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February  2024

This month’s title is not a song, a movie or even a book. I just could not find the right thing to capture what I was looking for. In early December I received a reader statement that inspired the title I gave to that section of this issue and finally the issue itself.

Is it appropriate for me to associate myself with Valentine’s Day in a professional setting? I have never done so before! After you read her statement, I will let you decide. I am honored to have received it, considering what it must have taken to tell me her story.

In recent months, several of my clients have had their e-photo refused by the civil servants handling files sent through the Étrangers en France website. There are two possible reasons for this.

The first reason is one everybody is supposed to know: the face must not be covered at all. It would appear that the website requirements are stricter than those accepted by the machine. The machine will not take the picture if the image is non-compliant. For example, if the hair is judged to be too close to the eyes when the picture is taken, the French administration may refuse it. To make sure your photo is accepted, pull all your hair back, no glasses, no hat, and so on. It might not be your style, but such pictures never show us at our best.

The second reason may be sneakier, especially for foreigners who rarely pay much attention to how they sign their name. I know many who have different signatures for different situations, such as women who do or do not include their married name. For French people, this is like writing your name, not signing. The French usually perfect their signature in their early teens, and by the time they are adults it has become a stylistic thing, totally illegible, that is kept for life. To confirm an e-photo, one must sign with a finger on the screen on the right side of the equipment. I have witnessed so many refusals that I now advise everybody who needs to take these pictures to bring their passport or at least a very good copy. If the signature closely resembles the one on the passport, the French administration is more likely to accept it.

Below are provisions of the new law most likely to be of interest to my readers, as well as some details. On January 25th the Conseil Constitutionnel struck down many provisions of this law. I will keep my readership informed of is going to happen regarding this matter.

Quotas to regulate migration will be put into effect for certain types of immigration status. The French parliament will then vote on a law detailing guidelines to be valid for three years.

To benefit from the family reunification procedure, the foreigner must reside in France for at least two years, instead of 18 months as previously.

For most multiyear cartes de séjour, an A2 level of French is now required. Regarding issuance of the carte de résident, it is now B1, and B2 for naturalization.

The first issuance of an immigration status now involves signing an integration contract with France. Any breach of this contract by the foreigner could mean losing the right to stay in France legally.

Children born in France must inform the French administration of their desire to become French citizens no earlier than age 18. They lose this right if they are sentenced in France for a crime. The other requirements on this provision stay the same.

Spouses and parents of French citizens can request a carte de résident only after residing legally in France for five years.

Foreign students holding student immigration status must create an escrow account to obtain their visa, although some exceptions may be defined later. The money will be released later except to any person who disobeys an expulsion order.

The right to work is available to undocumented aliens. Other foreigners keep the same rights.

Regularization through work as an employee has been made easier. The person still has to have lived in France for three years, but only needs to have been an employee for one of the last two years of residence, which status is shown by submitting one year of pay slips, rather than two, as previously.

There is a new carte de séjour within the passeport talent status called talent – profession médicale et de la pharmacie to facilitate hiring people in these professions.

The offense of illegal residence (with an expired visa or without a residence permit) has been reinstated. It will be punishable by a fine of 3,750 euros and an additional three-year ban from France.

There was a frenzy for several weeks in the expat community, including the media dedicated to this population, about fears that it would be impossible to renew the visiteur immigration status for more than five years. When I was asked to comment about this, I initially replied that the actions of the government and parliament are unpredictable, so it is impossible to anticipate what will happen, especially when dealing with an immigration law.

A provision of the new law obliges the foreigner to request a carte de résident after five years of continuous residence. People who have the visiteur immigration status are exempted! I see this as a double-edged sword. It will help foreigners who have dutifully met the requirements every year, have integrated well in France and do not need to go through the somewhat complicated procedure to ask for a carte de résident when there is no appointment at the prefecture scheduled. Currently, the websites do not offer the first request for a carte de résident option and therefore submitting it is difficult.

But it also puts serious pressure on foreigners who stay in their community, do not learn enough French and prefer their traditional way of life. The minimum level of French to obtain the card is B1, and the administration wishes to strengthen enforcement of the integration contract that all foreigners with legal immigration status must sign. I doubt the government really intends this to improve foreigners’ integration; I believe it is meant to punish those who do not wish to integrate.

Still, I am sure that those who are integrating will now be even more motivated to reach the minimum requirements. Reminder: holding a carte de résident means not having to go to the prefecture for ten years, having all rights to work and being assured of almost automatic renewal of the card. All it takes is to submit a basic request and the administration must accept it.

Here is the provision in question. After article L. 433-1 of the Code de l’entrée et du séjour des étrangers et du droit d’asile (CESEDA), an article L. 433-1-1 is inserted, as follows :

“By way of derogation from article L. 433-1, no more than two consecutive renewals of a temporary residence permit bearing the same wording.

“These provisions do not apply to foreign nationals exempt from signing a republican integration contract mentioned in article L. 413-5.”

The list in L 413-5 includes visiteurs.

« Art. L. 433 1 1. – Par dérogation à l’article L. 433 1, il ne peut être procédé à plus de deux renouvellements consécutifs d’une carte de séjour temporaire portant une mention identique. »

This provision existed de facto at first over 20 years ago and later became law: an undocumented alien who lives in France for at least ten years and can prove it with enough documents is entitled to a vie privée carte de séjour. Almost as soon as this went into effect, it faced strong opposition for granting a legal stay to someone who could not prove ties with France, whether personal or professional. The opponents asked what possible grounds there could be for granting this legal stay.

But the vast majority of people understand and accept that a ten-year presence is enough in itself on which to base granting such immigration status. There are many reasons to validate this decision, even though it may seem odd to claim a legal right grounded in illegal conduct. It is common knowledge that ten years’ worth of documentation means that the foreigner has actually stayed in France a lot longer, as it often takes several years to settle and have a life stable enough to generate the required documentation.

Hardly anyone can live in France illegally for ten years or more with no source of income, so the vast majority of those concerned have work but their employers refuse to declare them, pay the social charges and make the employment legal under French labor law, which fully applies to undocumented aliens. Thus they cannot get an employment contract or prove past work. It can also be assumed that if an undocumented alien has managed to live in France so long without being caught by the police, it is likely that they have never committed a crime and that they have an impressive level of integration in France.

As expected, the opposition to issuing such immigration status aired its views in the media and in parliament, raising fears that this provision would be maintained in the new law. So it is reassuring to know that in that law this procedure still exists, with the same terms. Note that an appointment to review the situation came about two years after the request was submitted, showing that the prefecture did not consider it a priority and gave it back-burner treatment.

When I sent out the December 2023 issue, I was sure I was done with my series on the living conditions of Filipinas in France. I reasoned that I had addressed all the situations I could that would illustrate the type of life they have in the West. The one I did not seek seemed too sensitive and complex: a Filipina who marries a Frenchman and obtains immigration status. Although I have helped a few Filipinas in that situation, I never asked them to tell their story: for some it is painful, or they may feel ashamed, and some aspects could be seen as illegal. Getting statements on the other situations had already demanded a huge amount of trust developed in a long relationship.

But then someone I have been helping recently learned about the statements I have published over the last several months and read them avidly. Out of the blue, she sent me hers: It was the situation I had not yet dealt with.

Yes, this is a provocative title. With every February issue, I wonder whether to mention Valentine’s Day. But until now there has not been a pertinent topic I could tie to it. As I was drafting this section, however, I thought it might deserve the title.

There is a lot to say about the ways one can look at fake marriages. Even French law defines different situations.

When talking about fake marriages, people often think criminal organizations sell such marriages for a large sums of money. French law just defines mariage blanc andwhich are felonies under article L-623-1 of the CESEDA:

“Entering into a marriage or recognizing a child for the sole purpose of obtaining or having obtained a residence permit or the benefit of protection against expulsion, or for the sole purpose of acquiring or having acquired French nationality, is punishable by five years’ imprisonment and a fine of 15,000 euros. These penalties are also incurred when the foreigner who has contracted marriage has concealed his or her intentions from his or her spouse.”

Mariage blanc is when both spouses conspire to get married for the sole purpose of the foreign spouse obtaining a legal stay in France, while mariage gris is when the foreigner disguises the motive for getting married and fools the French spouse to obtain a legal stay in France.

The situations I have encountered are not like this, however. The Filipina who wrote the statement below explained to me that her marriage went wrong, and she details what happened to her. It fits a pattern I have seen again and again.

Regarding this woman’s statement, it does not matter when or how they met. He was a Frenchman and she was a Filipina woman, sans-papiers, with no prospect of regularization in sight. She does not say why; she had nice employers and she had been in France for seven years. I did not ask.

Here is the pattern I usually see: He was nice, so she enjoyed his attention and care, which were unusual in her daily life. He liked her attention and she expressed her gratitude. One thing led to another, and one encounter to another. If they continued to see each other, moved by reciprocal care and warm feelings, it often turned into serious dating, and shortly after they got married. This cannot fit the definition of fake marriage.

What interests me in this situation, and therefore in the statement below, is that she hints she was fooling herself even while being lucid enough to know that obtaining a legal stay this way was a very strong draw, which enhanced everything else. Women in this situation may be drawn, consciously or not, into such a relationship, going as far as getting married, at least partly because it is a sure way to obtain legal status and be able to enjoy the security and everything else that comes with private life immigration status. A somewhat similar comment can be made about marrying a wealthy and often an older man.

After the wedding, the woman must wait at least six months before submitting a regularization file to the prefecture. The file must include at least one document for every month on which both their names appear, proving their communal life. The procedure can be quite long as the French administration can be quite picky and suspicious in such situations. Eventually, she gets a carte de séjour valid for one year. It is critical to understand that she must stay married for at least three years (now five, under the new law) to retain the right to live legally in France. This often means she needs to please her husband so he does not want to divorce her during that time.

In the pattern I have often seen, the wife starts having a new life, possibly a better job, probably a more fulfilling social life. Not being scared of being arrested opens countless opportunities. The husband, who enjoyed being her primary and often sole center of attention, begins to feel disappointed by their relationship, where she has financial independence and can go anywhere worry-free.

The woman, realizing how he feels, must reach what may be a difficult and painful compromise to keep her husband from being so disappointed that he files for divorce, even as she wants to continue enjoying the benefits of her new life. The fact that she brings in more money than before may please him, provided she does not earn too much (i.e., more than him).

When it is safe immigration wise, and she feels the relationship has soured, she may find reasons to work farther away. This allows her to be at home less and less often, until one day she has de facto moved out. As a Filipina, she does not think of divorce but finds ways to move out or let him be home less and less. The Philippines is one of the rare countries where divorce is still illegal, and it is only beginning to consider changing that.

To sum up the usual course of events in such relationships:

1 – She idealizes him because he shows care and can get her papers, which mean freedom, so she is willing to do anything for him. He idealizes her because he typically is middle-aged, lonely and frustrated in life, and suddenly a young woman worships him. Her submission melts his heart, while she sees him as a path to freedom.

2 – She has to stay married five years. More and more she feels a disconnect between what she dreamed of in having papers and the life under his control. Feelings of resentment build up in her.

3 – When her immigration status is fully secured, she can live the life she wants. By that time, in most cases, either he has gotten tired of her or she has found a way to put significant distance between them.

If she trusts him to let her live her life during the in-between years, however, the couple has a real chance of lasting.

Here is the story that she sent me, lightly edited for clarity.

“I arrived in France in 2006 and spent many years working without papers. It was really not easy because I was hearing all the time something like oh, this person was controlled and arrested in the metro; the police were controlling somewhere, many times it was Belleville, but it was also somewhere else!

“My life, all things considered, was not that difficult compared to many others I knew because I had very nice bosses who really cared about me. Thank God!

“Sometime in 2013 I met this man and eventually he offered to marry me after having had a relationship for over a year and I agreed, I was so thankful. With all my proofs in the file plus his help, I arrived at the prefecture and I was approved. Thanks to him, I got my papers.

“We were married (and lived together) for seven years. Very early on, it was obvious that he was interested in young women. I discovered that there was one at first, then later I found out that there had been many more. At one point, I decided to separate from him.

“This was not at all the end of my life, I moved back to my old neighborhood in Paris and I continue working happily. Life is not perfect, we are still not divorced, we are just separated, and nothing legal has been done. I have God in my life and every day HE really gives me everything I need to live perfectly content and happy.”

I have received a lot of emails regarding the situation with the HSBC and CCF banks. For people who have lived in France a long time, it does not raise concern and is barely news, as we know HSBC’s French presence has shrunk considerably and the bank has pretty much left France altogether.

In July 2000, HSBC purchased a major French bank, CCF, along with a few minor ones. It might seem that some 23 years later CCF reappeared just as HSBC was leaving the country, but that would be a slight exaggeration. In fact, la Banque des Caraïbes purchased HSBC’s French operations and is changing the name and logo on the former CCF branches of the bank, keeping all the branch employees. I have not done enough research to learn exactly who the new shareholder of this bank is. The new senior management could be such that many employees will leave.

Here is one of the messages I received regarding this issue.
“I received a letter today from HSBC regarding their merger with CCF and outlining the changes there will be for account holders. Of course, I do not have the vocabulary for this kind of information. Can I make an appointment with you in the next few weeks to discuss what I need to do?”

To collect your residency permit in Paris, the booking link has changed. It is now You may also see it listed as RDV-préfecture.

Either link will take you to the same page. Sadly, the possibility of securing an appointment reasonably quickly – i.e., without having to try for weeks before getting one – has not improved that much, but there is a slight improvement there, and sometimes the appointments can be scheduled two months in advance or even a bit more so.

Here are the updated guidelines from the Paris prefecture as of 21st December 2023:

Reception by appointment only on the Préfecture de Police website.
Your residence permit can be issued if
• you have received an SMS informing you that your permit is available
• you have been informed by email that your permit is available.
To make an appointment, visit the RDV-préfecture website.

This is still rather theoretical, as most people never get the SMS on their phone. They wait and wait, sometimes to the point of jeopardizing their ability to renew their immigration status between four and two months before the expiration date of the current card, which they still do not have in their possession. Therefore, I strongly advise everybody in this situation to strictly follow these guidelines:

1 – Wait three months after the request has been approved, either by receiving confirmation or from the day of the appointment at the prefecture.

2 – Then go online to and ask for confirmation that your card is ready.

3 – Once you receive confirmation, often about two weeks later, you can book the appointment as described above.

I now own a parking space in the building just across the street from my office in the 11th arrondissement of Paris. The rent is 100€/month, all charges included. An initial deposit of 100€ is required.

The parking space is in the first basement of a residential building at 58 rue Montreuil. The space is 10 square meters (107.64 square feet). It is the space on the right in the photo accompanying the ad linked to below.

Secure access by beeper. The access gate is somewhat narrow, so suitable for smaller cars, although my Peugeot 2008 (4.16m x 1.74m) fits fine.

Best regards,



After four years in France with student status I prepared a file asking for the self-employed one as I currently hold an APS. I submitted a PDF file to, in which there was everything on the list and organized in the same order. I received this answer:
Votre demande de rendez-vous nºxx a été classée sans suite le 26/10/2023 pour la raison suivante : Bonjour xx, Pour la demande de changement statut d’étudiant vers la Profession libérale, il faudrait déposer un dossier complet avec les documents suivants : l’Insee, l’Urssaf, le business plan et le diplôme.
Translation: Your request for appointment nº xx was closed on 26/10/2023 for the following reason: Hello xx, To request a change of status from student to self-employed, you need to submit a complete file with the following documents: Insee, Urssaf, business plan, and diploma.Sounds like something went wrong. This is insane – all the documents they mentioned were in what I sent. What more do they want? How can I submit a request that they will read? This is a total nightmare, and there is no explanation for why they refuse to read what I sent them. I feel discriminated against. Please help.


This is an annoying problem but also an easy one to fix if you did indeed send all the documents the first time.
Here is the origin of the problem: Now that almost all administrative procedures start online, there are several ways to upload the documents. Some of them severely limit the number of documents that can be submitted, such as one to prove your career and one for your finances for the artistic passeport talent carte de séjour. Others go to the other extreme, allowing one to add as many documents as you want; the system never seems to get blocked, although I would think it eventually does.
In my experience, does not get blocked but allows you to upload your documents one by one. Thus I think the civil servant saw one document and opened it. Depending on how you organized it, he did not immediately see the documents he considers critical and ditched your file, stating that it was not compliant. Call it laziness, impatience or incompetence, the fact remains that you need to submit once more. For a lot of reasons, I strongly advise you to merge the documents that go together.
I would put all the URSSAF declarations with the statement of good standing as well as the original, and the recent statements of the existence of the business issued by INSEE. Then ideally all the invoices you issued with all the bank statements, unless you issue 100 or more invoices a year, in which case you should separate invoices and bank statements into two files. You are submitting a first request so the cover letter should be with your résumé and your diplomas. The CPAM health coverage should go with your passport, the carte de séjour and the address. The French income document would go with URSSAF even though putting the bank statements in first position also makes sense if they are on their own. A different person might prefer organizing the file differently as the most efficient organization varies according to the activity. If one is also submitting a press book, the prizes and awards received should be together and on their own.
The bottom line is that the key is to submit a file in such a way that the civil servant sees as soon he opens the file that it contains the documents he is looking for. To increase the chance of success, naming the documents intelligently is important. The civil servant then sees before opening them that what he is looking for is there.
In conclusion, it is unsettling, to say the least, to be treated in such a rude way, completely disregarding what has been submitted. The foreigner goes into panic mode as the decision is totally contrary to reality, giving the impression that the system is rigged and the civil servants never read what is sent and there is no hope of getting fair treatment.
Last but not least, be extremely careful about where you upload the file that requests a change of status.
Let me backtrack some here. More and more requests for a change of status obtaining the right to work are being made, either as an employee or as self-employed, before the “real” request for the carte de séjour is submitted. The logic is that obtaining the right to work is the essential element in being approved for the change of immigration status – but it is not the only one. Hence all these procedures are de facto a two-step process.
Now, this is where the French administration has created a fantastic maze. Both and confer the right to work. Depending on your current immigration status and the one you hope to get, you will submit one or the other request to obtain the right to work.
I urge everyone who is thinking of going through this procedure to always start with the site of the prefecture where you have your file, and therefore where you pick up your carte de séjour. From there go to the section of the website dedicated to your status, then go through the options offered and find the change of status one. From there follow the links that are pertinent to your situation. Double-check several times, if need be, to make sure before you start uploading the file. Furthermore, since even then it is possible to send it to the wrong place, submit the request to work ideally two months before the expiration date of your immigration status. If it does go to the wrong place, you will get a negative response about two to three weeks later, giving you sufficient time to upload to the correct site.
This sensitive issue comes prior to the difficulties described above, when it is the right site but they are not happy with the file as submitted or documented, or just the order in which the documents are organized!



I submitted my request for French naturalization while I was holding a carte de séjour carte bleue europénne. I had a student card before that and obtained my bachelor’s and my master’s in France. About a year after sending the file, I got the appointment and it went really well. The civil servant told me that I would get a favorable evaluation. So I understood that it was almost certain that I would be accepted and get French nationality. I was totally stunned when I received the registered letter telling me that my request was denied.
I was married in the USA, and my Japanese wife came to live with me with a family immigration status linked to my carte bleue europénne. We were married when I submitted my naturalization request and she wrote the letter that she did not want to become French as she would have lost her Japanese nationality, which was unthinkable. It happened that she had no residency permit in France after I had my appointment at the prefecture. It happened because she was on a long mission in an African country and did not know how to renew the card. She applied for a visa a few days ago at the French Consulate there and had no problem getting it, considering my status.Now that she is with me again, I want to appeal the decision since the reason for the refusal was that my wife did not have French residency anymore, that we did not live together, and that we were not divorcing. So their conclusion was that I was not committed enough to France as I had my wife living in a foreign country. I hope to prove that my roots are in France, that I have never wished to reside outside France, and that my wife’s expired carte de séjour was exclusively the responsibility of the French consulate where she was stationed. Do you think it is the right way to present this appeal and what are the chances of success?


I could answer you with just a few words: The French administration is never wrong and is never sorry. Even when a court rules against the administration it is difficult to get the situation fixed, even after the judgment is properly served. So you have zero chance of successfully appealing this decision. I want to say the same thing about your wife’s situation with her immigration status while on mission. There was a way for the consulate to allow her status to be prolonged so that the procedure to renew the carte de séjour would have been possible. The fact that the French administration is mainly responsible for this chaos is not sufficient to prove that they are responsible for the situation and therefore they should reverse their decision.
Now, having said that, I should explain what the prefecture evaluates and the hierarchy they use to decide if an applicant complies with requirements. I am talking here about obtaining naturalization, not just having the right to submit. I say this every time because the public is hugely misled about this. I call it the funnel syndrome.
The requirements to submit a naturalization file are:
1 – Having held legal immigration status in France for five years
2 – Having declared an income at least equal to the French minimum wage for the last three years
3 – Proving at least a B1 level of proficiency in French (soon it should be B2). 
If your file has this, it will be received and reviewed.
The real requirements to comply with naturalization procedures can be summed up this way: All your major centers of interest in life are anchored in France – professional, personal, and family life.
So if the applicant’s spouse is not in a perfect immigration situation, the naturalization request is denied. This covers a spouse sans-papiers, of course, as well as one who received a negative answer from the prefecture, usually called OQTF (obligation de quitter le territoire français), even if was appealed with excellent chances of success – and definitely one who does not reside in France. You see the situation very differently and I respect that. But the French administration deals with facts: your spouse is a foreigner living in a foreign country and had lost her French immigration status. Once this legal analysis is done and your request denied, you cannot appeal the decision because the reason they cite is valid.
Other situations can trigger denial of a naturalization request. One of the most common is not being in good standing with taxes and social charges. If you owe anything to the tax office or URSSAF it is a strike against you. Furthermore, if there is a procedure against you, either audit or collection, your naturalization request will be denied because you do not sufficiently comply with the law.
The same concept applies if you have traffic violations, from too many parking tickets to speeding tickets as well as traveling on public transport without a ticket. All this seems banal but the French administration sees the unlawful aspect of it.
The prefecture also measures the applicant’s loyalty to France regarding finances. The foreigner may work in France and receive a small income, topping it up with savings and investments in the country of origin. If the unearned income generated by these investments equals the earned income in France, the naturalization request will be denied. Some or all of these investments should be in France. This does not affect retirement accounts.
Getting back to your situation, I understand how frustrating it is but you will have to resubmit a completely new file. Also, learning from previous errors, make sure the new file details a lot of your spouse’s work and the traveling she does for her job. Assume that your naturalization procedure could take two years, and make sure this timing is compatible with the validity of her carte de séjour. In any case, if she goes on a long mission, she should immediately register with the French consulate of the destination country, explaining that your naturalization request is being reviewed and that her presence in that country is strictly professional. Doing this, even though it might look odd to the people working in the consulate, can have a second benefit: as she would be registered with them, she should easily get her carte de séjour extended if need be.

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