France is the EU's second-largest economy and the world's seventh. It has a sophisticated commercial court system, a codified civil procedure that dates to Napoleon, and enforcement mechanisms that — when properly deployed — produce results with a speed that surprises creditors accustomed to the country's reputation for bureaucratic deliberation.

The gap between France's reputation and its enforcement reality is where most international creditors lose money. They assume French courts are slow, French procedures are complex, and French debtors are protected by impenetrable regulation. Two of those three assumptions are wrong. The third is only half right.

1. The référé-provision is the fastest commercial remedy in Europe

The référé-provision (Articles 834-835 of the Code de procédure civile) allows a creditor to obtain a provisional payment order from the presiding judge of the Tribunal de Commerce in as little as 15-30 days from filing. The order is enforceable immediately, even if the debtor appeals.

The conditions are straightforward: the creditor must demonstrate that the obligation is "not seriously contestable" (obligation non sérieusement contestable). For commercial claims supported by signed contracts and delivery confirmations, this threshold is routinely met. The debtor can raise defences, but the judge assesses them at a summary level — if the defence isn't substantively compelling, the provisional order issues.

International creditors rarely use the référé-provision because their French lawyers default to the full procédure au fond (standard proceedings), which can take 12-18 months. The référé produces the same economic result in a fraction of the time. The reason most avocats don't suggest it first isn't competence — it's billing structure. A 30-day procedure generates less revenue than an 18-month one.

Our Paris team files référé-provision applications as the default approach for undisputed or weakly disputed commercial claims. Over the past three years, 78% of our French référé applications have produced enforceable orders within 45 days of filing.

2. The saisie conservatoire freezes assets before judgment

The saisie conservatoire (conservatory seizure, Articles L511-1 to L512-2 of the Code des procédures civiles d'exécution) allows a creditor to freeze the debtor's bank accounts, receivables, or physical assets before obtaining a judgment. The application is made ex parte — without notifying the debtor — and can be granted within 24-48 hours.

The requirement is that the creditor demonstrates a claim that "appears founded in principle" and a threat to recovery (such as the debtor dissipating assets or showing signs of insolvency). The threshold is lower than most creditors expect. A debtor who has stopped communicating, restructured their corporate holdings, or transferred assets to affiliated entities typically meets the "threat to recovery" criterion.

Once the saisie conservatoire is executed, the debtor discovers that their bank accounts are frozen and their accounts receivable are redirected. The psychological and commercial impact of this discovery tends to produce settlement discussions within days rather than weeks.

We used a saisie conservatoire against a Lyon-based automotive parts manufacturer that owed €310,000 to a Belgian client. The debtor had been transferring inventory to a warehouse operated by a newly incorporated affiliate. We obtained the seizure order on a Friday afternoon. The debtor's managing director called our Lyon office at 9:15 on Monday morning. Payment was arranged by Wednesday.

3. The injonction de payer is simpler than most creditors realise

The injonction de payer (payment order, Articles 1405-1425 CPC) is France's equivalent of the German Mahnverfahren. It's a paper-based procedure — no hearing required — where the creditor submits the claim with supporting documentation to the Tribunal de Commerce. If the judge is satisfied, an order to pay is issued, typically within two to four weeks.

The debtor then has one month to oppose the order. If they don't, the order becomes enforceable as a judgment. If they do oppose, the case proceeds to a hearing — but at that point, the creditor has already secured a court order that frames the dispute on their terms.

For EU creditors, the European Order for Payment (Regulation 1896/2006) provides an alternative pathway that is recognised across all EU member states without the need for an exequatur proceeding.

4. French bailiffs have more power than you think

The huissier de justice (judicial officer/bailiff) in France is a private professional with state-delegated enforcement authority. Unlike bailiffs in many other jurisdictions, French huissiers can independently access debtor bank account information through the FICOBA database (the national register of bank accounts held by the Direction Générale des Finances Publiques). This means that when we obtain an enforcement title, our huissier can identify every bank account the debtor holds in France — without needing to guess which bank to target.

The huissier can also execute saisie-attribution (third-party seizure) against the debtor's clients, redirecting payments owed to the debtor directly to the creditor. For debtors who have moved their banking to avoid garnishment — a tactic we see regularly — the saisie-attribution bypasses the bank entirely and attaches the debtor's income at source.

The French enforcement intelligence

France's enforcement system is more powerful than its reputation suggests. The tools exist. The issue is that most international creditors — and many French lawyers — default to the slowest, most expensive procedure when faster options are available. The référé-provision produces results in weeks. The saisie conservatoire freezes assets in hours. The injonction de payer secures orders in weeks. French bailiffs can locate every bank account the debtor holds.

The question isn't whether French law favours creditors. It does — if you use the right instruments in the right sequence.

If you're owed money by a French entity, brief our Paris team. We'll tell you which instrument produces the fastest result for your specific case — and it probably isn't the one your current lawyer has suggested.