Since 27 June 2026, a sixth condition has been added to the domiciliation agrément: proof of AML/CFT training
Article L123-11-3 of the French Commercial Code sets the conditions for obtaining the prefectoral agrément without which no domiciliation company may operate. In its version in force since 27 June 2026 (law no. 2026-534 of 25 June 2026), a sixth condition has been added to the five already known to networks: proof of having completed training in anti-money-laundering and counter-terrorist-financing (AML/CFT). For a network director, this is no longer a line of common sense in an internal manual — it is now part of the agrément file.
The text first sets out the principle: no one may carry out domiciliation activity without prior agrément from the administrative authority, before registration with the commercial register. It then lists the cumulative conditions — premises with a room that guarantees confidentiality and allows for management-body meetings and the keeping of records; ownership or a commercial lease of those premises; no final conviction for a long list of offences (money laundering, corruption, forgery, criminal conspiracy...); no withdrawal of domiciliation agrément within the last five years; no personal bankruptcy. The sixth condition, new in this version, adds the obligation to prove AML/CFT training "according to arrangements set by decree" — a decree whose precise arrangements have not yet been published.
AppH's Pack Accueil does not deliver this training and does not verify its authenticity or validity: that remains the responsibility of the network director and, where applicable, the training provider. What a network of six to fifty agencies does gain by organising it is tracking: which authorised person at which agency completed the training, on what date, with what renewal deadline to watch before the next inspection or the next agrément application. The assistant can keep that dashboard agency by agency and send a reminder before the deadline; at no point does it judge whether the network complies — it just keeps the list.
For AppH
- A director running several agencies sees at a glance where each one stands on this new condition, instead of hunting for it scattered across paper files or separate spreadsheets.
- The deadline reminder follows the agency, not one person's memory: a change of local manager does not erase the record of training already completed.
Against / the honest limit
- AppH does not deliver the AML/CFT training, issues no certificate, and does not verify the authenticity of a supporting document: those acts belong to neither the assistant nor the Pack Accueil.
- AppH never rules on the network's AML/CFT compliance or its eligibility for the agrément: that assessment remains entirely the director's, and ultimately the administrative authority's.
The law of 25 June 2026 adds one more piece to an already long agrément file, and the implementing decree has not been published yet. Our role is not to anticipate that decree or to rule on a network's compliance: it is to stop a training deadline from getting lost between two agencies because it lived only in one person's head. On inspection day, an up-to-date dashboard beats a file that has to be rebuilt.
Reviewed by a human at AppH