Environmental Law 2025

FRANCE Law and Practice Contributed by: Carine Le Roy-Gleizes, Corentin Chevallier, Alice Messin-Roizard and Antoine Juquin, UGGC Avocats

public safety or the quality, circulation or conservation of water. 16.2 Public Environmental Information Under French law, the public has the right to obtain environmental information from public authorities and bodies. This principle applies to every interested per- son – and to all public and private bodies – in the name of environmental public service to the extent that it is not sensitive information (classified, public security, etc) and is related to environmental matters. Specific activities (relating to waste, high industrial risks, contaminated lands, etc) are regulated by par- ticular provisions. Géorisques enables the public to remain informed on both natural and technological risks, as well as histori- cal pollution. 16.3 Corporate Disclosure Requirement Under the French Commercial Code, some corporate entities are obliged to annually disclose information concerning the entity’s corporate and social responsi- bility (CSR) engagement with their shareholders. This includes management of the social and environmental consequences of its activity. Furthermore, the Duty of Vigilance Law of 2017 creat- ed an obligation for the parent company to implement a “vigilance plan”, which applies to approximately 150 companies. The plan aims to control the corporate entity’s activi- ties and prevent significant breaches in environmen- tal or human rights regulations. Since January 2020, several major French companies have been subject to claims brought by NGOs challenging the climate- related aspects of their compliance plans; however, the rulings so far have mainly concerned procedural aspects. In June 2025, the Paris Court of Appeal deliv- ered its first substantive ruling on the subject, fully upholding the December 2023 judgment of the Paris Judicial Court, which had ordered La Poste to sub- stantially revise its vigilance plan, deemed incomplete concerning aspects of labour law.

The EU Directive on Corporate Sustainability Due Dili- gence, effective from 2024 and applicable by 2028, introduced an EU-wide duty of vigilance. It requires companies to identify and address human rights and environmental impacts across their operations and global value chains. Lastly, in 2024, new chambers were established within both the Paris Judicial Court and the Paris Court of Appeal to handle environmental disputes involving large corporations more efficiently. These chambers will have exclusive jurisdiction over cases concerning corporate sustainability due diligence. 16.4 Green Finance The EU Sustainable Finance Disclosure Regulation (SFDR) and the EU Taxonomy Regulations apply in France. France is also required to transpose the EU Corporate Sustainability Reporting Directive (see 6.5 ESG Requirements ). As of 2021, the SFDR imposes mandatory ESG dis- closure obligations for asset managers and financial market participants. The SFDR aims to help investors by providing transparent information about the extent to which financial products take social and environ- mental features into account. Furthermore, the EU Taxonomy reporting must take place annually, in the non-financial statement or in a separate report until 2024 and in the management report from 2025 onwards. Among other things, this taxonomy enables companies to demonstrate their commitment to the low-carbon transition and enables investors to have a better understanding of the risks and opportunities of their investment portfolios. In February 2025, the EU Commission proposed to simplify the rules of sustainable finance reporting, sus- tainability due diligence and EU Taxonomy through an “Omnibus” package; some of the reporting require- ments in the CSRD and application of the CSDDD were postponed. The 2021 French Energy Climate Law, aligned with the EU SFDR Regulation, requires portfolio management companies to disclose climate change and biodiver- sity risks. They must also provide details on their pol-

229 CHAMBERS.COM

Powered by