Short answer: in 2026, a French HR department no longer sends faxes out of habit — it sends them because certain counterparties have no other documented channel: income protection departments at small mutual insurers, foreign supplementary pension funds, inter-company occupational health services, regional temp agencies, training providers, bailiffs handling a wage garnishment. These workflows carry a company's most sensitive data: salary certificates, sick leave notices, unfitness-for-work opinions, payslips. Handling them with a fax machine sitting in a hallway is, in 2026, the single biggest GDPR risk facing an HR department. An online fax service with named email reception, a timestamped transmission log and scheduled deletion of documents solves the problem without changing the channel on the recipient's side.
Every payroll manager knows the paradox: the French DSN (nominative social declaration) has digitized most of the workload, net-entreprises centralizes filings, and the salary certificate used to trigger daily sickness benefits has been submitted online via net-entreprises for years. And yet, every month, a pile remains. An income protection form to be returned "by post or by fax to the claims department." A request for an additional document from a construction industry paid-leave fund. An occupational physician's opinion that the health service will only send by fax because its email system isn't secure.
That pile is small. It is also the most explosive one in the department, because it contains health data and named salary information. Here is a map of the workflows that survive, and the operating procedure to keep them clean.
Where fax still holds on in HR and payroll
Income protection and group policies
This is the biggest reservoir. Group income protection providers — institutions governed by the French Social Security Code, mutual insurers under the Mutual Insurance Code, commercial insurers — all have an employer extranet. But that extranet covers enrollment, contributions and sometimes claim tracking; it almost never covers additional documents for an incapacity or disability claim. The case handler calls back, asks for the last three payslips and the statement of daily benefits paid, and gives out a direct fax number — often more reliable than the department's generic email address, which takes six days to be read.
The same logic applies to portability of coverage after a contract ends: the certificate to be sent to the former employee and to the insurer sometimes travels this route.
Specialized funds and special schemes
Paid-leave funds in the building and public works sector, foreign supplementary pension funds (a posted employee claiming benefits in Germany, Italy or Switzerland), bodies managing special schemes: each has its own forms and its own channel. When a French employer has to respond to an Austrian or Portuguese pension fund within a tight deadline, fax avoids a week of postal delay. We cover the specifics of sending outside France in sending a fax abroad in 2026: the country code, the number format and the page count matter more than you'd think.
Occupational health services
Inter-company occupational health and prevention services have widely varying levels of equipment. Many send fitness, unfitness or workstation-adjustment opinions by post; some, in order to meet the fifteen-day appeal window, also send a fax copy. Conversely, an employer who has to report an early return to work or submit an updated job description before a return-to-work medical sometimes faces the same channel.
The stakes here are as much legal as technical: an unfitness opinion triggers a one-month deadline to redeploy or dismiss. The date of receipt is part of the file. A timestamped transmission report is worth far more than "I got it last week."
Temporary work, staffing and employer groups
Temp agencies generate a constant flow of timesheets, assignment contracts and amendments. The big chains have client portals; independent agencies and agricultural employer groups still largely run on fax, because the site foreman or the farmer who signs off the hours on a Friday evening has no extranet login.
Wage garnishments and legal proceedings
A bailiff serving a wage garnishment order, a court registry requesting an employer's certificate, a fund's debt recovery department: this correspondence is still frequently faxed. Legal professionals have their own practices, which we covered in fax in the legal professions in 2026.
The real problem isn't the fax, it's the fax machine
Let's be blunt: all of these workflows can travel by fax with no particular legal difficulty. Proof can be established, timestamping exists, the recipient receives the document. What causes the problem is the machine sitting in the open-plan office.
A typical HR fax machine means:
- sick leave notices, unfitness opinions and payslips printed into a tray accessible to anyone walking past;
- an internal log that only keeps the most recent transmissions, overwritten in a loop;
- no record of who sent what — yet traceability of access to HR data is exactly what an audit will ask you for;
- an internal hard drive that, on many multifunction devices, keeps an image of scanned documents until the machine is scrapped.
The CNIL regularly points out, in its recommendations on personnel management, that data relating to employees' health must be subject to access restricted to authorized persons only, usually the occupational health service and one specifically designated case handler. A shared output tray does not meet that requirement. The General Data Protection Regulation also classifies health data as a special category (Article 9), which raises the level of technical measures expected.
This is precisely the reasoning we develop in fax and GDPR in 2026: the channel isn't the problem, the drop-off zone is.
The HR operating procedure: six rules
1. A dedicated number, a dedicated inbox
Don't let HR faxes arrive on the company's main number. A number specific to the department, feeding into a restricted shared inbox (hr-fax@) with two or three named recipients, is enough to transform the compliance of the workflow. How fax-to-email works is explained in our guide to receiving faxes by email.
2. Separate the health stream from the administrative stream
Sick leave notices, unfitness opinions and income protection documents must not land in the same place as temp agency timesheets. If your department handles significant volume, request a second number reserved for medical documents, accessible only to the designated authorized contact.
3. A minimalist cover sheet
In HR more than anywhere else, the cover sheet must reveal nothing. No employee name, no reason, no "Mr. X's disability claim." A neutral subject line, an internal reference, the page count, and the confidentiality notice. We published an annotated template in fax cover sheet: template and required wording.
4. Scan properly, once
A handwritten sick note scanned crooked at 200 dpi means a case handler calling back and a claim losing ten days. A duplex scanner with automatic document feeder sitting on the payroll desk, set once and for all to black and white at 300 dpi, eliminates 90% of rejections. For fragile or folded documents — health record booklets, foreign A5-format forms — an A3 cutting mat and a metal ruler prevent skewed scans. And for documents that arrive stapled in bundles, a stapler with a built-in staple remover saves an absurd amount of time. The settings are detailed in our article on unreadable faxes.
5. Archive the report, not just the document
For every transmission tied to a procedure — unfitness, garnishment, contesting a sick note — file the PDF you sent and the transmission report in the employee's file, under a meaningful name. It's the only way to answer a question eighteen months later. The retention periods applicable in HR (payslips: 5 years for the employer, staff register: 5 years after departure, contribution records: 3 years) also apply to these attachments.
6. Destroy whatever has been printed
If printing is unavoidable — a case handler annotating, a handwritten signature to add — it must end up in a cross-cut document shredder, not in the wastepaper basket. A P-4 model is the reasonable minimum for health data.
Comparison: the three possible setups
| Departmental fax machine | Networked multifunction device | Online fax | |
|---|---|---|---|
| Health documents printed in open access | Yes | Yes, unless secure print is used | No |
| Named traceability of the sender | No | Partial | Yes |
| Log kept beyond 50 transmissions | No | Varies | Yes |
| Reception while working from home | No | No | Yes |
| Depends on an analog line | Yes | Yes | No |
| Scheduled deletion of documents | No | No | Yes |
The right-hand column isn't a sales pitch: it's the only one that ticks the boxes of a workable HR record of processing activities. And it becomes mandatory for another, purely practical reason — the analog line that the department's fax machine relies on is disappearing. We described how to keep your existing number in keeping your fax number after the end of the PSTN.
The special case of multi-site organizations
A group with five sites and payroll centralized at head office faces a classic situation: each site inherited a local fax number, local counterparties (the county occupational health service, the local temp agency) use it, and head office sees nothing arrive.
The answer isn't to shut the numbers down — you'd lose files for six months. It's to keep each local number and redirect it to the central HR inbox, then gradually publicize the single number. The details of this transition are set out in our article on multi-site fax.
What should no longer go by fax in 2026
For the sake of completeness, we should also say what you need to stop sending:
- The salary certificate for daily sickness benefits: online submission on net-entreprises is the official channel, faster and with no re-keying at the fund's end.
- Social security declarations: the DSN has absorbed almost everything, there is no reason to fax anything.
- Payslips to employees: the digital payslip with a secure online vault, provided for by the French Labour Code, is the norm. Faxing a payslip to an employee on sick leave is a practice to be eliminated.
- Documents containing bank details: they have no business on a channel whose output you cannot control at the recipient's end.
The decision criterion is simple, and we formalized it in fax or secure messaging: if the recipient has a structured channel and you can verify their identity, use it. Fax is for the counterparties who have nothing else.
Frequently asked questions
Can a sick leave notice be sent by fax to an income protection provider?
Yes, nothing prohibits it if the provider asks for it. But the transmission must be traced and the document must not stay printed. In practice: send from an online service, use a cover sheet with no employee name, file the PDF and the transmission report in the case file, and destroy any paper copy.
Does an unfitness opinion received by fax start the one-month clock?
The deadline runs from the employer's receipt of the opinion. A timestamped fax constitutes evidence of that receipt, just like a postal delivery confirmation — provided you can produce the transmission report and the document. That's exactly why keeping the log matters as much as keeping the opinion itself.
Does the HR fax need to appear in the record of processing activities?
Yes. The channel is part of the means used to transmit personnel data and, where applicable, health data. List the number, the receiving inbox, the authorized persons, the retention period for the documents and any processor involved — for which a contract within the meaning of Article 28 GDPR is required.
Can employees send their supporting documents by fax?
Technically yes, and it's common for employees travelling or based abroad. In that case, give them the dedicated number that feeds the restricted HR inbox, never the main company number. The online sending form is available from the home page.
Does fax work to foreign funds?
Yes, subject to the country code and the quality of the connection. Country-by-country coverage can be checked on the list of supported countries.
Summary
- Residual HR fax use is concentrated in five families of counterparties: income protection and mutual insurers, specialized and foreign funds, occupational health services, temp agencies and employer groups, bailiffs and court registries.
- The risk doesn't come from the channel but from the shared output tray and the absence of traceability.
- Minimum measures: dedicated number, restricted named inbox, separation of the health stream, neutral cover sheet, archiving of the document + report pair, secure destruction of printouts.
- To be eliminated: salary certificates (net-entreprises), social security declarations (DSN), payslips to employees, bank details.
- In multi-site organizations, keep local numbers on redirection before switching to a single number.
- Online fax is the only setup compatible with a workable record of processing activities — and the only one that will survive the shutdown of analog lines.
For specific cases, our FAQ details accepted formats, delivery times and how confirmations work.
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