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The measures of the decree
The decree brings several measures of the 2026 Finance Act into force for payments made from 22 October 2026.
The decree first concerns young impact innovation companies (JEII), a category created by the Finance Act. These companies devote between 5% and 20% of their expenses to research and meet social utility criteria. Subscribing for units in innovation funds (FCPI) invested in these companies now gives entitlement to a 30% reduction. Direct subscriptions to their share capital, at 40%, have applied since 21 February 2026.
Second, the increased 25% rate for subscriptions to the share capital of solidarity companies of social utility (ESUS) is extended until 31 December 2027. By way of exception, it applies to payments made from 1 October 2026, with no gap since the previous authorisation, which ran until 30 September 2026.
Rates and caps on payments
The reduction is a percentage of the amounts paid, taken into account up to an annual cap which also varies with the category of company.
| Subscription | Rate | Payments taken into account (single person / couple) |
|---|---|---|
| Eligible SME, standard rate | 18% | €50,000 / €100,000 |
| Solidarity company of social utility (ESUS) | 25% | €50,000 / €100,000 |
| Young innovative company (JEI), research of at least 20% of expenses | 30% | €75,000 / €150,000 |
| Young impact innovation company (JEII), direct | 40% | €50,000 / €100,000 |
| Young disruptive innovation company (JEIR), research of at least 30% of expenses | 50% | €50,000 / €100,000 |
| FCPI units invested in JEI or JEII | 30% | €75,000 / €150,000 |
For JEI, JEIR and JEII, the reduction obtained for payments made from 2024 to 2028 is also limited to €50,000 in total, and any excess cannot be carried forward.
Since 21 February 2026, FCPI invested more broadly in unlisted SMEs, without an innovation requirement, no longer give entitlement to the reduction. Among funds, only FCPI invested in JEI or JEII remain eligible, together with local investment funds (FIP) for Corsica and the French overseas territories.
The company’s category is assessed on the date of subscription and is shown on the statement that the company, or the fund management company, gives to the subscriber.
Subscription and holding conditions
The reduction applies to cash subscriptions, on incorporation or to a capital increase. Buying existing shares from a shareholder does not qualify.
The shares must in principle be held until 31 December of the fifth year following the subscription, or five years for FCPI units. Otherwise, the reduction is clawed back, subject to exceptions (in particular redundancy, disability or death).
Shares subscribed with the reduction cannot be held in a PEA, a PEA-PME, a company savings plan (PEE) or a retirement savings plan (PER). They are held directly or in an ordinary securities account.
Amendments adopted at first reading of the 2027 Finance Bill
The 2027 Finance Bill is being debated in Parliament. On 15 October 2026, the National Assembly adopted in plenary session two identical amendments, including one tabled by Gabriel Attal, which would raise the standard rate from 18% to 25%. This rate had already applied for part of the years 2020 to 2023. The increase would remain subject to the approval of the European Commission and would apply, at the earliest, to payments made from 1 January 2027.
This measure may still change during the debates. It remains to be seen what will be voted at the end of December.
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