Decision No. 2014 - March 11, 2014 0294 Concerning The Rules For The Accounting Of La Poste Pursuant To Article L. 5 - 2 (6 °) Of The Post And Electronic Communications Code

Original Language Title: Décision n° 2014-0294 du 11 mars 2014 relative aux règles de comptabilisation de La Poste en application de l'article L. 5-2 (6°) du code des postes et des communications électroniques

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JORF n ° 0167 of July 22, 2014
Text N ° 85

Decision n ° 2014-0294 of 11 March 2014 on the accounting rules for La Poste en application de l 'article L. 5-2 (6 °) of the postal code and electronic communications

NOR: ARTR1416955S ELI: Not available

Electronic Communications and Communications Authority Posts,
In view of the amended Postal Directive 97 /67/EC of the European Parliament and of the Council of 15 December 1997 Concerning common rules for the development of the internal market in Community postal services and the improvement of the quality of service, in particular Articles 14 and 15;
In view of the postal code and electronic communications, And in particular its articles L. 2, L. 5-2(6 °), R. 1-1-14 and R. 1-1-15 ;
In view of Act No. 90-568 of 2 July 1990 on the organisation of the public postal service and in France Télécom, and in particular Article 2 thereof;
Given the N ° 2010-123 of 10 February 2010 on La Poste et aux activités postales;
Vu le Decree n ° 2011-849 dated 18 July 2011 specifying the method of calculation of the net cost of the Complementary networking to enable La Poste to carry out its mission Spatial planning;
In view of Decision No. 2007-0443 of the Electronic Communications Regulatory Authority and of the posts as of 15 May 2007 on the specifications of the accounting systems, in application of 6 ° of Article L. 5-2 of the Electronic Communications and Position Code
In view of Decision No. 2008-0165 of the Authority Regulation of electronic communications and posts in Date of 12 February 2008 on accounting rules, pursuant to 6 ° of Article L. 5-2 of the Postal Code And electronic communications ;
In view of Decision 2010-0363 of the Electronic Communications Regulatory Authority and of the posts as of 8 April 2010 concerning the accounting rules, pursuant to article L. 5-2 (6 °) of the postal code and electronic communications ;
In view of Decision No. 2012-0207 of the Authority Regulation of electronic communications and posts dated 14 February 2012 concerning the statutory accounting refunds of La Poste, pursuant to article L. 5-2 (6 °) of the postal code and electronic communications ;
In light of Decision No. 2013-0128 of the Authority Regulation of electronic communications and posts dated 29 January 2013 on the accounting rules and statutory accounting refunds of La Poste, pursuant to article L. 5-2 (6 °) of the postal code and electronic communications ;
Given the document " The regulatory accounting system of La Poste " Dated March 2013 and transmitted to the Authority on 28 March 2013;
In view of the file relating to the change in the allocation of the costs of the collection process-concentration transmitted by La Poste to the Authority on 17 January 2014;
Seen the Public consultation on the draft of this decision, conducted from 31 January to 28 February 2014;
Given the responses to this public consultation;

I. -Background

Under the provisions of Article 14 (1) of the amended Postal Directive 97 /67/EC, " Member States shall take the necessary measures to ensure that the accounts of universal service providers meet the provisions of this Article ".
Under Article 2 of this Article," The universal service provider (s) shall keep separate accounts in their internal accounts in order to draw a clear distinction between, on the one hand, the services and products which form part of the universal service and, on the other, the services and Products that are not part of the product. This distinction is taken into account when the Member States calculate the net cost of the universal service. This internal accounting is based on the consistent application of the principles of cost accounting, which can be objectively justified. "
Transposing the provisions of this article, 6 ° of article L. 5-2 of the postal code and electronic communications (hereinafter " CPCE ") Specifies that the Electronic Communications and Postal Regulatory Authority (hereinafter ' ARCEP "), " (...) in order to implement the principles of separation and transparency of accounts, in particular to guarantee the financing conditions of the universal service, specifies the rules for the accounting of costs for the separation of costs Which fall within the universal service of those who do not, establish the specifications of the accounting systems and ensure compliance by the universal service provider with the obligations relating to cost accounting Laid down in the decree provided for in Article L. 2. In this respect, in the field of universal service, the authority receives communication of the results of the auditors' audits, without any opposition to professional secrecy. It shall make an annual check, at the expense of the universal service provider, by an organisation which it is acting, competent and independent of the universal service provider, the conformity of the accounts of the universal service provider with the rules that it Has established. It shall publish a declaration of conformity relating to the universal service (...) ".
Under these provisions and the 6 ° of Article L. 5-2 of the ECCC referred to above, the ARCEP is competent to (i) establish the specifications of the accounting systems Costs and (ii) determine the accounting rules for the costs used in the preparation of these regulatory accounts. The ARCEP is based on regulatory accounting implemented by La Poste, the principles of which were defined by Decisions No. 2008-0165 dated February 12, 2008 (1), No. 2010-0363 (2) dated April 8, 2010 and n ° 2013-0128 as of 29 January 2013 (3). These principles are also formalised in a document entitled " The regulatory accounting system of La Poste " The latest version forwarded to the ARCEP is dated March 2013.
This decision deals with the allocation rules in the regulatory accounting of La Poste (i) the costs of collection-concentration and (ii) amounts related to the Pre-retirement devices.

II. -Changes to the Post Office Expense Rule

II. -1. On Collection Costs-Concentration

II. -1.a. Current rules

The collection-concentration process corresponds, for the incoming flows in the postal network, to the preparation of the postal flows before they are processed in the sorting establishments: Includes collection, obliteration and straightening-up activities (order of objects with the clearance area in the upper right to the right), concentration sorting, departure handling, handling in the cabin (for the Recommended, tracked, or declared value items) and verification of mail from postage meter machines. It does not cover the operations carried out at the point of contact point of La Poste (post office or partner point).
This process takes place mainly in production establishments managed by the mail directorate, identified By La Poste under the names of Plates-Forms of mail preparation and distribution ("PPDC" Serving as the intermediate point for the concentration of fluxes) and Plates-Formes distribution mail ("PDC", establishments serving as the starting point and arrival of the tours factors), whether they are autonomous or localized in the Plates-Industrial forms mail ("PIC", corresponding to sorting centres). This process represents just over 5 % of the charges attributable to the postal processes.
Collection-concentration operations carried out in the different production establishments are grouped together in " Site "
The regulatory accounting distinguishes between two types of charges in production establishments: (i) charges " Direct ", allocated by construction sites and consisting mainly of the remuneration of the staff assigned therein; (ii) charges" Indirect " Which are not allocated per site, relating to shared operational costs such as depreciation and maintenance charges for machinery, real estate or management staff (4).
To date, direct charges are Recorded in the accounting system of La Poste at a level which accurately reflects the details of the concentration-raising yards, according to the following main categories: concentration in PDC, PPDC, industrial flux deposits in IPC and Other direct charges (collection, back-office). They shall be allocated in proportion to the traffic concerned, according to large families of products reflecting the different modes of entry into the network and called " Technical products " (Gear products) Postage stamp ", garnet products" Non-postage stamp ", produced in number, etc.).
These allocation rules have at least two limits, identified in particular during the regulatory audits of the 2011 and 2012 fiscal years. They do not sufficiently reflect the details of the projects implemented in the collection and concentration process, nor their weight in the allocation of costs. Moreover, they date from the introduction of the regulatory accounting system in the early 2000s and do not include the reorganisation of the collection-concentration activities since (modernisation programme). Cap Qualité Courrier " Having set up the organization in PDC and PPDC, introduction of mechanization for the adjustment and timbrage).

II. -1.b. New rules

La Poste conducted an internal study between the months of September 2011 and April 2012 on the operations carried out in the collections-concentration establishments. The purpose of this study was to (i) identify more precisely the construction sites and associated loadings, using data from observations " Terrain "
A series of four survey waves (two months each) out of 1,474 sites (655 in PPDC, 566 in CDP and 212 in PIC/PPDC) (5) and about 2,500 sites, was conducted. The observation range, ranging from 10 a.m. to 10 p.m., corresponded to the opening hours of the concentration-collection sites. The data collected during this study include (i) registration information (identification of the establishment and the site observed, date), (ii) information on the conditions of the investigation (number of investigators present, slices) Observation schedules) and (iii) site-specific characteristics (number of machines, number of deployed agents, traffic handled, type of operation, etc.).

Allocation of concentration charges in PPDC

From this Investigation results in a more detailed description of the sites by type Establishment and associated resources in the PPDC, where nine sites related to the collection activities were identified: Depot for business, obliteration mail large format, processing of tracked objects, postage for third party account, processing of small-format gears, manual processing of large objects, processing of flows of Postage meter machines, processing of in-transit flows, processing of secure flows.
The investigation revealed the time-agent devoted to each of these sites, as well as the volume and nature of the flows processed. The result is the relative weight, in staff time and therefore of direct staff costs, of each of the yards, as well as, for each yard, an average cost of processing per object. These average costs make it possible to manufacture unit cost indexes for construction sites, corresponding to the staff time devoted to the processing of a consignment on a site reported to the staff time devoted to the processing of a consignment on a construction site. Reference (here, the processing of small-format gears).
The results are presented in the table below: the processing of a consignment in the construction site " Manual processing of large objects " For example, it consumes 2.20 times more staff time than the processing of a small-form gearbox, which passes through the machines performing the obliteration, the adjustment and the timbrage. Its unit cost is therefore 2.20 times higher. These time (and hence cost) indexes can be used for the distribution of direct collection charges in PPDC between sites, as long as processes are not substantially modified.


Enterprise Depot


Obliteration Large Format Mailbox


Object Processing Tracked


Third Party Postage


Small-format Gear Processing


Manual processing of large objects


Handling of postage meter streams


Flow processing In transit


Secure flow processing


Allocation of concentrations in PDC

Concentration operations carried out in GPC correspond to the reception, handling and transit of flows, mainly mail collected from customers, deposited in the yellow boxes or at the wicket of the PDC. Press flows, packages and large mailings are subject to special processing.
For small-format (PF) and large-format (GF) shipments, as well as previously uninsulated bulky shipments, they are processed In two types of containers, called BAK and Ké7. The mass consists of placing these containers in rolling structures, called stacker carts, and handling them to the transport link. According to the basic operating time frame of La Poste, the time-and thus the unit cost-of loading the different types of containers is the same; on the other hand, the proportion of small size and large format shipments differs according to The container.
The study observed the relative share of the BAK and Ké7 in the stacker carts and the relative share of the PF and GF consignments in the BAK and the Ké7, which allows the charges to be spread between the PF and GF shipments. As a result of trafficking, it is therefore possible to determine the unit cost of processing a PF shipment and a GF shipment. This information is returned in the form of a cost index using as a reference the processing cost of a small format submission, shown in the table below: A large object is 1.32 times more expensive than a small object.


Small format


Large Format-Encombrant


These indexes are used to rebuild the cost of a product based on its Consumption of the various shipyards (where it is treated in PPDC) and its format (when processed in PDC).

II. -1.c. Analysis

The file transmitted by La Poste to the ARCEP dated 17 January 2014 and the additional exchanges between the operator and the Authority lead to the following observations:

-the time between the date of production of the study and that of its operation does not call into question the relevance of the results put forward by the operator, no substantial change in the process of collection-concentration having been Recorded in this interval;
-the elements provided by the operator relating to the methodology and operation of the survey data do not suggest the existence of biases that can significantly alter the relevance of the results ;
-the new allocation of PPDC concentration loads as well as The introduction of new indexes for the distribution of PPDC and PDC charges on products leads to a more reliable allocation of the costs of the collection-concentration process.

The effect of these new rules on the costs of Different products have been examined: the inclusion of these indexes reduces the costs allocated to the products and industrial products and increases those allocated to the products followed (registered letter and declared value) and to those of direct marketing The universal service (as a result of taking account of post office deposits). The low weight of the collection-concentration in the attributable costs of the products, however, leads to a limited overall impact on the total costs of each category of products whether or not they are part of the universal
. Analyses that the indexes obtained by the studies of La Poste reflect satisfactorily the operational reality of the operator and that their use in the allocation of costs is therefore preferable to the current situation. However, an update of these indexes will be required in case of process evolution (significant organizational change, deployment of new types of preparatory sorting machines).

II.2. On amounts for pre-retirement devices

II. -2.a. Current processing

La Poste has put in place pre-retirement schemes for civil servants and, in some cases, contract staff. The aim of these schemes is to gradually reduce the working time of officers approaching the legal retirement age, with a reduction in their remuneration and the payment of compensation at the time of retirement. These arrangements, proposed to civil servants and/or employees between 56 and 58 years of age, are between 6 and 31 December 2012. (6).
The staff costs recorded in the accounting system correspond to the remuneration received regardless of the Status of the employee, whether or not he or she is in business. The pre-retirement arrangements are undeniably translated into allowances and retreats:

-when an agent enters the device, the provisions are the subject of appropriations corresponding to the remuneration of the time not Worked throughout the period of the device as well as the allowance paid at the time of retirement;
-for the duration of the presence of the agent in the device, recoveries are made on the provisions; they finance the Compensation for the unworked portion. The sum of the recoveries is normally equal to the initial allocation made for each agent.

As of today, there is no harmonized treatment of allocations and recoveries related to pre-retirement devices in the accounts. In the case of the sign, management of the activities carried out at the points of contact of the network open to the public of La Poste (post offices and partner points), these amounts are isolated and considered as charges " Non-attributable " (7) goods and services; in the case of mail, package and financial services, these charges are not isolated. This treatment does not appear satisfactory in two respects: (i) it does not carry out a direct analysis of the origin of those costs within the meaning of Article 14 of Directive 97 /67/EC as amended on 15 December 1997; (ii) it mixes, from an accounting point of view, The means implemented for production activities with resources dedicated to non-performing devices.

II. -2.b. New rules

The new rules are designed to identify and allocate the amounts for La Poste pre-retirement devices on the basis of relevant inducers, and to restrict the allocation of personnel costs to costs Attributable to the only amounts corresponding to an activity time:

-the endowments correspond to the financing of the future unworked time earnings. They shall not be assimilated to the means of production implemented in a given year and shall, as such, be isolated from the costs of the various production processes attributable to the products. Therefore, it is necessary to identify and isolate them by occupation, and then to allocate them to the non-attributable expenses;
-the recoveries finance, for a given year, the unworked time pay. They must be identified and deducted from salary costs in order to have a total remuneration load reflecting the productive apparatus of La Poste for the financial year in question. It is therefore necessary that these recoveries be identified by trade, then allocated to the charges attributable in proportion to the charges (direct and indirect) of the remuneration of staff already allocated.
-certain adjustments on the Pre-retirement provision (8) may cover recoveries. Where appropriate, the amounts concerned shall be allocated on the non-attributable charges in order not to change the share of the salary costs of the means of production implemented and allocated to the attributable costs.

The effect of These new rules (changes in the allocation of collection costs-concentration and amounts relating to end-of-career devices) on the costs of different products were examined. The ARCEP noted that these developments do not significantly alter the costs attributable to different benefits.

Item 1

Starting in the 2013 fiscal year, the unit cost indexes used for the allocation of collection charges in the PPDC and For the mass of shipments in CDP are those mentioned in Annex 1 to this Decision.

Article 2

Starting in the financial year 2013, The allocation of personnel costs to attributable costs is Restricted to amounts corresponding to a period of activity. Other personnel expenses are taken into account in the non-attributable costs of the regulatory accounting.

Item 3

The Director General of the Regulatory Authority for Electronic Communications and posts shall be responsible for the implementation of this Decision, which shall be notified to La Poste and published in the Official Journal of the French Republic and on the website of The Authority.