Tax audit

The audit opens with a file.

A company that keeps computerised accounts in France hands the inspector a copy of every entry for the year, at the start of the audit, in a format the state prescribes down to the field name. Eighteen fields, a set file name, a single sort order.

See the eighteen fields

A clean FEC file is not built the night before.

The accounting entries file, in French the “fichier des écritures comptables” or FEC, is the electronic copy of every entry in a financial year. The obligation sits in article L. 47 A, I du livre des procédures fiscales: computerised accounts are presented by handing over this file, at the start of the audit.

The software does not decide the format. article A. 47 A-1 of the same book fixes the fields, their order, the file name and the permitted character sets. A general ledger export to a spreadsheet does not meet the requirement, even when it holds exactly the same figures.

That is the part companies underestimate. An export is whatever the system happens to produce; the FEC is a defined file. Anything the system does not deliver has to be built into the configuration.

For a French subsidiary run from abroad, the obstacle is rarely technical accounting. It sits in the chain: a group ERP, an in-house chart of accounts, entry descriptions in another language, document numbering that follows head office logic. The file exposes all of it at once.

It can be tested in advance. The FEC can be produced and checked for a closed financial year, long before any audit notice arrives.

The eighteen fields, in order

Mandatory fields of the accounting entries file for commercial companies under the “plan comptable général”
No.	Field	Content
1	JournalCode	Journal code of the entry
2	JournalLib	Journal name
3	EcritureNum	Number in a continuous sequence
4	EcritureDate	Posting date
5	CompteNum	Account number
6	CompteLib	Account name
7	CompAuxNum	Sub-account number
8	CompAuxLib	Sub-account name
9	PieceRef	Reference of the supporting document
10	PieceDate	Date of the supporting document
11	EcritureLib	Entry description
12	Debit	Debit amount
13	Credit	Credit amount
14	EcritureLet	Matching reference
15	DateLet	Matching date
16	ValidDate	Date the entry was locked
17	Montantdevise	Amount in foreign currency
18	Idevise	Currency identifier

Order matters: the fields follow the sequence set by the regulation. Amounts appear as debit and credit, without a sign. Dates are written YYYYMMDD, with no separator.

File name, format, encoding

One file per financial yearEvery entry from every journal of a year sits in a single file, sorted by the date the entry was locked.
A prescribed nameSirenFECYYYYMMDD, where YYYYMMDD is the closing date. For a year ending 31 December 2026 and SIREN 908368616, the file is called 908368616FEC20261231.
Two families of formatA flat file with columns separated by a tab or by the “|” character, or a structured XML file. Permitted encodings are ASCII, ISO 8859-15 and Unicode UTF-8.

What makes a file fail

Empty or automatic descriptionsEcritureLib and CompteLib have to say something. “Entry”, “Miscellaneous” or an internal key tell nobody anything.
Numbering with gapsEcritureNum runs as a continuous sequence. Gaps and duplicates are among the first things examined.
Half-finished matchingEcritureLet and DateLet belong together. Matching without a date, or a date without matching, stands out immediately.
A group chart of accountsCompteNum follows the “plan comptable général”. A mapping applied at consolidation rather than in the French books can be read straight off the file.
Entries locked after the factValidDate is the date the entry was locked, neither the posting date nor the closing date. A whole year locked on one day invites a question.

The penalty, and how it is counted

Failure to present the accounts in the required format is penalised under article 1729 D du code général des impôts. The fine is 5 000 euros or, where an adjustment is made and the amount is higher, 10 % of the additional tax assessed. It applies per financial year audited: across three years it is counted three times.

A file handed over but not compliant counts as a file not handed over. The dividing line is not between “supplied” and “not supplied” but between usable and unusable.

Who does what

Your side

Access to the accounting system and its export functions
Decisions about the configuration
The line to your IT provider
Keeping the file for the statutory period

FRADECO

Checking the format, the mandatory fields and the internal consistency
Reconciling the file against the trial balance and the annual accounts
Saying what the configuration still has to deliver
Producing the file from the running bookkeeping, where we keep it
Sitting with you through the audit and handling the correspondence

Our part

Getting the file right in four steps.

1Produce the file while nothing rides on itFor the last closed year, from the system actually in use, with the access rights that exist today.
2Check the structureFields present and in order, file name, encoding, separator, format of dates and amounts.
3Check the substanceContinuous numbering, debit and credit balanced per entry and per year, agreement with the trial balance and with the tax return package (“liasse fiscale”) filed.
4Fix it at sourceWhat is missing belongs in the configuration and in posting habits, not in a file edited after export.

The choice of software is of course yours. We keep the French books so that the file comes out right, we check it before the audit, and we handle the correspondence when the administration asks for it.

When it pays off: once after every year-end close. The file is requested at the start of the audit, and the notice rarely arrives with comfortable warning.

Frequently asked

What we are asked about the FEC.

The answers cover the situations we see most often at French subsidiaries of foreign groups. An individual case always deserves a look of its own.

The obligation

Who has to produce an FEC?

Any business required to present accounting records that keeps its books on a computerised system. Legal form and size play no part: a three-person SAS is caught in the same way as a listed group.

When is the file requested?

At the start of the audit. Handing over the copy counts as presenting the computerised accounts, and the practical arrangements are agreed with the inspecting office.

Are accounts kept in a spreadsheet enough?

A spreadsheet is a computerised system, so the obligation applies. But a working file does not produce eighteen fields in the prescribed order, with continuous numbering and a lock date, on its own. This is where the gap between what exists and what is required is widest.

The books are kept abroad on the group ERP. Does that change anything?

The obligation attaches to the accounts of the French entity, wherever the system runs. What changes is the lead time: a compliant export from a group ERP usually goes through the team that administers it, and those requests are rarely done in a day.

Format

Does the file have to be in French?

The field names are those of the regulation. For the content, account and entry descriptions have to stay intelligible: descriptions in another language in the books of a French company invite questions, and questions lengthen an audit.

Which formats and encodings are accepted?

A flat file with columns separated by a tab or by the “|” character, or a structured XML file. Permitted encodings are ASCII, ISO 8859-15 and Unicode UTF-8. Dates are written YYYYMMDD, with no separator.

Can an FEC be corrected after export?

Editing the file by hand means presenting something other than the accounts. Differences belong in the books and in the configuration, after which the file is exported again.

In practice

What happens if the file is rejected?

A non-compliant file counts as a failure to present. The penalty under article 1729 D du code général des impôts applies, and the inspector may fall back on other means of proof. Compliance therefore belongs before the audit notice.

Is the penalty counted per audit or per year?

Per financial year. An audit covering three years can trigger three penalties of 5 000 euros, or 10 % of the additional tax assessed where that figure is higher.

How long do the files have to be kept?

Books, records and supporting documents are kept for six years under article L. 102 B du livre des procédures fiscales, and ten years under article L. 123-22 du code de commerce. In practice the longer period governs the archive.

Is the FEC connected to e-invoicing?

They are two separate obligations resting on the same master data. Accounts with clean account numbers, document references and customer identifiers produce a usable FEC and connect more easily to an approved platform. The timetable for the reform is set out on our page on e-invoicing in France.

Related work

The file comes out of the books and is used in the audit. Two services bear on it directly.

Accounting

Bookkeeping under the “plan comptable général”, journals and descriptions set up properly, year-end close and tax return package.

See the service

Tax advisory

Support during the audit, answers to the inspector’s requests and handling of proposed adjustments.