The Debtor and Creditor of the Indemnity
Building sale after notice: the selling landlord remains the debtor — not the buyer — unless the sale agreement expressly transfers the obligation (Cass. 3e civ., 13 Sept. 2011).
Split ownership: only the usufructuary is the debtor, since they can refuse renewal without the bare owner's agreement (Cass. 3e civ., 19 Dec. 2019).
Registered creditors: creditors have no statutory right over the eviction indemnity — but can obtain an attachment (saisie-attribution) over the sequestered funds.
The Chronological Sequence (Arts. L. 145-29 & L. 145-30)
The Sequester
Payment directly to the tenant gives the landlord no guarantee of obtaining the premises within the three-month window. A sequester provides that guarantee by linking release of the funds to actual key handover and fulfilment of exit conditions. The sequester can be appointed by agreement between the parties, by the court judgment fixing the indemnity, or subsequently by requête (the last route carries risk). Always request sequester appointment in the original claim proceedings.
The three-month departure clock and the 1% per day penalty mechanism only work if the sequestered amount covers the entire indemnity, including all accessories and accrued interest. Where certain components (notably redundancy payments which may not be fixed at the time of the judgment) remain undetermined, the full sequester deposit cannot be made, and therefore the departure deadline cannot be triggered. Landlords who want a clean exit date need all indemnity components fixed before attempting to start the clock (Cass. 3e civ., 19 October 2022, n° 21-16.055).
Key Handover and Exit Conditions
The premises must be returned empty of all furniture and occupants. A handover with furniture remaining on-site is not a valid restitution (Cass. 3e civ., 4 February 1986). Where the landlord accepts the keys without expressing any reservation and a bailiff's record confirms only minor residual items, the tenant has been held to have restituted (Cass. 3e civ., 2 February 2000). The landlord should always inspect on handover and note any reservations formally.
If there is a dispute over exit repairs, this does not entitle the landlord to delay payment of the indemnity — the sequester cannot retain funds on that account. The landlord's remedy for disputed exit repairs is a saisie conservatoire over the sequestered indemnity (CA Versailles, 6 October 2010). The parties can contractually agree that the tenant must carry out exit repairs before handing back the keys — this is enforceable as the Art. L. 145-29 provisions are not mandatory (Cass. 3e civ., 6 March 1985).
The 1% Per Day Penalty
This penalty operates automatically through the sequester and is not a conventional penalty clause: the court cannot moderate it and the referral judge cannot suspend it (CA Paris, 7 January 1983). The conditions for it to run are strict: a sequester must be in place; the full indemnity including interest must have been deposited; a formal notice must have been served on the tenant at the expiry of the three-month period; and the delay must be attributable to the tenant. Force majeure or the landlord's own conduct can delay the start of the penalty. For hotel operators who cannot vacate because administrative authorities are refusing to assist with the eviction of residential occupants, courts have held the penalty cannot run (Cass. 3e civ., 13 September 2018).
Interest on the Indemnity
Interest on the indemnity begins to run from a date fixed at the court's discretion under Article 1231-7 of the Civil Code: courts have fixed the start date variously at the date of the summons, the date of the first instance judgment, or the date of the Court of Appeal ruling. The financial return on the sequestered indemnity during the period between deposit and release belongs to the tenant (Cass. 3e civ., 3 December 2003). Payment of the indemnity directly, or notification of deposit to the sequester, stops the accrual of moratoire interest from that date.
Recovery of Indemnities Where Tenant Does Not Relocate
Where the tenant, having received the accessory indemnities tied to relocation costs, ultimately does not relocate, the landlord can bring a claim for recovery of those sums. The Court of Cassation confirmed this in 2019: accessory indemnities for transfer duties, commercial disruption, and removal costs paid in anticipation of a relocation that did not occur can be reclaimed (Cass. 3e civ., 28 March 2019, n° 17-17.501). The res judicata of the original judgment does not prevent this claim because the subsequent non-relocation is a new factual development.
- Debtor: the landlord who served the refusal notice. Building sale after the notice does not transfer the obligation unless the sale agreement expressly says so (Cass. 3e civ., 13 Sept. 2011). Usufruct: only the usufructuary owes the indemnity (Cass. 3e civ., 19 Dec. 2019). Creditor: the tenant or later assignee of the fonds — the right passes with the business.
- Sequence (Arts. L. 145-29 & L. 145-30): 15-day repentance window → payment or deposit + notification → 3-month departure window → key handover / fund release → 1% per day penalty after formal notice at month-end. Always request sequester appointment in the original proceedings.
- Full deposit required (Cass. 3e civ., 19 Oct. 2022, n° 21-16.055): the entire indemnity including all accessories and accrued interest must be deposited before the 3-month clock and the 1% penalty can start. Undetermined components (e.g. redundancy costs) block the mechanism — landlords must have all components fixed before attempting to trigger the departure deadline.
- Key handover: premises must be empty; landlord should inspect on handover and note reservations formally. Disputed exit repairs do not entitle the landlord to delay payment — remedy is saisie conservatoire over sequestered indemnity. Financial returns on sequestered funds belong to the tenant.
- 1% penalty: not a penalty clause — court cannot reduce it; referral judge cannot suspend it. Must have: sequester in place; full indemnity deposited; formal notice served after 3-month window expires; delay attributable to the tenant. Cannot run where eviction is blocked by administrative authority (Cass. 3e civ., 13 Sept. 2018).
- Non-relocation recovery (Cass. 3e civ., 28 March 2019): where the tenant received accessory indemnities for a relocation that did not occur, the landlord can reclaim those sums. The res judicata of the original judgment does not prevent this — subsequent non-relocation is a new factual development.
Getting the sequence right is critical: a misstep in timing on either side can have significant financial consequences. We advise landlords and tenants on the payment and restitution procedure, sequester appointments, and the practical steps needed to trigger — or avoid — the 1% daily penalty.
Book a ConsultationThis article is for general information and educational purposes only. It does not constitute legal advice and does not create a lawyer-client relationship. Laws and regulations may have changed since publication. Always seek qualified French legal advice on eviction indemnity payment and restitution procedures.
Key Legal References
Three-month departure window; sequester mechanism; key handover conditions
Formal demand mechanism; 1% per day penalty after default and formal notice
15-day repentance window after judgment becomes res judicata
Building sale after refusal notice: selling landlord remains debtor unless sale agreement transfers obligation
Split ownership: only the usufructuary is the debtor of the eviction indemnity
Indemnity claim passes with the fonds de commerce to the assignee; creditors have no statutory right over it
Full indemnity including accessories and interest must be deposited before the 3-month clock and 1% penalty can start
Financial returns on sequestered indemnity belong to the tenant during the sequester period
1% penalty cannot run where hotel operator cannot vacate due to administrative authorities blocking eviction of residential occupants
Accessory indemnities paid for relocation can be recovered where the tenant ultimately does not relocate; res judicata does not prevent this
