Since 2017, the French tax authorities have received every year, from many countries, information on the financial accounts that French residents hold abroad. This is the automatic exchange of information, organised by an international standard developed under the aegis of the OECD: the Common Reporting Standard, or CRS.
This article explains in plain terms how this exchange works, what information the French tax authorities receive and what it means for a French resident who holds an account abroad. Every situation remains specific: in case of doubt, a lawyer’s analysis helps determine the most appropriate steps.
In brief
- Financial institutions in more than 110 jurisdictions identify every year the accounts of their customers resident in other States and send the information to their tax authorities, which pass it on to those of the State of residence.
- For a French resident, this information in principle reaches the French tax authorities: the account holder’s identity, the account number, the balance or value at the end of the year, income and sale proceeds.
- For accounts of individuals, the standard in principle provides for no threshold: a small account may also be reported.
- The tax authorities compare this information with the declarations of accounts (form 3916-3916-bis) and with the income declared; a discrepancy may lead to a request for information or a pre-ticked box 8UU.
- An undeclared account exposes the holder to fines and to an extended reassessment period and, depending on the case, to surcharges or even criminal prosecution: a lawyer’s analysis helps identify suitable solutions.
Contents
What is the automatic exchange of information?
The automatic exchange of financial information (AEOI) developed after the 2008 financial crisis, as part of the fight against tax fraud and tax evasion. In 2014, the OECD adopted the Common Reporting Standard, which lays down common rules: which institutions report, which accounts, what information and on what timetable.
Within the European Union, this standard was transposed by Directive 2014/107/EU, known as “DAC 2”. France was among the first States to apply it: the first exchanges took place in 2017, for accounts held in 2016. Other jurisdictions followed from 2018, such as Switzerland. More than 110 jurisdictions now exchange information under this standard, including all European Union Member States, Switzerland, the United Kingdom, Monaco, Andorra, Singapore, Hong Kong and the United Arab Emirates; see the list of countries whose banks report to the French tax authorities.
The United States does not apply the Common Reporting Standard. France nevertheless receives certain information on the accounts its residents hold in the United States, under the intergovernmental agreement concluded with that country in 2013; this reciprocity is more limited, in particular because account balances are not transmitted.
The main stages
| Year | Stage |
|---|---|
| 2014 | Adoption of the Common Reporting Standard by the OECD and of the European “DAC 2” directive |
| 2016 | Collection of the first information by the financial institutions of the first participating countries, including France |
| 2017 | First exchanges between these countries, for the year 2016 |
| 2018 | First exchanges for other jurisdictions, including Switzerland |
| 2026 | Application of the European “DAC 8” directive, which extends the exchange to crypto-assets |
| 2027 | First exchanges planned on crypto-assets, for the year 2026 |
How does the exchange work?
The mechanism takes place in three stages, often summed up as “collect, report, exchange”:
- financial institutions (banks, brokers, certain insurance companies, etc.) identify the tax residence of their customers, in principle by means of a self-certification provided when the account is opened, which states the State of residence and the tax identification number;
- every year, they send to the tax authorities of their State the information on the accounts of customers resident in other participating States;
- those authorities then pass this information on to the tax authorities of the account holder’s State of residence, in principle before the end of September of the following year.
Accounts held indirectly, for example through a company or a structure that carries on no real activity, may also be reported, in the name of the individuals who control it.
What information is transmitted?
For each account concerned, the information transmitted in principle includes:
| Category | Examples of information |
|---|---|
| Identity of the holder | Name, address, State of residence, tax identification number, date and place of birth |
| Identification of the account | Account number, name and identifier of the financial institution |
| Amount | Balance or value of the account at 31 December, or the fact that it was closed during the year |
| Income | Gross amounts of interest, dividends and other income paid into the account, gross proceeds from the sale of securities |
For accounts of individuals, the standard in principle provides for no threshold: an account with a modest balance may therefore be reported. A threshold of 250,000 US dollars may, depending on the State, apply to certain company accounts opened before the standard came into force.
What do the French tax authorities do with this information?
The French tax authorities compare the information received with taxpayers’ returns: declarations of accounts abroad (form no. 3916-3916-bis) and income declared (form no. 2047 and return no. 2042). This information is also used in tax audits (see the article can the French tax authorities see your foreign bank accounts?).
When a reported account does not appear in the returns, the tax authorities may in particular pre-tick box 8UU of the income tax return (see the article on the pre-ticked box 8UU) or send the taxpayer a request for information (letter no. 751-SD). Depending on the case, they may also ask the taxpayer to justify the origin and terms of acquisition of the assets (Article L23 C of the French Tax Procedure Code): see the article on the request to regularise an undeclared foreign account.
An example
Paul, a French tax resident, has held an account with a Luxembourg bank for several years. At 31 December 2025, the balance is €3,000,000 and the account produced €75,000 of interest during the year. In 2026, the bank sends this information to the tax authorities of its country, which pass it on to the French tax authorities, in principle by the end of September 2026 at the latest. The French tax authorities can then check whether the account appears on a form 3916-3916-bis attached to the income tax return filed in the spring of 2026, and whether the €75,000 of interest was declared.
What are the consequences for an undeclared account?
Holding an account abroad is legal, but a French resident is in principle required to declare it every year and to declare its income (see which foreign bank accounts must be declared in France?). When these obligations have not been met, the law provides in particular for:
- a fine of €1,500 per undeclared account and per year, increased to €10,000 for an account located in a State or territory that has not concluded with France an agreement giving access to banking information;
- the tax evaded, with late-payment interest (0.20% per month) and, depending on the case, an 80% surcharge (Article 1729-0 A of the CGI), which then replaces the fine without being lower than it;
- a reassessment period for income tax extended to ten years, unless the total balance of the accounts abroad did not exceed €50,000 at any time during the year;
- in the most serious cases, criminal prosecution for tax fraud: when the fraud was committed by means of accounts opened abroad, the fine may reach €3 million, or double the proceeds of the offence, and the prison sentence seven years (Article 1741 of the CGI).
A voluntary regularisation does not, in principle, remove fines and surcharges, but it may make it possible to limit some of them: late-payment interest may thus, under certain conditions, be reduced by 50% when an amended return is filed voluntarily. Since the law of 23 October 2018, the tax authorities are moreover, in principle, required to report to the public prosecutor cases in which the tax reassessed exceeds €100,000 and carries certain surcharges. Before taking any step, it is advisable to consult a lawyer in order to analyse the situation and determine the most appropriate actions: see the articles regularising an undeclared foreign account: what to do if you forgot to declare it? and what fines apply for failing to declare an account abroad?, as well as the page on regularising an undeclared foreign account.
What I see in my cases
In my cases, undeclared accounts are almost always discovered by this route: the tax authorities receive the information, then send a letter to the taxpayer. These exchanges are what has changed most in recent years: information arrives from all over the world, and the tax authorities make full use of it. The accounts concerned are mainly securities accounts, life insurance policies and retirement accounts, located in all the countries of the European Union, in the United Kingdom, the United States, Israel, China, Hong Kong, Singapore and, increasingly, in Argentina and Canada.
FAQ
Is an account with a small balance reported?
In principle yes: for accounts of individuals, the standard provides for no threshold. An almost empty account may therefore be reported, and it is in principle to be declared every year on form no. 3916-3916-bis (see the guide form 3916: how to declare a foreign account, step by step).
Are accounts held in Switzerland concerned?
In principle yes: Switzerland has exchanged information with France under the Common Reporting Standard since 2018, for accounts held in 2017.
Are accounts held in the United States concerned?
The United States does not apply the Common Reporting Standard, but France receives certain information on its residents’ accounts under the agreement concluded with the United States in 2013, without account balances. The obligation to declare these accounts in France does not, in principle, depend on whether information is exchanged.
Are crypto-assets concerned?
The Common Reporting Standard covers financial accounts. For crypto-assets, a comparable mechanism has been adopted: in the European Union, Directive (EU) 2023/2226, known as “DAC 8”, has applied since 1 January 2026, and the first exchanges are planned for 2027. See the article crypto taxation: DAC 8 and the Travel Rule.
What happens when the tax authorities question a taxpayer about an account abroad?
They generally send a request for information (letter no. 751-SD) or, depending on the case, a request for justification of the origin of the assets (Article L23 C of the French Tax Procedure Code), which is in principle answered within sixty days. The answer, as a general rule, commits the taxpayer for the rest of the procedure: it is advisable to consult a lawyer before answering, in order to analyse the situation. See also the article on myPOS and the automatic exchange of foreign accounts.
Read more
- Can the French Tax Authorities See Your Foreign Bank Accounts?
- Which Foreign Bank Accounts Must Be Declared in France?
- Tax Return 2042: Foreign Accounts, Box 8UU or 8TT Pre-Ticked
- Request to Regularise an Undeclared Foreign Account: What to Do and What to Expect
- Regularising an Undeclared Foreign Account: What to Do If You Forgot to Declare It?
- What Fines Apply for Failing to Declare an Account Abroad?
