- Changes to employee health care coverage requirements - Nominative social declaration (DSN)

1. Newsletter September 2015
January 2016 sees the introduction of
two important changes relating to
French social security:
1) Coverage for all employees
through an employer health care
scheme will be obligatory from
1 January 2016
2) The Nominative Social Declaration
will change significantly the way
in which employee information is
declared.
CHANGES TO EMPLOYEE HEALTH CARE
COVERAGE REQUIREMENTS
The loi de sécurisation de l’emploi
(Security of Employment Act) passed in
June 2013 has made the implementation
of complementary health care for ALL
employees obligatory by 1 January 2016.
Steps to ensure compliance should be
taken now if coverage provided does not
yet meet requirements.
A minimum level of health care insur-
ance will need to be provided (details
were set out in a decree published in
September 2014) covering general
health care, dentistry and eye care to be
borne by the employer.
A further decree published in November
2014 set out the criteria that must be
included in order to benefit from the tax
and social charge exonerations as a
qualifying contract under the scheme
known as ”contrats responsables”. This
decree put a ceiling on fees chargeable
by health care professionals and estab-
lished a framework for coverage of opti-
cians’ charges.
With effect from 1 January 2016, all
company health care schemes will be
required to respect these new conditions
in order for their cost to be deductible
for corporate income tax and potentially
avoid additional social security charges
being applied.
In the event that a health care contract
does not respect the new obligations,
the contributions made will be treated as
a benefit in kind and in addition this
could lead to re-assessments in the
event of a social security or tax audit. It
is therefore important to ensure that
steps are taken to ensure compliance
before the end of 2015. Our firm can
provide a liaison with the health care
organisations to facilitate the implemen-
tation of these changes.
NOMINATIVE SOCIAL DECLARATION
Another significant introduction in Janu-
ary 2016 will be the nominative social
declaration (déclaration sociale nomina-
tive or DSN) which is intended to replace
most existing social security declarations
that are currently filed monthly or quar-
terly. The declaration, which will lead to
monthly filings for all businesses in the
future, will replace:
♦ Monthly or quarterly social contribu-
tion unified returns filed with URSSAF
(la déclaration unifiée des cotisations
sociales (DUCS));
♦ The certificate indicating an em-
ployee’s salary which is used to de-
termine the level of social security
reimbursements during absences
such as maternity leave or illness
(l’attestation de salaire pour le verse-
ment des indemnités journalières
(DSIJ));
♦ The employee leaving certificate
(l’attestation employeur destinée à
Pôle emploi);
♦ Labour movements & statistics decla-
rations filed by large businesses (la
déclaration et l'enquête de mouve-
ments de main d’œuvre); and
♦ De-registration of group complemen-
tary assurance contracts (la radiation
des contrats groupe pour les contrats
en assurance complémentaire et sup-
plémentaire).
Depending on the size of the business,
the DSN will be filed by the 5th or 15th
of the month following the end of the
month to which it relates.
Events having an impact on the employ-
ment contract – such as the termination
of an employment contract – will be re-
quired to be declared within 5 days of
the event taking place and filed at the
same time as the monthly DSN.
The DSN is intended to change the man-
ner and frequency that employment
related events are declared however it
will also have an incidence on the fre-
quency of payments for businesses with
more than 9 employees who paid certain
contributions quarterly (eg. retirement)
until now. These contributions will be
paid on a monthly basis going forward.
If you have any questions regarding
the contents of this newsletter,
please contact:
Patrick Scanlon
FERRIERES & Co
46 Rue du Général Foy
75008 PARIS
France
info@ferrieres.net
+33 (0) 1 42 94 29 33
www.ferrieres.net
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