Concierge Companies and Real Estate Professional Licenses: How to Operate Legally Without a Carte T or G (Complete Guide)

Want to diversify your concierge company’s services and handle more of your clients’ requests? This guide shows you clearly what you can do without a real estate professional license, what will require a carte T (the French real estate transaction license) or a carte G (the French property management license), the concrete risks, and the options for staying 100% compliant. Without holding the license yourself, carte G delegation gives you that legal framework.
Short-term rentals are now worth more than €43 billion a year in France, with 2 million active listings and 300 million nights booked every year, according to Airbnb. Long-term rentals, for their part, account for nearly 12 million rentals a month, for an estimated €120 billion a year in business volume (source: INSEE and the Ministry of Housing).
Rental demand has never been stronger, and owners want to outsource as much management as possible. That’s a huge opportunity for concierge companies like yours that want to go beyond cleaning and check-in. But you may not have a carte T or carte G (yet), the famous licenses that govern every transaction and rental management activity in France, and without them the law sharply limits what you can do.
That’s exactly where Unlocker comes in. Thanks to our carte T and carte G delegation, you can operate fully legally, without bearing the administrative and financial burdens that the Hoguet Law (the 1970 French law regulating real estate professionals) imposes. Read more in our Hoguet Law compliance guide.
Carte T, carte G: what’s the difference?
Before getting into delegation, you need to understand what each license allows. Both come from the 1970 Hoguet Law, which governs any real estate activity carried out on behalf of others.
In plain terms
- The carte T (real estate transactions) covers marketing and brokerage activities: connecting parties, publishing listings, negotiating, concluding leases or sales.
- The carte G (rental management) covers management and collection activities: rent, security deposits, property management mandates, property administration.
Depending on the services you offer, you may be affected by one, the other… or both.
| Type of activity | Carte T | Carte G | With Unlocker’s offer |
|---|---|---|---|
| Publishing listings on your website | Yes | Yes | Yes |
| Advertising or negotiating a rental for an owner | Yes | No | Yes |
| Signing a rental contract or lease in the owner’s name | Yes | Yes | Yes |
| Collecting rent and security deposits | No | Yes | Yes |
| Managing a bank account in the owner’s name | No | Yes | Yes |
| Signing property management mandates | No | Yes | Yes |
| Handling inspection reports, maintenance, check-in/out | Yes (if mandated) | Yes | Yes |
| Offering ancillary services (cleaning, shuttle…) | Yes | Yes | Yes |
| Handling real estate transactions or sales | Yes | No | Yes |
| Managing the day-to-day tenant relationship | Partial (depending on the contract) | Yes | Yes |
| Benefiting from the mandatory financial guarantee | Yes | Yes | Yes |
What to remember
The carte G lets you manage and collect, the carte T lets you market and contract, and the two together give you access to the entire rental and transaction chain. That’s exactly the combination Unlocker makes available to you through its professional license delegation, so you can offer all of these services legally.
What you risk as a concierge company (and what you can do legally)
If you manage properties on behalf of owners, you’re potentially subject to the Hoguet Law: it governs any real estate activity carried out for others on a regular basis, and it makes no distinction between a real estate agent and a concierge company. As soon as you take part in a transaction or handle funds for an owner, you fall within the scope of the law and must hold a carte T or carte G (issued by the chamber of commerce and industry), or go through a delegation.
What brings your concierge company within the scope of the Hoguet Law
| Type of activity | Subject to the Hoguet Law? | License required |
|---|---|---|
| Publishing listings on your own website | Yes | Carte T or G |
| Negotiating a lease or a price on an owner’s behalf | Yes | Carte T or G |
| Signing a rental contract in the owner’s name | Yes | Carte G |
| Collecting the owner’s rent, deposits or commissions | Yes | Carte G |
| Signing a property management mandate | Yes | Carte G |
| Managing Airbnb listings as a “co-host” in the owner’s name | No | None (if money flows directly to the owner) |
| Check-in/out, cleaning, maintenance, welcoming guests, laundry | No | None |
| Advising the owner on pricing, photos, strategy | No | None |
| Collecting payment for your own extra services (extra cleaning, welcome basket, shuttle) | No | None |
Short-term rental activities are affected too
Even for seasonal rentals (Airbnb, Booking, Abritel…), the Hoguet Law applies as soon as you broker deals or collect money for a third party:
- If you publish listings on Airbnb in your own name, that’s an activity that falls under the carte T.
- If you collect guest payments and pay them out to the owner, that’s an activity that falls under the carte G.
- If you simply act as a co-host (the platform pays the owner directly and you invoice your service separately), you’re outside the scope of the Hoguet Law, so you’re legally fine.
What you risk if you’re not compliant
| Type of risk | Consequence | Legal reference |
|---|---|---|
| Illegal practice of a real estate activity | Up to a €7,500 fine and 6 months in prison | Article 14 of the Hoguet Law |
| Nullity of signed contracts | A judge can cancel the contracts you’ve entered into | Case law |
| Repayment of commissions received | The owner can claim back the amounts collected | Settled case law |
| Ban from practicing | Temporary suspension or ban from operating | DGCCRF / CCI |
Without a license, you can handle on-the-ground operations (welcoming guests, cleaning, maintenance), advise and optimize, or sell your own ancillary services. But you can’t publish listings in your own name, collect money on the owner’s behalf, or sign or negotiate a lease on someone else’s behalf. That’s precisely why Unlocker offers carte G delegation for seasonal rentals, as well as carte T delegation, to secure these gray areas.
The advantage of professional license delegation for your owner clients
People often talk about professional licenses as if they only matter to concierge companies. In reality, owners are the first to be affected: if they entrust their property to a concierge company that holds no license (and isn’t covered by a delegation), they’re exposed to risks too.
The risks for the owner
| Risk | Potential consequence | Explanation |
|---|---|---|
| Invalid contract | The mandate or contract signed may be ruled void | If the concierge company acts without a license, the contracts become legally fragile |
| No financial guarantee | Rent and security deposits aren’t protected | In a dispute, the owner has no recourse |
| Shared liability | The owner can be held jointly liable for the offense | By entrusting their property to an unauthorized concierge company, they can be treated as an accomplice to illegal practice |
| Tax risk | The tax authorities can reclassify the income or the money flows | Especially if rent passes through undeclared or unregulated accounts |
Why choose a regulated concierge company
An owner who works with a concierge company operating under Unlocker’s delegation knows that rent and deposits are regulated and traced by an approved company holding both the carte T and carte G, that contracts are signed in the name of an authorized professional, and that money flows are secured through dedicated IBANs, with no commingling of funds.
In plain terms for your concierge company
Position yourself as a trusted partner, not just a service provider. When you work under Unlocker’s delegation, you can reassure your clients about the safety of their funds, the validity of their contracts and the full traceability of money flows, and above all about your ability to manage everything legally without exposing them to risk. It’s a powerful sales argument for convincing an owner to entrust you with all their properties.
Compliance, your best growth lever
A real estate professional license isn’t just an administrative burden: it’s what separates an amateur concierge company from one that can scale without risk. Thanks to Unlocker’s delegation, you can access everything the Hoguet Law governs (signing, collecting, managing, publishing listings…) without needing your own carte T or carte G, whether you manage short-term or long-term rentals, and whatever your status: concierge company or real estate agency.
Once the delegation is in place, one point remains that you shouldn’t neglect: knowing which of the property management mandate, the partnership agreement or the service agreement you need each owner to sign.
- Loi n° 70-9 du 2 janvier 1970 (loi Hoguet), article 1er (activités visées) — verified on September 26, 2026
- Loi n° 70-9 du 2 janvier 1970 (loi Hoguet), article 3 (carte professionnelle délivrée par la CCI) — verified on September 26, 2026
- Loi n° 70-9 du 2 janvier 1970 (loi Hoguet), article 14 (sanctions de l'exercice illégal) — verified on September 26, 2026
- Décret n° 72-678 du 20 juillet 1972, article 30 (garantie financière d'au moins 110 000 €, Légifrance) — verified on September 26, 2026
Rachel Stehlin has been Legal Services Manager at Unlocker since September 2022. A lawyer by training, with a master's degree in law from the University of Haute-Alsace, she spent more than 13 years as a court-appointed delegate for the protection of adults under guardianship. At Unlocker, she handles legal questions around rental management and the carte G (the French property management license).
Frequently asked questions
Can a concierge company operate without a carte T or G (the French real estate transaction and property management licenses)?
Yes for welcoming guests, cleaning, maintenance or advice. No as soon as it publishes listings in its own name, negotiates a lease or collects rent on an owner's behalf: those activities fall under the Hoguet Law (the 1970 French law regulating real estate professionals) and require a carte T or G, or a delegation.
What is carte G delegation?
It's an agreement under which a company that already holds the carte G, like Unlocker, legally carries the property management mandates and rent collection for a concierge company that has no license of its own.
What does a concierge company risk if it operates without a real estate professional license?
Up to 6 months in prison and a €7,500 fine for illegal practice, plus the nullity of the contracts it signed and repayment of the commissions it received, under Article 14 of the Hoguet Law.
Do the carte G and the carte T cover the same activities?
No. The carte T covers transactions (publishing listings, negotiating, connecting parties), while the carte G covers management and collection (rent, security deposits, property management mandates). Some activities, like signing a lease, require one or the other depending on the context.
Is being an Airbnb co-host enough to stay outside the scope of the Hoguet Law?
Only if guest payments go directly to the owner and you invoice your service separately. As soon as you collect the money yourself and pay it out afterward, you fall within the scope of the carte G.
Carte G: The Complete Guide for Concierge Companies
Hoguet Law, how it works, contracts, costs and FAQ in a single guide.
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Delegation is activated in 48 to 72 hours per property.



