Locum doctor in France: status, BNC and 2026 tax return
Licence, fee retrocession, CARMF, RSPM, micro-BNC or form 2035: our practical guidance to secure your locum doctor status and your 2026 tax return without social or tax surprises.
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. A locum doctor works as an independent self-employed professional, earns fee retrocessions taxed as BNC income, and contributes to URSSAF and CARMF. Below EUR 83,600 of receipts (2026 threshold), micro-BNC applies a flat 34% allowance.
You are starting out as a locum, or you have been taking assignments for months without really setting your framework. A locum doctor is not a disguised employee: the activity is genuinely self-employed, fees are retroceded, and you alone carry the social and tax obligations. That is exactly where the errors we most often correct arise: confusion over social status, a forgotten CARMF affiliation, the wrong tax regime chosen in the first year.
This article focuses on the situation specific to locums. For the overview of an established physician, see our complete accountant's guide for the self-employed doctor and our support for doctors. If you are considering a dedicated structure, see instead the move from BNC to a SELARL for a doctor.
The locum doctor status: self-employed, not salaried#
A locum doctor temporarily replaces an absent colleague. Legally, the activity is independent. The locum is never the employee of the replaced doctor, even if assignments recur. This independence then drives the entire social and tax treatment.
The pay takes the form of a fee retrocession. In practice, the replaced doctor collects patient fees, then pays a share to the locum at the rate set in the contract. The locum issues a retrocession note to the replaced doctor.
- For the locum, these amounts are BNC receipts (non-commercial profits).
- For the replaced doctor, the retrocession paid is deducted from their own receipts.
The contractual sector follows a simple rule that is often overlooked: during the assignment, the locum applies the sector (1 or 2) of the replaced doctor, not their own sector choice.
Qualified or not: registration or replacement licence#
The authorisation to practise depends on your academic situation.
| Situation | Formality with the Ordre | Basis |
|---|---|---|
| Qualified doctor (medical doctorate) | Registration with the Ordre des médecins | Public Health Code |
| Non-qualified student or intern | Replacement licence issued by the departmental council of the Ordre | Art. L. 4131-2 of the Public Health Code |
To obtain the licence, the intern must have completed the full 2nd cycle of medical studies and a number of 3rd-cycle semesters set according to the specialty. In all cases, the written replacement contract must be sent to the departmental council of the Ordre.
Taxation: BNC income, two possible regimes#
Your retrocessions are non-commercial profits. Two regimes coexist, and the right choice depends mainly on the actual level of your professional expenses.
| Criterion | Micro-BNC (special declarative regime) | Controlled declaration (form 2035) |
|---|---|---|
| Receipts threshold | <= EUR 83,600 (2026 threshold) | No cap; mandatory above the threshold |
| Professional expenses | Flat 34% allowance (minimum EUR 305) | Actual expenses deductible |
| Filing | Form 2042-C-PRO | Form 2035, then carried to 2042-C-PRO |
| Best for | Low actual expenses, start of activity | Significant actual expenses (travel, equipment, contributions) |
The allowance mechanism is detailed in our article on the way the micro-BNC regime works. For the real-regime mechanics, see how to complete the 2035 return under the real regime.
A useful update: the 25% surcharge that once hit those who did not join an approved management organisation is abolished as from the taxation of 2023 income. Joining an AGA is therefore no longer a tax necessity, even if it retains other benefits.
Trade-off: micro-BNC or controlled declaration?#
The 34% micro-BNC allowance is a flat estimate of your expenses. The logic is simple: if your actual expenses exceed 34% of your receipts, the controlled declaration on form 2035 is in principle more favourable; if they stay below, micro-BNC keeps things simple while protecting your taxable result.
For a locum who travels a lot (mileage, accommodation, equipment, deductible social contributions), the 34% threshold is often crossed faster than expected. We recommend pricing your actual expenses from the first year rather than defaulting to micro-BNC, then reviewing each year.
VAT: exempt care#
Personal care provided for a therapeutic purpose is exempt from VAT under article 261, 4, 1° of the General Tax Code. For a locum doctor performing care procedures, this means:
- no VAT to charge on care fee retrocessions;
- no deductible VAT on your professional purchases.
Procedures without a therapeutic purpose (non-therapeutic aesthetic medicine, for example) are taxable, but this situation remains marginal for a locum. The sector detail appears in our article on VAT and invoicing for doctors in 2026.
Social contributions: self-employed status, URSSAF and CARMF#
This is the most often underestimated part. The locum doctor is a self-employed worker. The locum is excluded from the micro-entrepreneur regime (auto-entrepreneur), because doctors fall under the Public Health Code and CARMF, not Cipav or the social security scheme for the self-employed. You can be on micro-BNC for tax purposes, but never on the micro-social scheme.
Two funds are involved:
- URSSAF: health, family allowances, CSG-CRDS.
- CARMF: basic pension, supplementary pension and the disability-death scheme.
For the general contributions of the self-employed, our article on the social contributions of self-employed workers sets out the common framework.
The RSPM, an option designed for locums#
Since 2020, URSSAF has offered the Simplified Scheme for Medical Professions (RSPM), designed for locum doctors. It simplifies the calculation of URSSAF contributions through an overall rate applied to net fees.
| Net fees bracket | Indicative overall rate (per URSSAF) |
|---|---|
| Up to EUR 19,000 | About 13.50% |
| Portion from EUR 19,000 to EUR 38,000 | About 21.20% on the excess portion |
| Above EUR 38,000 | Switch to the standard practitioners' scheme on the following 1 January |
A flat contribution to CARMF's disability-death scheme (RID) is added. The URSSAF rates must be confirmed each year: we present them here as indicative, per URSSAF.
Our reading#
Three priorities shape a well-kept locum file. First, never confuse micro-BNC with the micro-social scheme: the confusion wrongly suggests the auto-entreprise is open, exposing you to CARMF adjustments. Second, anticipate the social-charges cash flow: in the early years, contributions are reconciled with a delay, and a locum who has spent every retrocession ends up in difficulty. Third, decide the tax regime on real figures, not on an impression.
The underestimated risk#
The most frequent trap we see: the locum who believes they are an auto-entrepreneur. The logic seems coherent (independent activity, modest receipts, fiscal micro-BNC), but it is wrong on the social side. A doctor cannot fall under the micro-social scheme. By wrongly declaring under that regime, they expose themselves to retroactive CARMF affiliation, with a recovery of contributions for the years concerned. The issue sometimes surfaces only at the first pension settlement, several years later.
In practice: the locum's checklist#
- Confirm your right to practise: registration if qualified, replacement licence if not qualified.
- Sign a written replacement contract and send it to the departmental council of the Ordre.
- Declare the start of your self-employed activity and register with URSSAF and CARMF.
- Review the RSPM option with URSSAF if your fees are moderate.
- Issue a retrocession note for each assignment and keep it.
- Track your receipts and professional expenses from the very first euro.
- Compare micro-BNC and the controlled declaration on your real figures before choosing.
- Set aside your social contributions in a dedicated account.
A common case#
A locum doctor recently consulted us after two years of assignments declared under micro-BNC, convinced everything was in order. His receipts stayed below the threshold and he felt protected by the 34% allowance. On reviewing his file, two points stood out: his actual expenses (frequent travel to rural areas, equipment) clearly exceeded 34% of receipts, and above all his CARMF affiliation was incomplete. We reconstructed the social situation, regularised the affiliation, and priced the tax trade-off for the coming years. The lesson: a locum file is framed from the start, not after the fact.
As a chartered accountancy firm registered with the Ordre des experts-comptables and used to supporting healthcare professionals, we see these situations recur. Correcting them early avoids heavy adjustments.
Frequently asked questions
Can a locum doctor be an auto-entrepreneur?+
No. A doctor falls under the Public Health Code and CARMF, not Cipav or the social security scheme for the self-employed. The micro-entrepreneur (micro-social) regime is closed to them. They may, however, fall under micro-BNC for strictly tax purposes, which is a different matter.
How are fee retrocessions taxed?+
Retrocessions received are non-commercial profit (BNC) receipts. Depending on your situation, they fall under micro-BNC with a flat 34% allowance or under the controlled declaration on form 2035 with deductible actual expenses. The locum issues a retrocession note to the replaced doctor for each assignment.
At what threshold do you switch to the controlled declaration on form 2035?+
Micro-BNC applies as long as your receipts do not exceed EUR 83,600 (2026 threshold). Above that, the controlled declaration on form 2035 becomes mandatory. You may also opt voluntarily for form 2035 below this threshold, notably when your actual expenses exceed the flat 34% allowance.
Does a locum doctor charge VAT?+
No, for care procedures. Personal care provided for a therapeutic purpose is exempt from VAT under article 261, 4, 1° of the General Tax Code. No VAT is therefore charged on care retrocessions, and no VAT is deductible on purchases. Only procedures without a therapeutic purpose would be taxable.
What is the RSPM and who can benefit from it?+
The Simplified Scheme for Medical Professions, opened by URSSAF since 2020, simplifies the calculation of a locum doctor's URSSAF contributions. It applies an indicative overall rate of about 13.50% up to EUR 19,000 of net fees, then about 21.20% on the portion from EUR 19,000 to EUR 38,000, before switching to standard rules above.
Is a replacement licence needed to work as a locum?+
A qualified doctor is registered with the Ordre and needs no licence. A non-qualified student or intern must obtain a replacement licence from the departmental council of the Ordre, after completing the full 2nd cycle and a number of 3rd-cycle semesters set according to the specialty, under article L. 4131-2 of the Public Health Code.
Key takeaways#
- A locum doctor works as an independent self-employed professional and earns fee retrocessions taxed as BNC income.
- Qualified: registration with the Ordre; not qualified: replacement licence (art. L. 4131-2 PHC) and a written contract sent to the Ordre.
- Micro-BNC up to EUR 83,600 (34% allowance) or the controlled declaration on form 2035 (actual expenses); the choice depends on your real expenses.
- Care is exempt from VAT (Tax Code art. 261, 4, 1°).
- Self-employed status is mandatory: URSSAF and CARMF, never the micro-social scheme; the RSPM option is available for moderate fees.
Official sources#
- Légifrance, Public Health Code, article L. 4131-2 (replacement, replacement licence)
- Conseil national de l'Ordre des médecins, replacement and replacement licence
- URSSAF, locum doctor and the Simplified Scheme for Medical Professions (RSPM)
- CARMF, locum doctor contributions (pension, disability-death scheme)
- BOFiP, VAT exemption for personal care (Tax Code art. 261, 4, 1°)
- impots.gouv.fr, micro-BNC regime and forms 2035 / 2042-C-PRO
This article informs on the framework applicable to locum doctors in France in 2026. It does not replace an analysis of your personal situation in light of your documents and the law in force. URSSAF contribution rates are indicative and must be confirmed each year. Last updated: 16 June 2026.

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.
- Légifrance : Code de la santé publique, art. L. 4131-2 (remplacement, licence)
- Conseil national de l'Ordre des médecins : remplacement et licence de remplacement
- URSSAF : Médecin remplaçant et Régime simplifié des professions médicales (RSPM)
- CARMF : cotisations du médecin remplaçant (retraite, invalidité-décès)
- BOFiP : Exonération de TVA des soins à la personne (CGI art. 261, 4, 1°)
- service-public.fr : Régime micro-BNC (régime déclaratif spécial)
- impots.gouv.fr : Déclaration 2035 et 2042-C-PRO (BNC)
This topic is part of our service Tax accountant in Paris | CIT, VAT & tax audits
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