I. THE VALUATION
I.1 Regulatory Framework
| a) Is there a legal framework in your Member State for the valuation of real estate for lending purposes (loan origination)? If yes: • Is this framework specifically for the valuation of real estate for lending purposes or are provisions enshrined in a broader piece of legislation? • Is it limited to the transposition of European or International Standards or is it broader in nature? • Please provide references and indicate whether it applies to both residential and commercial property. If there are differences between both property types, please explain. |
Yes, a legal framework exists. Articles L313-20 to L313-22 of the French Consumer Code Code de la consommation (Articles L313-20 to L313-22), within the legal framework of real estate credit (effective July 1, 2016), mandate that lenders must conduct and document a professional valuation of a property before issuing a mortgage loan offer to ensure borrower solvency. |
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| b) If there is no specific legal framework, is the valuation of real estate for lending purposes covered by other means, e.g. self-regulation, sector recommendations or supervisory guidance? | |
| c) Do national valuation standards exist? Is there any cross-reference to European and/or International Valuation Standards (EVS/IVS)? |
France relies on the Charte de l'Expertise en Évaluation Immobilière, which is the national reference cross-referenced with IVS and EVS. (La charte is signed by 16/17 associations, last version of 2025). The rules apply to residential property (and mixed residential/professional property where the borrower acts as a consumer) but do not apply to purely commercial real estate, which falls outside the scope of the Code de la consommation. |
| d) How has the regulator in your Member State transposed Article 19(1) of the MCD regarding “reliable standards” for the valuation of residential property (into legislation or delivered through a professional body)? Indicate whether and how “reliable standards” are defined and whether and how the content of those standards are prescribed. |
Monetary and Financial Code (Code monétaire et financier – CMF) for commercial lending Chapitre III : Les établissements de crédit spécialisés (Articles L513-1 à L513-33) - Légifrance For secured funding structures, Articles L513 2 to L513 7 CMF require that loans be adequately secured by real estate, which in practice necessitates robust property valuation, detailed further by ACPR regulations and instructions rather than by statute. Commercial real estate valuations for lending purposes in France are therefore driven by the CMF’s prudential framework, EU banking regulation (CRR/CRD), and ACPR supervisory guidance, rather than by explicit valuation rules set out directly in the CMF. Réglementation bancaire sur l’évaluation des biens immobiliers |
I.2 Valuation Bases & Methodology
| a) What valuation bases (Market Value, Mortgage Lending Value, etc.) are typically used in your Member State for the valuation of property for lending purposes (please disregard at this stage the specific requirements of Art. 229 CRR considering that the Property Value is not an independent basis of value). |
Market Value (Valeur de Marché) is the primary basis. Mortgage Lending Value (Valeur Hypothécaire) is used, defined as a prudent value excluding speculative elements. But it does not replace the market value. |
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| b) Based on what definition? Please provide the definition and reference to where it can be located. | see charter SL: Valeur venale = market value, based on International Valuation Standards 2024, RICS Valuation – Professional Standards 2025 (Red Book) and TEGOVA’s European Standards for Property Valuation 2025. |
| c) In case other valuation bases are used in your Member State for the valuation of property for lending purposes, please specify the effect, if any, on the final valuation. | |
| d) Depending on the valuation base used, which valuation approaches or methods (comparison, income, cost, etc.) are typically applied in your Member State to value properties for lending purposes in each category? | Same approaches : comparison, income and cost |
I.3 Valuation Report: Form & Content
| a) Does the legal or professional framework in your Member State specific to the valuation of properties provide minimum requirements in terms of the form and content of the valuation report? If yes, please indicate what these minimum requirements are. | French legislation does not prescribe detailed statutory requirements for the form and content of valuation reports but the Charte de l'Expertise provides minimum requirements. Reports must include property identification, legal/town planning status, description, and detailed methodology. |
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| b) Should the form and content of valuation reports be prescribed, are there differences between residential and non-residential properties? Please describe as appropriate. |
Yes, differences exist in practice even though the Charte de l’expertise immobilière imposes a common core structure: residential valuation reports are generally shorter and more standardised, rely mainly on the sales comparison approach, include a simplified market analysis, and are often produced using lender specific templates derived from the Charte. By contrast, non residential (commercial) valuation reports are more detailed and analytical, typically rely on income based approaches (capitalisation and/or DCF), include extensive market and lease analysis with risk and sensitivity assessments, which the Charte explicitly allows by applying a principle of proportionality between asset complexity and depth of analysis. Because French law does not set fixed rules for valuation reports, practice is mainly shaped by professional standards. |
| c) If the form or content of the valuation report are not prescribed, what form does the valuation report typically take? Please specify differences between residential and commercial property valuation reports. |
I.4 Technology & Valuation
| a) Does the legal or professional framework in your Member State provide specific rules/guidance on the use of digital valuation tools (AVMs, Artificial Intelligence etc.)? If yes, what does this consist of and is it restricted to a particular type of property? Please specify whether there is a correlation with the requirements of Article 208(3a) CRR and of section 7.4 of GLOAM or whether the latter provisions are of stand-alone application in your Member State. |
In France, there is no specific legal framework nor dedicated section of the Charte de l’expertise immobilière that formally regulates the use of AVMs, AI, or fully automated valuation tools for lending purposes as substitutes for expert valuations. Digital valuation tools are therefore not regulated as such, and their use is mainly addressed indirectly through prudential banking regulation (Code monétaire et financier, CRR/CRD); supervisory expectations of the ACPR; and professional principles of reliability, independence, and accountability set out in the Charte. |
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| b) For what purpose are digital tools and/or AI employed in your Member State? - Mortgage origination, monitoring and review of property values, revaluation etc. - Capital requirements, covered bond funding, securitisation transactions, mortgage portfolio risk management etc. |
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| c) Scope of digitisation: Please determine the scope of automated and digitised tools in your Member State. Are they confined to data collection, do they deliver reliable property values or are they even used to produce full or partial valuation reports including description of locations, infrastructure, building characteristics etc.? If the latter is the case, is internal data used or it is permitted to purchase data from an external data provider? | In France, the scope of digitisation is generally limited. |
| d) Quality requirements: How are the reliability of the tools and their outputs assessed, e.g. by controlling the inputs, back-testing, supervision and/or plausibility checks by valuers etc.? | The Charte de l’expertise immobilière remains clear that the valuer is responsible for the final opinion of value, which limits the use of automated outputs without human review. |
| e) Do you foresee an increase in the use of automation and digitisation of property valuation processes in the future? Please describe potential technological developments which could impact the valuation profession and accelerate its transformation, notably through the use of AI. | Increasing use of AI for data scraping and predictive "Green Premium" modeling is expected by 2030. |
I.5 ESG, climate risk, transformation risk
| a) How are ESG factors and climate risk taken into consideration in the valuation process? Do Market Values and/or Mortgage Lending Values reflect the ESG characteristics of properties? |
ESG factors and climate risks are taken into account in valuation in line with the principles of the Charte de l’expertise immobilière, as applied by AFREXIM. AFREXIM explicitly recognises that the ESG performance of real estate assets increasingly influences transaction prices, rents, liquidity, and investor demand, and therefore may be reflected in Market Value when supported by market evidence, while the valuer remains an observer and analyst of the market and not a normative judge of sustainability performance. AFREXIM has developed ESG rating grids (already operational for offices and shopping centres) that rely on objective, weighted criteria (such as energy performance, carbon trajectory, climate risks and regulatory compliance) allowing valuers to compare assets and analyse correlations between ESG scores and transaction prices, with the declared objective of progressively modelling their impact on values. Following the Charte de l’expertise immobilière, the valuer remains fully responsible for interpreting ESG and climate data and for determining whether, and to what extent, these factors are reflected in the final opinion of Market Value. |
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| b) Are there rules in your Member State requiring assessment of EU Taxonomy alignment of a property in the valuation report and the subsequent impact of compliance/non-compliance on property values? | Reports increasingly include EU Taxonomy alignment, especially for institutional commercial lending |
| c) Are digitised tools and AI applied in order to capture and/or measure the impact of ESG factors and climate risk on property values? |
I.6 Market Initiatives
| a) Please describe any market initiatives which have been undertaken in your Member State (including cross border initiatives) and which have promoted market best practices and/or transparency of valuation practices. |
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II. THE VALUER
II.1 Regulatory Framework
| a) Is property valuation a regulated profession in your Member State (through legal, regulatory or statutory rules)? | The title "Valuer" is not protected by law in France |
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| b) Is the use of the title of valuer protected in your Member State? If yes, by whom? | The title "Valuer" is not protected by law in France |
| c) If the title of valuer is not protected in your Member State, how do lenders ensure that they work with ‘qualified’ valuers? Are there ‘professional’ certifications for property valuers in your Member State? If yes, please name them. | The title "Valuer" is not protected by law in France. Lenders ensure quality by requiring certifications such as REV, MRICS/FRICS RV, or membership in recognized bodies like AFREXIM or SNPI. |
| d) Is the regulatory or professional framework the same for all valuers, whether they value residential and/or commercial property? Or are there differences? Please describe as appropriate. |
II.2 Qualification and Independence
| a) The qualified valuer • How has the regulator in your Member State transposed the requirements of Article 19(2) of the MCD, of Articles 229(1) and 208(3b) of the CRR regarding the instruction of “professionally competent valuers” or valuers who possess the “necessary qualifications, ability and experience” (transposition through legislation or by self-regulation)? Indicate how professional competence and qualification requirements are prescribed. |
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| a) The qualified valuer • If professional competence, qualification, ability and experience requirements are not prescribed, what is general practice with regard to professional qualifications? |
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| b) The independent valuer • How has the regulator in your Member State transposed the provision in Article 19(2) of the MCD or in Articles 229(1) and 208(3)(b) of the CRR regarding “sufficient independence from the credit underwriting process” or “independence from the loan processing and loan decision process” (through legislation or delivered through self-regulation)? Indicate whether and how the requirement is defined and whether and how it is prescribed. |
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| b) The independent valuer • If “sufficient independence” is not prescribed, what is general practice to ensure the valuer is unbiased and not subject to undue pressure? |
II.3 External vs. Internal
| a) Does the legal or professional framework in your Member State specific to the valuation of property for lending purposes lay down rules for banks and lenders as to whom they may use to value properties? • If yes, do credit institutions have the possibility to employ both internal and external valuers? • Is one type of valuer typically employed more frequently than the other? |
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| b) If there is/are no legislation/rules regarding the use of external and internal valuers, what is typical practice? |
II.4 Professional Indemnity Insurance
| a) Does the legal or professional framework in your Member State specific to the valuation of property for lending purposes require: • Valuers to have professional indemnity insurance cover? • Lenders to use only valuers covered by professional indemnity insurance? |
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| b) If there are no such requirements, how are lenders/valuers covered for the risk? • Is/are there legislation/rules in your Member State determining the responsibility of the valuer vis-à-vis his client? If yes, please describe the legislation/rules and the responsibility of the valuer. |
Mandatory for all professional valuers under national professional standards. |
III. VALUATION & CAPITAL REQUIREMENT
| a) Property Value How are the Property Value requirements of Article 229(1) CRR transposed in your Member State: • by calculating the Mortgage Lending Value • by Market Value adjustments ◦ adjustments determined by the valuer on a single property by property basis ◦ adjustments determined by the credit institution on a portfolio level based on internal historic market data series ◦ adjustments determined by the credit institution on a portfolio level based on data provided by external research institutes or data providers |
France does not apply Mortgage Lending Value (MLV) as a distinct statutory or professional valuation basis. Property Value is determined through Market Value, complemented by prudential adjustments applied by credit institutions, in line with CRR and ACPR supervisory expectations. |
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| b) Monitoring of property values Has the regulator in your Member State laid down criteria regarding "more frequent monitoring where the market is subject to significant changes in conditions"? |
Property values are monitored in line with CRR minimum frequencies (typically annually for commercial property and less frequently for residential property – every 3 years in general), with more frequent monitoring triggered by internally defined risk indicators rather than regulatory thresholds. |
| b) Monitoring of property values Has the regulator in your Member State laid down criteria regarding “advanced statistical or other mathematical methods” complying with the technical requirements of Article 208(3a) CRR? |
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| b) Monitoring of property values Please provide an overview of the different statistical methods/tools complying with Article 208(3a) CRR applied by lenders in practice. |
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| c) Review of property values and revaluation • Has the regulator in your Member State laid down criteria which define “review” of the property valuation? If so, what are the minimum and maximum periods within which a review must be conducted? Based on which criteria? |
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| c) Review of property values and revaluation • Has the regulator in your Member State laid down criteria which define “material decline relative to general market prices”? How are ESG-related considerations assessed as an indicator for a material decline? |
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| c) Review of property values and revaluation • Please provide a description of how ‘reviews’ are carried out in your Member State, e.g. by a new full-size valuation report, a desk-top valuation, a valuation certificate, a plausibility assessment or alike. What criteria are used to determine how the reviews are to be carried out? |
Reviews are commonly performed through desktop or model‑based updates, while a full revaluation is required where a material decline or sensitive risk is identified. |
| c) Review of property values and revaluation • For the calculation of average values in accordance with Article 229 (1)(e) CRR in the context of upward revisions of values, are there any guidelines from regulators or lenders addressing the data points to be used and the comparability of properties? Please indicate whether there are requirements from regulators or lenders for ‘sufficient data’ and ‘unequivocal increases of value’. |
IV. VALUATION OF THE COVER POOL
| a) Are valuation rules for cover assets provided at national level in accordance with Article 6(5a) CBD? Are they provided by national covered bond legislation or by professional guidance/standards? |
France applies a long standing and robust covered bond framework based on obligations foncières issued by specialised credit institutions (sociétés de crédit foncier – SCFs), first established by the Law of 25 June 1999. Framework governing sociétés de crédit foncier (SCF) and obligations foncières, supplemented by prudential supervision from the ACPR. French covered bonds are mainly issued under two dedicated legal frameworks, both embedded in the French Monetary and Financial Code: 1. Sociétés de Crédit Foncier (SCF) : o Can issue covered bonds backed by multiple asset types, including residential mortgages, public-sector loans, and substitute assets. o SCFs issue the well-known “obligations foncières.” 2. Sociétés de Financement de l’Habitat (SFH) o More narrowly focused on residential mortgage loans and substitute assets. o Issue “obligations de financement de l’habitat” (OHs). |
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| b) What valuation bases apply for the valuation of cover assets (Market Value, Mortgage Lending Value)? | In the French covered bond framework, while expert valuations are generally performed on a Market Value basis, Mortgage Lending Value (or a prudently filtered long term value) effectively operates as a cap for eligibility and cover tests within the cover pool, ensuring conservatism and long term stability of collateral values backing obligations foncières. |
| c) In the case of Market Value valuations, are there any prudential or longer term/sustainable features of the property to be considered? If yes, to what extend? | In France, cover assets are valued on a Market Value basis by independent valuers. However, for inclusion in the cover pool and for regulatory tests, this value is effectively capped by a prudent, long term value reflecting Mortgage Lending Value principles, to limit volatility and ensure conservatism. Any additional prudential buffers or stress adjustments are applied by the issuer at coverpool level, not automatically built into the valuer’s valuation. |
| d) How is the requirement that the valuation shall be carried out by a valuer who possesses the necessary qualifications, ability and experience transposed in your Member State (Article 6(5b) CBD)? Are there specific qualification requirements for valuers? | Valuations must be carried out by experienced and competent valuers selected on the basis of professional standing and expertise, and they must be independent from loan origination and credit decisions through clear organisational separation. |
| e) How is the requirement that the valuer shall be independent from the credit decision process transposed in your Member State (Article 6(5c) CBD)? | Valuations must be carried out by experienced and competent valuers selected on the basis of professional standing and expertise, and they must be independent from loan origination and credit decisions through clear organisational separation. |
| f) Are there differences in valuation rules and/or qualification requirements with regard to the property type (residential vs. commercial properties) or to the loan amount? | The same overall rules apply to residential and commercial properties, but commercial or more complex assets are subject in practice to more detailed analysis, closer monitoring and greater prudence (refer to answers done in the previous section). |
| g) Are there specific monitoring, review and revaluation requirements for cover pool assets at national level (see Article 129(3) CRR referring to Article 208 CRR)? | Monitoring, review and revaluation of cover pool assets follow Articles 129 and 208 CRR, with regular checks, more frequent reviews during periods of market stress, and valuation methods proportionate to risk. There is no general allowance for unchecked upward revaluations: any increase in value must be well supported and consistent with maintaining cover pool quality and overcollateralisation. |
| h) Do regulators of your Member State provide a waiver from the limitation of calculating average values for cover assets in case of upward revision of values (Article 129(3) second subpar. CRR)? |
V. OTHER
REGULATORY HARMONISATION AND NATIONAL DIVERGENCES
| 1. What challenges does your Member State face in harmonising with EU regulations (e.g. legal, technical, market-related)? | France is broadly compliant with EU valuation rules, but full harmonisation is constrained by legal, technical, and market specific factors. The main challenge lies in adapting traditional French market value based valuation practices to the EU’s newer prudently conservative “property value” concept under CRR3, which creates uncertainty over methodology, documentation, and the division of responsibility between valuers and banks. Methodological differences persist, as France relies heavily on notarial transaction data, while EU supervisors seek greater cross border comparability for prudential purposes. |
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DATA QUALITY, TRANSPARENCY AND COMPARABILITY
| a) What data sources are typically used by valuers in your Member State, and to what extent do they comply with Article 208(3a) of the CRR? |
In France, valuers typically rely on a combination of official notarial transaction databases and professional market sources. DVF (Demandes de Valeurs Foncières) database, published by the tax authorities : historical transaction prices for residential and land. Notarial databases: PERVAL and BIENS. Valuers primarily use the Notaries' databases (BIEN/PERVAL) and the government's DVF (Demande de Valeurs Foncières) open data for transaction transparency. |
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| b) What measures have been taken to improve transparency and comparability of valuation data within your Member State? | The DVF helps in that regard. |
| c) Is there a central database or platform for sharing valuation data in your Member State? | There is not a single and central database platform combining all data. However, DVF is a national reference (for residential and lands only). |
EDUCATION, TALENT PIPELINE AND PROFESSIONAL DEVELOPMENT
| a) What training programs or continuing education opportunities are available for property valuers in your Member State? | There are events, trainings organized by several real estate associations, professional bodies, universities, etc. In France, for everyone working in real estate, 14h CPD are mandatory per year. |
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| b) Is there collaboration between universities, professional bodies, and regulators to ensure a sustainable pipeline of qualified valuers? | |
| c) How does the EU regulatory environment influence the development and attractiveness of the valuation profession? | Complicated question to answer as I need to give you the big picture of France. |
FUTURE TECHNOLOGICAL AND REGULATORY DIRECTIONS
| 1. What technological developments are expected to impact valuation processes in your Member State over the next five years? |
Balancing strict ESG requirements with market liquidity and the cost of frequent revaluations, and consistency of data. The other direction is the one related to Digital Assets and Tokenisation. |
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