Concierge Companies & the Hoguet Law: Are You (Really) Compliant When Handling Client Funds?

Plenty of concierge business managers handle funds on an owner’s behalf without realizing they’re under the Hoguet Law (the 1970 French law regulating real estate professionals), and the criminal risk that comes with it. Here’s what the law requires, and how to stay on the right side of it legally without holding your own carte G (the French property management license).

The invisible risk of handling client funds

Plenty of concierge business managers operate with a sword hanging over their heads and don’t know it. That’s exactly what carte G delegation secures, without you holding the license yourself.

The common (and illegal) practice: The tenant pays the concierge company, the concierge company keeps its commission and sends the rest to the owner.

The problem: Under the Hoguet Law, as soon as you collect funds on behalf of a third party (the owner), you’re carrying on the business of a real estate agent. That requires a Carte G (Gestion, or property management), specific insurance and, whenever the financial guarantor requires it, a dedicated account for client funds. Breaking this rule is punishable by a €30,000 fine and a ban from practicing.

Why the carte G is a nightmare for concierge companies

Getting your own carte G is an obstacle course:

1. Degree or experience: You often need a two-year real estate degree or 3 to 10 years of experience.

2. Financial guarantee: It’s expensive and hard to get for young companies.

3. Accounting audit: Managing the dedicated account for client funds, which the financial guarantor requires, is heavily monitored and administratively burdensome.

Many therefore choose to stay “under the radar,” but that’s a risky strategy that keeps you from scaling with peace of mind and from signing big mandates.

Technology in the service of the law

There’s a legal alternative that doesn’t require you to get your own carte G: split payment.

The point isn’t to get around the law, but to change how the money flows. If the tenant’s money never touches your bank account, you aren’t “handling” funds. You’re no longer a financial intermediary, just a technology service provider.

How Unlocker makes you 100% compliant

Unlocker was built around this legal problem. We turn a criminal risk into a competitive advantage.

How Unlocker’s split payment works

1. Tenant payment: The funds land in a secure payment account (ring-fenced).

2. Automatic split: As soon as the money comes in, Unlocker separates the owner’s share from your concierge commission.

3. Direct payout: The owner receives their net amount, and you receive your fee.

4. Carte G delegation: For leases (a mobility lease, or bail mobilité, which is a 1-to-10-month furnished lease with no deposit, or a Civil Code lease, which is governed by the general rules of the French Civil Code rather than the 1989 residential tenancy law), you use our own carte G as a partner, which gives you legal cover on drafting the contracts.

The result: You sleep well, and your owners are reassured by a financial structure worthy of a bank.

Automating your compliance

Compliance shouldn’t hold back your growth. With Unlocker, you go from a “small concierge company” to a real estate fintech held to the highest standards in the market.

Ready to secure your business today? See how split payment protects you from this risk.

Related reading

• Concierge Company Without a Carte G: How to Offer Long-Term Rentals
• Concierge Companies and Real Estate Licenses: The Complete Guide
• Long-Term Rentals Without a Carte G: The Legal Trick