SIREN, SIRET and the RNE — French company data

A French business customer can be perfectly legitimate, fully registered, and still return almost nothing from a public register lookup. France runs two national registers with different owners and different jobs: the répertoire SIRENE at INSEE, which assigns the SIREN and SIRET numbers, and the Registre national des entreprises (RNE) at INPI, live since 1 January 2023. Around them sit a single formalities window, a diffusion regime that can lawfully hide a sole trader’s address, and an activity code that is about to be rewritten for every company in the country. Here is how the pieces fit, and where a KYB rule written for other markets quietly fails in France.

1. Two registers, two jobs

SIRENE is the identification repository. Its legal basis is décret n° 73-314 of 14 March 1973, reproduced at Articles R123-220 to R123-234 of the Code de commerce, and it is managed by INSEE. It records what INSEE calls the civil status of every enterprise and every establishment — companies, associations, public bodies — whatever the legal form, the sector or the location in France and the overseas territories. INSEE assigns the numbers; it does not adjudicate anything.

The RNE is the legal register. It was created by Article 2 of the PACTE law, loi n° 2019-486 of 22 May 2019, and became operational on 1 January 2023, held by INPI. It absorbed three earlier registers — the national commercial and companies register, the trades register and the agricultural actives register — into one fully dematerialised file. Every enterprise carrying on a commercial, craft, agricultural or independent activity on French territory must be registered in it, with the overseas exceptions of French Polynesia, New Caledonia and Wallis and Futuna. Its public data are published free of charge through INPI’s open data portal, in JSON, with an API.

The local registre du commerce et des sociétés kept by the commercial court registries did not disappear; a company registered at the RCS is automatically entered in the RNE. So a French company generates entries in three places at once, and a due-diligence procedure that names only one of them will eventually ask for a document the counterparty cannot produce.

2. SIREN, SIRET, NIC — what each one identifies

INSEE defines an establishment as a geographically individualised production unit that remains legally dependent on its legal unit. A SIRET therefore identifies a place, not a person, and a single legal person can hold dozens of them. Two practical consequences follow.

First, a contract, a mandate and a sanctions screen belong against the SIREN; a delivery address, a merchant location and a payment terminal belong against the SIRET. Storing whichever number the customer happened to type into a single “French company number” field guarantees a reconciliation problem later, because the two are not interchangeable and the SIRET changes when an establishment moves while the SIREN does not.

Second, SIRET churn is normal and is not a red flag. A business that relocates a shop closes one SIRET and opens another under the same SIREN. Treating a changed SIRET as a change of counterparty produces false positives at exactly the firms that are most obviously real.

3. One door for formalities since 1 January 2023

The PACTE law also replaced the way French businesses file. Since 1 January 2023, formalities for creation, modification and cessation of activity must be filed online through the guichet unique des formalités des entreprises, operated by INPI. It replaced six separate networks of centres de formalités des entreprises — the chambers of commerce and industry, the chambers of trades and crafts, the chambers of agriculture, the commercial court registries, the social-security collection body and the business tax services — which had collected filings largely on paper.

For a payments firm the consequence is timing, not paperwork. A French customer who tells you their details have changed has filed once, through one channel, and the change then propagates to SIRENE, to the RNE and to the RCS on their own schedules. Divergence between the three during that propagation window is ordinary, and a rule that treats any mismatch between INSEE data and INPI data as an inconsistency indicator will fire on customers who have done everything right.

4. Diffusion status: why a French sole trader can be invisible

This is the trap that has no equivalent in most other member states. Natural persons registered in SIRENE may exercise a right to the diffusion or non-diffusion of the repository data concerning them, under Article A123-96 of the Code de commerce. Until 2023 that right was binary: a person could elect to be non-diffusible, and their record then disappeared from public consultation entirely.

Décret n° 2022-1014 of 19 July 2022, taken to align the repository with the GDPR, changed the design. A new version of the Sirene database was released on 21 March 2023, and a status of diffusion partielle replaced the old all-or-nothing non-diffusion. Two things moved at once. Legal persons can now request partial diffusion too, which was never previously available to them. And for natural persons under partial diffusion, a defined core becomes public where nothing was before: the SIREN and SIRET, the commune and the country (code and name), the administrative status — active or ceased for the legal unit, active or closed for the establishment — and the economic variables, meaning the principal activity, the employee-count bracket and the enterprise category. INSEE put the scale of the change at more than 2.8 million establishments and 1.9 million legal units becoming partly visible.

What stays hidden is what a KYB file usually wants. For a natural person under partial diffusion there is no name and no street address in the public data; for a legal person that has opted for partial diffusion, the sigle and the street number and street name are withheld.

There is a second consequence, and it is a compliance one rather than a data one. Records carry a diffusable_commercialement marker, and API consumers are expected to read it before deciding what a field may be used for. Data lawfully available to a back-office reviewer is not automatically data you may echo back into a customer-facing screen or a pre-filled form. A firm that pre-fills an onboarding journey from a register feed should be filtering on that flag, not on whether the field happened to be populated.

5. The APE code has no legal value — and every one of them moves in 2027

INSEE assigns an APE code automatically at registration, drawn from the nomenclature d’activités française (NAF). The official position on what it is worth is unusually blunt: the APE code has no legal value and cannot be relied on to justify applying, or not applying, a given right. It can help indicate which national collective agreement applies to employees, but that is an indicator and not an automatic match.

An enterprise receives one APE code, however many activities it carries on. The principal activity is determined by headcount for industrial activities, by turnover for commercial and service activities, and in mixed cases the industrial activity counts where it represents at least 25% of total turnover. Corrections run through two different channels: a genuine change of activity is a formality, filed at the single window; a code wrongly assigned to an unchanged activity is a reporting matter, raised with INSEE through its own online service.

Then the whole nomenclature moves. INSEE adopted NAF 2025 in December 2023 and Eurostat approved it in May 2024, following the European revision of the activity classification. It enters the statistical repositories from 2026 and works through statistical production to the end of 2029 — but the date that matters commercially is 1 January 2027, when the new code applies to every legal unit in SIRENE, micro-enterprises included. Businesses can already consult their future code against their SIREN through INSEE’s dedicated service, and request a rectification before it takes effect.

So any French merchant-category mapping, risk tier or prohibited-activity list keyed to NAF codes has a hard deadline. The correspondence table from the previous nomenclature is published, which makes the remapping a planned data exercise rather than a January surprise — provided someone schedules it.

6. Kbis, RNE certificate, and what a file actually needs

The extrait Kbis remains the document French counterparties expect to be asked for. It is issued by the commercial court registries, evidences registration at the RCS, and is conventionally required to be less than three months old. It is free to the company for its own extract through the registries’ online service; a third party pays a small statutory fee — of the order of €3.06 electronically, €4.00 by post and €2.44 at the court counter.

What has changed is who may insist on it. A long list of administrative procedures no longer requires a Kbis at all: the SIREN, or a certificate of registration in the RNE, is enough, and the RNE certificate now functions as a Kbis equivalent. That does not bind a private counterparty — a payments firm may still ask for a Kbis — but it does mean an applicant who offers an RNE certificate instead is not being evasive, and a procedure that accepts only a Kbis is asking for the more expensive of two equivalent documents.

7. Two worked examples

A sole trader who “does not exist”. A French entrepreneur individuel applies for a business account. The register lookup returns a SIREN, an active administrative status, a commune, a NAF code and an employee bracket — no name, no street address. The automated check scores it as unverifiable. Rule: Article A123-96 of the Code de commerce, as reworked by décret n° 2022-1014 and implemented in the Sirene release of 21 March 2023; this is partial diffusion working exactly as designed. What the analyst does: stops treating register silence as a negative signal, verifies identity and address from the customer’s own documents, and records the diffusion status on the file so the next reviewer does not repeat the escalation. Outcome: a legitimate customer is onboarded, and the firm stops generating a recurring queue of false unverifiable results against the single most common French business form.

A merchant whose category is about to change underneath you. A payments firm prices and risk-tiers French merchants from their NAF code. Rule: the APE code has no legal value and is an INSEE statistical classification; NAF 2025 replaces the current nomenclature for every SIRENE legal unit on 1 January 2027, with the correspondence table already published. What the team does: runs the correspondence table against its live French merchant book now, identifies the codes that split into several successors — the ones where a machine conversion has to choose — and resolves those from the merchant’s actual activity rather than waiting for the new code to arrive. Outcome: the repricing and re-tiering happens as a scheduled data migration with human review on the ambiguous cases, instead of as an unexplained January shift in the portfolio’s risk profile.

8. FAQ

9. What to do, today

Split SIREN and SIRET into separate linked fields and stop treating a changed SIRET as a changed counterparty. Add diffusion status to the French onboarding data model, and remove any rule that scores a sparse register response as a verification failure — for French sole traders that is the normal result, not the exception. If you pre-fill anything from a register feed, filter on the commercial-diffusion flag rather than on whether the field is populated. Accept an RNE certificate wherever your procedure currently demands a Kbis, since the state itself treats them as equivalents. And put the NAF 2025 remapping on a 2026 delivery plan: run the correspondence table against the live French book, find the codes that split, and resolve those from the merchant’s real activity while there is still time to ask.

Related: the French beneficial ownership register at INPI · FICOBA, the French account register · the Belgian enterprise number (BCE/KBO)