RBE access requests get 12-working-day decision rule, 3-year certificate

Anyone requesting access to the beneficial-ownership register (registre des bénéficiaires effectifs, RBE) now faces a fixed decision clock. The Inpi, as register keeper, or the competent court clerk — the greffe of the tribunal de commerce, or of the tribunal des activités économiques or the tribunal judiciaire ruling in commercial matters in the districts concerned — must rule on the request within 12 working days on the basis of the information and supporting documents suppliedService Public. Where the requester already holds a valid access certificate, that period drops to seven working daysLegifrance.

The clock can be extended. In the event of a sudden surge in access requests, the 12-working-day period may be extended by the same length, and extended again by a further 12 working days if volumes stay high, with the number of extensions reported to the administration each half-year. Where the Inpi or the clerk asks the requester for additional information or documents needed to examine the file, the period grows by seven working days, on top of any high-volume extensions. If no answer arrives by the end of the applicable period, the request is deemed rejected.

The rejection is now implicit, with a transitional rule to watch: for requests filed on or after 10 November 2026, silence counts as an implicit rejection decision when the response period, including any extensions, expiresService Public; for requests filed before that date, silence counts as rejection after two months. A refusal, express or implied, can only rest on five grounds: missing documents or information, an unproven legitimate interest or one that does not match the requested use, serious signs the data will be used for unauthorised purposes, a legitimate interest recognised by another EU Member State's register that does not cover the requested use, or a disclosure to a requester outside the EU that would breach the GDPRLegifrance. An express refusal must be reasoned, state the available remedies and time limits, and the Inpi or clerk must keep the papers showing the checks carried out.

A granted request comes with a three-year access certificateService Public. While it lasts, the holder may file new access requests without having to justify their role or employment againService Public, though identity is still checked each time. The holder must report any change of circumstances that could alter the assessment of their legitimate interest, notably a change of role or job. During the first year the role or job may only be re-checked on reasonable grounds for believing the legitimate interest has lapsed; afterwards it may be checked at any time. Access may be revoked once its conditions are no longer met, including where the competent authorities of another EU Member State have withdrawn access they granted the holder.

The same page update widens full-register access: alongside the courts, customs, tax and supervisory authorities already listed, certain agents of the Autorité des marchés financiers (AMF) and the Autorité nationale des jeux (ANJ), and members of the sanctions committee of the Agence française anticorruption (AFA), are now named as entitled to the whole register. Declaring companies and entities may access all the beneficial-ownership information they declared, as may a natural person declared as a beneficial owner for the company concerned.

Legal basis: Code monétaire et financier, articles L561-46-2 and R561-58-2 to R561-58-6, as created by décret n° 2026-310 du 24 avril 2026.