T, G or S: Which Endorsement Does Your French Property Business Need?

“I need a T licence.” The phrase turns up in every agency start-up plan, and it is usually imprecise. The French estate agency licence is not a single title: it is a document that carries endorsements (mentions), and each one opens a specific scope of activity. A missing endorsement means a prohibited activity. Here is how to tell them apart.

The five Hoguet endorsements

Law no. 70-9 of 2 January 1970 reserves to licence holders all brokerage and management operations relating to the property and business assets of others. The application form, Cerfa no. 15312, lists the available endorsements.

“Transactions on property and business assets” — the T licence. The most requested one. It covers acting as intermediary for the sale, purchase, letting or subletting of built and unbuilt property, as well as operations on business assets (fonds de commerce). It is the licence of the sales agency, and of letting.

“Property management” — the G licence. It covers managing property on behalf of its owners: collecting rents, reconciling service charges, overseeing works, dealing with tenants, accounting to the landlord. It is the licence of the administrateur de biens.

“Block management” — the S licence. It covers administering buildings in co-ownership: convening and running general meetings, implementing decisions, managing the common budget, maintaining the building. It is the licence of the syndic de copropriété.

“List seller” (marchand de listes). A narrowly defined activity: selling prospective tenants or buyers lists or files of available properties. It does not overlap with transactions and has its own rules.

“Tourism services”. It covers Hoguet-law operations in the tourism field, notably the letting of furnished holiday accommodation carried out professionally on behalf of others.

Where the line runs between T and G

This is the most frequent confusion, and it has a direct consequence on the application.

The transactions endorsement covers the act of intermediation: introducing parties, showing properties, negotiating, having a lease or preliminary sale contract signed. The mandate ends with the deal.

The management endorsement covers the relationship that then continues: the management mandate, rent collection, accounting to the owner.

An agency that finds a tenant for a landlord, hands over the keys and stops there stays within transactions. The same agency that then collects the rent every month enters property management — and needs the matching endorsement.

That boundary carries a second effect, often discovered too late: the financial guarantee. It is only required where the professional receives or holds client money, but its €110,000 minimum is assessed per activity carried out. A T + G agency that handles funds in both scopes therefore does not reason on a single amount. The mechanism is detailed in our article on obtaining the estate agency licence.

Combining endorsements: possible, but not free

A single holder can carry several endorsements on one licence: T and G, T and S, all three. Combination is the ordinary situation of a full-service practice.

It is not automatic, though. Each endorsement requires its own conditions to be met: professional aptitude, professional indemnity insurance, and a financial guarantee as soon as client money is handled within the scope concerned.

An endorsement can be added during the licence’s validity, at the territorial chamber of commerce and industry of the registered office, with the matching evidence and the fee set by the CCI. An agency therefore need not wait for the three-year expiry to broaden its activity — but neither may it start trading in the new scope before the endorsement is granted.

The objects-clause trap

One mismatch turns up regularly in refused applications: the company’s articles mention an activity the licence does not cover, or the reverse.

The practical rule fits in a sentence: the objects clause, the licence endorsements and the activity actually carried out must describe the same thing. A company whose objects are limited to transactions cannot be granted a management endorsement without first amending its articles, and an agency doing block management without the S endorsement exposes itself to article 14 of the Hoguet law — six months’ imprisonment and a €7,500 fine for unlicensed practice.

Why the split is so strict

The compartmentalisation can look pedantic. It answers a market reality: service quality degrades where entry into the trade is not controlled. Panle Jia Barwick and Parag Pathak, in “The Costs of Free Entry: An Empirical Study of Real Estate Agents in Greater Boston”, published in 2015 in the RAND Journal of Economics, study a brokerage market with fixed commissions and low entry barriers and show that mass agent entry reduces average service quality (see the study).

Each endorsement corresponds to a distinct skill set and a distinct risk: the block manager handles co-ownership funds and carries responsibility for a collective building; the property manager holds rents and deposits; the sales agent affects the validity of a preliminary contract. The split is the regulatory translation of those differences.

How to decide, in practice

Three questions frame an application.

1. What will you invoice? A brokerage commission on a sale or a letting, monthly management fees, block-management fees voted at a general meeting: each points to an endorsement.
2. Will you hold client money? If so, in which scope? The answer determines the financial guarantee to arrange, per activity carried out.
3. Where will you be in three years? Adding an endorsement later is possible, but each addition means a fresh CCI filing and fresh evidence. Better to frame the objects clause broadly from the start.

Written down before the articles of association are drafted, those three answers head off most of the back-and-forth with the chamber of commerce.

One further check is worth building into the same exercise: whether each planned activity actually falls inside the Hoguet law at all. Selling your own portfolio, dealing in property on your own account, or running a purely editorial listings website are outside the reserved field and call for no endorsement — while an apparently marginal service, such as taking a holding deposit on behalf of a landlord, pulls the agency straight into the financial-guarantee regime. Mapping activities against endorsements is therefore also a way of deciding which services you do not want to offer.

Take action

List your future fee streams, attach each to an endorsement, then check that your articles cover all of them before incorporation. Our full profile of the French estate agency licence details the conditions attaching to each endorsement, and our article on professional aptitude explains how to evidence your qualification level.