Reform of the INSEE classification on 1^st January 2027: check your APE code

Every French company will be given a new APE code on 1^st January 2027. The new code can already be consulted, and the gap with the old one is felt above all on the side of the applicable collective agreement.

INSEE is replacing the French classification of activities with NAF 2025. The switch is automatic: companies are asked to do nothing, and each will be given a new code on 1^st January 2027. The new codes can already be consulted on the Sirene website.

A reform of a statistical classification looks as though it has no legal consequences. It does have them, and they show up at the worst moment: during an inspection, an employment tribunal claim or a sale.

The APE code has no legal force, and that is precisely the problem

The APE code does not determine the applicable collective agreement. That depends on the company’s actual main activity, assessed in concrete terms. The case law is settled on the point, and the code amounts to no more than a rebuttable presumption.

In practice, matters stand quite differently. The code appears on payslips, it steers URSSAF, it guides the labour inspectorate, it governs access to certain forms of assistance, and it is what the employment tribunal looks at before hearing the employer’s explanations. An inaccurate code does not create the law, but it creates the argument — and the burden of getting out of it falls on the company.

What the switch actually changes

The correspondence table between the old and the new classification is not one-to-one. Some activities are split between several new codes, others grouped together. Where the conversion is ambiguous, INSEE decides on the basis of the information it holds — that is, the activity declared at registration, sometimes twenty years old, and rarely updated since.

The companies most exposed are those whose activity has moved on without the declaration following: the retailer who has become mainly a wholesaler, the craftsman who now manufactures more than he installs, the services company whose industrial activity has been absorbed by a subsidiary. They will inherit a code that fits their past and is wrong in the light of their present.

What to do, and when

The check takes a few minutes. Look up the new code on Sirene, compare it with your main activity as it is actually carried on today — assessed, for a company with several activities, by reference to the predominant turnover — and set the result against the collective agreement you apply.

Three situations call for action. If the code is wrong and the agreement right, a request for correction to INSEE is enough, but it takes time: better to start it before the deadline. If the code is right and the agreement open to question, it is the agreement that must be reviewed, and what is at stake runs to years of back payments. If the objects clause no longer matches the activity, the question goes beyond classification: it touches the validity of the company’s acts and is settled by amending the articles.

The timetable

Companies that want a correction would do well to act now: applications filed in the last quarter of 2026 will arrive in a considerable flow. Those whose activity has changed since registration have a further reason to set about it — the reform is an opportunity to regularise a long-standing situation without the step looking like an admission.

This article sets out the law as it stood at the date of publication and does not constitute legal advice. Every situation calls for individual examination: let us take thirty minutes to check yours.