Chartered Accountant for Commissaires de Justice (Judicial Officers)
Chartered accountant for commissaires de justice (former bailiffs): third-party funds accounting, regulated fees vs free fees, BNC 2035 and CAVOM pension. Quote in 24h.

A chartered accountant for commissaires de justice (the officers who replaced bailiffs on 1 July 2022) separates third-party funds (sums recovered, consignments, escrow) from the practice's income on dedicated accounts, and splits revenue between regulated tariff fees for monopoly acts and free fees. You file under the BNC regime (déclaration contrôlée 2035) and pay into the CAVOM pension fund.
- Third-party funds kept on dedicated accounts, whose representation must be justifiable at any time during the profession's inspections.
- Revenue split between regulated tariff fees, for monopoly acts, and free fees, for your competitive activities.
- A BNC tax regime with the déclaration contrôlée 2035 return and membership of the CAVOM pension fund.
Who is this for?
- Commissaires de justice and their practices (former bailiffs), whether sole practitioners or in a company.
- Public and ministerial officers who handle third-party funds every day.
When to contact us
- Before a professional inspection or taking over a practice, when the representation of third-party funds must be flawless.
- When the line between tariff fees and free fees blurs the reading of your revenue.
What you get
- A clear separation of third-party funds and the practice's own income, justifiable at any time.
- A reliable revenue split and a secured BNC 2035 return.
A commissaire de justice practice cannot be run like an ordinary professional firm. As a public and ministerial officer, you handle funds every day that are not yours: sums recovered on behalf of creditors, consignments, escrow. On top of that comes a dual-regime remuneration, a regulated tariff for monopoly acts and free fees for your competitive activities. The practice's accounting turns on these two points, and that is where the profession's inspections focus.
Our firm supports regulated professions that handle third-party funds from the chartered accountancy firm in Paris 8. This page covers what matters in a commissaire de justice practice: separation of third-party funds, revenue split, taxation and profitability steering.
Quick answer. The commissaire de justice (who replaced the bailiff, or huissier de justice, on 1 July 2022) keeps regulated accounts. They strictly separate the funds held on behalf of third parties (sums recovered, consignments) from the practice's own income, on dedicated accounts whose representation must be justifiable at any time. Revenue splits into regulated-tariff emoluments (monopoly acts), free fees (amicable recovery, official reports, advice) and disbursements rebilled at cost. The activity falls under non-commercial profits (controlled 2035 return), practice through a SCP or SEL is possible, and the pension depends on CAVOM.
Since 1 July 2022, the profession of bailiff (huissier de justice) and that of judicial auctioneer have merged into a single profession, the commissaire de justice (ordinance no. 2016-728 of 2 June 2016). Many clients still search for the term bailiff: the core work (service of documents, enforcement, official reports, recovery) remains, with a broader scope, notably towards the sale of movable assets.
You are a public and ministerial officer, appointed by the Minister of Justice, and the profession is supervised by the National Chamber of Commissaires de Justice. This ministerial-officer status carries precise accounting consequences: third-party funds handling, regulated tariff, fund representation obligations and professional secrecy.
A significant share of the sums passing through the practice are not income: they are funds held for third parties (sums recovered for creditors, consignments, escrow). These funds must be strictly separated from the practice's own funds.
In practice, this means:
- Dedicated accounts for client funds, distinct from the practice's operating accounts, with no offsetting between the two logics.
- Full traceability: every receipt collected for a creditor and every remittance is attached to the relevant file.
- Fund representation that is justifiable at any time: the consistency between sums owed to third parties and balances on account is a central control point.
The underestimated risk
In practices that handle funds, the most costly error usually comes from mixing logics: practice income confused with third-party funds, a reconciliation lag between sums recovered and remittances. These are the discrepancies an inspection looks for. Third-party funds accounting is therefore the first compliance deliverable.
Your turnover is made up of three kinds of income to be distinguished from the moment of billing:
- Regulated-tariff emoluments, for monopoly activities (service of judicial and extrajudicial documents, enforcement of enforceable titles, judicial auction sales of movables). The tariff is set by ministerial order: pricing freedom is limited.
- Free fees, for competitive activities (amicable debt recovery, reports requested by individuals, legal advice, property management, voluntary sales of movables, mediation). The price is negotiated.
- Disbursements, sums advanced on behalf of the client and rebilled at cost, with no margin. They are not taxable income and remain outside the scope of VAT.
The correct split of these three kinds drives both the reading of profitability and the correct VAT treatment. The practice's services are in principle subject to VAT at the standard rate, while disbursements are excluded: rigorous till and billing settings prevent reassessments.
The activity falls, for tax purposes, under non-commercial profits (BNC), with a controlled 2035 return. Practising through a company is possible: a professional civil company (SCP) or a liberal practice company (SELARL, SELAS), possibly under a holding (SPFPL). The choice of form and of the manager's remuneration carries social and tax consequences that deserve an assessment specific to your situation. For structuring and governance questions, the support of legal advice in Paris complements the accounting analysis.
The pension falls under CAVOM (the pension fund for ministerial and public officers and judicial companies): it is not the same fund as for lawyers or notaries, and the contribution base deserves to be anticipated in your cash forecast.
A common case in our files: a commissaire de justice SELARL consults us with sound practice accounting, but a blurred boundary between practice income and third-party funds, and a till that mixes regulated emoluments and recovery fees. The work consisted of making the separation of funds reliable, establishing a regular consistency between sums owed to third parties and balances, and reconfiguring billing to cleanly split emoluments, free fees and disbursements. Bookkeeping and review form the foundation of compliance here. No figure from this case can be generalised: each practice has its own activity mix and organisation.
Part of your activity is under a regulated tariff: profitability is therefore steered through the activity mix and time spent, not through price. The share of free fees (amicable recovery, reports, advice) is where you have the most control over margin.
| Indicator to track | Why it matters |
|---|---|
| Split of emoluments / free fees / disbursements | Reading of the revenue structure and margin potential |
| Effective recovery rate | Performance of the key competitive activity |
| Average remittance time to creditors | Quality of third-party funds management |
| Funds owed vs balances consistency | Compliance and fund representation indicator |
| Output per staff member | Productivity and team sizing |
- Separation of funds: continuously check the consistency between sums owed to third parties and balances, with no tolerance for crossed flows.
- VAT split: distinguish emoluments, free fees (taxable) and disbursements (out of scope) at the till and billing level.
- AML-CFT: anti-money-laundering and counter-terrorism-financing obligations are reinforced for professions handling funds; documenting due diligence is part of the file.
- Structural costs: budget professional liability insurance and the CAVOM contribution as recurring costs.
Our approach respects the professional secrecy and independence expected of a regulated profession, as for the notarial offices, law firms and judicial administrators and insolvency practitioners we support.
Every commissaire de justice practice has its own activity mix, organisation and tools. The starting point is a conversation about your actual situation: volume of acts and recoveries, how third-party funds are kept, form of practice. We offer an initial meeting to frame the scope and priorities.
Updated 20 June 2026. Informative content reviewed by a chartered accountant registered with the Île-de-France Chartered Accountants Board. A decision specific to your practice requires examination of your situation, your documents and the regulations in force.
The market and its segments
The commissaire de justice is a regulated profession of public and ministerial officer, created on 1 July 2022 from the merger of bailiffs and judicial auctioneers (ordinance no. 2016-728 of 2 June 2016). The activity falls under BNC (controlled 2035 return) and is carried out as a sole practice or through a company (SCP, SEL). Its accounting specificity lies in the handling of third-party funds (separation and representation) and a mixed remuneration (regulated-tariff emoluments, free fees, disbursements).
Securing the accounting of a commissaire de justice practice
1. Separate third-party funds from practice income
Keep dedicated accounts for sums held for third parties (recoveries, consignments), strictly distinct from operating accounts, with no offsetting between the two.
2. Guarantee fund representation
Regularly check the consistency between sums owed to creditors and balances on account, so that it can be justified at any time during an inspection.
3. Split revenue at source
Configure billing and the till to distinguish regulated-tariff emoluments, free fees and disbursements, a condition for correct VAT and an accurate reading of margin.
4. Budget structural costs
Record professional liability insurance and the CAVOM contribution as recurring costs, and document the AML-CFT due diligence linked to handling funds.
5. Set up activity-based steering
Track the split of emoluments / free fees / disbursements, the recovery rate and output per staff member, to act on the margin of competitive activities.
Frequently Asked Questions
What is the difference between a huissier and a commissaire de justice?
It is the same profession. Since 1 July 2022, the bailiff (huissier de justice) and the judicial auctioneer have merged into a single profession, the commissaire de justice (ordinance no. 2016-728 of 2 June 2016). The work (service of documents, enforcement, reports, recovery) remains, with a scope broadened notably towards the sale of movables.
Why does a commissaire de justice keep third-party funds accounting?
Because some of the sums passing through the practice do not belong to it: sums recovered for creditors, consignments, escrow. These third-party funds must be strictly separated from the practice's income, on dedicated accounts, with fund representation that is justifiable at any time.
How are a commissaire de justice's revenues split?
Into three distinct kinds: regulated-tariff emoluments (monopoly acts), free fees (amicable recovery, reports, advice, voluntary sales) and disbursements rebilled at cost. This split drives both the reading of profitability and the correct VAT treatment.
What tax regime applies to a commissaire de justice?
The activity falls under non-commercial profits (BNC), with a controlled 2035 return. Practising through a company is possible: SCP, SEL (SELARL, SELAS), possibly with an SPFPL. The choice of form and remuneration is decided case by case.
Are a commissaire de justice's services subject to VAT?
The practice's services are in principle subject to VAT at the standard rate. Disbursements, which are sums advanced for the client and rebilled at cost with no margin, are outside the scope of VAT. Rigorous till and billing settings prevent errors.
Which pension fund covers a commissaire de justice?
The pension falls under CAVOM (the pension fund for ministerial and public officers and judicial companies). It is not the lawyers' fund: the contribution base should be anticipated in the practice's cash forecast.
How do you steer profitability when part of the fees is regulated?
With monopoly emoluments set by a regulated tariff, profitability is steered through the activity mix and time spent, not price. The share of free fees (amicable recovery, reports, advice) is the main margin lever, tracked in a regular dashboard.
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Written by Samuel Hayot
Chartered Accountant, registered with the Institute of Chartered Accountants. Certified Pennylane trainer.
Regulated French accounting firm based in Paris 8, whose founder is also a statutory auditor, built to support companies across France with a digital and decision-oriented approach.
Sources
Official and operational sources cited for this page.