Project manager (maître d'œuvre): billing, subcontracting and liability (2026 guide)

Quick answer. A project manager (maître d'œuvre) bills fees for an intellectual service, subject to VAT at the standard 20% rate, and not to the construction reverse charge, which applies only to subcontracted building works (article 283, 2 nonies of the French General Tax Code). The project manager carries ten-year (décennale) liability under articles 1792 and following of the Civil Code and must hold insurance from the start of the worksite (article L241-1 of the Insurance Code). Fees are most often billed by progress stages.

The project manager designs, coordinates and supervises a construction project on behalf of the building owner. The role blends intellectual work — design, studies, site supervision, acceptance — with heavy liability, since the project manager answers for defects for ten years. From an accounting and tax standpoint, three questions recur constantly: how to bill fees correctly, how to frame subcontracting without exposure, and which insurance to take out.

At Hayot Expertise, we support project management firms, architects and construction businesses. The most common confusion concerns VAT: a project manager is not a works contractor, and the billing regime differs significantly. This guide clarifies each point, with references.

Project management fees remunerate an intellectual service. They are usually calculated as a percentage of the estimated cost of works (the engagement rate) or as a fixed fee, then spread across the phases of the engagement. In public contracts of the loi MOP type (Law no. 85-704 of 12 July 1985, now codified in the Public Procurement Code), these phases are standardised: preliminary sketch, preliminary and detailed design, project, assistance with works contracts, supervision of works execution, assistance with acceptance operations. Private contracts use equivalent phases.

Progress billing means issuing periodic statements as the engagement actually advances:

1. Set a fee schedule tied to the engagement phases and the worksite timetable.
2. At each milestone, measure the actual progress of your service (not the progress of the contractors' works).
3. Issue a statement showing cumulative fees earned, less statements already invoiced.
4. Recognise revenue on a percentage-of-completion basis and book any unearned advance as deferred income.

This approach smooths cash flow and secures revenue recognition. Anticipate e-invoicing for 2026-2027: receiving electronic invoices becomes mandatory for all businesses on 1 September 2026.

When a project manager or a company entrusts part of its service to a third party, Law no. 75-1334 of 31 December 1975 applies. It protects the subcontractor and sets several obligations:

• Acceptance and approval (article 3). The main contractor must have each subcontractor accepted and its payment terms approved by the building owner. Otherwise, it cannot rely on the subcontracting agreement.
• Direct payment in public contracts (article 6). The accepted subcontractor is paid directly by the building owner for the part it performs, except where that part is below 600 euros.
• Direct action and guarantees in private contracts (articles 12 to 14). An unpaid subcontractor may act directly against the building owner one month after an unanswered formal notice. The main contractor must provide either a personal joint guarantee from an approved institution or a payment delegation.
• Void clauses (articles 7 and 15). Any waiver of direct payment or direct action is deemed unwritten.

For independents working as subcontractors, we detail the pitfalls in our articles on the sole trader and subcontracting and on common accounting mistakes in construction.

This is the most misunderstood point. Project management is an intellectual service: its fees are subject to VAT at the standard 20% rate, billed normally by the project manager. The construction reverse charge (article 283, 2 nonies of the General Tax Code) applies only to subcontracted construction works: there, the taxable customer accounts for the VAT, and the subcontractor invoices net of tax with the wording "Autoliquidation" (reverse charge). Project management, technical study and architect engagements are expressly excluded.

If you handle both fees and subcontracted works, the two regimes coexist on separate lines. For the rules specific to subcontracted works, see our dedicated guide on subcontracting invoicing and VAT reverse charge; sector tax specifics appear in the construction tax regime.

The project manager is a constructor within the meaning of the Civil Code. As such, it carries ten-year liability and must be insured.

Article L241-1 of the Insurance Code requires anyone whose ten-year liability may be engaged to prove, from the opening of the worksite, that they hold cover. As a firm registered with the French Institute of Chartered Accountants and statutory auditors, we systematically check, when reviewing a project manager's accounts, that insurance certificates match the period and nature of the engagements.

• Project manager under the micro-enterprise regime. The micro regime remains possible for a fee-based activity, but it removes neither the ten-year insurance nor the constructor's liability. Watch the VAT franchise threshold (37,500 euros for services in 2026): above it, invoicing switches to 20% VAT.
• Architect and non-architect project manager. Architects must register with their professional order and follow specific rules; a non-architect project manager works freely but remains bound by ten-year liability if it takes part in the act of building.
• General contractor. A party that commits to the complete works is no longer merely a project manager: it sells works and may fall under the reverse charge for the subcontracted portion. The boundary between intellectual engagement and works contractor must be documented in the contract.

• Do not reverse-charge project management. Applying the reverse charge to intellectual fees is a frequent error that distorts both parties' VAT.
• Distinguish the project manager from the works contractor. The billing and insurance regime depends on this qualification; an ambiguous contract invites a reassessment.
• Have subcontractors approved. Without acceptance, you cannot rely on the subcontracting agreement.
• Anticipate e-invoicing. Receiving is mandatory from 1 September 2026, issuing is phased through 2027; our teams offer e-invoicing support.
• Track progress. Undocumented progress billing weakens revenue recognition in the event of an audit.

Recently, an independent project manager working on renovation sites contacted us after an audit. He had applied the reverse charge to all his invoices, including his site-supervision fees, believing he fell under the construction regime. The result: VAT not collected on his own services and invoices to correct.

We rebuilt his billing by separating two flows: his project management fees, subject to 20% VAT, and the share of works he actually subcontracted, falling under the reverse charge. We also set up progress billing tied to the engagement phases and checked his subcontractors' approval. Beyond the correction, this clarification secured his cash flow and his insurance file. The lesson is simple: the qualification of the service drives the regime, not the "construction" label.

Hayot Expertise advice. Have your contracts and billing chain audited before the next worksite. Check the qualification of each engagement (intellectual fees or works), the approval of your subcontractors, VAT consistency, and the validity of your ten-year and professional indemnity certificates. Dedicated accounting support for the project management profession avoids costly corrections and smooths relations with the building owner.