Business address for healthcare professionals

Your company's registered office is not your place of practice

This is the most important distinction, and the one most often confused. The registered office is the administrative address of your practice company: the one that appears on its incorporation record, its articles of association and its official documents. The place of practice is the consulting rooms where you receive your patients, and it is this that you declare to your professional body (the Ordre). The two addresses may be identical, but nothing requires them to be. Company law accepts that a liberal professional practice company (société d'exercice libéral, SEL) may set its registered office at an address separate from the practice, including with a domiciliation company. The guide issued by the Ordre des médecins (the medical council) even recommends separating the registered office and the place of practice into two distinct articles in the articles of association, precisely because these are two different concepts. The company is entered on the roll of the departmental council for the place of its registered office, while each practitioner remains attached to the departmental council for the place where they practise.

What a business address gives you in practical terms

Beyond the address, a business address gives you the proof of the right to occupy required to incorporate your practice company or your sole proprietorship, the receipt and scanning of your administrative mail, and access to a chartered accountant who knows your professional funds (caisses), your non-commercial profits (bénéfices non commerciaux, BNC) and your reporting obligations. It also lets you keep your personal address separate from that of your structure, without exposing your home on the public registers. If you practise in your own name, without a company, the principle is the same: your sole proprietorship declares an administrative address on the one-stop shop, which you can have serviced as a business address rather than using your home, all without changing anything in the declaration of your practice to your professional body (the Ordre).

What your professional body expects, depending on your profession

Setting your company's registered office at a business address never exempts you from declaring your actual place of practice, and the rules vary from one profession to another.

• Doctors practise on the basis of a usual professional residence. Since 2019, practising at one or more separate sites is subject to a prior declaration to the departmental council, to be sent at least two months beforehand, with the Ordre holding a right of objection. It is no longer an authorisation, and the former criterion of an insufficient supply of care has disappeared for the declaration in principle.
• Allied health professionals, that is nurses, physiotherapists, chiropodist-podiatrists or speech and language therapists, practise from a main practice and may open a secondary practice by declaring it to the Ordre. Any further site beyond that requires an authorisation justified by an insufficient supply of care in the area concerned.
• Community pharmacists are a special case: the pharmacy is premises authorised by a licence, and the company that operates it is tied to it. The scope for separating the registered office from the place of operation is therefore far more limited here than for a practice.
• Psychologists do not come under a professional body. The title is protected and registration is done with the regional health agency (agence régionale de santé, ARS), now on the RPPS register. In the absence of an Ordre, there is no declaration of a place of practice to a council, but the choice of registered office follows the same rules of company law.

SEL and SCM: what a business address can do, and what it cannot

Two structures come up constantly among healthcare professionals, and they do not have the same relationship with a business address. The liberal professional practice company, whether a SELARL or a SELAS, carries on the profession: it is the one that receives the fees and is entered on the roll of the professional body (the Ordre). Its registered office may be domiciled at an address separate from the practice, provided that the Ordre approves the articles of association and the domiciliation agreement, so it is better to submit the plan to it in advance. The resource-pooling company (société civile de moyens, SCM) does only one thing: pool premises, staff or equipment between practitioners who each keep their own patients. It does not carry on the profession and is not entered on the roll of the Ordre as a SEL would be. An SCM can be given a business address, but since its very purpose is to manage the resources of a practice, it is most often domiciled at the address of that practice, which remains consistent with its function.

Mail, medical confidentiality and health data

This is the point we take most seriously, and the one on which a generalist domiciliation company can expose you. The staff of a domiciliation company are not bound by medical confidentiality and are not authorised to process health data, which are sensitive data within the meaning of the General Data Protection Regulation. Having a patient letter, a test result or correspondence between colleagues opened and scanned by an unauthorised third party creates a genuine risk: the disclosure of confidential information by a person entrusted with it is punishable by one year's imprisonment and a fine of 15,000 euros. Our recommendation is simple and cautious: keep the business address for the company's administrative flows (the Urssaf, the tax authorities, the registry and the bank), and have any correspondence relating to your patients sent directly to your practice, to be opened by you or by staff bound by confidentiality. The law also requires the domiciliation provider to have premises fitted with a room suitable for ensuring confidentiality and to keep a file for each domiciled business.

Practising at several sites with a single registered office

A single registered office coexists without difficulty with several places of practice. The registered office fixes the company's administrative attachment and the departmental council with jurisdiction over it, while each practice follows its own professional body rules, by declaration or by authorisation depending on your profession, as seen above. This pattern is common: a practitioner who splits their time between two practices, or a SEL that brings together several partners practising in different places, keeps a single registered office address. Just remember to notify any change of professional address to your professional body (the Ordre) within the deadlines it sets, because that particular obligation never goes away.

What a business address does not change

Setting your registered office in Tours has no effect on three things that are nonetheless often wrongly associated with it. Your pension fund depends on your profession, the CARMF for doctors, the CARPIMKO for allied health professionals, the CARCDSF for dentists and midwives, the CIPAV for psychologists, and not on the address of your registered office. Your agreement (conventionnement) with the statutory health insurance (Assurance maladie) and your attachment to the regional health agency's zoning follow your physical place of establishment, not your registered office. Finally, your treatment claim forms bear your RPPS number and the professional address of your practice. The registered office address serves to incorporate your company and to receive its administrative mail, nothing more, and that is precisely the service we provide, backed by an accountancy firm specialising in the liberal and health professions.