France’s new electronic payroll reporting system, the Déclaration Sociale Nominative (DSN), is gradually being rolled out more extensively. It is now employers who paid more than €50,000 social security contributions for 2014 that are required to draw up a DSN as of July 2016.

Obligation to report

The progressive roll-out established by the decree of 18 May 2016 does not apply to private individual employers or to employers using services designed to simplify payroll procedures such as the enterprise service employment voucher (TESE), the “chèque emploi associatif” (special employment cheque used by non-profit organisations), the “titre firmes étrangères” (service for foreign firms) or the “titre emploi simplifié agricole” (simplified system for agriculture). In addition, while all other employers are concerned, the dates for switching to the DSN differ depending on whether the personnel employed comes under the general regime or the agricultural regime and whether the employer draws up its social security returns itself or via an appointed third party, like a chartered accountant.

Timeframe

For personnel covered by the general regime, DSN implementation is as follows:

Employers with no appointed third party:
– if the amount of social security contributions due for 2014 is less than €50,000, the DSN must be introduced as of salary payment in January 2017,
– if the amount of social security contributions due for 2014 is equal to or above €50,000, the DSN must be introduced as of salary payment in July 2016.

Third parties appointed by the employer:
– if the amount of social security contributions due for 2014 is less than €10,000,000, the DSN must be introduced as of salary payment in January 2017,
– if the amount of social security contributions due for 2014 is equal to or above €10,000,000, the DSN must be introduced as of salary payment in July 2016.

To determine the threshold of contributions, all amounts recovered by URSSAF (in metropolitan France) and CGSS (in overseas departments) should be taken into account. This particularly encompasses social security contributions, CSG, CRDS, unemployment insurance contributions, CSA, the Fnal contribution, and transport payment. Any penalties and increases paid by the employer are not included for determining these thresholds.

It is worth noting that regarding appointed third parties, the €10,000,000 threshold is assessed with regard for the total amount of social security contributions declared and paid for all principal employers. Therefore, if this threshold is reached or exceeded, the DSN must be drawn up as of July 2016 for all the client employers, irrespective of individual amounts of contributions paid in 2014.

Penalties

If a system other than the DSN is used once it becomes mandatory, the defaulting employer may be fined €2.50 per employee, within the limit of €750 per company, per month.

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