SURFI and RUBA — French supervisory reporting

If your project documentation says you file SURFI, it is describing a framework that stopped being current in January 2022. SURFI was the French national supervisory reporting taxonomy for banks and assimilated institutions. It has been replaced by RUBA — Reporting Unifié Banques et Assimilés — which the ACPR describes as applying to the Banque domain, using the Eurofiling architecture, and replacing the SURFI taxonomy. The obligation did not go away; the taxonomy, the versioning discipline and the instruction behind it all changed. This piece sets out what the framework is now, who files what, how versions land, and where a payments firm’s work actually concentrates.

1. SURFI, RUBA, and what changed

SURFI was the national accounting-and-prudential reporting framework the ACPR and the Banque de France collected from French credit institutions, financing companies, payment institutions and electronic money institutions. It sat underneath and alongside the European frameworks — FINREP, COREP and, for investment firms, the IFR returns — carrying the nationally specific tables the European templates do not.

From 1 January 2022, RUBA replaced it. The ACPR’s own guidance to reporters is unambiguous on the point: RUBA remplace depuis le 1er janvier 2022 le reporting SURFI. The taxonomy documentation is equally direct — RUBA applies to the Banque domain, uses the Eurofiling architecture, and replaces the SURFI taxonomy.

Three things follow, and only the first is obvious.

• The name changed, the duty did not. Nothing was deregulated. Institutions that filed SURFI file RUBA.
• The architecture changed. Eurofiling is the same architectural family used by the European supervisory taxonomies, which is what makes it realistic to run national and European reporting through one XBRL toolchain instead of two.
• The versioning discipline changed. RUBA taxonomies are published as numbered versions tied to a specific arrêté date, with drafts released ahead of finals. That cadence is now part of the reporting calendar.

2. Legal basis and where the tables live

The framework’s content is not published as a single regulation. The tables and the submission arrangements are set out in the annexes to the ACPR instruction governing the unified banking reporting — Instruction n° 2024-I-17 for the current cycle — and are supplemented by the taxonomy packages published on the ACPR’s eSurfi site. Alongside sit:

• the French Code monétaire et financier, which establishes the obligation to transmit accounting and prudential documents;
• the European framework — CRR/CRD for credit institutions, PSD2 and the e-money directive as transposed for payments firms — which fixes what the prudential numbers mean;
• the ECB statistical regulations, which drive several of the statistical tables.

The practical point for anyone building the return: the instruction annexes are the specification, not the taxonomy files. The taxonomy tells the toolchain what is structurally valid. The instruction tells the reporter what each table means and who owes it.

3. Taxonomy versions are calendar events

RUBA taxonomies are published against the arrêté (reference) date from which they apply, which is what makes them plannable — and what makes it obvious when a firm has fallen behind:

Note also that the validation-rule files are versioned separately from the taxonomy and can be reissued mid-life. A file that passed last quarter can fail this quarter on an unchanged taxonomy, because the controls moved.

4. Who files what

The reporting population is broad but the table set is not uniform. What an institution owes depends on its category, its size, its consolidation position, and whether it falls under the SSM.

For a payment or e-money institution, the working expectation is a national reporting set built around the balance sheet and profit-and-loss statements, own funds and prudential ratios, safeguarding, counterparty and instrument breakdowns, and cross-border flows feeding the Banque de France’s balance-of-payments compilation. What that institution does not owe is much of the credit-institution table set, and that is where over-scoping wastes months.

The authoritative answer to “which tables?” is not read off the instruction by inference. It is published to each reporter individually as the Carte de Visite Fonctionnelle — the ACPR-generated list of reports the institution must submit, derived from the fiche déclarative the institution itself completes on OneGate. CVF releases have carried RUBA changes directly: one 2025 release enriched the CVF of SSM-supervised institutions with RUBA state 53 Effectifs.

5. Submission: the OneGate channel

RUBA submissions travel through OneGate, the Banque de France collection window. Two practical consequences for a first-time reporter.

First, accreditation is per collection and declarant pair, requested from the portal’s own login page against a nominative professional email address — not a shared mailbox. Being authorised as an institution does not produce the ability to file; that is a separate request with its own validation, and it can be granted for one collection and refused for another.

Second, a ticket number is not an acceptance. The delivery detail screen carries a per-step status — success, warning or failure — and for signed deliveries a signature block reporting the signatory, the signature validity, the certificate validity and the validity of the habilitation. Monitoring that stops at receipt of a ticket will report green on a file that failed validation two steps later.

6. Where the work actually concentrates

The build effort is rarely in the arithmetic. It concentrates in three places.

• Counterparty classification. Sector, residence and instrument breakdowns follow statistical definitions that do not match commercial customer segments. This mapping is built once and maintained forever.
• Chart-of-accounts alignment. National tables expect French accounting concepts. A group ledger built on IFRS group policy needs a mapping layer, and that layer is where restatements silently drift.
• Reconciliation across frameworks. The national return, the European prudential returns and the statistical collections draw on overlapping data at different granularities. Where they disagree, the divergence has to be explainable — supervisors compare them.

7. Three scenarios

Scenario 1 — the project scoped against SURFI. A group’s French branch programme carries a workstream named “SURFI reporting”, written from a vendor summary dated 2020. Facts to rule: RUBA replaced SURFI from 1 January 2022, uses the Eurofiling architecture, and is versioned against arrêté dates. What the reporting lead does: rescope against the current RUBA taxonomy and the instruction annexes, and check whether the chosen tool supports Eurofiling-architecture taxonomies rather than a bespoke SURFI import. Outcome: the toolchain question is asked before procurement rather than after. The failure mode is buying to a specification that has not existed for four years.

Scenario 2 — the file that failed on unchanged tables. A firm submits the same tables it filed last quarter, from the same taxonomy version, and the delivery fails validation. Facts to rule: validation-rule files are versioned separately from the taxonomy and were reissued for RUBA 1.2.0 and 1.2.0.1. What the analyst does: check the control-file version before assuming a data error, and add control-file reissues to the same watch list as taxonomy releases. Outcome: an hour of investigation instead of a week. The failure mode is re-deriving correct numbers to fix a validation change.

Scenario 3 — the table that appeared without warning. An SSM-supervised institution finds a headcount state expected in its RUBA scope that was not there the previous period. Facts to rule: the CVF is regenerated periodically and enriched by release; one release added RUBA state 53 Effectifs to the CVF of SSM-supervised institutions. What the team does: pull the CVF each quarter, diff it against the stored prior version, and treat additions as change requests with the release’s effective date. Outcome: the new state is built before it is chased. The failure mode is discovering scope changes through a late-filing reminder.

8. FAQ

9. What to do, today

• Search your own documentation for “SURFI” and rescope anything that treats it as the current framework.
• Confirm your reporting tool supports Eurofiling-architecture taxonomies, not a bespoke national import.
• Put RUBA draft and final taxonomy publication dates in the reporting calendar alongside the arrêté dates they apply to.
• Watch validation-rule file reissues separately from taxonomy releases — they move independently.
• Pull the Carte de Visite Fonctionnelle each quarter and diff it against the prior version; that is where scope changes surface first.
• Request OneGate accreditation per collection and declarant pair early, against nominative professional addresses, and accredit a second person.

Related: ONEGATE — the Banque de France reporting channel · Carte de Visite Fonctionnelle · The French reporting calendar for a payment firm · AMF MiFIR transaction reporting · Testing a new return before first submission · RPC, CRT and CRC — French balance-of-payments returns · QLB — the AML questionnaire on the SURFI collection · ERMES TRACFIN — filing a déclaration de soupçon · SIREN, SIRET and the French RNE