{"id":2116132,"date":"2026-09-04T03:07:43","date_gmt":"2026-09-04T01:07:43","guid":{"rendered":"https:\/\/kohenavocats.fr\/2026\/09\/04\/first-annual-accounts-french-company-foreign-founder-deadline\/"},"modified":"2026-09-04T03:07:43","modified_gmt":"2026-09-04T01:07:43","slug":"first-annual-accounts-french-company-foreign-founder-deadline","status":"publish","type":"post","link":"https:\/\/kohenavocats.fr\/en\/2026\/09\/04\/first-annual-accounts-french-company-foreign-founder-deadline\/","title":{"rendered":"When Are the First Annual Accounts Due for a French Company Set Up by a Foreign Founder?"},"content":{"rendered":"

For a foreign founder, the first annual accounts of a French company are governed by a sequence of dates rather than by the date printed on the company\u2019s first Kbis. The Kbis is the official extract showing key registration information. The decisive dates are the date of incorporation, the first accounting year-end, the date on which the accounts are approved, and the date on which a complete filing is accepted by the commercial court registry, known in French as the greffe<\/em>. A company formed in France may have to prepare accounts even when it has made no sale, opened no French bank account or remained dormant.<\/p>\n

The answer also depends on the vehicle. A SAS is a simplified joint-stock company; a SASU is a one-shareholder SAS; a SARL is a private limited liability company; an EURL is a one-shareholder SARL; and an SA is a public limited company. A French subsidiary is not treated like a branch of a foreign company. This article explains the first-year calendar, the approval and filing process for a founder abroad, the separate corporate tax return, and the response to a rejected or late filing. It uses RCS for the Commercial and Companies Register, INPI for the French National Institute of Industrial Property, the Guichet unique for the one-stop business-formalities portal, RNE for the National Business Register and BODACC for the official bulletin of civil and commercial announcements.<\/p>\n

The practical conclusion is simple but form-sensitive: identify the first closing date in the articles, prepare the accounts for that period, apply the approval rule for the exact legal form and the articles, then file the correct documents through the Guichet unique or the competent greffe<\/em>. The tax return on form 2065 is a separate deadline. A foreign founder should maintain one calendar for all of these events and retain evidence of every submission.<\/p>\n

I. When are the first annual accounts and first tax return due in France?<\/h2>\n

A. How do the incorporation date and year-end determine the first accounts?<\/h3>\n

The first question is the date on which the first accounting period ends. The date is normally selected in the constitutional documents and is not necessarily 31 December. The official Service Public guidance on choosing an accounting year-end<\/a> states that a company may choose the end of its accounting year freely, subject to the applicable rules. It also states that the first year may be shorter or longer than twelve months, up to twenty-four months. That flexibility can be useful for a company incorporated late in the year, but it must be coordinated with tax and corporate obligations.<\/p>\n

For example, a French subsidiary incorporated on 15 September 2026 may close its first period on 31 December 2026. Its first accounts then cover a short period of roughly three and a half months. The same company may choose 31 December 2027 as its first closing date, creating a longer first period. The longer period does not mean that the company can postpone every compliance obligation indefinitely. For a company subject to French corporate income tax, the first balance sheet cannot be closed later than 31 December of the year following the year of creation, according to the updated answer published by impots.gouv.fr<\/a>.<\/p>\n

The accounting year-end must also be distinguished from the filing date. At year-end, the company closes its books, performs the necessary inventory work and prepares a balance sheet, an income statement and notes to the accounts. The balance sheet describes assets, liabilities and equity at the closing date. The income statement records income and expenses for the period. The notes explain material information needed to understand those statements. A company with no turnover may have simple accounts, but \u201csimple\u201d is not the same as \u201coptional\u201d.<\/p>\n

The general accounting obligation is connected with Article L. 123-12 of the French Commercial Code<\/a>, which requires a trader to record movements affecting its assets and liabilities and to carry out an inventory at least once every twelve months. For a French company, the accounting file should therefore capture formation expenses, capital contributions, shareholder loans, bank charges, professional fees, foreign exchange movements and any transactions with the foreign parent. Keeping an empty ledger because trading has not started can produce an incomplete first balance sheet.<\/p>\n

There is a separate tax timing point for a company subject to imp\u00f4t sur les soci\u00e9t\u00e9s<\/em>, abbreviated IS, meaning French corporate income tax. The official tax answer says: La premi\u00e8re d\u00e9claration de r\u00e9sultat \u00e0 d\u00e9poser concernera la p\u00e9riode comprise entre la date de cr\u00e9ation et la date de cl\u00f4ture du premier bilan.<\/q> It also says that a newly created company that does not close a balance sheet during its creation year does not have to file a results declaration for that same year. This does not cancel bookkeeping or corporate governance. It only explains why the first form 2065 may cover a longer period than the calendar year in which the company was incorporated.<\/p>\n

Form 2065 is the annual French corporate income tax return. The ordinary deadline for a non-31 December year-end is the last day of the third month following the close, with an additional fifteen days for electronic filing, according to the official impots.gouv.fr page on results taxation<\/a>. If the accounting year ends on 31 December, a different early-May rule applies. A foreign founder should have the accountant record the applicable tax deadline rather than copy the annual-accounts filing deadline into the tax calendar.<\/p>\n

Consider a company incorporated on 15 September 2026 with a first closing on 31 December 2027. Its first IS return concerns the period from 15 September 2026 to 31 December 2027. The company does not file a first-year results return merely because 31 December 2026 passed without a balance sheet. It must still prepare accounting records for the entire period and plan for the tax return after the actual first closing. The fact that this is the first year does not remove the need to preserve invoices, bank statements, contracts and evidence of capital movements.<\/p>\n

The approval calendar depends on the legal form. For a SARL, Article L. 223-26 provides that the managers\u2019 inventory and annual accounts are submitted to the shareholders for approval within six months of the end of the accounting year, subject to a court extension. The current text is available on L\u00e9gifrance, Article L. 223-26<\/a>. For an EURL, Article L. 223-31 applies a specific one-shareholder mechanism and preserves the six-month approval period. The sole shareholder\u2019s decision must still be documented and entered in the appropriate register.<\/p>\n

A SASU follows a specific rule as well. Under Article L. 227-9 of the French Commercial Code<\/a>, the president prepares or stops the relevant accounts and the sole shareholder approves them, where appropriate after the statutory auditor\u2019s report, within six months of the closing date. If the individual sole shareholder is also the president, the signed inventory and accounts filed within the same period can, in the statutory circumstances, serve as approval. The company should still preserve the decision and the evidence of filing.<\/p>\n

A multi-shareholder SAS requires more care. Article L. 227-1 excludes several provisions applicable to soci\u00e9t\u00e9s anonymes, including Article L. 225-100, subject to the special rules of the SAS chapter. The articles of association determine the collective decisions and their procedure. The Criminal Chamber of the Cour de cassation, 7 January 2026, no. 24-83.864<\/a>, held that the six-month approval rule for an SA cannot automatically be used to establish the offence of non-establishment of accounts by a multi-shareholder SAS. The Court explained that the analysis changes where the SAS has one shareholder or where its articles set an approval period. A founder should therefore read the articles before treating six months as a universal SAS rule.<\/p>\n

That decision does not make a SAS\u2019s accounts optional or give its president an open-ended period. The company remains required to prepare accounts at the end of its accounting year, follow its articles and file after approval where the filing obligation applies. The decision means that a legal analysis must identify the obligation allegedly breached: failure to establish accounts, failure to approve them, or failure to deposit approved accounts. Those are connected events, but they are not interchangeable.<\/p>\n

For an SA, the ordinary general meeting is generally held within six months of the end of the accounting year under Article L. 225-100<\/a>. A foreign group using an SA should add the meeting deadline, the date for dispatching the documents to shareholders, the statutory auditor timetable and the filing deadline to the same control sheet. For a subsidiary, the parent company\u2019s global reporting calendar may be earlier, but it cannot replace the French company\u2019s own statutory calendar.<\/p>\n

Once the accounts have been approved, the filing period is normally one month for a paper filing and two months for an electronic filing. For a SARL or EURL, Article L. 232-22<\/a> requires the accounts and the result-allocation documents to be deposited within that timetable. For a company by shares, Article L. 232-23<\/a> imposes the corresponding filing obligation on a SAS, SASU or SA, subject to the documents and exceptions specified in the provision. The regulatory summary in Article R. 123-111<\/a> states: Les soci\u00e9t\u00e9s commerciales sont tenues de d\u00e9poser, dans le d\u00e9lai d’un mois \u00e0 compter de leur approbation par l’assembl\u00e9e ordinaire<\/q>, and extends that period to two months for electronic filing.<\/p>\n

The dates can be illustrated without pretending that every company has the same timetable. A SARL closing on 31 December 2027 must ordinarily have its accounts approved by 30 June 2028. If approval takes place on 30 June and the electronic filing is validly completed on 20 August, the filing falls within the two-month period after approval. A paper filing would have to be completed within one month. For a multi-shareholder SAS, first check the articles and the actual approval date before applying that example. For a SASU or SARL, apply the statutory six-month approval rule unless a lawful court extension changes the timetable.<\/p>\n

A branch must be placed on a different line in the calendar. A branch is not a new French legal person; its foreign head office remains the company. Under Article R. 123-112<\/a>, a foreign commercial company opening a first establishment in France files its constitutional documents and, each year, the accounting documents it prepared, had audited and published in the state of its registered office. The French filing follows the deadline of the law governing the foreign head office. Documents may need a French translation, and copies may need certification by the person authorized to bind the company in France. This is not the same as preparing and approving the accounts of a French subsidiary.<\/p>\n

The branch distinction matters to a founder deciding whether a parent-company reporting package is sufficient. If the French operation is a branch, the foreign company\u2019s accounts may be the relevant documents under Article R. 123-112. If the operation is a French SAS, SASU, SARL or EURL, the French legal entity must prepare its own accounts and follow the French approval and filing rules. A Kbis or registration extract may identify the establishment, but it does not answer the legal-form question by itself. Check the entity name, registration number and type shown in the company file.<\/p>\n

B. What does a foreign founder need to approve and file remotely?<\/h3>\n

The first remote task is not uploading a PDF. It is assembling a decision-ready package. For a French company, that package normally starts with the annual accounts: balance sheet, income statement and notes. It then includes the result-allocation proposal and the resolution or decision that approves the accounts and records what happens to the profit or loss. Depending on the company\u2019s size, legal form and circumstances, the package may also include a management report, a statutory auditor\u2019s report, consolidated accounts or a group-management report.<\/p>\n

Article L. 232-22 expressly refers to the accounts, the proposal for allocation of the result and the resolution or decision on that allocation for a SARL or EURL. Article L. 232-23 describes the documents for companies by shares and addresses the case where the accounts are not approved. If approval is refused, the company does not solve the issue by silently filing a later approved version as if no refusal had occurred. The refusal decision must be analysed and, where required, deposited within the relevant timetable.<\/p>\n

The INPI\u2019s official annual-accounts filing service<\/a> explains that the Guichet unique transmits the filing to the competent greffe<\/em>. Since 1 January 2023, the online route has been the standard channel. After validation, information is transmitted to the RNE and published on DATA INPI; the greffe<\/em> also publishes the relevant information in the BODACC. This is why a foreign founder should keep both the portal receipt and the later acceptance or rejection notice. \u201cSubmitted\u201d and \u201caccepted\u201d are not necessarily the same status.<\/p>\n

At the beginning of the process, the declarant must identify whether the filing concerns accounts of a company or a group and whether it is an initial or rectifying deposit. An initial deposit supplies the accounts and corporate documents for a period not previously accepted. A rectifying deposit corrects or completes a previous filing. Choosing the wrong option can make the history difficult to read, particularly where a filing was rejected for an incorrect company identifier, missing decision, invalid signature or incomplete attachment.<\/p>\n

The signature route is a frequent obstacle for a founder who lives outside France. INPI explains that the signatory must be a natural person, such as the legal representative or a duly appointed mandataire<\/em>. A mandataire<\/em> is a person authorized to act for the company in the formalities process. The electronic route may require an advanced electronic signature based on a qualified certificate, or FranceConnect+ authentication where the person signing can use that service. A foreign founder who cannot use the required identity system should arrange a written mandate for a French accountant or lawyer before the filing deadline.<\/p>\n

The mandate should identify the company, the exact financial years, the authority to submit an initial or rectifying filing, the authority to answer a rejection, and the authority to send proof of regularization to the court if a judicial procedure is pending. A short email saying \u201cplease handle the accounts\u201d may not be enough to resolve a court notice. Keep the signed mandate, the identity document or corporate authorization used by the mandataire, and the final submission receipt in the company\u2019s permanent file.<\/p>\n

Remote approval must also follow the company\u2019s articles and the legal form. For a one-shareholder company, the sole shareholder records a written decision. For a multi-shareholder company, the shareholders must use the meeting, written consultation or electronic process permitted by the articles and the applicable provisions. The minutes should identify the financial year, the accounts placed before the shareholders, the result allocation, the vote or decision, and the date. If a proxy is used, the proxy should identify the shareholder, the meeting or decision, and the scope of the authority.<\/p>\n

Time-zone problems should be addressed before the date of approval. A shareholder in New York, Singapore or London may receive the documents on a local date different from the French company\u2019s date. The corporate file should use one consistent date and time standard, and the minutes should state when the decision was adopted under the company\u2019s rules. Where a foreign parent must approve a related-party transaction or a capital support arrangement, that group approval should be kept alongside, but not confused with, the French company\u2019s annual-accounts decision.<\/p>\n

Translation requires the same discipline. A foreign-language power of attorney, shareholder resolution or parent-company certificate may need a French translation for the filing or for communication with the greffe<\/em>. The translation should not alter the company name, registration number, dates or amounts. Preserve the original and the translation. Do not replace the French subsidiary\u2019s accounts with the parent\u2019s consolidated accounts merely because the consolidated report is already available in English.<\/p>\n

Confidentiality is a filing option, not a non-filing option. Article L. 232-25<\/a> allows eligible micro-enterprises to declare that their annual accounts will not be made public and allows certain eligible small or medium-sized companies to request limited publication under the conditions stated in the Code. The company must attach the appropriate declaration at the time of filing and verify that it falls within the relevant legal category. A foreign parent\u2019s preference for privacy does not itself create eligibility.<\/p>\n

Before the founder signs, run a short control list:<\/p>\n