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CPAM - Proof of residence

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Just got a slightly surprising letter from our CPAM today.  Having come off our E106's last year and successfully joined (and paid for) the French system for the last year, they have now decided that we need to prove that we are permanent residents!  One of the documents they are asking for is a "carte de sejour."  Now, we don't have one as our Mairie does not issue them and advised us that they were "not necessary" which is also the given wisdom on here.  Any ideas?
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    We have received what sounds like the same letter today - totally different from previous years and quoting 2007 legislation.  "votre dossier doit faire l'objet d'un nouvel examen par nos services".... "vous devez, en effet, justifier d'une résidence stable et régulière sur la territoire français" etc.  It is quite precise in what is required : les documents attestant de la régularité de votre séjour (carte de séjour, récépissé en cours de validité, convocation, rendez-vous en préfecture...).   Certainly we have never been asked for this before - does this sound similar to your letter Cooperlola?    We actually have Titres de Séjour but they run out next month so we will be visiting our Mairie tomorrow morning to find out whether or not they are going to renew them.  I understand that while Titre de Séjour's are no longer required they can be provided if requested.  So I guess like many other things a lot depends on the local attitude.

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If you read the instructions carefully the section asking for the carte de séjour etc is for people from outside the EU.  For French and those within the EU it asks for carte de séjour or passport.  Don't forget to take in your revenue fiscale de reference, that proves you are a tax resident and tells them how much you are earning for their calculations.
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Interesting. Although the principles are national, I suspect that the various CPAMs are each sending out their own version of the 'standard' requirements. I haven't seen one of these letters - we both work, so there is no question that we contribute (just the amount is in question) and belong to the system - but I have heard from those who have seen the letters. Certainly in parts of Brittany I understand that Titre de Sejour (which carries your address in France) is being asked for 'as proof of residence' - unless you are entitled to a French passport, which very few recent British E106 holders are likely to be, then a passport is certainly no alternative. And even then it won't prove that you actually live in the passport issuing country. Though a passport is required too, as proof of identity. 

And at least one of the companies specialising in health insurance and top-ups for non-French residents seems to have interpreted this move in terms of once your E106 has expired, you have to buy its expensive private health plan...

Edit - I also understand that for those who have succeeded in getting the mairie or prefecture to agree to renew a carte de sejour, then all sorts of extra proof is demanded to verify your financial and health status compared with the near-formality that it was before the current legislation came in. So is Sarko's bite beginning to be felt?

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    I see what you mean La V - in the list of "Pièces à joindre au dossier" on the back of the form for declaration of revenue - however our covering letter states" l'imprimé de demande de la CMU de base est erroné sur ce point......"   We have been here for over 5 years now and I assumed that this was just something they do every now and again to ensure that the rules are being complied with - however maybe this isn't the case.

The issue is that we need (somehow) to prove that our residence is stable and regular - which won't be proved by a UK passport or a utility bill.

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Will, I have re-read the form, and although the letter states that a carte de sejour is required, as Vette says, the form in fact only asks for this from non EU citizens.  For those in the EU a passport is acceptable.  However, other documentation (EDF bills, income tax form etc) is required for all, so I guess that's how they prove you live here.
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Naturally, nothing is ever easy!  Now I'm in the process of filling in the form, and see they've asked for my RFR.  I haven't had my Avis d'Impot yet, so don't have one for this year.  I've written to my tax office to ask them for it but wondered if there's a way to find this out.  I cannot find anything on tax web-site to steer me in the direction as to how to work this out myself. 
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An income tax form is pretty good proof of residence - though one may not actually have a tax liability, or may pay tax elsewhere under a dual taxation agreement, you have to declare in France if you are resident. The great thing is, this could catch out those who do not declare anything in France. EDF bills, local taxes etc could still apply to a holiday home so only prove address, not residence. I think Sarko may be regretting the fact that Titre de Sejour was scrapped for Europeans.


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[quote user="cooperlola"]... we haven't had our Avis des Impots yet.  Still doesn't help me work my RFR out though.  Humph.[/quote]

Have you a local Trésorerie nearby? If you have perhaps you could go there, armed with a tax reference number, and say your Avis has not yet arrived and can they let you know your RFR as you need it for CPAM etc etc. Worth a shot.



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I have e-mailed them (they are, uncommonly, rather good at replying to e-mails) and await a response.  Failing that, I will do as you say, Sue.  It's all a bit rum this, as the whole form has to be completed and all the documentation in the CPAM's hands by the middle of September.  I'm just glad I've got back from my ramblings in the UK - if I hadn't been around it would have been a bit of a shock - especially as the letter contains the threat that if it's not back by then, our benefits could be suspended.
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When I visited my CPAM office in Spring after the E106 expired, I was informed that I would hear from them again in September in order that they could reassess my contributions based on my level of income.

I have today received the same form that Cooperlola has and I think it will be sufficient to send along with details of income.

Copy of Carte Vitale and the attestation

Copy of passports

Copy of marriage certificat  and childrens birth certificate ( if appropriate)

EDF factures  or tenancy agreement IF you have been in France for more than 3 months.

Fortunately, I have had the tax form thing back so I can press on with it straightaway.

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It also appears from  this thread, that some have been refused under the new regulations, but I'm unclear as to why.  Does anybody know what the new qualifying criteria are?

here is a rather disturbing article on the subject


and the piece of legislation


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The CPAM form and the required supporting documents are quite straightforward.  It applies to persons no longer covered by an E106 where residency is now the qualifying element.

Complete the personal details on page 1, enter your revenue fiscal de reference on page 3 and sign at the bottom.  Then attach the following:-

Photocopy of your current tax avis;

Photocopy of current CMU attestation and carte vitale;

Photocopy of passport;

Photocopy of last two EDF bills (evidencing more than three months residence).

That's it. 

Documents justifying your entitlement to residence (régularité de votre séjour) such as the titre de sejour are only applicatable to non-EU citizens.


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It would appear that both European and French law may have changed recently and those who are not French nationals, do not have a current E-form, and have never worked and paid social security contributions in France may now be outside the system. This has been published elsewhere on the internet, and is, apparently, a standard e-mail that is being sent out by a provider of health insurance to non-nationals in France (so bear in mind there could be vested interests at play, though it does appear to quote actual legislation). And yes, it does appear to contradict the perceived 'compulsory' nature of CMU affiliation for all French residents. Look in particular at the last two sentences:

"Now CMU  may no longer be available to all residents of France; only residents who are French nationals or have worked in France and paid social security contributions can qualify and those arriving in France from other EU member states are being refused state medical cover. Even worse, there is evidence that cover is being withdrawn from those that already have it and that they are required to return the Carte Vitale.

We should emphasise that holders of the E106 or E109 are not affected until the Forms expire and holders of the E121 whilst their entitlement is valid. 

If you are already affiliated under the provisions of CMU you should wait until you receive a notice of cancellation.

If you do receive such a notice or, are refused affiliation as a new applicant,  you need medical insurance at once, to protect yourself against accidents and emergencies.

 This event is not confined to France only as many member states do not have an alternative such as CMU. The legal back ground for those that are interested is below:


On the 23 March 2006 there was a judgement (affaire C-408/3) by the Cour de Justice des Communautés européennes (CJCE) which is  important as regards the right of citizens of Member States to reside in another Member State. The CJCE also reiterated the two conditions required for such residence. 

 Firstly, the aforementioned citizens’ right of residence, as granted by the Maasstricht Treaty, is a fundamental, personal and immediate right.

Secondly, only two conditions are required of the aforementioned citizens in order that they can reside in a Member State other than their own, the two conditions being: They must have health cover and they must have sufficient resources to support themselves without recourse to the social assistance of the host Member State.  

Extract from the Sarkozy Law

Art.L.121-1 – Except if his presence constitutes a menace to public order, every citizen of the European Union, every national of another State party to the agreement for the European Economic Area or for the Swiss Confederation, has the right to stay in France more than three months if he satisfies one of the following conditions:

1.If he exercises a professional activity in France;
2.If he has, for himself and members of his family, sufficient resources in order not to become a charge on the social assistance system, as well as having health insurance (assurance maladie);

 It should be noted that the normal subscription to be paid under the provisions of CMU are far short of the actual cost to the French State which exceeded €3000 per capita in 2005 and is probably much  more by now. 

Law 2007/209 Art 63 amends existing laws that contain clauses that conflict with the new regulations. An example is art 3 of law  99-641 dealing with exemptions from the obligation to  apply for affiliation to the French state system.  A sixth exemption is now included relating to people who are non-actif and do not qualify under EU regulations such as the “E” forms."

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I guess that a number of us will find out within the next couple of weeks, whether we are going to be allowed to continue within the CMU sytem or not - once these documents which we are sending in get vetted.

Edit : Thanks, Will, for you comprehensive reply (as ever.)

Further edit! : I have just received an e-mail from Exclusive Healthcare (my top-up insurers) which - apart from some additional stuff - is pretty much verbatim what Will has quoted, above.  (But as you say, they'd no doubt like more of our money).  Their advice is to wait until I actually get a refulsal though, it has to be said.  But it may come...


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That e-mail doesn't really stand up to scrutiny.

Loi 2007/209 Art 63 contains a two phrase amendment to the education code - no apparent link to heath insurance.

Loi 1999/641 Art 3 merely sets out the normal entitlement to CMU -available to any person residing in France in a stable manner and who is not already affilliated under another obligatory sickness insurance regime.  It goes on to set down the modalities for establishing the level of contributions. There is no mention in art 3 of any exemptions from the obligation to apply for affilliation.

As Will says, take note of it's source....

The piece of legislation in Cooperlola's link is a modification to the social security code which sets out the residence qualifications for affiliation to the various social security and heath insurance organisataions.

The principal changes are as follows:

1) The period of permanent residence necessary to qualify for affilliation is now increased to six months during a calendar year of affiliation.

2) Annual residency checks are now being introduced.

3) These checks will involve the exchange of information between the various agencies.

Despite the information issued by the aforementioned commercial insurance organisation, there is no mention of any exclusion for EU nationals who fulfill the normal residency requirements.

The full text of the decree (quickly translated - errors and omission excepted) is as follows:


Art. R. 115-6. - to benefit from the services pursuant to the third subparagraph of article L. 111-1 and of articles L. 380-1, L. 512-1, L. 815-1, L. 815-24 and L. 861-1, as well as maintenance of the right to services envisaged by the article L. 161-8, one is regarded as resident in France if one’s principal residence is on metropolitan territory or in an overseas department.

This provision is not applicable to the rights of minors regarding the provision of sickness insurance and maternity.

Residence means the place where people normally live, i.e. place of their usual residence, provided that this residence is permanent and on metropolitan territory or in an overseas department.

The condition of principal residency is satisfied when the recipients are personally and indeed present at their principal residence on metropolitan territory or in an overseas department. Subject to the application of the provisions of article R. 115-7, one is deemed to be resident in France if one remains there for more than six months during the calendar year of payment of the services.

Residence in France can be proven by any means. A decree of the minister in charge of the social security sets down the list of requirements relating to the condition of residence.

Art. R. 115-7. - A person must declare to the organization providing the service mentioned the first subparagraph of the article R. 115-6 any change in marital status or place of residence, in particular, any transfer of residence outside the metropolitan territory of France or of an overseas department which would call into question the entitlement to benefits provided by the organisation.

Article 2 Section 2 of chapter VI of the Ier title of the Ier book of the social security code (second part: Decrees in Council of State) is thus modified:

1° the article R. 161-1 becomes the article R. 161-1-1;

2° article R. 161-1 is rewritten as follows:

Art. R. 161-1. - the sickness insurance organisations which provide the services pursuant to articles L. 161-8 and L. 380-1 and organisations mentioned in B of the article L. 861-4 which provide services defined in the article L. 861-3 to persons affiliated to an obligatory social security system and to recipients of this benefit of right to the services envisaged in the Ier chapter of title VI of the Ier book and with the article L. 311-5, will introduce a check to confirm residency in France in the following cases:

"1° At the time of the renewal of the annual contribution to the general regime pursuant to the article L. 380-2;

"2° At the time of the annual calculation of the resources pursuant to the same article;

"3° At the time of a change of organisation;

"4° At the time of the declaration of having to service or its withdrawal;

"5° At the time of the request for complimentary health protection as envisaged in article L. 861-1 or at the time of the expiry of the right to this protection, when the interested party is already affiliated with the general regime pursuant to the article L. 380-1.

In any event, this check will take place once a year.

Article 3 The article R. 380-1 of the same code is modified as it follows:

1° With I, before the words: "the people", are inserted the words: "to be affiliated by having the right to the general regime,

2° After II, it is created one III thus written: "III. - to benefit services provided by the sickness insurance and maternity, people mentioned within article L. 380-1 must reside in France in accordance with the provisions of the article R. 115-6.

Article 4 In the first sentence of the article R. 380-5 of the same code, the words: "on the basis of available information or, failing this, on a base not exceeding five times the annual ceiling of the social security" are replaced by the words: "on a base fixed at five times the annual ceiling of the social security".

Article 5 The article R. 512-1 of the same code is thus modified:

1° Before the first subparagraph, a subparagraph is inserted: "For the application of the article L. 512-1, for persons with one or more children, residence in France is defined under the conditions fixed at the article R. 115-6. ";

2° The following subparagraph is inserted: "the family allowance organisations periodically carry out checks on residency and these checks will be undertaken in conjunction with the checks carried out by the other social security organisations."

Article 6 Into chapter VI of the Ier title of book VIII of the social security code, after article R. 816-2, article R. 816-3 is inserted:

"Art. R. 816-3. - For the application of this chapter, the condition of residence is defined under the conditions fixed in article R. 115-6. "the organisations providing the allowances mentioned within the present chapter will carry out an annual check of residency. This check will be undertaken in conjunction with the checks carried out by the other social security organisations.


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I seem to remember that at the time this was all being talked about last year the Government's intention was to introduce a pincer movement to tackle fraud.

Firstly some kind of reintroduction of the old minimum income requirement to prevent people without adequate resources settling in France.

This was to be done by implementing a rule  that unless people had at least a level of income sufficient to disqualify them from receiving free healthcare and other such benefits then they would not be entitled to stay in France.

Secondly if people who were already in the system , but were thought to be living above their declared means, then  punitive levy would be imposed based on an imputed income reflecting their lifestyle.

I suspect that we are now seeing the first stages of the implementation of these policies.


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Certainly, SD, there is no reference whatsoever in the letter from our CPAM, which sparked this thread in the first place, to any income qualifications (above the usual ones), just proof of permanent residence.  To be fair to Exclusive Healthcare, they have made it quite clear in their e-mail to me, that I should only panic if and when we are refused CMU cover and asked to return our cards.  It is evident from another thread that there is at least one poster on here to whom this has happened already. But their circumstances seem quite different from ours, as their income source is from gites (which don't seem to be registered as a business - just declared as "other income" - although I must stress that this is merely an assumption on my part, and I may well have misunderstood the o/p in this case.)

Thank you for your comprehensive reply.  Whatever happens, it seems pointless to panic at this stage until there is an outcome from our response to the CPAM's letter.

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Yes quite right. In the immortal words of both Douglas Adams and Clive Dunn - 'Don't panic'.

There seem to be several quite different interpretations of what this is all about - all we can do is wait and see what happens in reality.


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