Filing a Claim with the URSSAF Amicable Appeals Board (CRA): 2-Month Deadline, Complete File, Negotiation Leverage
The Amicable Appeals Board (Commission de recours amiable, or CRA) is not a mere formality before litigation: it is a genuine lever for challenging — and negotiating — an assessment. Too many employers treat it as a box to tick. That is a mistake: a well-built claim often shifts the reassessment.
This article is part of the series URSSAF Inspection: The Employer’s Guide. Previous steps: the formal notice (mise en demeure) and the enforcement order (contrainte).
What the CRA Is
The CRA is made up of members of the board of directors of the URSSAF (the French social security collection body). It constitutes the mandatory preliminary amicable appeal (Article R.142-1 of the French Social Security Code) required before any litigation. It issues an opinion that is passed on to the board of directors, which almost systematically endorses it.
The Deadline: 2 Months, and the Correct CRA
File your claim with the CRA within the 2-month deadline running from notification of the formal notice (mise en demeure) (Article R.142-1 of the French Social Security Code). The filing date is the date of dispatch: keep proof of it.
Pitfall: failing to file with the CRA of the correct body (particularly in the case of multiple establishments or of a single collection point, or VLU). DAIRIA tip: always identify the correct CRA in advance, even where the risk appears limited.
Reminder: a mere request for a waiver of surcharges (majorations) does not amount to filing a claim with the CRA — see the formal notice (mise en demeure).
A File as Complete as a Litigation File
DAIRIA strategy: submit a claim file as complete as a litigation file. Do not hold anything “in reserve.” Attach a schedule of numbered exhibits and a summary of your arguments to make the file easier to read. The CRA does not redo the inspection: it reviews the regularity and merits of the reassessment, item by item.
Beware of partial challenges: explicitly challenge only what you intend to dispute, without giving the impression that you accept the rest.
The Implied Decision of Rejection
The CRA’s silence throughout the regulatory period amounts to an implied decision of rejection, which opens the way to the judicial court (tribunal judiciaire). Point of attention: if you have not yet brought the matter before the court, a late explicit decision may still be issued; produce it as a new exhibit and adjust your submissions accordingly.
Frequently Asked Questions
What is the deadline for filing a claim with the CRA? Two months from notification of the formal notice (mise en demeure) (Article R.142-1 of the French Social Security Code).
What if the CRA does not respond? Implied rejection, which opens the way to the court.
Should the file be carefully prepared? Yes, just as much as a litigation file.
Written and supervised by Guillemette Watine, attorney, former URSSAF litigation inspector, head of the URSSAF practice at DAIRIA Avocats.
Next step → Challenging the reassessment before the judicial court (social division)