Signature Circular Translation for France

Beneficial ownership (RBE) and the KYC context

When an account is opened or a business relationship formed in France, the other side wants to establish the company’s beneficial owner as well as its authorised signatory, under know-your-customer (KYC) principles; that information rests largely on the register of beneficial owners (registre des bénéficiaires effectifs, RBE). Within this picture the signature circular is read as the document showing authority to represent, and in translation the signatory’s name and title are carried across clearly enough for a bank or notary to run the check.

In that verification the circular is assessed together with the extrait Kbis and the statuts, and the trade name and the names of the authorised persons are expected to agree across them. The translation carries the trade name across as it stands, does not equate it with a French document, and shows plainly whether authority is sole or joint. Limits of amount or subject matter are conveyed exactly; generalising a limit can mean the document is asked for again during the KYC review, and the transaction is delayed. Whether the authority arises from the articles of association or from a separate delegation is likewise made visible in translation, since that is what shows where the authority comes from.

Statuts and the document set

In a corporate file destined for France, signing authority is usually read alongside the company’s articles of association (statuts), a current registry extract (extrait Kbis) and the activity records. The French recipient verifies the representative’s authority by working across these documents, so the trade name and the names of the authorised persons are expected to appear consistently in all of them. The translation of the Turkish circular takes its place within that whole; the trade name is carried across as it stands and is not equated with a French document.

In French practice authority may arise from the articles of association, or it may be created by a separate delegation of powers (délégation de pouvoir), in which case the chain of authority has to be visible in the translation. The distinction in the circular between sole and joint signature is preserved, because it determines whether a signature binds the company. Where authority is limited by amount, subject matter or term, those limits are conveyed exactly; a generalising phrase risks making a limited authority look unlimited.

How current the circular is also counts; when a company’s management or its form of representation changes, the old document ceases to be valid and a new circular is drawn up. If an out-of-date document is put before the French side, the recipient may ask for a current copy, so it is best to work with a circular dated close to the transaction. The date of issue, the notary’s details and the notarial register number are kept exactly as they are in the translation, because these show which state of the representation structure the document reflects.

The counterparts: extrait Kbis and représentant légal

In France, who represents a company is read from the current registry extract issued by the trade and companies register (extrait Kbis) and from the legal representative (représentant légal) named in it. The translation of a Turkish signature circular has to answer what the French recipient will be looking for as the représentant légal and their signing authority. The translation does not characterise the Turkish document as an extrait Kbis; the document is conveyed under its own identity and explained in brackets where necessary.

Pouvoir/procuration and the form of representation

In French practice a delegation of authority is usually made by a separate instrument (pouvoir / procuration) or by a délégation de pouvoir. The distinction in the circular between sole and joint signature determines whether a signature binds the company, and it is kept explicit in translation. Where authority is limited by amount, subject matter or term, those limits are conveyed exactly; a trade name is an identity and is not translated.

A listed translator and the order of approval

In France a translation submitted for official use has to be produced by a sworn translator (traducteur assermenté) on the list held by a court of appeal; where the translation is produced in Türkiye, a sworn translator signs it, it is notarised, and an apostille is added. Because a signature circular is a notarial document, the apostille is obtained from the judicial justice commission.

• Do not leave the sole/joint distinction unclear.
• Do not translate the trade name and so damage the identity of the document.
• Confirm with the other side whether they want a listed assermenté translator or the Türkiye chain.

France is a party to the Hague Apostille Convention; confirm the current position from the official HCCH list. You can run your file through our single office in Ankara Kızılay, see the cost on our pricing page, and upload your document to request a quotation. This page is for general information and is not a substitute for legal advice; consult your accountant or lawyer on questions of authority to represent.