Submitting a Request to the URSSAF’s Conciliation Commission (CRA): 2 Months, Complete Dossier, Negotiation Leverage

The Conciliation Commission (CRA) is not just a formality before going to court: it is a genuine tool for dispute — and negotiation. Too many employers treat it as a box to tick. This is a mistake: a well-structured request can often influence a reassessment.

This article is part of the URSSAF Control: Employer Guide. Previous steps: the formal notice and the injunction.

What is the CRA?

The CRA is composed of members of the URSSAF Board of Directors. It constitutes the mandatory prior amicable recourse (art. R.142-1 CSS) before any contentious action. It issues an opinion that is almost always ratified by the Board of Directors.

The Deadline: 2 Months, and the Right CRA

Submit your request to the CRA within 2 months from the notification of the formal notice (art. R.142-1 CSS). The submission date is the date of sending: keep the proof.

Pitfall: failing to submit to the correct organism (especially in cases of multiple establishments or VLU). DAIRIA’s Advice: Always identify the correct CRA in advance, even if the risk seems limited.

Reminder: a simple request for a waiver of penalties does not constitute submission to the CRA — see the formal notice.

A Dossier as Complete as a Contentious Dossier

DAIRIA’s Strategy: produce a submission dossier as complete as a contentious dossier. Hold nothing back. Attach a numbered list of documents and a summary of arguments to facilitate reading. The CRA does not redo the assessment: it verifies the regularity and validity of the reassessment, item by item.

Be cautious of partial contestation: only explicitly contest what you wish to challenge, without implying that you admit to the rest.

Implicit Rejection Decision

The silence of the CRA during the regulatory period constitutes an implicit rejection decision, which opens the way to the judicial court. Key point: if you have not yet brought the case to court, a late explicit decision may arise; produce it as new evidence and adapt your submissions accordingly.

Frequently Asked Questions

What is the deadline to submit to the CRA? 2 months from the notification of the formal notice (art. R.142-1 CSS).

What if the CRA does not respond? Implicit rejection, which opens access to the court.

Should the dossier be carefully prepared? Yes, like a contentious dossier.

Written and supervised by Guillemette Watine, lawyer and former inspector of URSSAF litigation, head of DAIRIA’s URSSAF department.