Domiciliation licence: the préfet's silence means rejection, not approval — and there are three deadlines to track in parallel
France's Commercial Code sets three separate clocks for a licensed domiciliation company: two months for the préfet to review an application (after that, no response means REJECTION — the opposite of the general French rule that silence means approval), six years of licence validity, and two months to declare any substantial change. For a multi-branch network, these three clocks run in parallel, branch by branch.
Article R123-166-3 of the Commercial Code is clear on a point that often surprises owners: unlike the general rule that administrative silence equals approval, here the préfet's silence after two months equals REJECTION of the licence application. A branch that files a renewal and gets no answer in time isn't tacitly covered — it has to follow up or refile. Once granted, the licence stays valid for six years (Article R123-166-2).
There's a third, lesser-known deadline: Article R123-166-4 requires declaring to the préfet, within two months, any substantial change to the information given in the original application — a change of premises, a change of legal representative, opening a secondary branch. For a single branch, tracking these three clocks (review window, six-year renewal, change declaration) on a shared calendar is manageable. For a network of 20 to 50 branches, each with its own licence date and its own changes, manual tracking quickly becomes the kind of task that slips between two more urgent files.
For AppH
- An agent that's given each branch's licence date and computes the three deadlines (end of review, six-year renewal, change declaration) can alert the team before the deadline hits — without ever filling in or filing the paperwork on the branch's behalf.
- Across a multi-branch network, it's no longer one date to remember but N different dates; a dashboard that centralizes them keeps a branch from discovering a tacit rejection after the fact.
Against / the honest limit
- AppH doesn't file the licence application, doesn't decide whether a change counts as "substantial" under the rule, and doesn't replace a legal professional's judgment on a disputed file: it tracks the dates and drafts the reminder, a person decides and acts.
- The cited text (R123-166-2 through -4) has been in force since 2010 with no known amendment to date — this isn't breaking news, it's a structural rule many owners only discover once the deadline has already passed.
What strikes us about this rule is the asymmetry: most French administrative procedures favor silence (no answer = approval), this one favors the opposite. An owner used to the general rule can reasonably assume they're covered after two months of silence — and find out otherwise. We'd rather have an agent that tracks the exact filing date and alerts before the deadline than rely on the instincts of an owner juggling 30 other files.
Reviewed by a human at AppH