FRANCE Trends and Developments Contributed by: Myriam Epelbaum, Tom Vauthier and Pauline Joly, Bredin Prat
duced the first concrete easing measures under the Omnibus package by postponing the application of the CSRD by two years for other companies (falling within waves 2 and 3 of its implementation). France transposed this measure through Law No 2025-391 of 30 April 2025 (“DDADUE 2025”). Nevertheless, some companies opted to publish a CSRD sustainability report voluntarily to demonstrate earlier compliance and maintain transparency vis-à-vis stakeholders. Environmental Matters in the First CSRD Sustainability Reports CSRD sustainability reports from the CAC 40 com- panies dedicate on average 38% of their page count to environmental issues. However, this first wave of reporting reveals a clear hierarchy among environ- mental topics. Climate-related matters (ESRS E1) are overwhelm- ingly deemed to be material by companies: all CAC 40 French companies identified at least one climate- related issue as material, with many presenting a transition plan under the ESRS format (E1-1) and declaring targets consistent with the Paris Agree- ment’s 1.5°C pathway (numerous companies having their targets SBTi-approved). This centrality of climate matters reflects both regulatory expectations and a comparatively high level of maturity inherited from prior non-financial reporting frameworks. By contrast, other environmental topics – such as pol- lution, water and marine resources and the circular economy – were less frequently considered material and, when they were, disclosures tended to remain limited. Matters related to biodiversity were seldom identified as material, making this an underdeveloped theme overall, with very few companies publishing transition plans or quantitative information on land- use effects. Focus on the Climate Transition Plan Disclosure The French Financial Markets Regulator (Autorité des Marchés Financiers – AMF) recently pointed out that climate disclosure has improved under CSRD. However, the regulator also observed the significant heterogeneity in methodologies, scope coverage and target boundaries between issuers.
Transition plans frequently lack quantified contribu- tions of individual levers, financial resources are sel- dom linked to climate objectives, and disclosures around carbon credits, residual emissions and antici- pated financial effects remain incomplete or unclear in the eyes of the AMF. The AMF specifically underlined that several issuers declared an alignment of their transition plan with the 1.5°C pathway, even though this alignment was only partial (often limited to Scope 1 and 2) and that “Net Zero” or GHG neutrality claims often lacked transparency and did not fully meet the standards set under the ESRS framework. Greenhouse Gas (GHG) Emissions Report and Transition Plan on Activities Located on French Territories Since 2010, all companies with more than 500 employ- ees have been required to prepare a balance sheet of their GHG emissions (“GHG emissions report”) and a transition plan to reduce the GHG emissions estab- lished in accordance with the French Environmental Code. These documents are submitted to the public Agency for Environment and Energy Management (Ademe) every four years. Such information must be easily accessible by the public on a dedicated web- site. This GHG report and transition plan are distinct from those required under the CSRD sustainability report- ing framework. As a result, companies may be exempt from prepar- ing a separate GHG report and transition plan under the French Environmental Code if they already pub- lish this information in their own CSRD sustainability report, or if they are covered by the CSRD sustainabil- ity report of a French parent company, provided that the sustainability report includes specific descriptions of activities carried out in France. The limitation of the French regime to national activi- ties is justified by its regulatory objective – namely to provide the French administration with reliable data for the assessment of emissions produced domestically, and to guide the implementation of the National Low Carbon Strategy (Stratégie Nationale Bas Carbone). Comparable obligations are imposed on local authori- ties and non-profit organisations.
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