Creation incentives in French rural zones: from ZRR to ZFRR (2026 update)

The former ZRR scheme, instituted by the 1995 Pasqua Law, aimed to encourage business establishment in low-density rural territories. It provided five years of full corporate tax exemption followed by a three-year tapering, plus social charge relief on new hires. Over time it coexisted with other territorial schemes (BER, AFR) without always articulating clearly. The 2024 Finance Law (article 73) operated a reform: as of 1 July 2024, the ZFRR (Zone France Ruralités Revitalisation) replaces the former ZRR and BER with a unified framework and new cartography drawn up by ANCT (Agence Nationale de la Cohésion des Territoires).

Companies created in ZRR before 30 June 2024 retain acquired rights for the residual duration originally provided (typically five full years then three tapered). Any creation after 1 July 2024 falls automatically under the new ZFRR regime, which applies based on the effective establishment municipality listed in the current ZFRR map. The map is revised every two years: the next update is scheduled for 1 July 2026.

To check if a municipality is ZFRR-classified, two main tools: the ANCT official search engine (with municipality name or INSEE code) and the Bpifrance Création interactive map. Caveat: some formerly ZRR-classified municipalities have left the new zoning; others have entered. Fine-grained verification is necessary before any establishment decision, as loss of eligibility represents a cumulative shortfall of €15,000 to €60,000 over eight years for a small business.

Corporate/income tax exemption (IR or IS) is full for five years from creation date, then tapered over three years: 75% in year six, 50% in year seven, 25% in year eight. From year nine, full taxation resumes. The EU de minimis ceiling (€300,000 over three rolling years) applies: for very large creations, the exemption may be capped beyond a certain profit threshold, but in practice the vast majority of small and medium-sized businesses stay below.

Employer social charge exemption (sickness, maternity, retirement, family allowances) applies to the first 50 employees hired on permanent or fixed-term contracts of at least 12 months, for the wage portion below 1.5 SMIC. The exemption is full up to 1.5 SMIC then tapered up to 2.4 SMIC, capped at 12 months per employee. This measure stacks with the general Fillon reduction but can only be charged once on the same base.

Cotisation Foncière des Entreprises (CFE) exemption can reach seven years, subject to municipal council decision. It requires explicit application before 31 December of the creation year (form 1447-C-SD) at the Business Tax Service. The Cotisation sur la Valeur Ajoutée des Entreprises (CVAE) exemption follows the same rhythm and applies to companies with turnover exceeding €500,000 excl. VAT. The property tax (TFPB) exemption on activity premises remains accessible in some zones, again by municipal decision.

• Income/corporate tax exemption — 100% for 5 years, then 75/50/25% over 3 years
• Employer social charges exemption — first 50 employees, capped at 1.5 SMIC, 12 months max
• CFE exemption — up to 7 years, by municipal decision
• CVAE exemption — for turnover > €500,000 excl. VAT, aligned with CFE
• Property tax exemption — activity premises, by municipal decision
• EU de minimis ceiling — €300,000 cumulated over 3 rolling years

First criterion: nature of activity. Banking, financial, insurance, residential real-estate leasing, asset management, and activities mainly conducted on markets (fairs, exhibitions) are excluded. Industrial, commercial, craft, agricultural, liberal-profession (under conditions), and service activities are eligible — except pure holding companies.

Second criterion: company size. ZFRR targets SMEs in the EU sense (fewer than 250 employees, turnover under €50M or balance sheet under €43M). Subsidiaries of groups over 250 employees are excluded, except when ownership crossover with an out-of-zone company stays below 25%. Size is assessed at group level, not just the legal entity.

Third criterion: effective establishment. The registered office must be located in a ZFRR-classified municipality, but more importantly the company must conduct real activity there (operating premises, present employees, commercial operations). A mere mailbox or fictitious office is not enough. The tax administration has a three-year review period to requalify and demand retroactive restitution. The requirement is lighter for service or consulting activities practicable remotely, but traceability (invoices, contracts, recurrent physical presence) remains necessary.

Particular attention is paid to the share of activity conducted outside the zone. If more than 25% of turnover is generated from clientele located outside ZFRR, the administration may consider the effective establishment condition unfulfilled. For freelancers and consultants, this often imposes structuring invoicing and client reception in ways that demonstrate genuine territorial anchoring.

In Germany, the GRW scheme (Gemeinschaftsaufgabe Verbesserung der regionalen Wirtschaftsstruktur) covers structurally disadvantaged regions (mainly Eastern Länder and some Western rural zones). It grants investment subsidies up to 35% for small businesses, modulated by A/C/D zone classification. Management is shared between federal State and Länder. Exemptions are investment-based rather than operating-based, which differs from the French ZFRR mechanic.

In Spain, Zonas de Promoción Económica (ZPE) instituted by Decree 1414/2024 target provinces of Teruel, Cuenca, and Soria (since 2018, extended to other provinces in 2024) with RETA contribution bonifications for 36 months and FEDER co-financed subsidies. In Italy, the « Aree Interne » programme (inner rural zones) provides IRPEF and IRAP bonifications of variable duration by region; SNAI (Strategie Nazionale per le Aree Interne) coordinates regional, national, and EU funds.

At EU level, FEDER 2021-2027 funds (European Regional Development Fund) co-finance much of national regional-aid schemes. European cartography is based on the NUTS 3 classification (Nomenclature of Territorial Units for Statistics), with a GDP-per-capita threshold below 75% of EU average for most-aided zones. A ZFRR-eligible company can thus locally stack national aid and FEDER co-financing, subject to maximum intensity rules (up to 35% for small businesses in European A zones).

The BoostPro IA simulator integrates the current ZFRR cartography (anticipating July 2026 revision) and cross-references eligibility with other stackable schemes (ACRE, honor loan, regional aids, FEDER). The personalized report (€29, 10 minutes) details for each scheme the exact conditions, average mobilizable amount, processing calendar, and project-specific pitfalls.