ClearstreamXact: Enhanced beneficial owner disclosure for France
Clearstream Banking1 informs clients that effective
24 November 2025
beneficial owners (BOs) of securities taxable in France must be disclosed via the BO Details section of an MT565 message or through CA Instructions in Xact Web Portal. The Upload BO list “BO Upload” functionality for France will no longer be available.
Impact on clients
We will continue to require two messages, and we will distinguish an instruction for a reduced withholding tax rate from a BO disclosure as follows:
- Messages without a BENODET section will be considered as a Tax rate instruction.
- Messages with a BENODET section will be considered as a BO Disclosure only.
Upon receiving a BO disclosure message, we will verify whether there is an instructed but undisclosed position available for allocation - either from a Standing Instruction on your account or a valid per-payment instruction for a reduced withholding tax rate.
There is no change to the respective deadlines to provide tax instructions and BO disclosures (please refer to the Market Taxation Guide - France).
Clearstream Banking will send an MT564 Reminder message 10 days before the disclosure deadline if the instructed and disclosed quantities are different.
For DVOP2 and DVSE events, there will no longer be a separate OTHR event announced as both reduced rate instructions and BO Disclosures, will be processed on the existing DVOP or DVSE event.
Straight-through processing (STP) BO disclosure
Formatted BO disclosure messages are processed and feedback will be provided for both accepted and rejected disclosures.
To provide beneficial owner information in an MT565 or an Xact Web Portal CA Instruction, Clearstream Banking offers two possibilities:
- A Unique BO ID assigned by Clearstream Banking to every beneficial owner on record;
- Any TIN issued by a Tax Authority previously certified with Clearstream Banking.
Information that was previously requested when using BO Lists, such as Beneficiary Name, Address Line 1 to 5, Status of the beneficial owner, will now automatically be retrieved from certificates on record with Clearstream Banking.
Common use cases:
- To correct relief at source instructions after payment, the original instruction must be cancelled and new tax instructions sent. Tax instruction corrections on a relief at source instructions are no longer possible.
- Multiple BO disclosures for a particular CA Event/Account/Withholding tax rate can be provided and will be treated as a single disclosure against the instructed quantity.
- A BO Disclosure message is needed for each CA Event/Account/Option/Withholding tax rate combination:
- Example: For a DVOP, if there were CA instructions for CASH and SECU at 0% withholding tax rate, a separate BO disclosure is expected for each instruction, CASH 0% and SECU 0%.
- Before a replacement BO disclosure can be provided, the previous one must be cancelled with an MT565 CANC or an Xact Web Portal CA instruction cancellation.
- When tax instructions are cancelled by clients, Clearstream Banking takes no action on any existing BO disclosure.
- After the BO disclosure deadline:
- Undisclosed quantities will be adjusted to the default market rate.
Example: A tax instruction on a dividend for 1,000 shares to be taxed at 10% with a BO Disclosure for only 800 shares, will generate a tax adjustment on the undisclosed 200 quantity to be taxed at market rate; - Over-disclosed quantities will cause the entire instructed quantity to be adjusted from reduced to default market rate and the BO Disclosures messages rejected;
Example: A tax instruction on a dividend for 1,000 shares to be taxed at 10% with a BO disclosure for 1,200 shares, will generate a tax adjustment on the instructed 1,000 quantity to be taxed at market rate. - Other adjustments that depend on the BO disclosure being finalised, such as Foreign Tax Credit adjustments, will also be processed.
- Undisclosed quantities will be adjusted to the default market rate.
We remind clients that a standing instruction for French dividends is valid only for mandatory dividend distributions that cover stock dividend, cash dividend proceeds and cash default option of choice dividend proceeds. Also, Clients with an one-time certificate (OTC) for a single beneficiary (OTC Box 1), must renew it before 21 November 2025 to maintain their standing instruction after this date (for more information, see Announcement C25017).
BO disclosure using Xact via Swift
The following table describes the option and format to be used for each scheme.
Beneficial owner identified with: | ||
Clearstream Banking Unique BO ID | TIN | |
(Sequence C: BENODET) | ||
Tax ID number | :95R::OWND/CEDE/ | :95S::OWND/TXID/xx/ |
Quantity of Securities Owned | :36B::OWND | :36B::OWND |
Examples: | ||
:16R:BENODET:95R::OWND/CEDE/123456 :36B::OWND//UNIT/300, :16S:BENODET | :16R:BENODET:95S::OWND//TXID/FR/99 99 999 999 999 :36B::OWND//UNIT/1500, :16S:BENODET :16R:BENODET :95S::OWND//TXID/DE/99999999999 :36B::OWND//UNIT/5500, :16S:BENODET | |
BO disclosure using Xact Web Portal
The following table describes the fields to be used for each scheme in Xact Web Portal.
Beneficial owner identified with: | ||
Clearstream Banking Unique BO ID | TIN | |
(Section: Beneficial owner details) | ||
Tax ID number | BO_ID | BO_TIN BO_TIN_Country |
Quantity of Securities Owned | BO_Quantity_Type BO_Quantity_of_Securities_Owned | |
Beneficial owner disclosures can be built in Xact Web Portal or prepared off-line and imported via the available template, see Xact Web Portal User Manual.
Up to 2,000 beneficial owners can be disclosed for French securities in a single Xact Web Portal CA Instruction.
Clients can see the status of their BO disclosures in Xact Web Portal and receive MT567/CA Instruction Status.
Feedback will be provided for every formatted beneficial owner disclosure, whether it has been processed successfully or if an error was encountered.
MT567 – Status of a Beneficial Owner disclosure in an MT567
CA Instruction Status | |||
Status | Accepted | Rejected | Rejected with Narrative |
(Subsequence A2a Reason: REAS) | |||
Status Code | :25D::IPRC//PACK | :25D::IPRC//REJT | :25D::IPRC//REJT |
Reason Code | n/a | :24B::REJT//CERT :24B::REJT//FULL :24B::REJT//LATE | :24B::REJT//CERT |
Reason Narrative | n/a | n/a | :70D::REAS//<rejection reason> Example: :70D::REAS//Beneficial Owner certificate not found matching account and TCA BO ID 123456 |
Xact Web Portal – How to look for disclosure status
In Asset Servicing / Instruction / CA Instruction
CA Instruction Status | ||
Status | Recorded | Rejected |
Reason Narrative | n/a | Example: Beneficial Owner certificate not found matching account and TCA BO ID 123456 |
Further information
Please refer to the Clearstream website for more information about Xact Web Portal or Xact File Transfer.
For further information, please contact the Clearstream Banking Client Services or your Relationship Manager.
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1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG, registered office at Mergenthalerallee 61, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.
2. This change builds upon the new processing of Dividend Option events (DVOP) in France since November 2024 (see Announcement C24054).