Architect fees, VAT and stage-based accounting in France (2026)
2026 guide to accounting for architecture practices in France: stage-based revenue recognition (MOP phases), 20% VAT on all architectural fees, decennial liability insurance obligations, and the BNC versus corporate structure decision — with worked examples and a VAT threshold of EUR 37,500 for services.
Expert note: This article was written by our chartered accountancy firm. Information is current as of 2026. For a personalised review of your situation, contact us.
Quick answer. Architectural fees are subject to standard 20% VAT (no exemption or reduced rate exists). Accounting-wise, an MOP (maîtrise d'ouvrage publique — public project ownership framework) engagement breaks into defined phases (ESQ, APS, APD, PRO, ACT, etc.), and revenue must be recognised on a stage-of-completion basis under French GAAP — whether the practice operates as a sole practitioner (BNC — bénéfices non commerciaux, or non-commercial income) or through an architect corporation, with mandatory registration at the Ordre des architectes (Architects' Order).
2026 context#
An architecture practice in France operates within a tightly regulated framework: practice as a sole professional (BNC) or through an architect company (SA, SARL, SAS, SELARL), mandatory registration at the Ordre des architectes, decennial liability insurance, and engagement-level accounting broken into phases following either the loi MOP (public-sector standard) or private contracts modelled on the same standard.
In 2026, fundamentals are unchanged: 20% VAT on fees, micro-BNC (micro-BNC — simplified non-commercial income regime) threshold at EUR 83,600 (34% flat-rate deduction), and the franchise en base de TVA (VAT exemption threshold) at EUR 37,500 for service activities. The legal structure choice — BNC versus a corporate entity — does, however, shape the tax and accounting regime in a material way.
A recent client case illustrates the point well: a principal of a small practice came to us to set up engagement-level accounting for the first time. Their core challenge was how to allocate fees and project costs (travel, design iterations, tender support) to the correct contract phase — which made the need for a disciplined work-in-progress discipline immediately clear.
Stage-based revenue recognition: MOP phases#
At the heart of architecture practice lies the decomposition of each engagement into phases, following the French public works framework established by Law n° 85-704 of 12 July 1985 on maîtrise d'ouvrage publique (public-sector project ownership), codified in the Code de la commande publique at Articles L2431-1 et seq. and R2431-1 et seq.
While the loi MOP formally governs public contracts, it has become the reference for private-sector architecture engagements as well. The standard phases are:
| Phase | Acronym | Content | Typical fee weighting |
|---|---|---|---|
| Preliminary study | ESQ | Site feasibility and outline concept | 5–10% |
| Diagnostic | DIAG | Existing-building survey (where applicable) | 5–10% |
| Schematic design | APS | Massing and cost framework | 10–15% |
| Design development | APD | Detailed drawings and dimensioning | 15–20% |
| Construction documents (permit package) | PRO | Full planning-permission file | 15–20% |
| Procurement support | ACT | Contractor tendering | 5% |
| Construction administration | DET | Site supervision (meetings, inspections) | 10–15% |
| Certification | VISA/EXE | Compliance of construction vs. drawings | 5% |
| Scheduling and co-ordination | OPC | General site co-ordination | 5–10% |
| Acceptance assistance | AOR | Handover and snagging | 5% |
Accounting treatment: each completed phase generates one or more progress billings (interim invoices) and recognised revenue. Partially completed phases at period-end must be carried as work-in-progress (account 333 under the Plan Comptable Général — French GAAP chart of accounts).
Worked example: EUR 50,000 engagement (ex-VAT)#
- Schematic design (ESQ) signed off in January: EUR 5,000 invoiced and recognised as service revenue.
- Design development (APS) in progress, February: engineering quotes issued; 30% of the phase completed = EUR 2,000 recognised in work-in-progress (account 333).
- Construction documents (APD) completed mid-March: EUR 8,000 invoiced; EUR 10,000 had already been billed on account; the balance is reconciled by recognising the remainder pro-rata to completion percentage.
No revenue should be recognised until the service is substantively rendered. This demands rigorous internal project tracking and documented milestone sign-offs.
VAT on architectural fees in 2026#
Standard rate 20% — no exemption#
Architecture is not a care or education service. It falls under the standard 20% VAT rate regardless of entity type (sole practitioner, SAS, SARL). No reduced rate applies in 2026.
Taxable services include:
- preliminary and feasibility studies;
- architectural design;
- planning-permission application package;
- site supervision and construction administration;
- all other architecture consulting and advisory work.
Input VAT recovery: once the practice is VAT-registered (above the EUR 37,500 threshold), input VAT may be recovered on:
- travel and subsistence expenses;
- 3D modelling and visualisation;
- office rent;
- professional conference registration fees (provided there is a direct link to chargeable work).
VAT exemption threshold: EUR 37,500#
If the practice's annual revenue remains below EUR 37,500 ex-VAT:
- No VAT is charged to clients (the invoiced amount is the final, all-inclusive price).
- No input VAT is recoverable (costs are carried at their gross, VAT-inclusive amount).
This is advantageous for very small or newly established practices but rapidly becomes a constraint once revenue approaches the threshold.
Legal structure: BNC vs. architect corporation#
Sole practice (BNC — non-commercial income)#
An architect may practise independently as a sole professional:
- Mandatory registration on the regional roll of the Ordre des architectes (Law n° 77-2, Art. 9).
- Tax regime: BNC with two sub-options:
- Micro-BNC: revenue below EUR 83,600; 34% flat-rate deduction applied to gross receipts (minimum deduction EUR 305).
- Controlled-return filing (BNC accrual basis): above EUR 83,600, or by election below that threshold; full liasse fiscale Form 2035.
- Social contributions: self-employed professional regime (CIPAV), approximately 25–35% of profit depending on income level.
- No VAT in micro-BNC (below EUR 37,500 — no VAT to invoice or to recover).
Worked example: sole-practitioner architect, EUR 60,000 annual revenue.
- Regime: micro-BNC.
- Taxable income: 60,000 × (100% − 34%) = EUR 39,600.
- Social contributions (CIPAV): approximately 30% × 39,600 ≈ EUR 11,900.
- VAT: franchise threshold applies — no VAT invoiced, none recovered.
Corporate practice (SA, SARL, SAS, SELARL)#
Law n° 77-2 of 3 January 1977 on architecture requires that more than half of the share capital and voting rights be held by architects (Article 13 of the law). This effectively mandates a shared directorship or co-management structure.
- Tax regime: Impôt sur les sociétés (IS) — corporate income tax at 15% on profit up to EUR 42,500 (reduced rate), then 25% above that ceiling.
- VAT: mandatory from incorporation onwards (no exemption threshold available).
- Director/shareholder social contributions: self-employed professional (TNS — travailleur non salarié) scheme.
- Accounting: full accrual basis (liasse fiscale Form 2033, or simplified micro-company format if revenue is below EUR 450,000).
Note: SELARLs (Sociétés d'Exercice Libéral à Responsabilité Limitée — professional limited liability companies for regulated professions) are a frequent choice for architecture practices; they combine personal asset protection with professional-practice status.
Mandatory decennial liability insurance#
Legal requirement (1977 Law, Art. 16)#
Every architect must carry decennial liability insurance covering their builder's liability. This is a prerequisite to practice and to signing construction contracts (Law n° 77-2, Art. 16; insurance obligation under the Code des assurances, Art. L241-1; presumption of builder's liability, Code civil, Art. 1792).
The client (maître d'ouvrage — building owner) separately subscribes a dommages-ouvrage (builder's all-risk) policy on their own behalf (Code des assurances, Art. L242-1).
Accounting treatment#
- Annual premium: operating expense — account 616 "Insurance premiums" or account 606 "Miscellaneous purchased services".
- Accruals treatment: if the premium covers January to December 2026 but the fiscal year closes on 30 June, the proportion covering July–December must be deferred as a prepaid expense (compte de charges constatées d'avance — account 486, balance-sheet asset).
- No recoverable VAT: insurance premiums bear the taxe sur les conventions d'assurance (TSCA — insurance premium tax), not VAT. TSCA is never recoverable as input tax.
Annual attestation#
The architect must submit a decennial insurance certificate each year to the regional Architects' Council (conseil régional de l'Ordre des architectes) — this is a critical document for maintaining registration.
Invoicing and client contracts#
Mandatory invoice content#
- Identity of the service provider (architect or firm);
- SIRET registration number;
- Invoice number and date;
- Detailed description: "Architectural services — Phase [ESQ / APS / …]";
- Amount ex-VAT and applicable VAT rate (20%, or "Franchise en base de TVA — VAT threshold applies");
- Payment terms and due date;
- Reference to the contract or project.
Phase-based progress billing#
Standard practice is to raise a deposit invoice at the start of each phase (e.g. 50% of the estimated phase fee) and a final invoice on completion. The accounting treatment is:
- The deposit received is provisionally credited to "Client advances" (account 409 "Clients — advance receipts").
- As the work is performed, the balance is reclassified to revenue (account 706 or 707 depending on the nature of the service) and the advance payable is reduced.
This requires detailed, phase-by-phase contract tracking.
Special situations in 2026#
Architect operating as a micro-entrepreneur (auto-entrepreneur)#
The auto-entrepreneur (micro-entreprise — simplified self-employment regime) status does not legally exist for architecture: Ordre registration is mandatory and incompatible with that status. In practice, an architect operates either:
- under micro-BNC (EUR 83,600 threshold, 34% deduction) — a simplified regime, but always BNC;
- via a corporate structure (which must satisfy the architect-capital requirement).
Subcontracting or joint-venture with an engineering firm (BET)#
An architect may engage a bureau d'études techniques (BET — structural, mechanical or thermal engineering firm) for specialist calculations:
- Subcontractor invoice: the BET invoices the architect at 20% VAT.
- Client invoice: the architect may pass through the BET cost as a separate line item or include it in the global fee.
- Reverse-charge VAT: subcontracted construction works fall under reverse-charge (TVA autoliquidée — VAT borne by the principal, CGI Art. 283, 2 nonies). An architect's intellectual design and supervisory services are generally outside this reverse-charge mechanism — verify on a case-by-case basis with your chartered accountant (expert-comptable).
Foreign partner or foreign firm#
A practice with foreign partners or foreign capital must respect the French ownership lock (capital and voting rights > 50% held by registered architects). Non-compliance results in refusal of registration at the Ordre.
Watch-outs in 2026#
Mistake 1 — Recognising the full contract at signature#
Do not invoice the entire contract value at the point of signing. Revenue must be spread across phases and recognised only as work is completed.
Mistake 2 — Ignoring work-in-progress#
A phase that is 50% complete must appear in account 333 (work-in-progress) and must not be fully recognised as revenue. Omitting this step overstates profit and creates exposure on tax review.
Mistake 3 — Lapsing on the decennial insurance attestation#
Allowing the certificate to lapse carries the risk of suspension from the Ordre roll and immediate contractual incapacity — you cannot legally sign construction contracts.
Mistake 4 — Mishandling VAT under the threshold#
Below EUR 37,500, you do not charge VAT — but you also may not recover it on your own costs (expenses remain at their gross, VAT-inclusive amount). Confusing the two directions creates a costly accounting error.
Mistake 5 — Conflating BNC and corporate-entity accounting#
A micro-BNC cannot recover VAT and uses simplified bookkeeping. A corporate entity is subject, from day one, to full VAT and the complete liasse fiscale (Form 2033). The choice must be made clearly before setting up the practice.
Our view as your chartered accountant#
Architecture is a profession that places unusually demanding accounting obligations on practitioners. Unlike an IT contractor or a generalist consultant, an architect manages three overlapping compliance responsibilities simultaneously: regulatory (the Ordre), insurance (décennale), and accounting (phases, revenue recognition, work-in-progress).
The most common difficulty we encounter in client files: phase-by-phase project tracking. A practice that fails to link its accounting to the actual milestones of each project finds itself, at year-end, unable to justify how it has spread revenue across periods. The Direction Générale des Finances Publiques (DGFiP — the French tax authority) does not accept vague estimates: a revenue item misallocated by one financial year can trigger multi-year reassessments and late-payment surcharges.
At Hayot Expertise, we have helped several small architecture practices migrate to genuinely project-oriented accounting, using either an Excel model or a cloud-tool integration (Pennylane, Qonto) that tracks phase progress and generates work-in-progress entries automatically.
VAT registration is frequently a point of no return: the moment an architect's revenue crosses EUR 37,500 ex-VAT, 20% VAT becomes mandatory on all fees. This is a significant fiscal decision that should be anticipated at least six months before the threshold is reached.
Hayot Expertise recommendation. From the first day of practice, invest in a standard engagement template that sets out each phase explicitly with indicative dates and fee weightings. Ask your chartered accountant to configure a chart of accounts that includes dedicated work-in-progress accounts (account 333 properly isolated per project). Document every completed phase — client sign-off record, interim invoice, evidence of completion percentage — and reconcile your monthly accounting with your project diary. Above all, renew your decennial insurance attestation before the expiry date: a single day's lapse makes you immediately non-contractual.
Frequently asked questions
As a micro-BNC architect, can I recover input VAT?+
No. Below EUR 37,500 of revenue, you operate under the franchise en base de TVA (VAT exemption threshold): you do not charge VAT to clients, and you cannot recover it on your own costs either. All expenses are carried at their gross, VAT-inclusive price.
Does a progress-billing invoice count as recognised revenue?+
Only partially. The advance payment received is initially credited to "Clients — advance receipts" (compte clients, avances reçues). It becomes recognised revenue progressively, as each phase is performed and validated. This makes precise, milestone-by-milestone project tracking essential.
How long must decennial liability insurance cover an architect?+
Ten years from the date of works acceptance (date du procès-verbal de réception — date of the practical completion certificate). This is a statutory obligation and a prerequisite for maintaining registration on the Ordre roll.
Can an architect practise under the auto-entrepreneur regime?+
No. The micro-entrepreneur (auto-entrepreneur) regime is not legally open to regulated professions such as architecture. An architect must operate either under micro-BNC (34% flat-rate deduction on receipts up to EUR 83,600) or through a properly constituted architect corporation registered with the Ordre.
How should incomplete phases be treated at year-end?+
Use account 333 (travaux en cours — work-in-progress) to record the proportion of each phase completed but not yet invoiced. At the closing date, this account must reflect the actual percentage completion of every active engagement.
Should BET (engineering firm) costs be re-invoiced to the client?+
This depends on the contract. If you quoted a global fee that absorbed BET costs, re-invoicing is not required. If you are billing on a cost-plus or pass-through basis, yes. The correct approach should be defined explicitly in the engagement letter at the outset.
Can a foreign architect operate a practice in France through a foreign entity?+
No. Only a professional or firm registered with a regional French Architects' Council (conseil régional de l'Ordre des architectes) may practise architecture in France. A foreign entity must comply with French law and obtain the relevant Ordre registration.
Is office rent deductible under the BNC accrual regime?+
Yes. Office rent is a deductible operating expense and is recorded in account 613 "Locations" (leases). Under micro-BNC, however, the 34% flat-rate deduction replaces all claims for actual expenses — no individual deduction for rent is available.
Key takeaways#
-
20% VAT on all architectural fees — no reduced rate or exemption in 2026. Micro-BNC practices below EUR 37,500 operate under the franchise en base de TVA and neither charge nor recover VAT.
-
Stage-based revenue recognition (ESQ, APS, APD, PRO, DET, etc.) per French GAAP and the MOP standard. Work-in-progress (account 333) must be reflected at every period-end closing.
-
Legal structure: BNC or corporate entity (capital and voting rights must be ≥ 50% architect-held). Micro-BNC (34% deduction, EUR 83,600 ceiling) versus corporate (IS at 15% up to EUR 42,500 then 25%, mandatory VAT from day one).
-
Mandatory decennial liability insurance covering ten years from works acceptance. Annual attestation to the regional Architects' Council is non-negotiable.
-
Phase-based progress billing with clear documentation of milestones (client sign-off, completion percentage). Engagement tracking is the foundation of compliant accounting.
Sources and official references#
- BOFiP — VAT on professional services (architecture)
- Légifrance — Law n° 85-704 of 12 July 1985 on public-sector project ownership (maîtrise d'ouvrage publique)
- Code de la commande publique — Articles L2431-1 and R2431-1 (MOP phases)
- Légifrance — Law n° 77-2 of 3 January 1977 on architecture
- service-public.fr — franchise en base de TVA 2026
- Légifrance — Code des assurances, Art. L241-1 and L242-1 (decennial liability)
- ANC — Règlement 2014-03 (Plan Comptable Général — French GAAP)

Article written by Samuel HAYOT
Chartered Accountant, registered with the Institute of Chartered Accountants.
Regulated French accounting and audit firm based in Paris 8, built to support companies across France with a digital and decision-oriented approach.
Sources
Official and operational sources cited for this page.
- BOFiP — TVA sur les prestations libérales (architecture)
- Légifrance — Loi n° 85-704 du 12 juillet 1985 relative à la maîtrise d'ouvrage publique
- Code de la commande publique — Articles L2431-1 et R2431-1 (phases de mission)
- Légifrance — Loi n° 77-2 du 3 janvier 1977 sur l'architecture
- service-public.fr — Franchise en base de TVA 2026
- Légifrance — Code de l'assurance art. L241-1 et L242-1 (assurance décennale)
- ANC — Règlement 2014-03 (Plan comptable général, méthode à l'avancement)
This topic is part of our service Tax accountant in Paris | CIT, VAT & tax audits
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