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France – New Penalties for UBO Non-Compliance
France has implemented stricter consequences for non-compliance with Ultimate Beneficial Owner (UBO) reporting requirements through a new law effective 15th of June 2025.
The legislation empowers commercial court clerks to initiate automatic deregistration proceedings for companies failing to maintain accurate UBO information.
Key Changes
The new legislation introduces significant changes to enforcement procedures. Commercial court clerks now have direct authority to initiate proceedings against non-compliant companies.
Following a formal notice, companies have a three-month window to comply before facing automatic removal from the Trade and Companies Register.
The law also implements enhanced penalties for both individuals and companies.
UBO Definition and Requirements
Under French law, an Ultimate Beneficial Owner is defined as any natural person who holds directly or indirectly more than 25% of share capital or voting rights, or who exercises control over management, administrative, or executive bodies, including control over the general meeting of shareholders.
In cases where no UBO can be identified, the company’s legal representative must be designated as the beneficial owner.
Compliance Timeline
All French-registered companies must maintain current UBO registration. Companies are required to submit updates within 30 days of any relevant changes to ownership or control structure.
Following a formal notice of non-compliance, companies have three months to meet requirements before facing deregistration.
Risks of Non-Compliance
Non-compliance triggers a two-tier penalty system. Administrative sanctions include automatic removal from the Trade and Companies Register after the three-month notice period expires.
Criminal penalties are more severe, with individuals facing up to six months imprisonment and fines of €7,500, while companies may incur fines up to €37,500.
How Mercator® by Citco (Mercator) Can Help
Mercator provides comprehensive UBO compliance – in France and in 121 jurisdictions where UBO requirements apply – and can assist companies in creating and maintaining UBO registers. For assistance, please contact mercator@citco.com.
