CSRD in France: National Law, Status, Scope and First Reporting Years

An ordonnance is a government order with the force of law. The Directive binds France, and companies apply it through the Code de commerce (French Commercial Code). What the Directive requires is set out in the CSRD explained after the Omnibus.

The five key figures for France are listed below.

• EU transposition deadline: 6 July 2024, on the CSRD timeline
• French rules: in force since 1 January 2024
• Large companies: financial years opened from 1 January 2027 (loi 2025-391, Art. 7)
• Omnibus bill: Assemblée nationale texte n° 2518, no vote as of 29 October 2026
• Certification: commissaire aux comptes or OTI (L. 232-6-3 III)

How France Transposed the CSRD: Status as of 29 October 2026

As of 29 October 2026, France has transposed the CSRD through ordonnance n° 2023-1142 of 6 December 2023 and décret n° 2023-1394 of 30 December 2023, and the ordonnance has applied since 1 January 2024 (its Article 32), subject to the transitional rules of its Articles 33 to 42. Its title begins "relative à la publication et à la certification d'informations en matière de durabilité" (on publishing and certifying sustainability information).

The EU's Cellar repository records the ordonnance, the décret and loi n° 2023-171 of 9 March 2023 as French measures notified for Directive (EU) 2022/2464; a record shows a notification, not a finding on content. France has no CSRD infringement case as of 29 October 2026.

The table below lists the dated steps, from Légifrance, the parliament and EUR-Lex.

Where the Rules Sit in the French Commercial Code

The reporting duty sits in Article L. 232-6-3 of the Code de commerce (individual, created by Article 8 of the ordonnance) and Article L. 233-28-4 (consolidated). The information sits in the management report (rapport de gestion), filed with the court registry (greffe). Article 7 of loi n° 2025-391 allows "omission from the court filing with transmission to the AMF" (Autorité des marchés financiers). The same ordonnance replaced the H3C (Haut conseil du commissariat aux comptes) by the H2A as audit regulator.

The 2025 Postponement Law and the New French Dates

Loi n° 2025-391 of 30 April 2025 (JORF n° 103 of 2 May 2025, in force since 3 May 2025) transposed the Stop-the-clock Directive in France: its Article 7 moved the first year for large companies from financial years opened on 1 January 2025 to 1 January 2027, and for listed SMEs from 2026 to 2028. Known as DDADUE 2025, it adapts French law to EU law, and its Articles 8 and 13 also amend the transposition.

Cellar records loi n° 2025-391 as the French measure notified for Directive (EU) 2025/794. The 2025 postponement under the Stop-the-clock Directive (EU) 2025/794 sets out the EU side.

France's Pending Bill for the 2026 Amendments

France has not yet transposed Directive (EU) 2026/470: as of 29 October 2026 the projet de loi DDADUE (government bill), whose Article 9 covers it, passed the Sénat on 18 February 2026 and sits in the Assemblée nationale's economic affairs committee as texte n° 2518. Filed in the Sénat on 10 November 2025 (n° 118, accelerated procedure), it has committee report n° 347 and text n° 348 of 4 February 2026.

Texte n° 2518 dates from 20 February 2026; four committees (law, sustainable development, finance, cultural affairs) were asked for opinions on 23 April 2026. As of 29 October 2026 there is no vote there, no joint committee (commission mixte paritaire) and no promulgation.

The government's Portail RSE states that the new thresholds apply in France only after transposition, expected by 19 March 2027 at the latest, the deadline of Article 5(1) of Directive (EU) 2026/470 (portal check of 2 September 2026). Until then the 2026 amendments made by Omnibus I bind France, not French companies.

Who Reports in France and from Which Financial Year

Under Article 33 II of ordonnance 2023-1142 as amended by loi 2025-391, French sustainability reporting applies to wave 1 for financial years opened from 1 January 2024, to other large companies from 1 January 2027, to listed SMEs from 1 January 2028 and to third-country groups from 1 January 2028. EU wave 1 covers large public-interest entities with more than 500 employees, financial years 2024 to 2026.

The table below sets the law in force beside the bill (draft, AN texte n° 2518, as of 29 October 2026).

Large Companies under the Current French Size Criteria

Décret n° 2024-152 du 28 février 2024 raised the large-company criteria to EUR 25 million balance sheet and EUR 50 million net turnover for financial years opened from 1 January 2024. Article D. 230-1 3° Code de commerce adds 250 employees; for groups, Article D. 230-2 2° sets EUR 30 million, EUR 60 million and 250. French size classes apply when at least two of three criteria are exceeded at the closing date (Art. L. 230-1 Code de commerce), and the thresholds are deemed crossed at the closing date of two consecutive financial years (Art. D. 230-1).

These are pre-Omnibus criteria; Article 9 of the bill would replace them by net-turnover and average-employee thresholds "fixés par décret", without numbers. The EU values of Directive (EU) 2026/470 (more than EUR 450 million net turnover and on average more than 1,000 employees) reach French companies only once transposed; see the CSRD thresholds for large companies after the Omnibus.

National Reliefs for Listed SMEs and First-Year Omissions

Listed SMEs may opt out of L. 232-6-3 for financial years opened before 1 January 2028, giving reasons (Article 33 II, last paragraph, of the ordonnance). Article 33 IV, inserted by Article 7 of loi n° 2025-391, adds that for the first three financial years opened from 1 January 2024, certain items of ESRS 1 Appendix C (Delegated Regulation (EU) 2023/2772) may be omitted depending on employee thresholds. Directive (EU) 2026/470 removes listed SMEs from the CSRD, and the bill would repeal 3° (draft).

What follows once you are in scope: the CSRD compliance plan step by step.

Who Provides Assurance in France: Statutory Auditors, OTIs and the H2A

In France, sustainability information is certified either by a commissaire aux comptes (statutory auditor) or by an organisme tiers indépendant (OTI, independent third-party organisation) (Article L. 232-6-3 III C. com.), and both must be entered on a list kept by the Haute autorité de l'audit (H2A). The H2A is an independent public authority (Article L. 820-1 C. com.) created by Articles 13 and 14 of the ordonnance.

OTIs pay the H2A 0.5 % to 0.7 % of their certification fees (Article L. 820-12 C. com.). Commissaires aux comptes listed before 1 January 2026 are deemed qualified after at least 90 hours of approved training (Article 37 of the ordonnance); the bill would move the Article 37 dates from 2026 to 2028 (draft).

French sustainability certification follows the assurance standards adopted by the European Commission and, until one exists, the standards of the Haute autorité de l'audit (Art. L. 821-59 Code de commerce). At EU level, limited assurance of CSRD reporting is the only level (Article 34(1)(aa) of Directive 2013/34/EU as replaced by Directive (EU) 2026/470); the EU standard is not adopted as of 29 October 2026 (due by 1 July 2027).

The H2A keeps the six lists below.

Supervision, Enforcement and Penalties in France

The specific criminal offence for sustainability certification, Article L. 822-40 C. com., was repealed by Article 8 II 20° of loi 2025-391 with effect from 3 May 2025 and is no longer a current penalty in France.

Disciplinary sanctions against sustainability auditors and OTIs rest on Article L. 822-31 C. com., in force since 1 January 2024.

ESMA's GLESI compliance table of 24 August 2026 lists the Autorité des marchés financiers (AMF) as France's enforcer of sustainability information; the AMF answer is covered under CSRD penalties and enforcement by Member State.

The Previous French Regime and Its Last Reporting Year

Before the ordonnance, French reporting rested on Article L. 225-102-1 C. com., introduced by ordonnance n° 2017-1180 of 19 July 2017 to transpose Directive 2014/95/EU, and the last report under that rule covers the financial year opened between 1 January and 31 December 2024.

That last report concerns only entities not subject to, or exempt from, L. 232-6-3 or L. 233-28-4 (Article 34 I of the ordonnance as amended by Article 13 of loi n° 2025-391). Under Article 34 II, a commissaire aux comptes or an OTI may verify it.

Article 2 IV of décret n° 2023-1394 abrogated articles R. 225-104 and R. 225-105 to R. 225-105-3. The last déclaration de performance extra-financière (DPEF) and its final year has its own page.

The Government's Reporting Portal

The French government's Portail RSE (portail-rse.beta.gouv.fr, run by the Direction Générale des Entreprises with Bpifrance and Les entreprises s'engagent) publishes 10 regulatory fact sheets, a three-phase guide to the sustainability report and a filling tool for the voluntary standard (VS, formerly VSME). The guide has three phases of three steps (double materiality, data, report); the tool is "Remplir ma VS (ex-VSME)".

France in the EU-Wide Comparison

France has CSRD transposing acts in force as of 29 October 2026 and a pending bill for Directive (EU) 2026/470, one row of the EU-wide comparison.

The EU-wide CSRD transposition tracker covers the 27 Member States and Norway.

Detail Pages on French Sustainability Reporting

The four detail pages below cover the predecessor regime and three other states.

• DPEF, the French predecessor regime: its duty and last year.
• CSRD in Germany: bill BT-Drs. 21/1857, pending as of 29 October 2026.
• CSRD in Belgium: notified its law of 2 December 2024.
• CSRD in Austria: the NaBeG, BGBl. I Nr. 6/2026.

When will France transpose the 2026 amendments?

No date exists as of 29 October 2026; the bill is in Assemblée nationale committee. The EU deadline is 19 March 2027.

Does the EUR 450 million threshold apply in France for financial year 2027?

Not until France transposes Directive (EU) 2026/470. The bill would leave the French thresholds to a décret.

What replaced the H3C in France?

The H2A, created by ordonnance 2023-1142, which keeps the lists of commissaires aux comptes and OTIs.

Can an independent third-party organisation certify a sustainability report in France?

Yes: an OTI entered on the H2A's list V may certify (Article L. 232-6-3 III C. com.).