Unique personnel register: mandatory entries and penalties 2026

Quick answer. The unique personnel register (RUP — registre unique du personnel) is a mandatory document recording each employee's identity, nationality, date of birth, gender, job title, qualification and employment dates. Required information varies by contract type (fixed-term, apprentice, temporary work, part-time, foreign workers). Failure to maintain or omit entries: fourth-class misdemeanor fine per employee affected.

The unique personnel register applies to all employers in France, from sole traders to multinational groups. Governed by articles L1221-13 to L1221-15-1 and D1221-23 to R1221-26 of the French Labor Code, it is a cornerstone of employment compliance. Labor inspectors make it a routine priority during audits, which is why mastering its requirements is essential: a simple omission can trigger a fine. This guide covers the complete content rules, acceptable formats, and non-compliance risks.

The unique personnel register (RUP) is an administrative register documenting, for every employee, the legally required information. Unlike a payroll database or ordinary spreadsheet, the RUP has a specific legal status: it is the official document employers must produce in the event of a labor inspection, URSSAF audit or administrative inquiry.

Core function: to prove that a given employee was legitimately hired on a specific date, under which employment framework (CDI, fixed-term contract, part-time, apprenticeship, etc.), and under which conditions (authorized to work, temporary assignment, etc.).

The RUP must be updated at hiring (recorded in chronological order of arrival) and upon subsequent changes (job change, contract renewal, departure, etc.). It must remain indelible: once a name is entered, it never disappears; corrections are marked visibly (visible strikethrough, dated margin note, never correction fluid or digital overwriting). The register records employees in the order they were hired.

Every employee working in your establishment must be recorded in the RUP with the following information (article D1221-23 of the Labor Code):

Personal identification block#

1. Name and first names — entered in hiring order, indelibly recorded at the time of hire.
2. Nationality — country of origin (e.g., French, Italian, Nigerian). For employees with multiple nationalities, record the primary one or first obtained.
3. Date of birth — full day, month, year.
4. Gender — M or F (or, following legal recognition of gender change, the designation matching current identity documents).

Employment and qualification block#

1. Job title — the employee's position (e.g., "commercial assistant," "QA lead," "construction worker"). Must match the employment contract or applicable industry convention.
2. Qualification — education level or degree of specialization (e.g., "Bac level," "skilled laborer," "engineer"). Used for salary grading under industry-specific collective agreements.

Employment dates and transitions#

1. Start date — actual hire date (not the contract signature date if different).
2. End date — last working day or contractual termination date (e.g., end of fixed-term contract, resignation, redundancy). Enter only upon employee departure.

Beyond the standard entries listed above, labor law requires additional details based on the type of employment relationship.

Fixed-term contract (CDD)#

• Mandatory notation: "Fixed-term contract" + intended end date.
• Reason for CDD: the legal ground (replacement, temporary peak workload, project-based, etc.); useful for audit and dispute prevention.
• Renewals: if the CDD is extended, note each new end date; do not delete the previous date (maintain an indelible record). Multiple renewals must be traceable in the register.

Apprentices#

• Mandatory notation: "Apprentice" + training period dates (start and end of apprenticeship cycle).
• Qualification pursued: CAP, BP, BTS, degree, etc.
• Training supervisor: name, if different from the employer.
• Separate section: apprentices and interns must be recorded in a dedicated section of the RUP, separate from regular employees, in chronological order of arrival.

Professional development contract employee#

• Mandatory notation: "Professional development contract" + training dates.
• Total duration and split: work time vs. classroom time.
• Target qualification.

Part-time employee#

• Mandatory notation: "Part-time" + hours per week or per month as per contract.
• Typical schedule: if hours vary, record the standard distribution or usual days/times.
• Variation terms: if the contract allows variable hours, note this (e.g., "part-time with possible variation").

Temporary worker (agency worker)#

• Mandatory notation: "Temporary worker" or "agency worker."
• Name and address of the temporary work agency — the legal employer of the worker.
• Assignment dates — the period during which the worker is assigned to your workplace.
• Reason for assignment (replacement, seasonal peak, project, etc.).

Employee assigned from another company (non-agency)#

• Mandatory notation: "Assigned by [Company name]."
• Type of arrangement: secondment, inter-group assignment, salary portage, etc.

Foreign worker#

• Mandatory notation: the type of work authorization (visa, residence permit, work permit, reference number).
• Authorization validity dates: start and end dates (if applicable).
• Nationality (already noted in personal ID block).
• Any restrictions: (e.g., "Tunisian national, visitor residence permit, no work authorization" — in this case, employment is illegal and must never be recorded).

Paper or digital?#

Articles R1221-26 and case law accept both formats:

Key rule: regardless of format, entries must remain indelible. Using Excel, you must never retroactively correct a cell; instead, add a dated correction row or traceable comment. Using payroll software (Silae, PayFit, Lucca), the system automatically maintains history and blocks backdated edits — the safest option.

Access and data protection#

The RUP must be made available to:

• Labor inspectors, during audits.
• Employee representatives / Works Council (CSE) members, upon request within their legal remit.
• URSSAF agents, during social audit or reassessment.

The data (dates of birth, nationality, gender) fall under GDPR and must be protected: limited internal access, no public posting, etc. GDPR compliance does not eliminate the legal duty to maintain the RUP, but it adds administrative complexity.

1. At hiring#

• Day 1: record name, first name, nationality, date of birth, gender.
• Day 2: complete with job title, qualification, exact start date.
• Same day or day 1, depending on contract: if fixed-term, apprentice, part-time, temporary or foreign worker, record the specific notation.
• Verification: cross-check against ID documents and employment contract.

2. During employment#

• Job change: update job title and qualification; add a dated note explaining the change (e.g., "2026-02-15: promoted from assistant to manager").
• CDD renewal: add the new end date; do not delete the previous one (maintain indelible history).
• Transition from part-time to full-time CDI: update with date and note (e.g., "2026-03-01: converted to full-time CDI").
• Work authorization renewal: update the new expiry date of the foreign worker's permit; retain the previous date in the history.

3. At departure#

• Record the end date: employee's last day.
• Note the reason (optional but recommended): resignation, end of CDD, agreed termination, dismissal, retirement, etc. (aids future audit; not legally mandated but considered good practice).
• Never delete the entry: the register must retain the record for 5 years after departure.

Interns and civic volunteers are not employees, so they do not appear in the main RUP. Labor law provides for them a dedicated section, recorded in chronological order of arrival, containing:

• Name, first name, date of birth.
• Internship period (start and end dates).
• Training or field of placement.
• Training supervisor or responsible party.

This section follows different rules than the main register (no qualification or contract type required), but it must exist if you host interns.

Article R1221-26 mandates retention for 5 years from the date the employee departed the workplace. After 5 years, register entries may be deleted or archived.

Retention summary table#

Best practice: archive annual registers (paper or dated PDF) in a dedicated folder labeled "RUP Archives." Organizing by year of departure simplifies compliance and auditing.

Employee with legal name or gender change#

Update name and first names to match current identity documents. Adding a dated note (e.g., "2026-01-15: legal name change" or a discreet comment) can prevent confusion during audit, without disclosing sensitive details.

Posted or expatriate employee#

If a French employee works abroad for your company or a Romanian national works for you in France (EU posting), they remain recorded in your French register with their nationality and work authorization type. Optional notation: "posted to [location], [dates]."

Agreed termination (rupture conventionnelle)#

Record the end date (after notice period ends or actual last day if shorter). Noting "agreed termination" is good practice, though not legally required.

Dismissal, resignation, contract end#

Each may be noted in the RUP (dedicated column or margin note), but only the departure date is mandatory. Omitting the reason does not expose the employer to additional liability beyond R1227-7 penalties for the omission itself.

RUP ≠ GDPR data processing register#

The unique personnel register is not the GDPR data processing register. You need both:

• RUP: legally mandated list of employees and their administrative details (Labor Code).
• GDPR register: documentation of all data processing (emails, CVs, payroll files, video surveillance, etc.) — see GDPR processing register for SMEs.

CNIL penalties ≠ RUP penalties#

The RUP contains personal data (inevitable: dates of birth, nationality, gender), so it must comply with GDPR: limited access, justified retention periods, security. A GDPR breach on the RUP risks separate CNIL fines. A Labor Code breach (absent or incomplete RUP) triggers a fourth-class contravention. Both risks coexist with independent penalty regimes.

Audit trail for remote verification#

If your accountant must verify the RUP remotely (via shared folder or PDF extract), ensure no backdated edits. Excel with version history or dated backups are essential. Payroll software (Silae, PayFit) auto-preserves this history — recommended.

Recently, a 35-person SME was audited by labor inspectors following an internal report about part-time work conditions. Producing their RUP, an Excel file, the employer had retroactively modified it to justify declared hours. While the change was technically invisible (no visible trace), cross-checking with a former employee revealed the discrepancy: the register did not match preserved payslips. Result: a penalty for a non-compliant register (article R1227-7, fourth-class contravention applied per affected employee), plus a materially weakened position in the dispute.

Lesson: the RUP's evidential value depends on its integrity. An incomplete register is an infraction; a tampered register is worse. Use tools that auto-track edits (payroll software, versioned cloud storage) rather than open Excel files.

Hayot Expertise advice. Establish the RUP from your first hires, even as a sole trader. Do not treat it as a secondary administrative formality: it is your first line of defense in an audit. Review it quarterly (or after every hire and departure) to catch omissions before an inspection. If you use payroll software, it typically manages the RUP automatically — verify it is configured correctly (nationalities, contract types, part-time options). For a paper register, use a quality bound ledger, never loose sheets. And strictly preserve archives for 5 years after each employee's departure. A bit of administrative rigor today prevents redressments tomorrow.