The disability pension paid by the CPAM constitutes an income taken into account by banks in the calculation of borrowing capacity. Obtaining a mortgage while in a disability situation remains possible, but the process has specific friction points, particularly regarding borrower insurance. The rules have changed recently, and the regulatory framework of September 2026 significantly alters the situation for affected borrowers.
New disability thresholds in borrower insurance: what changes in 2026
One of the recurring obstacles for people with disabilities was the opacity of insurance scales. Each insurer applied its own thresholds to define total or partial permanent disability, making comparisons difficult and refusals sometimes incomprehensible.
The opinion of the Financial Sector Advisory Committee (CCSF) dated May 26, 2026, changes the situation. Insurers have started applying, since September 1, 2026, harmonized thresholds: 66% for total permanent disability and 33% for partial disability. Complete generalization is expected by June 1, 2027, at the latest.
In practical terms, this harmonization allows borrowers to know in advance whether a disability rate recognized by Social Security will trigger the contract’s guarantee. Before this opinion, a borrower could be denied coverage by an insurer setting a threshold at 70%, while another would have covered them from 60%.
For those considering applying for a mortgage while disabled, this clarification facilitates comparisons between contracts and reduces the risk of unpleasant surprises after signing.
Borrower insurance and disability: the end of coverage gaps
The second part of the CCSF opinion addresses a technical issue that particularly penalized borrowers with disabilities: coverage gaps during a change of insurance.
Since the Lemoine law, any borrower can change their loan insurance at any time. However, for a person on sick leave or in a disability situation at the time of the substitution, there was a risk of being left without coverage during the transition between the old and new contracts.
The CCSF opinion now organizes a mandatory continuity of coverage. When the substitution occurs during the waiting period of a previously declared claim, the old insurer must maintain coverage for the claim and its immediate consequences. The new contract will treat any relapses as new claims according to its own conditions.
This measure removes a real barrier. Some borrowers with disabilities refrained from changing contracts for fear of losing their ongoing coverage, even when cheaper offers were available.
Mortgage and disability category: what the bank really looks at
The disability pension is included in the income calculation just like a salary. Banks incorporate it to determine the debt ratio. However, the disability category influences the lender’s perception of risk and, especially, that of the insurer.
- Category 1 disability (reduced work capacity) is generally the least problematic. The borrower can combine the pension with work income, which strengthens their application.
- Category 2 disability (inability to perform a professional activity) raises more questions about long-term income stability. The pension alone must cover the monthly payments within the debt ratio limit.
- Category 3 disability (need for assistance from a third party) requires a more in-depth examination by the insurer, with frequent surcharges or exclusions on certain guarantees.
The determining factor remains the debt ratio after including the pension. If the disability pension, possibly supplemented by other income, allows the borrower to stay below the threshold set by the HCSF recommendations, the application has a chance of success.
AERAS agreement and right to be forgotten: safeguards for high-risk profiles
When the insurer refuses to cover a borrower with a disability at standard rates, the AERAS agreement (Insuring and Borrowing with an Aggravated Health Risk) takes over. This system requires a re-examination of the application at three successive levels before a final refusal can be pronounced.
The agreement also sets a cap on surcharges for borrowers whose income does not exceed a certain threshold. The goal is to prevent the cost of insurance from making the loan unaffordable.
Furthermore, the threshold for the right to be forgotten set at 200,000 euros per borrower has been clarified by the CCSF opinion of May 2026. This amount is assessed per person and not per loan, meaning a couple can borrow up to 400,000 euros while each benefiting from the scheme, provided that each insured part does not exceed the cap.
Health questionnaire: when it still applies
The Lemoine law has eliminated the medical questionnaire for loans where the insured amount does not exceed 200,000 euros and where repayment ends before the borrower’s 60th birthday. For higher amounts or longer durations, the health questionnaire remains mandatory and disability must be declared.
Failing to declare a recognized disability constitutes a false declaration that can lead to the nullity of the insurance contract, and thus the loss of all coverage in the event of a claim.
Building a solid application: the documents that make a difference
Beyond the usual pension slips and bank statements, certain documents strengthen a mortgage application in a disability situation.
- The notification from the CPAM specifying the disability category and the amount of the pension, which attests to the regularity of payments.
- Proof of additional income (part-time work for category 1, rental income, savings).
- A personal contribution, even modest, which reduces the borrowed amount and reassures the bank about financial management capacity.
- Account statements from the last three to six months without incident, demonstrating sound management despite potentially reduced income.
Requesting multiple institutions remains a relevant approach. Risk policies vary from one bank to another, and a refusal from one does not imply a generalized refusal. A specialized broker can expedite this phase by targeting banks whose criteria match the borrower’s profile.
The regulatory framework of 2026 has reduced several gray areas that complicated access to credit for people with disabilities. The harmonization of thresholds, continuity of coverage, and clarification of the right to be forgotten do not eliminate all difficulties, but they provide borrowers with clearer benchmarks to build their applications and negotiate with insurers.
