Reporting foreign accounts, contracts and trusts in France

This is the part of the French system that costs foreign nationals the most, and it has almost nothing to do with how much tax they owe.

Article 1649 A of the French tax code requires a French resident to declare, with the annual return, every account opened, held, used or closed outside France during the year. The obligation attaches to holding the account, not to receiving income from it: an account with a nil balance, untouched for a decade, is still held and still reportable. The fine set by article 1736 IV is €1,500 per account and per year, raised where the account is held in a non-cooperative jurisdiction, and an omission extends the period during which the administration may reassess you from three years to ten.

Four separate obligations, often confused

Bank and investment accounts held outside France: article 1649 A, with the fine at article 1736 IV. Online banks and investment platforms are accounts for this purpose, whatever they call themselves.
Life assurance and capitalisation contracts taken out with a provider established outside France: article 1649 AA. A policy is not an account, and declaring it in the wrong place is not declaring it.
Digital asset accounts held on platforms established abroad: article 1649 bis C, with its own penalty scale at paragraph X of article 1736. This obligation is frequently missed because the holder does not think of an exchange as a bank.
Trusts: article 1649 AB places a reporting duty on the administrator where the settlor or a beneficiary is French resident, or where a French asset is in the trust. The duty falls on the administrator, but the consequences reach the family.

Why the penalty is so severe for so little tax

The logic is worth understanding, because it explains why arguing about the amount of tax involved gets nowhere. These provisions exist to give the administration visibility, not revenue. The sanction therefore attaches to the failure to inform, and it is calculated per account and per year rather than as a proportion of anything. Ten years of silence about four accounts is forty chargeable omissions, in a file where the tax at stake may be nil. Nothing in that calculation depends on intent.

The accounts people forget

The pattern is consistent across nationalities. A current account kept open in the home country for a standing order. A brokerage account left with a former employer's plan administrator. A savings product opened as a student. An account closed during the year, reportable for the very fact of having been closed. A payment platform holding a balance. A crypto exchange. None of these feels like a foreign account in the sense the form seems to intend, and all of them are.

If you have already missed a year

The exposure grows with every year of silence, because the fine is annual and the extended reassessment period keeps old years open. A taxpayer who regularises on their own initiative is treated more leniently than one an audit turns up, and information now flows automatically between tax administrations under international exchange arrangements, so an account abroad has not been safely invisible for some years. The work is to establish the full inventory, decide the correct text for each item, and regularise deliberately rather than piecemeal, with a professional able to conduct the exchange with the administration.

The inventory to build once

Every bank and brokerage account outside France, live or dormant. Every account opened or closed during the year. Every life assurance or capitalisation policy with a foreign provider. Every digital asset account, on every platform. Every trust in which you are settlor or beneficiary, with the administrator's contact details. Keep it as a standing list and update it annually, because the obligation is annual and memory is not.

The characterisation of a particular foreign arrangement under these articles is not always obvious, and reasonable views differ on some pension and savings structures. Where the position is genuinely uncertain, declaring is materially cheaper than being right, because the sanction punishes omission rather than tax. Regularising past years is a procedure conducted with the administration and requires a professional authorised to represent you; this firm prepares the position and coordinates, and does not itself file or represent.

Frequently asked questions

Do I have to declare an account with no money in it?

Yes. Article 1649 A of the French tax code covers every account opened, held, used or closed outside France during the year, and the obligation attaches to holding the account rather than to any income it produces. A nil balance changes nothing, and an account closed during the year is reportable precisely because closing it is one of the listed events. The fine at article 1736 IV runs per account and per year, and it is due whether or not a cent of tax was ever at stake.

Is a foreign life assurance policy declared like a bank account?

No, and the distinction matters because declaring in the wrong place is not declaring. Bank and investment accounts fall under article 1649 A of the French tax code. Life assurance and capitalisation contracts taken out with a provider established outside France fall under article 1649 AA, which is a separate obligation with its own reporting. A policy declared as an account, or an account declared as a policy, leaves the correct obligation unmet, and the sanction follows the obligation rather than the intention.

What about my crypto held on a foreign exchange?

It is separately reportable. Article 1649 bis C of the French tax code covers accounts of digital assets held with a platform established abroad, and paragraph X of article 1736 sets its own penalty scale. This is one of the most frequently missed obligations, because holders do not think of an exchange as an account-keeping institution and the obligation is more recent than the others. The account is reportable whether or not you disposed of anything during the year.

I have not declared for several years. What should I do?

Establish the complete inventory first, then regularise deliberately rather than filing one year and hoping. The exposure compounds because the fine is annual and the omission keeps old years open to reassessment for ten rather than three. Regularising on your own initiative draws a materially better response than being identified first, and tax administrations now exchange account information automatically, so time is working against the file. The procedure is conducted with the administration and requires a professional authorised to represent you.

Does declaring an account mean I will be taxed on it?

Not in itself. The declaration is an information obligation and is entirely separate from whether any income arising is taxable, which is settled by the ordinary rules and by the applicable treaty. An account holding cash that produces nothing generates a reporting line and no tax. This separation is precisely why the omission is punished so heavily: the administration is sanctioning the loss of visibility, not the loss of revenue, and it does so per account and per year regardless of the amounts involved.

ÉTHIQUE ET PATRIMOINE, a French simplified joint-stock company (SAS), registered office at 41 rue Saint-Ferdinand, 75017 Paris, France, Paris Trade Register no. 803 414 796, VAT no. FR 40 803 414 796, registered with ORIAS under number no. 24001817 (www.orias.fr) — Financial investment adviser (CIF) no. 18002418, member of ANACOFI-CIF, a professional association approved by the Autorité des marchés financiers, and Anacofi-Courtage for its brokerage activity. Presence: Paris, Montpellier, Singapore, Hong Kong, Bangkok, Shanghai and Dubai.

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Written by Stéphane Molère, Président d'Éthique et Patrimoine — page last reviewed on 2026-08-30 — rules quoted are those in force at that date.