Opposability of the Lease to the Buyer
A lease is opposable to the buyer — and therefore automatically transferred to them — if one of three conditions is met: the lease was made by authentic deed; a private-deed lease has acquired a date certaine (achieved for example by registration, by reference in a notarial act or court order, or by the death of a party); or the buyer had knowledge of the lease and accepted it at the time of purchase. If no date certaine exists and the buyer had no knowledge, the buyer may seek the tenant’s expulsion (Cass. com., 18 April 1951). Art. 1743 is not a public-order rule — the buyer can expressly or tacitly waive the absence of a date certaine and agree to execute the lease (Cass. 3e civ., 17 September 2008).
Once the lease is opposable, the sale automatically transfers it to the buyer, who must fulfil all future landlord obligations and can invoke the lease against the tenant. However, the buyer cannot invoke pre-sale tenant breaches not pursued beyond the sale (Cass. 3e civ., 10 November 2009). If a breach continues after the sale, the buyer can act for the entire period. The buyer may also rely on a clause résolutoire for a pre-sale situation persisting after the sale (Cass. 3e civ., 13 November 1979).
Subrogation of the Buyer
The parties may provide in the sale deed that the seller’s rights arising from the lease are ceded to the buyer, enabling pursuit of pre-sale breaches or arrears. Subrogation must be express (Cass. 3e civ., 2 October 2002). The seller’s obligations cannot be transferred to the buyer without the tenant’s express acceptance: a seller condemned before the sale to carry out works remains personally liable after it — that obligation does not pass to the buyer through a subrogation clause alone (Cass. 3e civ., 21 February 2019; Cass. 3e civ., 23 January 2020).
Side Agreements: Opposability to the Buyer
The automatic transfer of Art. 1743 covers only the lease itself. Agreements made outside the lease between the original landlord and tenant — rent reductions, subletting authorisations, tacit permitted use changes, works authorisations — are only opposable to the buyer if they had a date certaine at the time of the sale or if the buyer had knowledge of them. The burden of proof lies on the tenant (Cass. 3e civ., 20 July 1989; Cass. 3e civ., 17 November 1998; Cass. 3e civ., 29 September 2009). All such side agreements should be registered to acquire date certaine.
The Tenant’s Statutory Pre-emption Right
Article L. 145-46-1 C. com. (Pinel law; applicable to promises and sales from 18 December 2014: Cass. 3e civ., 12 November 2020) gives the commercial tenant a first right of purchase on a voluntary sale of the premises. The right is public-order: contractual derogations are unenforceable (Cass. 3e civ., 28 June 2018).
Exclusions from the Pre-emption Right
The right does not apply to: sale of an entire building comprising commercial premises; single simultaneous sale of several premises in a commercial ensemble; sale of one unit to a co-owner of a commercial ensemble; sale to the landlord’s spouse, direct ancestors or descendants (or their spouses); forced sales by auction; court-authorised amicable sales in insolvency proceedings (Cass. 3e civ., 17 May 2018; Cass. com., 23 March 2022; Cass. 3e civ., 15 February 2023); or sales by court-ordered auction in mortgage enforcement proceedings (Cass. 3e civ., 30 November 2023). The right does not cover non-sale transfers: contributions in kind, long-term leases, donations, splits of usufruct and bare ownership, or death transmissions. A tenant who received a notice to quit with refusal of renewal loses the pre-emption right (CA Paris, 25 January 2024).
The landlord must notify the tenant before any step that commits the property to a buyer — before instructing an agent on a selling mandate, before signing any conditional promise, and certainly before any binding sale agreement. Notification after a bilateral promise of sale has been executed is too late: the right is extinguished. Courts apply the residential pre-emption case law by analogy and take a strict approach to the timing obligation.
The Seller’s Retained Personal Obligations
While the lease itself passes to the buyer, three obligations remain personal to the original seller regardless of any subrogation clause in the sale deed:
| Obligation | Who bears it after sale? | Key rules |
|---|---|---|
| Eviction indemnity | Original landlord (seller) | Personal debt of the landlord who served the refusal notice; does not transfer to buyer (Cass. 3e civ., 10 December 1997). Buyer’s options: right of repentance (buyer holds this right after sale) or pay indemnity to obtain vacant possession. Notice carries over to buyer (Cass. 3e civ., 15 March 1989). |
| Security deposit | Original landlord (seller) | Personal debt arising from receipt of the deposit; does not transfer to buyer (Cass. 3e civ., 28 June 2018). Transfer in sale deed inopposable to tenant without tenant’s express acceptance. Buyer may not require a fresh deposit without proving the original was returned (CA Paris, 6 June 2001). |
| Suretyship (guaranty) | Buyer (automatically) | Transmits automatically to buyer as an accessory of the rent claim ceded on sale (Cass. ass. plén., 6 December 2004). Stops only if the guarantee instrument expressly provides that the sale terminates the guarantee. |
A buyer who acquires a property where the seller has already served a refusal notice has limited options. The evicted tenant retains the right to stay until the indemnity is paid in full (Art. L. 145-28). The buyer therefore faces an occupied property and two choices: exercise the right of repentance — which only the buyer holds after the sale — and thereby offer renewal, avoiding the indemnity; or pay the indemnity (recoverable from the seller as a personal debt) to obtain vacant possession. Structuring the sale price to reflect a withheld indemnity reserve is therefore essential where a refusal notice is already outstanding at the date of sale.
Rescission of the Sale
If the sale is rescinded, the original landlord is restored to their position as owner and landlord, and the eviction indemnity obligation reverts to them from any arrangement made in the sale deed. Rents collected by the buyer are returned to the seller, who in turn must return the sale price (Cass. 3e civ., 29 June 2005).
Whether you are structuring the sale of an investment property with a sitting commercial tenant, advising a buyer on the pre-emption right exposure, or acting for a tenant notified of a proposed sale, we advise on all aspects of the transaction and its impact on the lease.
Book a ConsultationLegal Notice. This article is for general information and educational purposes only. It does not constitute legal advice. Laws and regulations may have changed since publication. Always seek qualified French legal advice on the sale of a commercially leased property in France.
Key Legal References
Lease transferred automatically to buyer when opposable: authentic deed, date certaine, or buyer’s knowledge at time of sale; buyer steps into landlord’s shoes for future obligations
Subrogation of buyer in seller’s lease rights must be express; does not transfer seller’s obligations to buyer without tenant’s acceptance
Seller’s obligation to carry out works does not transfer to buyer through a subrogation clause alone
Tenant’s statutory pre-emption right: public-order; applies to voluntary sales from 18 December 2014; landlord must notify by RAR before any sale step; price and conditions stated on pain of nullity; one-month acceptance; two/four months to complete
Pre-emption right is public-order; contractual derogations are unenforceable
Art. L. 145-46-1 applies to promises and sales from 18 December 2014
Bilateral (synallagmatic) promise of sale constitutes a sale; subsequent attempt by tenant to exercise the pre-emption right is ineffective
Landlord may specify estate agent’s fee in the pre-emption notification provided it is made clear the fee is not at the tenant’s expense
Sales by court-ordered auction in mortgage enforcement proceedings are outside the scope of the tenant’s pre-emption right
Court-authorised amicable sales in insolvency proceedings are outside the scope of the tenant’s pre-emption right
Eviction indemnity is a personal debt of the landlord who served the refusal notice; does not transfer to buyer on sale of the property; buyer cannot be jointly and severally liable merely by virtue of the purchase
Tenant retains right to remain in occupation until eviction indemnity is paid in full; right opposable to building purchaser
Security deposit is a personal debt of the original landlord (arising from receipt, not lease end); does not transfer automatically to buyer on sale
Contractual transfer of security deposit in sale deed is inopposable to tenant without tenant’s express acceptance
Suretyship transmits automatically to buyer as an accessory of the rent claim ceded on sale
On rescission of the sale, rents collected by the buyer are returned to the seller who in turn returns the sale price; eviction indemnity obligation reverts to original landlord
