Before 2014: Almost Complete Freedom, With One Important Limit
Before 2014, the allocation of service charges in French commercial leases was almost entirely a matter for the parties’ agreement. Landlords could, and routinely did, pass virtually all charges to the tenant — including property tax, works costs, management fees, and even major structural repairs — provided the lease said so with sufficient clarity (Cass. 3e civ., 18 November 1998). The Court of Cassation confirmed that parties could validly transfer to the tenant even the major structural repairs listed in Art. 606 C. civ., provided they did so explicitly (Cass. 3e civ., 27 November 2002).
There was, however, one judicially developed limit: a charge transfer clause could not be applied to works that, by reason of their scale, amounted to complete reconstruction of part of the building. The total re-roofing of one building in a multi-building complex, for example, fell outside the scope of even the broadest charge clause (Cass. 3e civ., 29 September 2010). Nor could the landlord pass on the cost of works made necessary by structural defects, since to do so would exonerate them from their fundamental delivery obligation (Cass. 3e civ., 9 July 2008).
The Pinel Act: Charges That Can Never Be Passed On
Art. L. 145-40-2 C. com. (Loi n° 2014-626 of 18 June 2014) and Art. R. 145-35 (Décret n° 2014-1317 of 3 November 2014) introduced a mandatory list of charges that cannot be recovered from the tenant regardless of what the lease says. Any clause purporting to pass these charges to the tenant is deemed unwritten, as Art. L. 145-40-2 is a public-order provision under Art. L. 145-15.
| Category | Recoverable? | Key conditions / notes |
|---|---|---|
| Major structural repairs (Art. 606 C. civ.) and associated fees | NO | Includes architects’, engineers’, and other professional fees. Courts apply an expansive definition of Art. 606 repairs (Cass. 3e civ., 17 February 2015). Clear, precise clause required for roof repair (Cass. 3e civ., 16 March 2023). |
| Works to remedy age-related deterioration or achieve regulatory compliance — where they qualify as Art. 606 repairs | NO (with limits) | Only excluded where these works rise to the level of major structural repairs. Compliance works that do not reach that threshold can still be passed on. |
| Beautification works costing more than identical replacement | YES (exception) | Works that go beyond like-for-like replacement and improve the building can be passed on. Key battleground in shopping centre leases. |
| Taxes where the landlord is the legal debtor | NO in principle | The contribution économique territoriale (CET) cannot be passed on. Property tax (taxe foncière) and its additions can be passed on as an exception. Taxes linked to the tenant’s use (e.g. waste collection) can also be passed on. |
| Landlord’s rent management fees | NO | Fees for managing rent collection on the leased premises. Building technical/administrative management fees may still be passed on if not “rent management” fees. Courts watch this distinction carefully (TJ Versailles, 28 June 2023). |
| Charges, taxes, and costs attributable to vacant units or other tenants | NO | In multi-tenant buildings, the landlord cannot dilute vacant unit costs by spreading them across occupied tenants. |
The decree’s formulation on compliance and deterioration works has created real uncertainty. It excludes these works from the tenant only where they qualify as Art. 606 major structural repairs — but courts have long treated compliance and deterioration works as legally distinct categories that do not map neatly onto that divide. If courts maintain that position, the restriction may have limited practical effect. Charges clauses should be drafted explicitly and specifically; do not rely on broad “all charges” language.
Mandatory Disclosure: What the Landlord Must Provide
Art. L. 145-40-2 also introduced mandatory transparency obligations. At conclusion of the lease, and then every three years, the landlord must provide each tenant with:
- A prospective works statement for the following three years with a provisional budget;
- A retrospective works statement covering the preceding three years with costs.
The lease must contain a precise and exhaustive inventory of all categories of charges, taxes, and levies allocated between the parties. The landlord must also send each tenant an annual summary reconciliation statement. In a multi-tenant building, the landlord must inform tenants of any development that may affect the charge allocation between them.
Art. R. 145-36 C. com. (Décret of 3 July 2015) specifies that the annual charge reconciliation must be sent by 30 September of the year following the year concerned. In a co-ownership building, the deadline is three months after the co-ownership accounts are settled. These provisions are of mandatory application.
The mandatory inventory must be precise and exhaustive, not a generic reference to “all charges of whatever nature.” In practice this means listing each category of charge explicitly (property tax, building insurance, elevator maintenance, etc.) and stating whether each is borne by the landlord or the tenant. For multi-tenant buildings, the allocation key for each shared cost should also be stated. A poorly drafted inventory creates disputes at every rent review and at lease end.
Charge Allocation in Multi-Tenant Buildings: Surface-Based, Not Rent-Based
Before 2014, landlords sometimes allocated charges between tenants in proportion to their respective rents rather than floor areas — a practice that produced perverse results where long-standing tenants on lower indexed rents bore a disproportionately smaller share than new tenants paying market rents.
Art. L. 145-40-2 now requires that charge allocation in multi-tenant buildings be based on occupied surface area, not rent levels. The amount of taxes attributable to any tenant corresponds strictly to that tenant’s unit and their proportionate share of the common areas necessary to operate the leased premises. A rent-based allocation key is now contrary to both Art. L. 145-40-2 (surface-based allocation required) and Art. R. 145-35 (no passing on of charges attributable to other tenants). For property tax, in the absence of any co-ownership arrangement, the allocation is made pro rata to occupied surface area (CA Paris, 18 October 2017, n° 15/22813).
Recovering Charges: Provisions and Annual Reconciliation
Actual Cost vs Flat Rate
The standard mechanism is reimbursement at actual cost, with the landlord advancing charges and recovering them on production of supporting documents. A flat-rate mechanism (a fixed percentage of rent representing charges) was historically valid under freedom of contract. Since 2014 it is difficult to justify: any flat rate risks incorporating non-recoverable charge components. Flat-rate arrangements should be renegotiated or audited to confirm every element is in the recoverable category.
Provisions and Annual Reconciliation: Consequences of Failing to Reconcile
The most common mechanism is the advance provision, with a formal annual reconciliation once actual costs are known. The Court of Cassation has held that a landlord who fails to produce an annual reconciliation must repay all provisions received, less only documented charges (Cass. 3e civ., 7 April 2010; Cass. 3e civ., 17 September 2020). The Paris Court of Appeal has gone further: absence of annual reconciliation renders the call for provisions without legal basis, and all provisions must be refunded (CA Paris, 1 June 2022). A Paris first instance court ordered provisional repayment of five years of unreconciled provisions in interim proceedings (TJ Paris, 28 December 2023).
A landlord who has not complied with their obligation to justify charges annually cannot invoke the forfeiture clause against a tenant for non-payment of those charges. The Douai Court of Appeal held that the landlord’s failure to provide annual charge justification was a prior breach that blocked the forfeiture mechanism (CA Douai, 30 March 2023). Keep charge reconciliations up to date, or lose the main enforcement tool.
Prescription: How Long the Parties Have to Act
The action to recover unpaid charges, or to claim repayment of charges paid without justification, is subject to the five-year general limitation period of Art. 2224 C. civ. The two-year commercial limitation period of Art. L. 145-60 does not apply to charge claims. Time runs from the date the parties had knowledge of the final charge reconciliation, not from the date provisions were called or paid (CA Paris, 24 January 2018, n° 16/08577).
Charge disputes are one of the most common sources of commercial lease litigation in France — and one of the most avoidable with the right drafting. We advise landlords and tenants on charge allocation, compliance with Pinel Act obligations, and the recovery of overcharged or unjustified amounts.
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 service charge allocation in a French commercial lease.
Key Legal References
Mandatory charge inventory and disclosure obligations: precise and exhaustive inventory of all charge categories in lease; annual reconciliation by landlord; three-year prospective and retrospective works statements; public-order provision
Non-recoverable charges (exhaustive mandatory list): Art. 606 structural repairs and associated fees; rent management fees; contribution économique territoriale; charges attributable to vacant units or other tenants
Annual charge reconciliation: must be sent to tenants by 30 September of the year following the year concerned; in co-ownership buildings, within 3 months of annual accounts settlement
Art. 606 repairs: expansive definition; courts apply a broad scope to major structural repairs; associated professional fees also non-recoverable
Major roof repair: clear, precise clause required for a tenant to be made to pay; general charges clause insufficient
Works made necessary by structural defects in the building cannot be passed to the tenant; landlord cannot exonerate themselves from their fundamental delivery obligation
Landlord who fails to produce annual charge reconciliation must repay all provisions received, less only documented charges
Confirmation that failure to produce annual reconciliation obliges landlord to repay all provisions; tenant not required to prove individual charges are unjustified
Absence of annual reconciliation renders calls for provisions without legal basis; all provisions must be refunded
Landlord’s failure to provide annual charge justification is a prior breach that blocks the forfeiture clause mechanism for non-payment of charges
Rent management fees distinguished from technical/administrative building management fees; only rent management fees are non-recoverable
Property tax allocation in multi-tenant building without co-ownership arrangement: made pro rata to occupied surface area
Five-year general limitation period applies to charge recovery and repayment claims; not the two-year commercial period of Art. L. 145-60; time runs from date of final reconciliation
Confirmation of five-year prescription for charge repayment claims; prescription runs from date of knowledge of final reconciliation, not from date provisions were paid
