France transposed the Corporate Sustainability Reporting Directive (CSRD) into national law through Ordonnance n°2023-1142 (6 December 2023), with the Omnibus Stop-the-Clock delays written in via Law no. 2025-391. Wave 2 companies now report for FY 2027 (published 2028); listed SMEs report for FY 2028 (published 2029).
Small and growing businesses (SMEs) often feel the pressure sooner than the legal deadlines suggest — through data requests from larger French clients already in Wave 1 or Wave 2. Early preparation protects commercial relationships and turns compliance into a competitive advantage.
This guide covers the French transposition of CSRD, the updated Stop-the-Clock timeline, the role of the AMF, and the practical steps your business can take today. If you are new to the topic, start with our plain-language overview CSRD for Beginners.
1. Updated French CSRD Deadlines (2026)
France transposed the EU Omnibus Stop-the-Clock Regulation via Law no. 2025-391 (DDADUE 2025). The revised timeline for French companies is:
| Phase | Company type | First reporting year | First report published |
|---|---|---|---|
| Wave 1 | Large companies already under NFRD/DPEF | FY 2024 | 2025 |
| Wave 2 | Large non-listed companies (>250 employees or equivalent thresholds) | FY 2027 (delayed) | 2028 |
| Wave 3 | Listed SMEs | FY 2028 (delayed) | 2029 |
| Supply chain SMEs | Non-listed SMEs supplying Wave 1/2 companies | Voluntary — or when requested by clients | Ongoing |
Before the Omnibus: Wave 2 was FY 2025 (published 2026) and Wave 3 was FY 2026 (published 2027). Both delayed by two years. Monitor official updates as further refinements to ESRS are expected in late 2026.
Despite the delay in formal reporting, supplier data requests from French large companies have not slowed down. Wave 1 companies (already reporting) and Wave 2 companies (preparing now) are actively collecting value-chain data — which means French SMEs in their supply chains are receiving questionnaires regardless of their own reporting obligations.
For EU-wide context on all four waves, see CSRD Deadlines by Country.
2. How France Transposed CSRD into National Law
France transposed the CSRD through three main legal instruments. Knowing which law governs which obligation helps your business understand what applies to it and what does not.
Ordonnance n°2023-1142 (6 December 2023) — the primary transposition
This ordinance amended the French Code de commerce (Livre II, Titre III) to integrate CSRD disclosure obligations into French company law. It replaced the older NFRD-based DPEF (Déclaration de Performance Extra-Financière) regime for in-scope companies and aligned French reporting with ESRS. Published in the Journal Officiel on 7 December 2023 and entered into force on 1 January 2024 for Wave 1.
Décret n°2023-1394 (30 December 2023) — implementing measures
This decree set out the detailed thresholds, timelines, and assurance requirements needed to apply the ordinance. It defined how French companies calculate the CSRD size thresholds (employee, turnover, balance sheet) and specified the role of the statutory auditor in providing limited assurance on sustainability reports.
Law no. 2025-391 (30 April 2025) — DDADUE 2025 / Stop-the-Clock
This law transposed the EU Omnibus Stop-the-Clock Regulation (EU) 2025/780 into French law, formally delaying Wave 2 reporting to FY 2027 (published 2028) and listed SMEs to FY 2028 (published 2029). It keeps the ordinance structure intact — only the dates move.
Who enforces CSRD in France
Two French authorities supervise CSRD compliance:
- AMF (Autorité des Marchés Financiers) — supervises listed companies’ sustainability disclosures as part of regulated-market oversight. The AMF publishes annual reviews of reporting quality and issues guidance for issuers.
- H2A (Haute Autorité de l’Audit) — replaced the H3C in 2024 and oversees statutory auditors providing limited or reasonable assurance on sustainability information.
Non-listed companies report through the standard company-registry process (greffe du tribunal de commerce), with assurance provided by their statutory auditor (commissaire aux comptes).
How this connects to older French frameworks
French businesses have reported sustainability information for years under different regimes. CSRD does not replace them all — it layers on top:
- Loi Grenelle II (2010) — introduced environmental and social disclosure requirements for large French companies. Largely absorbed into the DPEF and now CSRD.
- Loi sur le Devoir de Vigilance (2017) — requires very large French groups to publish a Vigilance Plan covering human-rights and environmental risks in their value chain. Remains in force alongside CSRD.
- DPEF — the NFRD-era non-financial statement. Replaced by CSRD for in-scope companies from FY 2024.
Your business may also still supply data into its clients’ Vigilance Plans — which is why data requests have not slowed despite the CSRD delays. For EU-wide deadlines and waves, see CSRD Deadlines by Country.
3. What the Transposition Means for French SMEs
- If you are already in an earlier wave (for example, because you previously reported under NFRD/DPEF rules), your business is now preparing full CSRD reports.
- Typical SMEs sitting below the thresholds are not yet obliged to report under CSRD or ESRS, but larger clients will request data as part of their own value-chain reporting. Keep an eye on the wider timeline in CSRD deadlines for SMEs.
- French law provides first-year flexibility for certain disclosures where publication could harm competitive position, helping businesses ramp up proportionately.
4. What French SMEs should do now (voluntary preparation)
Even before mandatory reporting applies, there are straightforward steps your business can take to get ready.
Step A - Understand your exposure
- Identify whether you supply or depend on larger enterprises that will report under CSRD. They will expect data on workforce, supply chain, resource use, and governance.
- Check whether you meet any thresholds today that might trigger earlier obligations (for example, over 250 employees, €50m turnover, or €25m total assets).
- Review any existing sustainability or RSE documentation you already produce; many French SMEs have voluntary reports that can be aligned with CSRD expectations.
Step B - Start basic data collection
Begin gathering core sustainability information in a simple, proportional way. Useful categories include, as outlined in the CSRD requirements checklist:
- Environmental data: energy consumption, fuel use, water use, waste volumes, and proxy greenhouse gas indicators (such as electricity kWh or litres of fuel).
- Social/workforce data: number of employees, gender breakdown, training hours, and health and safety incidents.
- Governance/business conduct data: ethics policies, anti-corruption training, and supplier codes of conduct.
- Value-chain interactions: information you request from suppliers and data you provide to larger customers.
Step C - Use voluntary reporting frameworks
- Make use of French support programmes such as Bpifrance resources or ADEME training to understand expectations.
- Consider the Voluntary Sustainability Reporting Standard for SMEs (VSME) developed by EFRAG to structure disclosures; compare modules in VSME Basic vs Comprehensive.
- Prepare a simple annual summary for stakeholders (clients, lenders, insurers) showing that you are gathering relevant data and improving over time.
Step D - Communicate to clients and stakeholders
- Let your clients know you are proactively preparing for reporting — it builds trust and can differentiate you in tenders.
- In proposals or contracts, highlight the sustainability data you collect, improvement plans, and readiness to support downstream reporting requests.
- Consider publishing a one-page “Sustainability Snapshot” summarising key metrics and initiatives each year.
Step E - Build internal capability
- Assign responsibility for sustainability data collection (for example, in finance or operations).
- Develop simple workflows to gather utility bills, track workforce training, and map major suppliers, inspired by Value Chain Mapping for CSRD.
- Upskill staff or seek external training. French agencies such as ADEME or regional chambers of commerce frequently host webinars and diagnostics tailored to SMEs.
- Set realistic, incremental targets; improving one or two metrics per year is better than attempting everything at once.
5. Timeline for French businesses (at a glance)
| Phase | Company type | First reporting year | What you should do now |
|---|---|---|---|
| Wave 1 | Large companies already under NFRD/DPEF | Already or 2025 (for FY 2024) | Continue building full CSRD/ESRS reporting processes |
| Wave 2 | Large non-listed companies (over 250 employees or equivalent thresholds) | 2028 (for FY 2027) under the French delay | Formalise data systems, engage stakeholders, and refine double materiality assessments |
| Wave 3 | Listed SMEs | 2029 (for FY 2028) under the French delay | Pilot reporting processes now to avoid a last-minute scramble |
| SMEs in value chains | Smaller firms not yet required by law | Voluntary or when requested by clients | Use the extra time to build disclosure readiness |
Note: The above dates reflect the French transposition of the “Stop-the-Clock” package. Monitor official updates, as timelines may evolve.
6. Practical checklist for French SMEs
✔ Identify your role in the value chain: Are you a supplier to a larger firm subject to CSRD? ✔ Gather existing data: utility bills, workforce headcount, training hours, and waste figures. ✔ Select 3-5 core metrics this year (for example, electricity kWh, employee training hours, anti-corruption policy status). ✔ Document governance: Who is responsible for sustainability, how often you review progress, and how improvements are tracked. ✔ Prepare a one-page summary for clients: explain what data you collect and how you plan to improve performance. ✔ Engage staff: raise awareness of sustainability responsibilities, especially across finance, operations, and HR. ✔ Monitor French support programmes: leverage tools and guidance from Bpifrance, ADEME, and regional agencies. ✔ Review annually: update metrics, refine data collection processes, and communicate progress.
Frequently Asked Questions
Which French law transposed CSRD into national law?
CSRD was transposed through Ordonnance n°2023-1142 of 6 December 2023, which amended the French Code de commerce to integrate CSRD disclosure obligations. Décret n°2023-1394 followed on 30 December 2023 with implementing measures. Law no. 2025-391 (DDADUE 2025) then transposed the Omnibus Stop-the-Clock delays on 30 April 2025, pushing Wave 2 to FY 2027 and listed SMEs to FY 2028.
Who supervises CSRD compliance in France?
For listed companies, the AMF (Autorité des Marchés Financiers) reviews sustainability disclosures as part of regulated-market oversight and publishes annual reports on reporting quality. For assurance, the H2A (Haute Autorité de l’Audit) — which replaced the H3C in 2024 — oversees statutory auditors providing limited assurance on sustainability information.
What exactly is the “Stop-the-Clock” delay and how does it affect my business?
The “Stop-the-Clock” directive delays the mandatory first reporting date for companies in the second and third waves of CSRD by approximately two years. For France, this means large non-listed entities report for FY 2027 (filing in 2028), while listed SMEs report for FY 2028 (filing in 2029). Even if you are not in those categories, the delay provides more time to prepare before clients start requesting information.
Does this mean small French SMEs do not need to prepare anything?
No. While many SMEs are not directly required to report yet, they are indirectly affected because large clients, investors, banks, and insurers increasingly request sustainability data. Early preparation delivers practical benefits and protects commercial relationships.
What French resources exist to help me prepare?
Examples include Bpifrance webinars on CSRD readiness, ADEME’s “Pilotage RSE” portal, and regional chambers of commerce that offer diagnostics such as “Diag Adaptation” on climate resilience. These programmes provide templates, training, and diagnostic tools tailored to French SMEs.
Will the reporting standards (ESRS) change and should I wait for them?
EFRAG continues to refine the ESRS and simplified VSME standard, but SMEs do not need to wait. Collecting data now and testing voluntary disclosures will make future compliance easier and signal readiness to partners.
Key Terms
- CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464) requiring detailed ESG disclosures by companies.
- VSME – Voluntary Sustainability Reporting Standard for SMEs, offering proportionate disclosure modules.
- ESRS – European Sustainability Reporting Standards that underpin CSRD disclosures for large companies.
- Ordonnance n°2023-1142 – The French ordinance of 6 December 2023 that transposed CSRD into the Code de commerce.
- Law no. 2025-391 (DDADUE 2025) – French law of 30 April 2025 that transposed the Omnibus Stop-the-Clock delays.
- AMF – Autorité des Marchés Financiers, the French regulator supervising listed-company sustainability disclosures.
- H2A – Haute Autorité de l’Audit, the French authority overseeing statutory auditors and sustainability assurance (replaced the H3C in 2024).
- DPEF – Déclaration de Performance Extra-Financière, the NFRD-era French non-financial statement, replaced by CSRD for in-scope companies.
- Duty of Vigilance Law – French law (2017) requiring large groups to publish a Vigilance Plan covering human-rights and environmental risks — remains in force alongside CSRD.
- Stop-the-Clock Regulation – EU Regulation 2025/780 that postpones Wave 2 and Wave 3 CSRD timelines by two years.
- Double materiality – Requirement to consider both how sustainability matters affect the business and how the business affects people and the environment.
- Value chain – The network of upstream suppliers and downstream customers connected to your business, often the source of CSRD data requests.
Conclusion and Next Steps
For small and growing businesses in France, this moment is an opportunity rather than a compliance crisis. The transposition via Ordonnance n°2023-1142 and Law no. 2025-391 gives clear visibility of future obligations — and the Stop-the-Clock delay gives time to set up robust data collection, governance, and communication systems.
Focus on a handful of metrics this year, speak regularly with larger clients about your readiness, and tap into French support programmes such as Bpifrance, ADEME, and regional chambers of commerce. With a clear structure and consistent effort, CSRD becomes a competitive advantage — not an obstacle.