Hoguet Law and concierge services: are you really compliant? Easy Concierge helps you prove it
The FNAIM has just published a report shaking up the world of rental concierge services. The message is clear: many concierge services are exceeding their legal scope without knowing it. But beyond the regulatory reminder, a practical question arises: in the event of an inspection, how do you prove that you're operating within the rules?
This article breaks down the FNAIM report from April 2026, explains what the Hoguet Law concretely means for your concierge business, and shows you how Easy Concierge helps you document your compliance — with evidence to back it up.
The essentials at a glance
FNAIM Report
April 2026
Law concerned
Hoguet (1970)
Maximum fine
30,000 EUR + prison
Solution
Easy Concierge
Table of Contents
1. What the FNAIM says (and why it matters to you)
The report published in April 2026 by the French National Real Estate Federation sets the record straight on a subject many preferred to ignore: the Hoguet Law of January 2, 1970 fully applies to concierge services as soon as they go beyond the strict scope of physical service provision.
Critical point: This law is a matter of public policy — it cannot be waived, even with the best contract in the world. No contractual clause, no verbal agreement with the owner can exempt you from your legal obligations.
For the FNAIM, the conclusion is unequivocal: many concierge services routinely carry out activities that fall under regulated property management without holding the required authorizations. And most concerning is that the majority of them do so without even realizing it.
This report is not an attack on concierge services. It is a warning signal for a profession that is structuring itself and needs clear rules to continue developing smoothly. But the message is clear: ignorance of the law protects no one.
2. Hoguet Law: the basics every concierge must know
Law No. 70-9 of January 2, 1970, known as the Hoguet Law, regulates the practice of activities related to certain transactions involving real estate and businesses. In practice, it governs any person or company involved in the management, transaction, or administration of real estate on behalf of others.
T Card (Transaction)
Required for any intermediation activity in the sale or rental of real estate. This includes writing listings, selecting tenants, negotiating, and signing leases.
G Card (Management)
Required for any property management activity: building administration, rent collection, rate setting, financial management on behalf of an owner. This is the card that most concerns concierge services.
Why this matters for you
The line between "service provision" (no card required) and "property management" (card mandatory) is much thinner than most think. A concierge service that adjusts a rate or collects a security deposit check automatically falls within the regulated scope — even if that wasn't the intention.
3. With or without a professional license: the boundary explained
Without a professional license
These activities fall under physical service provision and require no Hoguet license:
- Guest welcome and key handover
- Cleaning and laundry
- Minor repairs and routine maintenance
- Check-in and check-out
- Coordinating contractors (plumber, electrician)
- Property setup (linens, supplies)
- Managing guest reviews (responses)
- Property photography
You remain within the scope of a standard service contract. No license required.
T or G Card mandatory
These activities fall under property management and require a professional license:
- Setting and adjusting rental rates
- Writing and publishing listings
- Tenant selection and screening
- Signing rental contracts
- Collecting rent or charges
- Receiving security deposits (even without cashing them)
- Negotiating with platforms
- Financial management on behalf of the owner
Without a professional license, performing these activities is a criminal offense.
Warning: security deposits are a common pitfall
Even holding a security deposit check without cashing it is considered receipt of funds requiring a G Card. The line is closer than you think. Many concierge services receive deposits "out of habit" or "as a favor" — that's enough to cross into illegal territory.
4. Highly dissuasive penalties
For those who think the risk is theoretical, the FNAIM report reminds us that operating without a license is a criminal offense, not a simple administrative oversight. The penalties are severe and inspections are becoming more frequent.
| Offense | Maximum penalty |
|---|---|
| Illegal practice of real estate intermediation | 6 months imprisonment + 7,500 EUR |
| Handling funds without a G Card | 2 years imprisonment + 30,000 EUR |
| Non-compliance with procedures (Le Meur Law, Nov. 2024) | Civil fine up to 100,000 EUR |
| Lack of professional liability insurance | Activity suspension + fine |
Criminal penalties
Operating without a license is an offense recorded on your criminal record. It can also lead to a ban on conducting any commercial activity.
Civil penalties
Contracts entered into without a license are null and void by operation of law. The owner can claim reimbursement of all commissions paid.
5. The sensitive point: rate management
Among all the "red zones" identified by the FNAIM, one concerns virtually all concierge services: setting and adjusting rates.
Many concierge services adjust prices daily — seasonality, local demand, competition, events... This is yield management, and according to the FNAIM, it falls under regulated property management as soon as the pricing decision is made by the concierge rather than the owner.
In practice, two situations arise:
1. You hold the G Card
You're within your rights, but you must be able to demonstrate your rigor in the event of an audit. A clear history of rate changes and their justifications is essential.
2. You don't hold the G Card
Every rate change must be validated by the owner to remain within the scope of a simple execution mandate. Without proof of this validation, you're in violation.
In both cases, traceability is your best protection. This is exactly why Easy Concierge developed its rate audit trail with owner validation workflow.
6. The Le Meur Law (November 2024): additional tightening
The FNAIM report fits within a broader regulatory context. The Le Meur Law, adopted in November 2024, significantly strengthened the framework for short-term rentals in France.
Mandatory registration
All furnished tourist accommodations must be registered with the local authority. Platforms must verify this number before publication.
Enforceable energy performance certificate
From 2034, properties rated F or G can no longer be rented short-term. The timeline is tightening for energy-inefficient buildings.
Enhanced municipal powers
Local authorities can now limit the number of rental days, impose quotas by neighborhood, and conduct inspections more easily.
Increased penalties
Civil fines can reach 100,000 EUR for non-compliance with registration and declaration procedures.
Key takeaway: The trend is clearly toward stricter regulation. Concierge services that don't anticipate this regulatory evolution are taking an increasing risk. Compliance is no longer optional — it's a matter of business survival.
7. Easy Concierge: a compliance module built for this context
This is exactly the need we addressed by developing the rate audit trail with owner validation workflow, available now in Easy Concierge. This module was designed by a concierge professional, for concierge professionals.
Audit trail
Every rate change is timestamped: who, when, what, IP address. A complete and tamper-proof audit trail.
Owner validation
The owner receives an email notification and validates changes from their account — individually or with one click.
CSV Export
The complete history exports to CSV to build a compliance dossier ready for any inspection.
Activate on demand: True to Easy Concierge's philosophy, this module is disabled by default. Each concierge service activates it based on their needs and regulatory situation. No unnecessary overhead — immediate protection for those who enable it.
8. How the audit trail works in practice
The concierge modifies a rate
Nightly rate, weekly rate, guest surcharge, cleaning fee... The change is logged in the journal with the previous rate, the new rate, the operator's identity, and their IP address. Nothing escapes tracking.
The owner is notified
A delayed email (15-minute buffer to batch changes) is sent to the owner with a secure link to their validation dashboard. No spam: changes are intelligently grouped.
The owner validates
From their account, they review the proposed changes and validate them — one by one or via the "Validate All" button with one click. Simple, fast, accessible even for non-tech-savvy owners.
The history is archived
Everything is tracked and exportable as CSV. In the event of an inspection, you produce a complete dossier: proof of proposal, proof of validation, timestamps, identity. An irrefutable record.
9. In the event of an inspection: the difference is stark
Without a dedicated tool
- Word against word with the owner
- No proof the owner approved the rates
- No history of changes
- No decision traceability
- Maximum legal risk
- Intense stress and improvisation
Likely outcome: fine + contract nullification
With Easy Concierge
- Complete and tamper-proof audit trail
- Proof that each change was proposed (not imposed)
- Timestamped owner validation
- CSV dossier exportable for the inspector or lawyer
- End-to-end traceability
- Total peace of mind during inspections
Outcome: demonstrated compliance, protected business
10. Professionalization: an opportunity, not a constraint
The FNAIM report may seem alarming, but it should be read differently: it's an opportunity for differentiation for concierge services that embrace transparency.
Property owners are increasingly informed
They know that entrusting their property to a non-compliant manager exposes them as well. An informed owner will always choose the concierge service that can demonstrate its rigor — with evidence to back it up.
A real competitive advantage
A concierge service that can show its audit trail, owner validations, and compliance history has an undeniable commercial advantage over those operating by the seat of their pants.
Trust as a growth lever
Regulatory transparency is not a cost — it's an investment in the owner relationship. The best-performing concierge services in 2026 are those that have made compliance a selling point.
"Easy Concierge was built by a concierge professional, for concierge professionals. Every feature addresses a real-world need. The rate compliance module is a perfect example: born from a regulatory reality, designed for simple daily use."
11. FAQ: the most frequently asked questions
Q.I'm a sole proprietor running a concierge service. Does the Hoguet Law apply to me?
A. Yes, your legal status is irrelevant. What matters is the nature of the activity you perform. If you set rates, collect rent, or manage deposits on behalf of an owner, you're covered — whether you're a sole proprietor, LLC, or corporation.
Q.My owner gave me power of attorney to manage rates. Is that enough?
A. No. A power of attorney does not replace the G Card. The Hoguet Law is a matter of public policy: no contractual agreement can circumvent the requirement to hold a professional license. However, if the owner validates each rate change (as Easy Concierge enables), you remain within the scope of an execution mandate.
Q.I only do Airbnb, not traditional rentals. Does the Hoguet Law still apply?
A. Absolutely. The Hoguet Law makes no distinction between short-term and traditional rentals. As soon as you're involved in managing real estate on behalf of a third party, you fall within its scope — whether on Airbnb, Booking, Abritel, or direct bookings.
Q.How do I obtain the G Card?
A. The G Card (property management) is requested from the CCI (Chamber of Commerce) in your department. Requirements: demonstrate professional aptitude (degree or experience), have a financial guarantee, and hold professional liability insurance. The process typically takes 2 to 4 weeks.
Q.Does Easy Concierge exempt me from needing the G Card?
A. No, Easy Concierge is not a substitute for the professional license. However, for concierge services without a G Card, the owner validation module proves that each pricing decision comes from the owner — keeping you within the legal framework of an execution mandate. For concierge services with a G Card, the audit trail provides the traceability required in the event of an inspection.
Q.How much does the compliance module cost?
A. The rate audit trail is included in the Easy Concierge subscription. No extra charge. You activate it when you need it, deactivate it when you don't.
Q.Is my audit data secure?
A. Yes. All data is encrypted, hosted in France, and GDPR-compliant. The history is tamper-proof: once recorded, an audit entry cannot be modified or deleted — that's what gives it its evidentiary value.
Hoguet compliance checklist for your concierge service
Use this list to assess your current situation. Each unchecked item represents a potential risk.
Protect your concierge service with Easy Concierge
Rate audit trail, owner validation, CSV export — everything you need to demonstrate your Hoguet compliance is already in Easy Concierge.
Tamper-proof audit
Every action tracked
Owner validation
With one click
CSV Export
Dossier ready for inspection
In summary
The FNAIM report of April 2026 is not bad news — it's an accelerator of professionalization for the concierge industry. Concierge services that get compliant now are taking a head start.
Don't let an inspection decide the future of your concierge service
Join the professionals who plan ahead. Easy Concierge gives you the evidence you need — before anyone asks for it.
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