FRANCE Law and Practice Contributed by: Sylvain Naillat and Helena Delabarre, Nomos
Digital sovereignty and sector-specific localisation trends Discussions on digital sovereignty and strategic autonomy continue at EU and member state level. While the GDPR does not impose a general data resi - dency requirement, sector-specific rules, certifica - tion schemes, or public procurement conditions may increasingly influence expectations regarding localisa - tion or EU-controlled processing in sensitive sectors. At present, however, this remains policy-driven and context-dependent rather than a generalised legal obligation under Chapter V of the GDPR.
US companies, although privacy advocates remain vigilant. CNIL International Strategy 2025–2028 The CNIL has adopted a strategy aimed at strength - ening European co-operation (including more efficient handling of cross-border cases) and promoting high data protection standards internationally through what it refers to as “data diplomacy”. New Adequacy Developments – Brazil In January 2026, the EU and Brazil concluded ade - quacy arrangements intended to facilitate secure and free data flow between the EU and Brazil. This reduc - es the need for SCCs or BCRs for transfers covered by the decision. Anticipated Developments UK adequacy decision The EU adequacy decisions for the UK were renewed in December 2025 for a further six-year period (until 27 December 2031), subject to a “sunset clause” and ongoing monitoring. While transfers may continue without additional safeguards, divergence between UK and EU data protection law remains a structural risk that organisations should monitor.
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