Ultimate Beneficial Owners: Beware of Automatic Deregistration!
Ultimate Beneficial Owners: Beware of Automatic Deregistration!
As of 15 June 2025, significant changes have come into effect regarding the sanctions applicable to companies' obligations to declare their ultimate beneficial owners (UBOs). The reform aims to strengthen the transparency of legal entities and enhance efforts in the fight against money laundering and terrorist financing.
🔎 What the French Monetary and Financial Code provides now:
The Registrar of the Commercial Court may proceed with the automatic deregistration of a company from the Trade and Companies Register (RCS), following a three-month formal notice sent by registered letter with acknowledgment of receipt, in the following situations:
In addition, the President of the Commercial Court may, at the request of the Public Prosecutor or any interested party, order the company to comply, appoint a legal representative to act on its behalf, or order its deregistration from the RCS if it fails to comply within three months of the injunction.
📬 A clear message to companies:
Updating UBO information is not just a formality — it is now a condition for the legal existence of the company on the Trade and Companies Register.
📌 Legal basis:
Law no. 2025-532 of 13 June 2025 – Article 4 (V)
Articles L.561-47, L.561-47-1, and L.561-48 of the French Monetary and Financial Code
🔎 What the French Monetary and Financial Code provides now:
The Registrar of the Commercial Court may proceed with the automatic deregistration of a company from the Trade and Companies Register (RCS), following a three-month formal notice sent by registered letter with acknowledgment of receipt, in the following situations:
- No declaration of beneficial ownership has been made,
- The declared information is inaccurate or incomplete, and the company fails to rectify the situation,
- A discrepancy is reported by a person subject to anti-money laundering obligations or a regulatory authority, and the issue is not rectified within the required timeframe.
In addition, the President of the Commercial Court may, at the request of the Public Prosecutor or any interested party, order the company to comply, appoint a legal representative to act on its behalf, or order its deregistration from the RCS if it fails to comply within three months of the injunction.
📬 A clear message to companies:
Updating UBO information is not just a formality — it is now a condition for the legal existence of the company on the Trade and Companies Register.
📌 Legal basis:
Law no. 2025-532 of 13 June 2025 – Article 4 (V)
Articles L.561-47, L.561-47-1, and L.561-48 of the French Monetary and Financial Code