Blog

Concierge companies face fines up to €100,000 — new rules in force since May 2026

by The Anywhere Team

May 26th, 2026




Concierge companies face fines up to €100,000 — new rules in force since May 2026

Since 20 May 2026, the implementing decrees of the Le Meur Law have come into force — and they change everything for short-term rental concierge companies. The "mere service provider" defence is gone: you are now directly liable for the compliance of every property you manage, on the same footing as the property owners themselves. A local authority can take action against you alone, without even involving your client. The maximum fine reaches €100,000 per non-compliant property. Here is what this means in practice for your business — and the steps you need to take immediately.

Since 20 May 2026, every listing published without full compliance directly engages your legal liability.

1. What has changed: the end of the intermediary "legal shield"

Until November 2024, concierge companies enjoyed solid legal protection. France's Court of Cassation (the country's highest civil court) had expressly ruled in 2021 that an intermediary who assisted in an irregular tourist rental was not liable for the civil fine set out in Article L. 651-2 of the French Construction and Housing Code (Code de la construction et de l'habitation). That provision only targeted the landlord directly. In practice, many concierge companies and rental management agencies could therefore avoid the heaviest sanctions, even when they were directly involved in letting out a non-compliant property.

The Le Meur Law of 19 November 2024 brought that era to an end. By creating a new Article L. 651-2-1 of the French Construction and Housing Code, the legislature now makes it possible to sanction any person who assists in an unlawful change of use — that is, converting a residential property into a furnished tourist rental (meublé de tourisme) without the prior authorisation required in regulated areas. The entry into force of the implementing decrees on 20 May 2026 made this regime fully operational.

2. Who is affected: a deliberately broad definition

The law adopts a particularly wide definition of "furnished tourist rental intermediary." Any person — individual or corporate, professional or not — who engages in or assists with the letting of a furnished tourist rental, whether for payment or free of charge, through brokerage, negotiation or the provision of services, is considered an intermediary. This expressly includes: Airbnb-focused concierge companies, estate agencies, rental management firms and property managers acting under a mandate.

One important nuance: for the civil fine specifically linked to assisting an unlawful change of use, the legislature has expressly excluded "the provision of a digital platform." Platforms such as Airbnb or Booking are therefore not exposed to this particular fine. However, concierge companies, agencies and mandataries remain fully exposed to it. This asymmetry is something you need to factor into your risk assessment.

1️⃣
Prior information obligation
Before any property is listed, you must inform the owner of their legal obligations: registration number, and the need for a change-of-use authorisation if the property is a secondary residence in a municipality subject to that requirement. This information must be provided before the listing goes live.
2️⃣
Verification and statutory declaration obligation
Before publishing any listing, you must obtain from the owner a sworn declaration (déclaration sur l'honneur) confirming the property's legal compliance. The Declaloc registration number (France's national short-term rental registration system) must appear on all listings you publish.
3️⃣
Obligation to respond to local authority inquiries
A municipality can send a compliance inquiry directly to you — not just to the property owner. Such a letter requests: the landlord's name, the exact address, the registration number, the status of the property (primary or secondary residence) and the number of nights let. You have one month to respond. Failure to reply, or an incomplete response, can carry serious financial consequences.
Every property under management now requires a complete compliance file before it can be listed.

3. The penalty scale: figures that speak for themselves

The amounts are no longer symbolic. The Le Meur Law doubled the maximum fine for unlawful change of use, raising it from €50,000 to €100,000 per non-compliant property. This fine now applies to intermediaries, concierge companies and mandataries who participated in the irregular rental. Failure to register on Declaloc exposes you to a civil fine of up to €10,000 per property, while a false declaration or use of a fraudulent registration number can be penalised by up to €20,000. Exceeding the maximum number of rental nights (90 or 120 depending on the municipality) is punishable by a fine of up to €15,000 per year.

In Paris, enforcement has intensified sharply since early 2026: more than 900 penalties were issued in 2024 alone. But this is far from a capital-city issue. Suburban municipalities and medium-sized towns now have the same enforcement tools at their disposal — notably the meublés API, which enables them to identify irregularly operated properties and initiate proceedings against all actors in the rental chain, owners and concierge companies alike.

"A concierge company managing 20 non-compliant properties without having verified their status could theoretically face €2 million in cumulative fines. This is no longer an abstract risk — it is the new reality of direct legal liability."

Editorial reformulation of the legal stakes

What this means for concierge companies: your compliance checklist

Audit your portfolio property by property. For each property under management, check: is the Declaloc registration number valid and displayed on all listings? Is the property a primary or secondary residence? If it is a secondary residence in a municipality subject to change-of-use authorisation requirements (Paris, Lyon, Bordeaux, Marseille and other cities with more than 200,000 inhabitants, among others), has that authorisation been obtained and finalised?

Update your management mandate agreements. Your mandates must now explicitly incorporate the new legal obligations. Include a clause requiring the owner to provide all compliance documentation (registration number, valid energy performance certificate (DPE), change-of-use authorisation where applicable). Obtain a signed sworn declaration before any listing goes live.

Check the applicable rental night cap for each municipality. Paris, Lyon, Bordeaux and several other cities have passed local resolutions reducing the maximum number of nights a primary residence may be rented out to 90 per year (versus the default 120-night limit). Verify the rules municipality by municipality for each property, and put a system in place to track the night counter. Exceeding this threshold can cost the owner up to €15,000 in annual fines — and your concierge company can be named as a co-defendant.

Prepare for local authority inspections. Build a compliance file for each property now: copy of the registration number, valid energy performance certificate, proof of the property's status, number of nights let. If a municipality sends you a compliance inquiry, you have exactly one month to respond. Anywhere's Online Check-in also supports this obligation by automating guest registration and identity document collection — providing valuable traceability evidence in the event of an inspection.

Check the rules of each co-ownership (condominium) building. Since 19 March 2026, the Constitutional Council has validated the right of co-ownership associations (copropriétés) to ban furnished tourist rentals (secondary residences) by a two-thirds majority vote. If any property you manage is in a co-owned building, check whether a recent general meeting has passed such a resolution. A property banned by its co-ownership cannot be let for tourist purposes.

What this means for property owners: your role in the liability chain

If you use a concierge company, be aware that its involvement does not remove your own liability. The law provides that the various actors can be sued jointly or separately. You remain in the front line for the most serious sanctions, including the €100,000 fine for unlawful change of use. The priority step: register your property on Declaloc if you have not already done so, and send the 13-digit registration number to your concierge company so it can display it on all your listings.

If your property is a secondary residence in an area subject to change-of-use authorisation requirements, make sure that authorisation has been obtained and is still valid. Do not assume that because your concierge company is publishing the listing, everything is in order: since 20 May 2026, it is obliged to inform you of this requirement — but it is your responsibility to obtain and maintain compliance. In the event of an inspection, a non-compliant property exposes you to a fine of up to €100,000, plus potential daily penalty payments.

In major cities, every property let without a change-of-use authorisation is now a direct legal risk for the concierge company managing it.

Key takeaways

⚖️
Direct liability since 20 May 2026
Concierge companies can no longer rely on a "mere service provider" defence. They are now directly actionable by local authorities for any involvement in an irregular rental — alongside the property owner, or alone.
💰
Up to €100,000 per non-compliant property
The maximum fine for unlawful change of use has been doubled and now applies to intermediaries. Additional penalties include: €10,000 for failure to register, €20,000 for a false registration number, and €15,000 for exceeding the maximum rental night cap.
📋
Three key obligations for concierge companies
Prior information to the owner about their legal obligations; verification and collection of the Declaloc registration number before any listing is published; mandatory response to local authority compliance inquiries within one month.
🏠
Co-ownership buildings: a new risk to monitor
Since March 2026, co-ownership associations can ban furnished tourist rentals (secondary residences) by a two-thirds majority vote. Check recent general meeting resolutions for every co-owned property in your portfolio.
📅
A challenge that raises the value of your profession
These new obligations increase the demand for professional guidance. Concierge companies that master the regulatory framework become indispensable strategic partners for property owners who cannot navigate this administrative complexity alone.
Sources · Derhy Avocat, "Conciergeries : nouvelles obligations et sanctions avec la loi Le Meur en 2026" (May 2026) · Law no. 2024-1039 of 19 November 2024 (Le Meur Law), French Official Journal of 20 November 2024 · Decree no. 2026-196 of 19 March 2026 establishing the national Declaloc online registration service · French Tourism Code, Art. L. 324-2-1 · French Construction and Housing Code, Art. L. 651-2 and L. 651-2-1 · Constitutional Council, decision no. 2025-1186 QPC of 19 March 2026 ·

This article is a summary provided for information purposes only and does not constitute legal advice. If you are uncertain about your specific situation, please consult a specialist lawyer.


← Back to blog