Opening a Bank Account in France for a US Entity: Obstacles and Solutions

Incorporating a French subsidiary — an SAS or SARL — is only the first step of a successful market entry. The second step, often underestimated, is opening an operational professional bank account. For US groups, this process can take several weeks to several months and runs into specific obstacles: FATCA compliance requirements, enhanced KYC due diligence, and a French banking regulatory environment that is naturally cautious toward entities with foreign ownership. This guide covers the practical challenges, the available banking options, and the strategies to structure the process and avoid prolonged delays.

⚠ Disclaimer

Banking practices and KYC requirements evolve frequently. The information in this article reflects practices generally observed at the time of publication. Account opening conditions, timelines, and documentary requirements vary by institution and client profile. This article does not constitute personalised banking or legal advice. Please consult a qualified adviser before proceeding.

1. Why it’s difficult: FATCA, KYC, and French banking regulatory environment

The primary obstacle for French subsidiaries of US groups is FATCA — the Foreign Account Tax Compliance Act. Enacted in the United States in 2010 and in force from 1 July 2014, FATCA requires foreign financial institutions (FFIs) to identify and report accounts held or controlled by ‘US persons’ (citizens, permanent residents, US entities). French banks are bound by an Intergovernmental Agreement (IGA) of Model 1, signed between France and the United States on 14 November 2013. Under this IGA, French banks report US account holder information to the DGFiP (French tax authority), which then transmits it to the IRS.

This obligation creates concrete friction for French banks. Every client with US ownership generates additional compliance costs: identifying US beneficial owners, collecting the correct tax forms (W-9 or W-8BEN-E depending on the entity type), and filing annual reports with the DGFiP. Banks also bear regulatory liability for any reporting failures — which creates a natural incentive toward caution and, in some cases, outright refusal. On top of FATCA, successive EU Anti-Money Laundering directives (most recently the 5th AMLD — Directive (EU) 2018/843, transposed into French law by the ordinance of 12 February 2020) layer additional KYC requirements, making the account opening dossier substantially more burdensome than for a purely French entity.

FATCA: who is affected?

A bank account is FATCA-reportable if the account holder is a US person (US corporation, US LLC) or where the entity’s FATCA classification and the rules applicable to substantial US owners trigger reporting. A French SAS wholly owned by a US corporation is a foreign (non-US) entity, but its US beneficial owners must still be disclosed. The bank may request a completed W-8BEN-E form (or another FATCA self-certification, depending on its internal procedures) signed by the French SAS, certifying its NFFE status and identifying the US owners.

2. The documentation dossier: what French banks require

Assembling a complete and coherent dossier is the single most effective action to accelerate account opening. A bank that receives an incomplete file will suspend its review — sometimes indefinitely. Here are the documents consistently required.

Documents relating to the French subsidiary

• Extrait Kbis less than 3 months old (the French business registration extract, issued by the commercial court registry after RCS registration).
• Signed and up-to-date statuts (articles of association — constitutive bylaws or updated version if amendments have been made).
• Proof of registered office address (commercial lease, domiciliation contract, or utility bill less than 3 months old).
• Valid government-issued photo ID for the Président (or Gérant for a SARL) and all beneficial owners holding directly or indirectly more than 25% of the share capital.
• Déclaration des Bénéficiaires Effectifs (DBE — beneficial ownership declaration) filed with the RCS, with its official filing acknowledgement.
• Description of business activities and revenue model: some banks require a brief business plan or activity description, particularly if the corporate purpose is broadly worded.
• Estimated financial flows: projected monthly volumes (client receipts, supplier payments, payroll), typical transaction amounts, target markets.

Documents relating to the US parent company

• Certificate of Incorporation (or Certificate of Formation for an LLC), issued by the state of incorporation, legalised or apostilled as required by the bank.
• Bylaws or Operating Agreement (for an LLC) — the governing document setting out the entity’s internal rules.
• Recent Certificate of Good Standing issued by the Secretary of State of the state of incorporation.
• List of officers and shareholders, with ownership percentages and copies of identification documents.
• EIN Confirmation Letter (the IRS letter confirming the Employer Identification Number — IRS Notice CP 575). Essential for FATCA compliance.
• Form W-8BEN-E: completed and signed by the French subsidiary, certifying its NFFE status and identifying its US beneficial owners.
• Depending on the bank: recent annual accounts or financial statements of the US parent (typically the last two fiscal years).

W-9 vs. W-8BEN-E: which form to provide?

Form W-9 is provided by US persons and entities (e.g., a US corporation opening an account directly, or a US individual as account holder). The French subsidiary (SAS or SARL), as a French legal entity, is not a US person — it provides Form W-8BEN-E. This form certifies the subsidiary as an NFFE and discloses any US beneficial owners above the reporting threshold (US individuals or entities indirectly owning more than 10% of the French subsidiary). An error on this form is one of the most common causes of account opening delays or outright refusals.

3. Banking options: a realistic assessment

Not all French banks are equally receptive to entities with US ownership. The choice of institution determines both the timeline for account opening and the quality of the long-term banking relationship. Actual timelines depend heavily on the ownership structure and the depth of the KYC review. The table below outlines the main categories of options available in France.

Practical recommendation: for the majority of mid-market US groups’ French subsidiaries, the most effective strategy is to apply in parallel at a professional online bank (for rapid access to day-to-day operations) while simultaneously submitting an application to a large traditional bank (for the long-term relationship, credit access, and counterparties that require a FR IBAN from a traditional institution). This dual approach avoids operational immobilisation during the often lengthy traditional bank review.

4. The capital deposit account: a preliminary step not to be confused with the business account

Before obtaining its Kbis, a French SAS or SARL in formation must deposit its share capital into a capital deposit account (compte de dépôt de fonds) held with a bank, notary, or the Caisse des Dépôts et Consignations. This account is distinct from the regular professional current account — the funds are frozen until the Kbis is issued, at which point they are released into the operating account. The bank issues an attestation de dépôt de fonds (capital deposit certificate) in return, which is a mandatory document for RCS registration.

For entities with US ownership, some institutions may be reluctant to open even this preliminary capital deposit account where enhanced KYC reviews are required. It is therefore strongly recommended to identify the target bank at the stage of drafting the bylaws, and to initiate KYC procedures in parallel — rather than looking for a bank after the statuts have already been signed.

5. The droit au compte: the legal safety net

Any company registered in France has a statutory right to a basic payment account, under Article L312-1 of the Code monétaire et financier (CMF). If a bank refuses to open an account, it must notify the refusal in writing, and the company can then apply to the Banque de France, which will designate an institution required to open a basic account.

This mechanism guarantees minimum access to banking services, but its limitations are significant: the assigned account covers only basic payment services (SEPA credit transfers, direct debits, and domiciliation of cheques). It provides no access to credit, overdraft facilities, or treasury management services. The droit au compte is therefore an ultimate safety net, not a substitute for a chosen banking relationship.

6. Structuring the process to avoid months of delays

Refusals and prolonged blockages rarely result from a bank’s ill will. They almost always stem from an incomplete dossier, a failure to anticipate KYC questions, or a poor choice of target bank. The following measures significantly shorten account opening timelines.

Before submitting the dossier

1. Identify the target bank before incorporating — ideally at the bylaw drafting stage. Verify that the institution accepts entities with non-resident shareholders, and if possible, make initial contact with the business banking team before submitting a formal application.
2. Assemble the complete documentary dossier for both the French and US sides before any application. Every missing document is a source of additional follow-up requests and delays.
3. Prepare Form W-8BEN-E with care: correctly identify the entity’s category (passive or active NFFE) and list all US beneficial owners above the reporting threshold. This form carries legal certifications — errors generate systematic clarification requests.
4. Clarify apostille / legalisation requirements upfront: some banks require US documents to be apostilled, others accept certified translations. Establish this before assembling the dossier.
5. If the US parent has an existing banking relationship with an international group present in France (BNP Paribas, Citibank, HSBC corporate banking, etc.), leverage that relationship: an introduction from the US banker to the French branch can materially accelerate the process.

During the review

1. Designate a single point of contact — preferably French-speaking — who can respond to information requests quickly. Banks pause their review clock while awaiting supplementary information; every day of delay in responding adds a day to the total timeline.
2. Do not submit duplicate applications to the same bank (e.g., through different branches): bank systems flag duplicates and may close all open files.
3. Keep a written record of every exchange — email confirmation of dossier submission, acknowledgements of supplementary documents provided. In the event of an unjustified blockage, these records are essential for internal escalation or for exercising the droit au compte.

The foreign IBAN trap

Some US groups initially use a Wise Business or Revolut Business account to begin French operations. These solutions are convenient for international flows, but carry a significant operational limitation: the IBAN issued is typically non-French (Belgian or Lithuanian, depending on the provider). In practice, although SEPA regulations prohibit IBAN discrimination based on country, some French institutions and counterparties have historically experienced operational issues in processing non-French IBANs. Anticipating this issue from the outset avoids costly operational disruptions.

7. Common mistakes to avoid

• Waiting for the Kbis before starting banking procedures. In reality, banks can review the dossier and prepare the account opening before receiving the Kbis — and some can open the capital deposit account before registration is complete.
• Neglecting the beneficial ownership declaration (DBE) with the RCS. The DBE is mandatory and banks verify its existence — its absence is a disqualifying factor.
• Submitting an incomplete or incorrectly categorised W-8BEN-E. This form must be prepared with the assistance of a tax adviser, given its legal certifications and compliance implications.
• Underestimating questions about the origin of funds. The bank will ask where the initial share capital came from (wire from the US parent: support with a board resolution and a bank statement from the parent company).
• Applying only to the most well-known large bank. Timelines and requirements vary considerably across institutions — a regional cooperative bank may process an application significantly faster than a large national bank.

8. How Expand CPA can facilitate the process

Expand CPA is a Franco-American accounting and tax advisory firm with offices in Paris, New York, and Tel Aviv. We support US groups throughout their French market entry — from legal structuring through to first operations. In the context of bank account opening, our support covers several concrete areas, and we regularly coordinate directly with banks, lawyers, and payroll providers to accelerate account openings.

• Documentary dossier preparation: we help gather, organise, and verify the completeness of all required documents — on the French side (Kbis, statuts, DBE) and the US side (Certificate of Incorporation, EIN letter, Good Standing certificate, board resolutions).
• FATCA compliance: our teams, familiar with FATCA and CRS obligations for Franco-American entities, assist with preparing the W-8BEN-E and correctly identifying your entity’s status (active or passive NFFE, beneficial owners to disclose).
• Coordination with your legal and banking advisers: we work alongside your lawyers and liaise directly with banking contacts to answer substantive questions quickly, reducing the back-and-forth that extends timelines.
• Accounting continuity from day one: once the account is open, Expand CPA can manage your French accounting, payroll and DSN filing, VAT returns, and annual tax return (liasse fiscale) — ensuring seamless continuity between operational launch and French compliance obligations.

Our bilingual (French-English) teams understand the constraints on both sides of the Atlantic — a practical reality that matters when a French bank asks questions about the ownership structure of a Delaware LLC, or when the New York headquarters needs to understand why a RIB is different from an ABA routing number.

Contact Expand CPA for tailored support with your French market entry.