Concealed work: with the Fraud Act of 25 June 2026, does the project owner become the new social guarantor of the subcontracting chain?, Le Moniteur des Travaux Publics et du Bâtiment

The Moniteur des Travaux Publics et du Bâtiment published an article by partner Clémentine de Guillebon and of counsel Ophélie Boulos examining France’s new law strengthening project owners’ duty of vigilance in combating undeclared work throughout the subcontracting chain.

The authors discuss how the law expands project owners’ obligations beyond their direct contractors to certain accepted subcontractors, creating new compliance responsibilities and increasing potential financial exposure for social security contributions and other liabilities. They also explore key interpretive questions surrounding the new framework and outline practical steps project owners should take now, including enhancing oversight procedures and updating contractual documentation.

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