Introduction
Decree no. 2025-840 of August 22, 2025 introduces a significant advance in the protection of personal data of individuals exercising management authority over a company.
By inserting a new article R. 123-54-1 in the French Commercial Code, these persons will now be able to keep confidential their personal address appearing in documents accessible to the general public via the Trade and Companies Register (RCS).
This new article is part of a wider drive to secure personal data, against a backdrop of heightened risks of harassment, usurpation or invasion of privacy.
Protection for managers and persons authorized to bind the company on a regular basis
The new article R. 123-54-1 is specifically aimed at persons exercising executive or management authority over the company.
This includes managers, chairmen, managing directors and deputy managing directors, members of the management board and the chairman of the management board, where applicable, the sole managing director, partners, and any person with the power to direct, manage or commit the company on a regular basis.
The protection covers information relating to their personal domicile, as mentioned in deeds or documents filed with the RCS. From now on, they will be able to request that this data not be made accessible to the public.
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Practical details: a centralized procedure via the one-stop shop
Requests for confidentiality must be made via INPI’s one-stop-shop platform.
If the request relates to a published document, a redacted copy of the personal address must be provided, which is then published by the clerk of the court in place of the original document, which is retained as proof.
Uncertainty for non-trading companies
A word of caution is in order when it comes to non-trading companies, such as associations, non-trading companies and liberal professions.
The new article R. 123-54-1 is inserted in Title II of the regulatory part of the French Commercial Code, entitled “Des commerçants”. However, this positioning raises a question about the scope of the decree: can managers of non-commercial structures validly benefit from this confidentiality option?
In practice, the INPI’s one-stop-shop platform enables these people to make the declaration. However, the Registrar, as custodian of the Trade and Companies Register, could refuse this request on the grounds that the regulatory basis would only apply to natural persons operating in a commercial context.
Exclusion of sole traders
It should also be emphasized that this provision does not apply to sole traders. The latter are not included in the list of persons covered by article R. 123-54-1, even though they too may be exposed to risks linked to the disclosure of their personal domicile.
Conclusion
The decree of August 22, 2025 represents a significant step forward in the protection of corporate officers’ personal data.
It provides a concrete confidentiality mechanism, but leaves certain legal uncertainties for non-commercial structures and sole traders.
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