Leasing gray card: in whose name should it be issued and what steps to follow?

In LOA or LLD, the vehicle’s registration certificate is not issued in the name of the driver. This administrative peculiarity generates recurring questions about each party’s responsibilities, the steps to be taken, and the consequences in case of contract transfer. Several boxes on the registration certificate come into play, and their correct interpretation affects both the insurance and the taxation of the vehicle.

Boxes C.1 and C.3 of the leasing registration certificate: who is listed where

The registration certificate of a leased vehicle distinguishes two roles. The C.1 box mentions the legal owner, which is the financing company or the lessor. Box C.4.1 identifies this same entity as the holder of the certificate.

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The lessee appears in box C.3 as the user of the vehicle. This name determines the reference address for calculating the regional tax and for sending fines.

Box Content in LOA/LLD Role
C.1 Financing company Legal owner
C.3 Name of the lessee (individual or company) Current user
C.4.1 Financing company Holder of the certificate

Since the extension of the New Generation Prefectures Plan (PPNG) in 2025, the professional leasing registration certificate (LLD) can include the name of the user company in box C.3 without additional mandate, according to ANTS circular No. 2025-12 dated March 10, 2025. This simplification reduces back-and-forth between lessor and professional lessee.

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To understand precisely which name the leasing registration certificate should be issued according to your situation, the distinction between these boxes remains the starting point.

Man holding registration certificate documents in front of a leased car at a car dealership

Leasing registration certificate procedures: contract start, address change, and buyout

The formalities vary depending on the timing of the contract. The lessee is not always the one who initiates the request, which creates confusion.

Vehicle registration

At the start of the leasing, it is the financing company (or the authorized dealer) that submits the registration certificate request on the ANTS website. The lessee has nothing to do at this stage, except provide their identification documents and proof of residence.

Lessee’s address change

A move requires updating box C.3. This modification is done online on the ANTS website, free of charge. The lessee can do it themselves, but some lessors prefer to centralize the process. The legal deadline remains one month after the address change.

Buyout of the vehicle at the end of LOA

When the lessee exercises the purchase option, they become the owner. The registration certificate must then be fully transferred to their name (boxes C.1 and C.3). The necessary documents are:

  • The transfer certificate signed by the financing company
  • The old registration certificate (the registration certificate does not necessarily have to be crossed out by the lessor according to the classic transfer procedure between professionals)
  • A proof of residence less than six months old and an identification document
  • The completed Cerfa form 13750

Field reports from the FNAA indicate that ANTS processing times via authorized representatives have dropped to under ten days on average since mid-2025, compared to about four weeks previously. Going through an accredited professional can thus speed up the transition.

Leasing takeover and unupdated registration certificate: the tax trap in sole proprietorship

The takeover of a leasing contract by a third party (often called leasing transfer) is a less documented case. When an individual or a company takes over an ongoing LOA contract, box C.3 of the registration certificate must be updated in the name of the new lessee.

If this update is not made, the vehicle remains administratively linked to the former lessee. For an individual, the consequences are limited to misdirected fines and insurance complications.

For a sole proprietor, the situation is more serious. The deductibility of leasing payments from taxable income depends on the consistency between the contract, the declared professional use, and the vehicle’s administrative documents. A registration certificate where the operator’s name does not appear in C.3 weakens the tax justification for the deducted payments.

In case of an audit, the tax administration may reclassify the payments as non-deductible expenses if the link between the vehicle and the professional activity is not clearly established. The registration certificate is part of the supporting documents examined, alongside the leasing contract and mileage records.

Advisor and client discussing administrative procedures for the registration certificate of a leased vehicle

Cost of changing the holder after leasing buyout

The price of the new registration certificate after exercising the purchase option depends on the vehicle’s fiscal power and the region of residence of the new owner. The regional tax (Y.1) varies from one region to another and constitutes the main expense.

There are also management fees and delivery charges. For so-called clean vehicles, some regions grant a total or partial exemption from the regional tax, significantly reducing the bill.

On the other hand, the simple change of lessee in C.3 (without transfer of ownership) is free when done on the ANTS website. This distinction between lessee modification and ownership change is often confused.

The leasing registration certificate follows a logic distinct from that of a purchased vehicle. Boxes C.1 and C.3 distribute the roles between owner and user, and each change in situation (address, takeover, buyout) requires a specific procedure. Failing to update box C.3 during a contract transfer exposes the professional lessee to a direct tax risk on the deductibility of their payments.

Leasing gray card: in whose name should it be issued and what steps to follow?