Bookkeeper vs French chartered accountant: what foreign companies must understand before opening a subsidiary in France

When a UK or US group opens a French entity, the natural instinct is to find a local bookkeeper or accountant, by analogy with the home-country setup. This translation is unreliable. The term bookkeeper has no regulated equivalent in France. A UK or US bookkeeper may be highly competent at posting transactions, preparing bank reconciliations or producing management accounts — but they are not registered with the French Ordre des experts-comptables, and they cannot legally perform the work reserved to that profession.

This is not a question of individual skill. It is a question of legal framework.

The French Ordinance of 19 September 1945, which established the Ordre des experts-comptables, creates the professional monopoly. Article 2 reserves to registered members, on a habitual and professional basis, the mission of maintaining, centralising, opening, closing, supervising, correcting and consolidating the accounts of companies and organisations to which they are not bound by an employment contract.

In practice: if your external service provider maintains the accounts of your French subsidiary on a habitual professional basis, they must be an expert-comptable registered with the Ordre, or must operate under the responsibility of such a professional. A bookkeeper in the UK or US sense, an administrative management company without registration, or an unregistered consultant cannot take on this mission without creating a legal irregularity.

This framework applies regardless of the client company's nationality, including for a French SAS or SARL owned by a foreign group.

The distinction does not prohibit all collaboration with an unregistered provider. In a well-structured organisation, a bookkeeper or administrative team can handle:

• Collecting and organising supporting documents (purchase invoices, expense reports, bank statements).
• Reconciling data with the group ERP.
• Preparing exports for the French accountant.
• Producing internal management reports for the group.
• Monitoring payments and managing collections.

What cannot be delegated without supervision from a registered expert-comptable: the statutory maintenance of accounts, the accounting review, the preparation of annual accounts, the preparation of the French tax return (liasse fiscale), and tax filings that engage the professional liability of the preparer.

The practical boundary: preparing data, yes. Validating, closing and signing off, no.

Key French compliance obligations for foreign subsidiaries#

The FEC deserves particular attention. Article L47 A-I of the French Tax Procedures Code (Livre des procédures fiscales) requires delivery of a standardised computer file at the start of any tax audit. A poorly structured, incomplete or inconsistent FEC can lead to rejection of the accounts and reconstruction of taxable profit by the tax authority. For a foreign subsidiary — with intercompany flows, multi-currency transactions and management fees — FEC quality is a direct tax risk factor.

A London-based consulting group creates a French SAS to carry its Paris activity. The group already has an in-house bookkeeper in London managing UK accounts. The initial plan is to extend that setup to cover the French entity.

First friction point: VAT. The French SAS invoices French clients and charges intercompany management fees to the UK parent. French VAT rules on services between related parties — place of supply, reverse charge, mandatory invoice mentions — differ substantially from UK VAT. The London bookkeeper is not familiar with these rules. An error in VAT collection or recovery triggers an assessment with interest and penalties.

Second friction point: the liasse fiscale. At year-end, the SAS must file a liasse fiscale 2065, which includes the balance sheet, profit and loss account in PCG format, and multiple tax schedules. This document has no direct equivalent in UK accounting. A UK bookkeeper cannot produce a French tax package.

Third friction point: the FEC. During a tax audit, the French tax authority requests the FEC in the DGFiP-standard format. If transactions were posted in Xero or QuickBooks without a proper PCG chart of accounts, the FEC export will be rejected or incomplete.

The right structure: the London bookkeeper continues managing group management accounts and intercompany reconciliations. A bilingual French expert-comptable firm — experienced with foreign subsidiaries — takes on the statutory accounting, all French filings, payroll, and FEC production. A data exchange protocol is established between the two.

Having a group bookkeeper is not an obstacle. It can simplify the subsidiary's operations if roles are clear.

What the group bookkeeper provides:

• Monthly export of intercompany flows from the central ERP (SAP, NetSuite, Oracle).
• Intercompany balance reconciliation at close.
• Validation of consolidation adjustments.
• Group reporting in IFRS or US GAAP.

What the French expert-comptable provides in parallel:

• Accounting maintenance under the PCG, with a chart of accounts adapted for intercompany flows.
• FEC production compliant with Article L47 A-I LPF.
• VAT, corporate tax, CFE, payroll tax declarations.
• Liasse fiscale 2065 and annual accounts filing at the Greffe.
• French GAAP to group reporting reconciliation bridge.
• Single point of contact in case of tax or social security audit.

Worked cost example: for a subsidiary generating EUR 800,000 in annual revenue with 5 employees, 3 main clients and regular intercompany flows, a full-scope engagement at a firm specialised in foreign subsidiaries typically ranges from EUR 6,000 to EUR 14,000 per year (accounting, VAT, tax return, payroll, reporting), depending on flow complexity. That budget is substantially below the cost of a tax reassessment or a social security reclassification resulting from poorly managed compliance.

In files we handle for UK, US and international subsidiaries in France, the recurring difficulties do not come from bad intentions at headquarters. They come from three structural misunderstandings.

First misunderstanding: believing the software solves the regulatory problem. Xero, QuickBooks or Pennylane are tools. They do not produce a compliant French tax package without specific configuration and review by a registered professional.

Second misunderstanding: confusing group reporting with French statutory accounting. A balance sheet in IFRS or UK GAAP does not serve to file accounts at the French Greffe, calculate French corporate tax, or feed the FEC. The reconciliation is a standalone step that takes time and must be documented.

Third misunderstanding: thinking the subsidiary is too small to need a qualified firm. A French SAS with two employees and EUR 300,000 in revenue has exactly the same declarative obligations as a fifty-person business: VAT, corporate tax, DSN, tax package, annual filing. Size does not reduce obligations. It only reduces the absolute value of potential penalties — which does not make them acceptable.

• Electronic invoicing reform: the rollout schedule for mandatory e-invoicing (reception, then issuance, by phased deadline) must be integrated into the subsidiary's organisation. Applicable deadline depends on company size — verify with your French accountant.
• Beneficial ownership register: must be updated on any group structure change. Non-compliance carries financial penalties.
• Payroll and DSN: subsidiaries processing payroll from a foreign headquarters consistently underestimate the complexity of French DSN filings and social charges. A French payroll specialist or a firm with a social law practice is strongly recommended.
• Permanent establishment risk: if foreign directors regularly perform their activity in France without the subsidiary being formally constituted, there is a risk of an undeclared permanent establishment. This must be assessed with a tax specialist.

• Verify that the accounting provider is registered with the Ordre des experts-comptables français.
• Formalise an engagement letter that clearly delimits the firm's scope and any tasks retained internally or by the group bookkeeper.
• Configure a PCG chart of accounts in your accounting tool, even if the group ERP runs on IFRS.
• Establish a data transfer protocol between the group bookkeeper and the French firm (format, frequency, validation).
• Build a shared closing calendar with headquarters, including key French dates (VAT filings, DSN, liasse fiscale deadline, Greffe filing).
• Plan FEC production from the outset of the accounting setup, not at the time of a tax audit.

This article is current as of 25 May 2026. It is informational and does not replace an analysis of your specific situation, documents and applicable law. Thresholds, deadlines and filing requirements should be verified against your structure and financial year.

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