what calendar, under which thresholds and in which format.
1. The instrument: Instruction 2024-I-17
RUBA currently rests on ACPR Instruction n° 2024-I-17 of 17 December 2024, which repealed and replaced Instruction 2023-I-15 and was itself amended by Instruction 2025-I-05 of 22 May 2025. It applies to collections with a reference date from 31 December 2024, except the CESSION state, which applies from 30 June 2025. It is issued under Articles L. 612-2 and L. 612-24 of the Code monétaire et financier.
The working content sits in three annexes:
- Annex I — the RUBA states themselves.
- Annex II — the activity thresholds that switch whole blocks of states on or off.
- Annex III — a matrix of states by category of institution, with periodicity and remittance deadline.
Two rules in the body matter for every filer. RUBA states are prepared under French national accounting standards, not IFRS. And they are reported in euros and sent by electronic transmission in XML-XBRL, to the technical specifications the ACPR publishes.
RUBA is also a Banque de France collection: its statistical content rests on Decision 2021-01 of 21 April 2021, amended by Decisions 2024-01 and 2026-04.
2. Which payment and e-money institutions are in scope
Article 1 of Instruction 2024-I-17 lists sixteen categories of reporter. Two concern this audience:
- Payment institutions under Article L. 522-1 CMF, except those that provide only payment initiation and/or account information services.
- Electronic money institutions under Article L. 526-1 CMF, with no carve-out.
The exclusion is narrow. A firm authorised for payment initiation or account information and nothing else is outside RUBA. Add a single other payment service and the firm is a RUBA reporter. The Banque de France’s summary of remittances also refers to “hybrid” payment and e-money institutions — firms combining payment or e-money services with another activity — for the safeguarding and volume states, so a hybrid structure does not take a firm out of scope.
3. How RUBA is built: common base, activity blocks, stand-alone states
RUBA states carry an RB number — RB.02 for SITUATION, RB.72 for CA_EP — while keeping the old SURFI short names. The Banque de France groups them in three families:
- Socle commun (common base). SITUATION, TIT_TRANS, RESU_INFI, C_IMPAYES, CAPITAUXP, INTRA_GPE, EFFECTIFS and CPTE_RESU. The Banque de France summary lists these as remitted by every subject institution, with no threshold.
- Activity blocks. Interbank, customer, repo, securities and forward financial instruments. A block is either owed in full or not at all, depending on whether the institution crosses the block’s threshold.
- Stand-alone states. Each with its own population and rules: consolidated non-IFRS statements, miscellaneous states, and the “prudential” states that carry safeguarding, payment volumes, e-money and own funds.
Annex III colour-codes each state for each category. For payment and e-money institutions, it marks some common-base and block states — RESU_INFI, C_IMPAYES, PENS_LIVR, TITRE_PTF, the forward-instrument states and IMPLANTAT — as not used for prudential purposes. That label concerns the ACPR’s use of the data, not whether the Banque de France still expects the state. Read it together with your Carte de Visite Fonctionnelle, which is the list the collection system actually expects from you.
4. The RUBA table set for a PI and an EMI
Annex III and the Banque de France’s remittance summary (version 1.3.0, dated 9 October 2026) give this core set. Deadlines are in calendar days after the reference date unless stated.
| State | Content | PI | EMI | Frequency | Deadline |
|---|---|---|---|---|---|
| RB.02 SITUATION | Balance-sheet situation | Yes | Yes | Quarterly | J+25 (J+10 working days for monetary-statistics reporters) |
| RB.03 TIT_TRANS | Trading securities, miscellaneous operations, fixed assets | Yes | Yes | Quarterly | J+25 |
| RB.38 CAPITAUXP | Provisions, equity and similar | Yes | Yes | Half-yearly | J+25 |
| RB.39 INTRA_GPE | Operations with the group | Yes | Yes | Half-yearly | J+25 |
| RB.53 EFFECTIFS | Activity indicators: staff, accounts | Yes | Yes | Annual | J+90 |
| RB.57 CPTE_RESU | Income statement | Yes | Yes | Half-yearly | By 31 March and 30 September |
| RB.06 / RB.07 CLIENT_RE, CLIENT_nR | Operations with resident / non-resident customers | Block | Block | Quarterly | J+25 |
| RB.31 CANTON_EP | Safeguarding of PI customer funds | Yes | — | Quarterly | J+25 |
| RB.33 VOLUME_EP | Payment volumes, amounts and number | Yes | — | Quarterly | J+25 |
| RB.72 CA_EP | PI own-funds requirement | Yes | — | Quarterly | Two months; three months for 30 June |
| RB.32 CANTO_EME | Safeguarding of EMI customer funds | — | Yes | Quarterly | J+25 |
| RB.34 VOLUM_EME | E-money breakdown | — | Yes | Quarterly | J+25 |
| RB.45 MON_ELECT | Electronic money | — | Yes | Quarterly | J+25 |
| RB.51 CAEFP_EME | EMI own-funds requirement | — | Yes | Quarterly | Two months; three months for 30 June |
| RB.55 / RB.56 BILA_CONS, RESU_CONS | Consolidated balance sheet and income statement, French GAAP | If applicable | If applicable | Half-yearly | J+90 |
Each category-specific state still points to its own source instruction: Instructions 2014-I-11 and 2010-06 for the payment-institution states, 2014-I-12 and 2014-I-02 for the e-money states, and Instruction 2009-03 for MON_ELECT. Those older texts set what the numbers mean. RUBA sets the format and the calendar. Our note on safeguarding under Article L. 522-17 CMF covers the rules the CANTON states measure.
5. Thresholds and the first 24 months
Annex II sets the triggers for the activity blocks. For a payment or e-money institution the one that matters is the customer block, CLIENT_RE and CLIENT_nR. It is owed once operations with resident customers, including leasing, exceed EUR 30 million or 20% of total assets plus liabilities. The aggregate counts customer assets, subordinated loans, leasing, and customer liabilities. The repo, securities and forward-instrument blocks each have a EUR 150 million trigger, and the interbank block has one at the same level.
Two rules override the thresholds:
- New reporters. Every newly subject institution files the customer-block states systematically for its first 24 months of activity, whatever its volumes.
- Monetary-statistics reporters. Institutions that report for monetary statistics under Banque de France decision 2009-03 file every activity block regardless of thresholds, on working-day deadlines.
The test is not self-assessed in real time. The ACPR’s General Secretariat assesses each institution’s position once a year. It uses the average of the last four quarterly returns it has received — September and December of year N−2, March and June of year N−1 — on the France perimeter of SITUATION. Fast growth therefore reaches the block with a lag, in both directions.
6. File format, filing rules and the xBRL-CSV question
RUBA is filed as XBRL against the RUBA taxonomy, which uses the Eurofiling architecture and is delivered through OneGate. The ACPR’s format page notes that, for RUBA, the decimal precision expected on monetary facts is −3 or finer under the applicable filing rules.
The live format question in 2026 is xBRL-CSV. From the 31 March 2026 reference date, the ACPR and Banque de France require xBRL-CSV for the EBA-based entry points — COREP, FINREP, resolution and similar — and reject xBRL-XML for them. Their February 2026 FAQ answers the RUBA question directly: the national taxonomies are not covered by the xBRL-CSV switch for now. A payment or e-money institution can therefore have to produce xBRL-CSV for one return and stay on XBRL-XML for RUBA.
Returns for reference dates before the switch stay in xBRL-XML whenever they are filed, so keep both generators alive.
7. How a RUBA taxonomy release lands
Each RUBA release comes as a package, and the delivery note lists its contents. For version 1.3.0 the package holds:
- the taxonomy, bundled with the EBA, Eurofiling and XBRL International components it imports;
- the DPM files — a data dictionary and annotated templates, plus a version annotated against the previous release with changes highlighted;
- the list of controls (validation rules) for the version, and the list of remittance rules;
- a taxonomy description and presentation;
- skeleton instance files containing every possible fact, filled with random data that carries no business meaning.
The annotated “versus” templates are the real change list. The skeleton instances test your toolchain, not your numbers.
Not every release is a project. Version 1.3.0 applies from the 31 December 2026 reference date, and its production version followed a draft put out for consultation on 18 March 2026. Its changes mostly answer IEDOM and IEOM requests: new overseas variants of several states and amended controls. A payment or e-money institution with no branch in the overseas departments or collectivities should find little to rebuild. It still has to load the new taxonomy and re-run its controls.
8. What changed from SURFI for payment and e-money institutions
The first RUBA delivery note, version 1.0.1 of September 2021, set out what the new taxonomy took over from SURFI. RUBA took over all the SURFI states, with a short list of exceptions: CREDITHAB moved to a dedicated taxonomy, the remuneration states went to the EBA taxonomy, RESU_PUBL was dropped, and some states changed for the balance of payments and the ECB’s monetary-statistics reform. Three points touch payment and e-money institutions directly:
- CA_EP moved in. The payment institutions’ own-funds state used to sit in a separate national COREP taxonomy. RUBA absorbed it, so it now travels with the rest of the national return.
- A transcoding file. The release shipped a CSV mapping each SURFI element to its RUBA definition — the tool for migrating an existing mapping rather than rebuilding it.
- Legacy wording survives. The 2025 amendment to Instruction 2014-I-12 still calls the EMI own-funds states “SURFI tables”; no separate SURFI filing exists.
9. Worked cases
A newly authorised EMI below every threshold.
Facts: an e-money institution authorised in March holds EUR 8 million of customer balances, far below the customer-block trigger.
What the rule says: Annex II makes the customer-block states mandatory for the first 24 months of any new reporter, whatever its activity level.
What the practitioner does: builds CLIENT_RE and CLIENT_nR into the first delivery and diarises month 24 to check whether the annual threshold assessment keeps the block in scope.
Outcome: no missing-state reminder in the first year, and a planned decision point rather than a silent drop.
A PI planning one xBRL-CSV engine for everything.
Facts: a payment institution’s reporting lead wants to retire the XML generator in 2026, now that the EBA-based returns have moved to xBRL-CSV.
What the rule says: the ACPR and Banque de France FAQ states that the national taxonomies are not affected by the xBRL-CSV switch for now. Returns for earlier reference dates also stay in xBRL-XML.
What the practitioner does: keeps XBRL-XML for RUBA and for corrections to earlier reference dates, and watches eSurfi for any announcement that RUBA will follow.
Outcome: no rejected RUBA delivery.
An account-information-only firm adding a payment service.
Facts: a firm authorised only for account information services extends its authorisation to money remittance.
What the rule says: Article 1 of Instruction 2024-I-17 excludes payment institutions providing only payment initiation and/or account information services. Any other service brings the firm in.
What the practitioner does: treats the extension as a RUBA onboarding project — common base, CANTON_EP, VOLUME_EP, CA_EP and the customer block, on French GAAP — and checks the Carte de Visite Fonctionnelle once it reflects the new status.
Outcome: the first quarter-end after the extension is filed, not discovered.
10. FAQ
What does RUBA stand for?
Reporting Unifié des Banques et Assimilés — the ACPR and Banque de France national return for banks and assimilated institutions, including payment and e-money institutions. It replaced SURFI from the 31 January 2022 reference date.
Which instruction governs RUBA today?
ACPR Instruction 2024-I-17 of 17 December 2024, as amended by Instruction 2025-I-05. It applies to collections from the 31 December 2024 reference date, and from 30 June 2025 for the CESSION state.
Do payment initiation or account information providers file RUBA?
Not if those are the only services they provide. Article 1 excludes them. A payment institution offering any other payment service is in scope.
Does RUBA move to xBRL-CSV?
Not for now. The ACPR and Banque de France stated in February 2026 that the national taxonomies are not covered by the xBRL-CSV switch that applies to EBA-based returns from the 31 March 2026 reference date.
When is the customer block owed?
When operations with resident customers exceed EUR 30 million or 20% of total assets plus liabilities, as assessed once a year by the ACPR. Every new reporter also owes it for its first 24 months.
11. What to do, today
- Head of reporting: rebuild the RUBA calendar state by state. Separate J+25 states, half-yearly states, CPTE_RESU’s fixed 31 March and 30 September dates, EFFECTIFS at J+90, and the two- and three-month own-funds deadlines.
- Finance: confirm that the RUBA feed is drawn from French GAAP figures, and document the bridge from any IFRS group ledger.
- Reporting engineering: keep XBRL-XML for RUBA alongside any xBRL-CSV work, and load RUBA 1.3.0 and its control list before the 31 December 2026 reference date.
- COO of a new or extended institution: plan for the customer block during the first 24 months, and track the annual threshold assessment after that.
- Compliance: reconcile CANTON_EP or CANTO_EME with the safeguarding records the same quarter they are filed.
Related: SURFI and RUBA — French supervisory reporting · OneGate — the Banque de France reporting channel · Carte de Visite Fonctionnelle
