A-Z Glossary for UK & US Buyers Purchasing Property in France.
How to use this glossary
Buying property in France involves terminology that can be unfamiliar to international buyers. Some French concepts have a direct equivalent in the UK or US; others are specific to the French legal, banking or tax system.
This glossary explains the most important terms in plain English, with the French terminology retained where it is likely to appear in your documents.
A
Accord de principe
English: Agreement in Principle / Mortgage Approval in Principle
A preliminary indication from a French lender that a mortgage may be available based on the information provided by the borrower.
It is not a formal mortgage offer and does not guarantee that the loan will ultimately be approved.
For international buyers: obtaining an agreement in principle before making an offer can help establish a realistic budget and demonstrate financial credibility to the estate agent and seller.
Apport personnel
English: Down Payment / Personal Contribution / Equity Contribution
The amount of your own funds that you contribute towards the property purchase.
For international buyers, French lenders commonly expect a meaningful personal contribution. The amount required depends on the borrower’s country of residence, income, assets, property and overall financial profile.
Assurance-emprunteur
English: Borrower Insurance / Mortgage Protection Insurance
Insurance taken out in connection with a mortgage to cover specified risks, typically death and permanent disability, and potentially incapacity or other risks depending on the policy.
Borrower insurance is an important part of the French mortgage process and can be particularly complex for older borrowers or applicants with significant medical history.
AERAS
English: French framework for borrowers with increased health risks
AERAS stands for S’Assurer et Emprunter avec un Risque Aggravé de Santé.
It is a French framework designed to facilitate access to borrower insurance and credit for people presenting an increased health risk.
Acte authentique
English: Authentic Deed / Final Completion Deed
The official legal deed through which the ownership of a French property is transferred.
It is signed before a notaire and represents the final stage of the property acquisition.
For international buyers, signing can generally be organised through a power of attorney (procuration) if travelling to France is not practical.
AML / LCB-FT
English: Anti-Money Laundering / Counter-Terrorist Financing
French banks must comply with extensive anti-money-laundering and counter-terrorist-financing regulations.
For an international buyer, this means the bank will need to understand not only where the money for the purchase comes from, but potentially how the buyer accumulated their wealth.
Apport + frais
English: Down Payment + Acquisition Costs
When a French lender indicates that a buyer should provide, for example, 20–30% equity, this often needs to be considered in addition to the acquisition costs, rather than assuming that the entire contribution can be used as the property deposit.
B
Banque
English: Bank / Lender
A regulated financial institution providing banking services and, where authorised, mortgage financing.
Banque privée
English: Private Bank
A bank or banking division specialising in affluent and high-net-worth clients.
Private banks can be particularly relevant for international buyers with substantial financial assets, complex wealth structures or significant investment portfolios.
Blanchiment de capitaux
English: Money Laundering
The process of disguising the illegal origin of funds.
French banks are required to conduct extensive checks to prevent money laundering, which can make international mortgage applications more documentation-intensive.
Bridge loan / Crédit-relais
A short-term loan designed to finance a property purchase before the sale of another property has completed.
This can be particularly useful when an international buyer wishes to acquire a French property before liquidating an existing property elsewhere.
C
Capital restant dû
English: Outstanding Mortgage Balance / Outstanding Principal
The amount of mortgage principal still owed to the lender at a particular point in time.
Caution
English: Personal Guarantee / Guarantor
A person or institution agreeing to repay the borrower’s debt if the borrower fails to do so.
Compromis de vente
English: Preliminary Sale Agreement / Binding Purchase Agreement
One of the principal forms of preliminary property contract in France.
The buyer and seller commit to the transaction subject to the conditions contained in the agreement.
A mortgage condition suspensive is often included where the purchase depends on financing.
Condition suspensive
English: Suspensive Condition / Financing Condition
A contractual condition that must be fulfilled for the property transaction to proceed.
The most important example for an international buyer is the mortgage financing condition, under which the purchase can be cancelled if financing meeting the agreed criteria cannot be obtained within the specified period.
Courtier
English: Mortgage Broker
A regulated intermediary who assists a borrower in identifying, structuring and negotiating mortgage financing.
For an international buyer, a broker can be particularly useful because not all French lenders have the same appetite for non-resident borrowers.
Courtier en crédit immobilier
English: French Mortgage Broker
A broker specialising in residential and property financing.
A specialist international mortgage broker should understand not only French lending criteria but also foreign income, currencies, tax residency and international banking structures.
Coût total du crédit
English: Total Cost of the Mortgage
The overall cost associated with the mortgage, including interest and applicable fees and charges.
The TAEG is the principal French indicator used to represent the overall cost of credit.
D
Délai de réflexion
English: Mortgage Offer Reflection Period
Once a French borrower receives a formal mortgage offer, a mandatory 10-calendar-day reflection period applies before the offer can be accepted. (Service Public)
This is an important difference for international buyers accustomed to UK or US mortgage processes.
Dépôt de garantie
English: Deposit / Contract Deposit
An amount paid by the buyer when signing certain preliminary property agreements.
It is normally credited against the purchase price if the transaction completes.
Dette privée
English: Private Debt
Financing provided by private lenders or investment structures rather than traditional banks.
Private debt can sometimes be considered for complex or non-standard financing situations.
DTI — Debt-to-Income Ratio
French equivalent: Taux d’endettement / Taux d’effort
A ratio comparing debt repayments with income.
The French regulatory framework generally limits the borrower’s debt-service ratio to 35%, subject to the applicable rules and limited flexibility available to lenders. (economie.gouv.fr)
This is broadly comparable to the concept of DTI used in the US, although the calculation methodology is not necessarily identical.
E
Échéance
English: Mortgage Instalment / Payment
A scheduled payment under the mortgage.
With a standard French amortising mortgage, the monthly payment generally consists of principal and interest, with borrower insurance potentially added separately.
Épargne
English: Savings / Liquid Assets
The borrower’s available cash and financial assets.
French lenders will often examine the level of liquid assets retained after completion, not simply the amount available for the deposit.
Endettement
English: Indebtedness / Debt Exposure
The level of debt already carried by the borrower.
Existing mortgages, loans and other financial commitments can affect the amount a French bank is prepared to lend.
F
FATCA
English: Foreign Account Tax Compliance Act
A US federal law requiring financial institutions outside the United States to identify and report certain information concerning US taxpayers.
For US buyers applying for a French mortgage, FATCA can create additional banking and compliance requirements.
FISE
English: European Standardised Information Sheet — ESIS
A standardised document containing key information about a proposed mortgage, including its interest rate, duration and costs.
It allows borrowers to compare mortgage proposals.
Frais de notaire
English: Notaire / Acquisition Costs
The costs associated with completing a French property transaction through the notaire.
Despite the common expression “notaire’s fees”, these costs include taxes and duties as well as the notaire’s remuneration and other expenses.
Frais de garantie
English: Mortgage Security / Guarantee Costs
Costs associated with securing the mortgage.
Depending on the financing structure, this may involve a mortgage, a lender’s special legal security, a guarantee institution or another form of collateral.
G
Garantie de prêt
English: Mortgage Security / Loan Guarantee
The security protecting the lender against the risk of non-payment.
The security may take different forms, including a mortgage or a personal guarantee.
Garantie hypothécaire
English: Mortgage Security / Property Charge
A legal security registered against property in favour of the lender.
Gearing
French equivalent: Effet de levier
Using mortgage debt to finance part of a property acquisition rather than paying entirely in cash.
For wealthy international buyers, financing can preserve liquidity and investment capital rather than tying the entire amount into a French property.
H
HCSF
English: High Council for Financial Stability
The French authority responsible for macroprudential financial policy.
Its rules have an important impact on mortgage lending conditions, including the generally applicable 35% debt-service ratio. (economie.gouv.fr)
Hypothèque
English: Mortgage / Legal Charge
A legal security registered against a property to protect the lender.
If the borrower defaults, the lender may, subject to legal procedures, enforce its security.
Hypothèque légale spéciale du prêteur de deniers
English: Special Legal Mortgage for the Lender
A French security mechanism protecting a lender financing the acquisition of real estate.
I
IFI
English: French Real Estate Wealth Tax
Impôt sur la Fortune Immobilière.
IFI applies to qualifying net taxable real estate wealth above €1.3 million. For non-residents, the tax generally applies to qualifying French real estate assets, subject to applicable tax treaties. (impots.gouv.fr)
Importantly, certain qualifying debts can reduce the taxable net real estate wealth. (impots.gouv.fr)
Related topic: French mortgage leverage and IFI planning.
Intérêts
English: Interest
The cost paid to the lender for borrowing money.
Intérêts intercalaires
English: Interim Interest / Construction Interest
Interest charged when funds are released progressively, particularly in new-build or construction projects.
IRA
English: Early Repayment Charge / Mortgage Redemption Penalty
Indemnité de Remboursement Anticipé.
A fee that may apply when a French mortgage is repaid before its contractual maturity, subject to applicable French legal limits and the terms of the loan.
IOBSP
English: French Banking and Payment Services Intermediary
Intermédiaire en Opérations de Banque et en Services de Paiement.
A regulated professional who can intermediate banking and mortgage transactions.
J
No terms in this section.
K
KYC
English: Know Your Customer
The identity and compliance checks carried out by banks and financial institutions.
For international buyers, KYC can include passports, proof of address, tax identification numbers, bank statements, tax returns and corporate documentation.
L
Loan-to-Value — LTV
French equivalent: Quotité de financement
The percentage of the property’s value financed through borrowing.
Example: a €3m property financed with a €1.8m mortgage has an LTV of 60%. The remaining €1.2m represents the buyer’s equity contribution.
Lombard Loan
French equivalent: Crédit Lombard / Prêt garanti par portefeuille
A loan secured against a portfolio of financial assets rather than directly against the property being purchased.
This can be an interesting financing solution for high-net-worth international buyers who wish to preserve their investment portfolio.
M
Mensualité
English: Monthly Mortgage Payment
The amount paid each month under the mortgage.
Mandat de courtage
English: Mortgage Brokerage Mandate
The agreement authorising a mortgage broker to search for and negotiate financing on behalf of the client.
Mortgage
French: Crédit immobilier / Prêt immobilier
A loan secured against real estate.
N
Notaire
English: French Notary
A regulated legal professional responsible for authenticating property transactions and numerous other legal acts in France.
Unlike the typical UK solicitor or US real estate attorney, the French notaire is a public officer with a specific statutory role.
Nantissement
English: Pledge / Financial Collateral
A form of security over certain financial assets.
For example, an investment portfolio may be pledged to secure a loan.
Nue-propriété
English: Bare Ownership
A form of ownership in which the owner holds the property but another person — the usufructuary — retains the right to use the property or receive its income.
O
Offre de prêt
English: Formal Mortgage Offer
The formal mortgage proposal issued by the lender.
It contains the contractual terms of the loan, including the amount borrowed, duration, interest rate and other costs.
It is legally different from an Agreement in Principle.
Off-plan
French: VEFA — Vente en l’État Futur d’Achèvement
The purchase of a property before construction is completed.
Financing is generally released progressively according to the construction schedule.
P
Prêt amortissable
English: Repayment Mortgage / Amortising Mortgage
A mortgage where each payment includes both interest and repayment of principal.
This is the most common mortgage structure in France.
Prêt in fine
English: Interest-Only / Bullet Mortgage
A mortgage where the borrower generally pays interest during the loan term and repays the principal at maturity.
This can be relevant for certain high-net-worth investors, but requires a clearly defined repayment strategy.
Prêt viager hypothécaire
English: Equity Release / Reverse Mortgage
A mortgage-based financing solution allowing an owner to release capital from a property while generally retaining ownership.
Prêt relais
English: Bridging Loan
Short-term financing used when buying a new property before another property has been sold.
Prêt hypothécaire
English: Property-Secured Loan / Mortgage-Backed Loan
A loan secured against real estate.
For an international buyer, the property used as collateral may sometimes be located outside France, depending on the lender and structure.
Prêt de trésorerie
English: Cash-Out / Liquidity Mortgage
A loan secured against property designed to release liquidity rather than directly finance the acquisition of a property.
Prêt Crypto
English: Crypto-Backed Loan
Financing secured against cryptocurrency assets.
Availability depends heavily on the lender, jurisdiction and regulatory framework.
Q
Quotité d’assurance
English: Insurance Coverage Percentage
The percentage of the mortgage insured for each borrower.
For example: 50% / 50% = each borrower is insured for half of the loan. 100% / 100% = each borrower is insured for the full loan amount, subject to policy terms.
R
Reste à vivre
English: Disposable Income / Remaining Income
The amount of income remaining after debt repayments and other relevant financial commitments.
French lenders consider this alongside the debt-service ratio when assessing affordability.
Remboursement anticipé
English: Early Mortgage Repayment
Repaying some or all of a mortgage before its contractual maturity.
Refus de prêt
English: Mortgage Refusal / Declined Application
A lender’s decision not to approve a mortgage.
Important: a refusal from one French bank does not necessarily mean that the project is unfinanceable. Different lenders have different policies concerning countries of residence, currencies, income structures and property types.
Revenus étrangers
English: Foreign Income / Overseas Income
Income earned outside France.
French lenders can consider foreign income, although the currency, country of residence, employer, taxation and stability of the income can all influence the assessment.
S
Source of Funds
French: Origine des fonds
The documented origin of the money being used for the property purchase.
Examples include: salary savings; investment portfolio; property sale; inheritance; business sale; dividend income; company distributions.
Source of Wealth
French: Origine du patrimoine
The explanation and documentation showing how the buyer accumulated their overall wealth.
For high-net-worth international buyers, this can be particularly important during French bank compliance checks.
Solvabilité
English: Creditworthiness / Financial Capacity
The borrower’s ability to meet their financial obligations.
Surendettement
English: Over-Indebtedness
A situation where an individual can no longer meet their financial obligations.
T
TAEG
English: Annual Percentage Rate of Charge — APRC
TAEG — Taux Annuel Effectif Global.
The French indicator representing the overall cost of a mortgage, incorporating the costs that must legally be taken into account.
It is particularly useful when comparing mortgage proposals.
TAEA
English: Effective Annual Insurance Rate
An indicator used to measure the cost of borrower insurance.
Taux d’endettement
English: Debt-to-Income / Debt-Service Ratio
The proportion of income allocated to debt repayments.
The French HCSF framework generally uses a 35% maximum debt-service ratio, subject to applicable rules and exceptions. (economie.gouv.fr)
Taux fixe
English: Fixed-Rate Mortgage
A mortgage where the interest rate remains fixed throughout the agreed period.
Fixed-rate mortgages are particularly common in France and provide borrowers with predictable monthly payments.
Taux variable
English: Variable-Rate Mortgage / Adjustable-Rate Mortgage
A mortgage where the interest rate can change according to the contractual mechanism.
Taux d’usure
English: French Legal Maximum Mortgage Rate / Usury Rate
The maximum legally permitted overall cost of credit for certain categories of French loans.
It is calculated using the applicable TAEG framework.
TRACFIN
English: French Financial Intelligence Unit
TRACFIN is the French government service responsible for receiving and analysing information relating to suspected money laundering and terrorist financing.
For international buyers, TRACFIN-related compliance contributes to the extensive checks carried out by banks concerning the source of funds and source of wealth.
U
Usufruit
English: Usufruct / Life Interest
A legal right allowing a person to use a property and/or receive its income while another person holds bare ownership.
V
Valeur vénale
English: Market Value / Fair Market Value
The estimated price at which a property could reasonably be sold under normal market conditions.
Vente en l’état futur d’achèvement — VEFA
English: Off-Plan Purchase / Purchase of Property Under Construction
A property acquisition where the property is purchased before construction has been completed.
Payments are generally made progressively according to the construction milestones.
Vente à soi-même
English: Sale-and-Leaseback / Self-Sale Structure
A structure in which an owner transfers a property to a company or legal structure controlled by them and subsequently leases the property.
The legal, tax and financing consequences need to be carefully assessed.
W
Wealth Management
French: Gestion de patrimoine
A comprehensive approach to managing an individual’s wealth, including investments, real estate, financing, tax planning and succession.
For high-net-worth international buyers, mortgage financing can form part of a broader wealth-management strategy.
Wire Transfer
French: Virement bancaire
An electronic transfer of funds between bank accounts.
International property purchases require careful coordination of transfers, particularly where funds originate outside the SEPA area.
X
Cross-Border Financing
French: Financement transfrontalier
Financing involving a borrower, lender, income source or collateral located in different countries.
This is particularly relevant to international buyers purchasing French property while living in the UK, US, Switzerland, UAE, Singapore or other countries.
Y
Y
There are few meaningful French mortgage terms beginning with the letter Y.
Rather than forcing an artificial definition, this section can be used to link to relevant international-financing topics.
Z
Zero-Interest Loan — PTZ
French: Prêt à Taux Zéro
A government-supported French financing scheme providing eligible borrowers with interest-free financing under specific conditions.
Its relevance to international/non-resident buyers is limited because eligibility depends on the borrower’s circumstances and the purpose of the acquisition.
International Mortgage Terms
A supplementary selection, beyond the traditional A-Z glossary: the terms your UK and US clients are most likely to search for.
Affordability Assessment
The lender’s analysis of whether the borrower has sufficient income and financial capacity to service the proposed mortgage.
Cash Purchase
Buying a property entirely with the buyer’s own funds, without a mortgage.
Important for international buyers: paying cash may speed up the purchase, but it can also concentrate a substantial amount of liquidity in the French property. Financing can preserve liquidity and investment capital.
Equity
The portion of the property value owned by the borrower rather than financed through debt.
Property value – outstanding mortgage = equity.
Interest-Only Mortgage
French equivalent: Prêt in fine
A mortgage where the borrower pays interest during the term and repays the principal separately, typically at maturity.
Loan-to-Value — LTV
The percentage of the property value financed by debt.
Debt-to-Income — DTI
A measure of the proportion of income used to service debt.
This is particularly familiar to US buyers but should not be assumed to be calculated exactly the same way in France.
Net Worth
The total value of a person’s assets minus their liabilities.
This is particularly relevant to private-bank and high-net-worth mortgage applications.
Proof of Funds
Evidence demonstrating that the buyer has sufficient funds available to complete the purchase.
Source of Funds
Documentation demonstrating where the money used for the transaction originated.
Source of Wealth
Documentation explaining how the buyer accumulated their overall wealth.
Tax Residency
The country in which the buyer is considered tax resident.
This can materially affect a French mortgage application.
Foreign Currency Income
Income earned in a currency other than euros.
French banks can accept major currencies such as USD, GBP or CHF, although currency risk is taken into account.
Currency Risk
The potential impact of exchange-rate movements on the value of income, assets or debt.
For example, a UK buyer earning GBP but borrowing EUR is exposed to GBP/EUR exchange-rate movements.
Non-Resident Buyer
An individual who is not tax resident in France but wishes to purchase French property.
Primary Residence
The property that serves as the borrower’s principal home.
Second Home / Holiday Home
A property acquired for personal use but which is not the buyer’s principal residence.
Investment Property
A property acquired primarily for rental income and/or capital appreciation.
French Bank Account
A bank account opened with a French bank.
A French bank account is not necessarily required before the initial mortgage assessment, although it will generally be required to implement the banking relationship and service the mortgage once financing has been approved.
Power of Attorney — Procuration
A legal authorisation allowing another person to sign documents on your behalf.
This can be particularly useful for international buyers who cannot attend completion in France.
