SURFI — the French supervisory reporting framework
SURFI is ACPR’s all-in-one supervisory reporting infrastructure for French-authorised credit institutions, EMIs, PIs and investment firms. The acronym stands for Système Unifié de Reporting Financier. It runs quarterly, captures both statistical and prudential information, and travels through ACPR’s OneGate submission portal. For French-authorised PSPs, SURFI is the canonical national supervisory return — sitting alongside the EBA-coordinated FINREP and COREP frameworks rather than replacing them. This piece walks through what SURFI covers, who files which tables, and the practical reality of building the data layer.
1. What SURFI is
SURFI — Système Unifié de Reporting Financier — is the unified French supervisory reporting framework operated by ACPR. It consolidates earlier separate national reporting cycles into a single XBRL-based submission. The framework covers balance-sheet, off-balance-sheet, income-statement, statistical and certain prudential information.
SURFI is national. The EBA-coordinated FINREP and COREP frameworks apply on top of it. A French-authorised bank files both SURFI and FINREP / COREP; a French-authorised EME or EP files SURFI and a reduced FINREP set; a French-authorised investment firm files SURFI and COREP-IFR.
2. Legal basis
- Code monétaire et financier — the substantive supervisory powers
- ACPR instructions and notices defining the SURFI taxonomy versions, tables and submission rules
- EBA-coordinated frameworks (FINREP, COREP, IFR-COREP, AnaCredit) layered on top
- Banque de France statistical-reporting instructions for the balance-of-payments and monetary-statistical components
3. Who files which tables
| Firm type | SURFI tables |
|---|---|
| Credit institution (banque) | Full SURFI set, plus FINREP, COREP and AnaCredit |
| EME (Electronic Money Institution) | Reduced SURFI for EMEs; reduced FINREP overlay |
| EP (Payment Institution) | Reduced SURFI for EPs; reduced FINREP overlay |
| Investment firm (Prestataire de Services d’Investissement) | SURFI for non-banks plus COREP-IFR |
| Branch of foreign-licensed PSP in France | SURFI for the French-attributable activity |
ACPR publishes the specific table lists per category. The catalogue is refreshed periodically as the EBA frameworks evolve.
4. What SURFI captures
Core blocks for a non-bank PSP (EME, EP):
- Balance sheet — assets, liabilities, equity, with the line-item granularity ACPR needs to assess capital and safeguarding
- Income statement — interest, fees, operating expenses, results from financial operations, impairment
- Customer-funds breakdown — e-money outstanding (EMEs) and customer-payment balances (EPs), split by safeguarding model
- Off-balance-sheet items — commitments, guarantees, contingent liabilities
- Counterparty breakdowns — by sector and country, used for both supervisory and statistical purposes
- Settlement-account positions — flows through the Banque de France’s settlement system
- Cross-border flows — for the Banque de France’s balance-of-payments compilation
5. The OneGate channel
OneGate is ACPR’s portal for SURFI submissions and several other regulated returns. Each authorised firm registers a OneGate account at authorisation; named users are credentialed; submissions travel as XBRL with the SURFI taxonomy. Acknowledgements are returned with validation results. Persistent data-quality issues are referenced by ACPR’s data-quality team and feed supervisory inspections.
6. Cadence and deadlines
- Frequency: mostly quarterly; some tables monthly (statistical), some semi-annual or annual
- Reference dates: 31 March, 30 June, 30 September, 31 December for quarterly tables
- Submission deadline: typically T+30 to T+45 calendar days, depending on the table
- Format: XBRL against the ACPR SURFI taxonomy
- Channel: OneGate
7. Where the mapping work concentrates
The same three areas swallow most engineering time on a first submission, the same as for FINREP in Spain:
- Safeguarding accounts — must match ACPR’s view, with the counterparty correctly identified
- Counterparty sectoring — every counterparty has an ECB sector code; build the mapping once and reuse it
- Off-balance-sheet items — guarantees and commitments are easy to under-report
French-specific additions:
- Cross-border flows by counterparty country — used by Banque de France for balance-of-payments statistics; granularity is higher than the EBA-coordinated FINREP
- Currency split — even for euro-denominated balance sheets, the table structure captures FX-denominated subsets explicitly
8. Reconciliation with other returns
SURFI year-end totals must reconcile to:
- The audited financial statements
- FINREP submissions (where the firm files FINREP)
- COREP / COREP-IFR submissions (for prudential figures)
- Banque de France statistical returns where overlapping
Persistent reconciliation breaks are a supervisory matter. ACPR’s data-quality team flags pattern errors and asks for explanation.
9. FAQ
Is SURFI optional for non-bank PSPs?
No. A reduced SURFI set is mandatory for EMEs, EPs and investment firms authorised in France. Carve-outs by proportionality exist for the smallest entities; check ACPR’s current instructions.
Does SURFI replace FINREP for me?
No. SURFI is the national French framework. FINREP is the EBA-coordinated EU framework. The two coexist. French-authorised PSPs file both, with the reduced FINREP for non-banks layered alongside SURFI.
What about branches in France of foreign-licensed PSPs?
Branches typically file SURFI for their French-attributable activity, alongside the head office’s home-state filings. Coordination with the head-office finance function is the operational task.
Which XBRL discipline applies?
ACPR publishes versioned SURFI taxonomies. Validation rules are strict — calculated relationships between line items must hold. Pre-production dry submissions catch most errors before they hit live.
How does SURFI interact with AnaCredit?
For institutions in AnaCredit scope, the underlying counterparty-reference data is shared. SURFI captures aggregates; AnaCredit captures granular loan-level data. Building a single counterparty master serves both.
What’s the most common rejection reason?
Counterparty-sector misalignment between the firm’s data and ACPR’s expected code list, followed by reconciliation breaks between SURFI and FINREP.
10. What to do, today
- Pull the current SURFI taxonomy from ACPR; pin the version against your reporting calendar.
- Register a OneGate account before the first reporting cycle; credentials take time.
- Build the counterparty-sector mapping once and reuse it across SURFI, FINREP, COREP-IFR, AnaCredit.
- Map safeguarding accounts to SURFI line items explicitly.
- Run a OneGate pre-production dry submission before the first live filing.
Related: EMI licence in France · FINREP for Spanish PIs and EMIs · AnaCredit for payment firms
