Digital share registers: what French law allows
Since 2017, a French private company can keep its share register in electronic form, including on a blockchain*. What the texts say, what they require and what they leave unchanged.
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The register, the reference for share ownership
In a French private company limited by shares, such as an SAS or an SA, shares are registered in the owner's name in an account kept by the company itself (French Monetary and Financial Code, article L. 211-7, accessed 16 October 2026). The share register (registre des mouvements de titres, or RMT) records every subscription, transfer, transmission or cancellation of shares in chronological order.
The French Commercial Code provides that these registers are kept by the company or by a person it appoints for that purpose (French Commercial Code, article R. 228-8, accessed 16 October 2026). They are consulted at every capital transaction and later during due diligence before a sale.
What the 2017 ordinance made possible
The French ordinance of 8 December 2017 (no. 2017-1674) allowed financial securities that are not admitted to a central securities depository, which essentially means those of private companies, to be recorded on a shared electronic ledger, known as a DEEP (Ordinance no. 2017-1674 of 8 December 2017, accessed 16 October 2026).
The report to the President of the Republic accompanying the ordinance states that this term covers "the main characteristics of the blockchain: its function as a register and its shared nature" (Report to the President of the Republic, Official Journal of 9 December 2017, accessed 16 October 2026). The text came into force on 1 July 2018 at the latest (Ordinance no. 2017-1674, article 8, accessed 16 October 2026).
Its effect is easy to state: recording shares on such a ledger is equivalent to recording them in an account (French Monetary and Financial Code, article L. 211-3, accessed 16 October 2026). Since 30 December 2024, the French Monetary and Financial Code has referred to this process as "distributed ledger technology" (Ordinance no. 2024-936 of 15 October 2024, accessed 16 October 2026).
What the 2018 decree requires
Decree no. 2018-1226 of 24 December 2018 set out the conditions (Decree no. 2018-1226 of 24 December 2018, accessed 16 October 2026). The ledger must guarantee that entries are recorded and remain intact. It must also make it possible to identify the owners of the shares and the type and number of shares held. Entries are covered by an up-to-date business continuity plan that includes periodic external storage of the data (French Monetary and Financial Code, article R. 211-9-7, accessed 16 October 2026).
The same decree amended the French Commercial Code. Registers of registered shares "may be kept in chronological order on paper or on any other durable medium, in particular by means of a shared electronic ledger" (French Commercial Code, article R. 228-8, accessed 16 October 2026).
What going digital does not change
The medium changes, the nature of the register does not. It is still kept in chronological order and its entries prevail over any supporting files, which cannot be used as evidence against it (French Commercial Code, article R. 228-8, accessed 16 October 2026).
Whether it keeps the register itself or appoints a third party, the entries still come from the company: changing the medium does not take the register out of the company's hands.
The integrity requirement has a practical consequence. An incorrect entry is not deleted: it is corrected by a new entry, which is itself recorded. The full history of the capital therefore remains readable, even years later.
A company moving from a paper register to an electronic one does not start from scratch. Past entries are migrated in order, so that each shareholder's position can be explained by the sequence of their transfers.
Choosing how to keep the register and migrating an existing one raise legal questions specific to each company. They are worth reviewing with your advisors, especially when the paper register has gaps or entries that need to be regularised.
Conclusion
French law allows private companies to keep an electronic register in which every entry is intact, identifiable and preserved. Able keeps the share register in a semi-automated way, anchored on a blockchain*: every validated entry is sealed, time-stamped and available in chronological order. A correction always takes the form of a new entry.
* Shared electronic ledger (DEEP): French ordinance of 8 December 2017 (no. 2017-1674) and decree no. 2018-1226 of 24 December 2018.