France transposed the Corporate Sustainability Reporting Directive (CSRD) into national law through Ordonnance n°2023-1142 (6 December 2023), with the Stop-the-Clock delays written in via Law no. 2025-391. At EU level, the Omnibus I simplification directive (in force 18 March 2026) then narrowed who reports: CSRD now applies to companies with more than 1,000 employees and net turnover above €450 million.
That leaves three groups of readers for this guide: French companies still in scope, which report for FY 2027 (published 2028) unless they already reported under the older NFRD regime; companies that have dropped out of scope; and the far larger group of French businesses that are not CSRD filers but receive sustainability data requests from clients and banks that are.
This guide covers the French transposition of CSRD, the post-Omnibus timeline and thresholds, the role of the AMF, and the practical route for suppliers asked for data. If you are new to the topic, start with our plain-language overview CSRD for Beginners.
1. Updated French CSRD Deadlines (2026)
Two EU reforms changed the timeline and the scope, and both now apply in France:
- The Stop-the-Clock Directive (EU) 2025/794 (April 2025) delayed the second and third reporting waves by two years. France transposed it via Law no. 2025-391 (DDADUE 2025).
- The Omnibus I simplification directive (Directive (EU) 2026/470), in force 18 March 2026, raised the scope thresholds to more than 1,000 employees and €450 million net turnover, and removed the listed-SME reporting track entirely.
The current position for French companies:
| Phase | Company type | First reporting year | First report published |
|---|---|---|---|
| Wave 1 | Large public-interest entities already under NFRD/DPEF | FY 2024 | 2025 |
| Wave 2 | Other large companies meeting the 1,000-employee and €450m thresholds | FY 2027 | 2028 |
| Wave 3 (listed SMEs) | Eliminated by Omnibus I | n/a | n/a |
| Suppliers and other businesses below the thresholds | Not CSRD filers | Voluntary, or when a client or bank asks | Ongoing |
Wave 1 companies that now fall below the new thresholds can use an optional transitional exemption for FY 2025 and FY 2026, subject to Member State implementation. For a full breakdown of what Omnibus I changed, see CSRD Omnibus Changes.
Despite the smaller scope, supplier data requests from large French companies have not stopped. Companies still reporting collect value-chain data, which means French businesses in their supply chains receive questionnaires regardless of their own reporting obligations. For EU-wide context, 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 you understand what applies 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 the European Sustainability Reporting Standards (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 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 Stop-the-Clock Directive (EU) 2025/794 into French law, delaying Wave 2 reporting to FY 2027 (published 2028). It kept the ordinance structure intact; only the dates moved.
Omnibus I (Directive (EU) 2026/470), the scope change
The Omnibus I directive entered into force at EU level on 18 March 2026. It raised the scope test to more than 1,000 employees and €450 million net turnover, removed listed SMEs from mandatory scope, and simplified the ESRS. The new thresholds apply to financial years starting on or after 1 January 2027, and Member States are working the changes into national law.
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 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.
A business below the CSRD thresholds may still supply data into its clients’ Vigilance Plans, which is one reason data requests have continued despite the smaller CSRD scope.
3. What the Rules Mean for Your Business
If your company is in scope of CSRD
Companies with more than 1,000 employees and over €450 million net turnover prepare a sustainability statement under the ESRS, built on a double materiality assessment, with limited assurance from a statutory auditor. Under the simplified ESRS adopted on 3 July 2026, only ESRS 2 remains mandatory for every reporter; the topical standards apply only where material. The simplified standards are mandatory from FY 2027, with optional early adoption for FY 2026. Our CSRD requirements checklist walks through the components of a compliant report.
If you have dropped out of scope
Companies between 250 and 1,000 employees, and listed SMEs, are no longer CSRD filers. Wave 1 reporters now below the thresholds can use the transitional exemption for FY 2025 and FY 2026, subject to French implementation. Voluntary reporting remains open, and many former in-scope companies keep a lighter version of their reporting for investors and lenders.
If you are a supplier asked for ESG data
Most French businesses fall here. You have no CSRD obligation, but larger clients, banks, and insurers request sustainability data as part of their own value-chain reporting. Omnibus I also capped what CSRD reporters may demand from value-chain partners with fewer than 1,000 employees: no more than the data points in the voluntary SME standard (VSME). The rest of this guide covers this path.
4. The supplier path: preparing without a legal obligation
Even without a mandatory reporting duty, there are straightforward steps a French business can take to be ready for the next questionnaire.
Step A - Understand your exposure
- Identify whether you supply or depend on larger enterprises that report under CSRD. They will expect data on workforce, supply chain, resource use, and governance.
- Check whether your company meets the CSRD thresholds today: more than 1,000 employees and over €450 million net turnover. Most businesses reading this section will be well below both.
- Review any existing sustainability or RSE documentation you already produce; many French businesses have voluntary reports that can be aligned with what clients ask for.
Step B - Start basic data collection
Begin gathering core sustainability information in a simple, proportional way. Useful categories include:
- 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 the voluntary reporting framework
- Use the Voluntary Sustainability Reporting Standard for SMEs (VSME) developed by EFRAG to structure disclosures; compare modules in VSME Basic vs Comprehensive. Free VSME report tools now generate a finished report at no cost.
- The VSME standard became an EU delegated act (the Voluntary Standard, or VS) on 3 July 2026; see what changes for FY 2027.
- France’s Portail RSE lets companies complete all VSME indicators online, and support programmes such as Bpifrance resources and ADEME training help you understand expectations.
Step D - Communicate to clients and stakeholders
- Let your clients know you are proactively preparing; 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.
- 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 to do now |
|---|---|---|---|
| Wave 1 | Large public-interest entities already under NFRD/DPEF | FY 2024 (published 2025) | Continue reporting; check whether the new thresholds or the transitional exemption apply |
| Wave 2 | Large companies over 1,000 employees and €450m turnover | FY 2027 (published 2028) | Formalise data systems, engage stakeholders, and refine the double materiality assessment |
| Listed SMEs | Removed from scope by Omnibus I | No CSRD obligation | Consider voluntary VSME reporting if clients or investors ask |
| Businesses in value chains | Firms below the thresholds | Voluntary, or when requested by clients | Build disclosure readiness at your own pace |
Note: the revised ESRS and the Voluntary Standard delegated acts were adopted on 3 July 2026 and are in the Parliament and Council scrutiny period. Monitor official updates until scrutiny completes.
6. Practical checklist for French suppliers
- Identify your role in the value chain: do you supply 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: 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 Stop-the-Clock delays on 30 April 2025, pushing Wave 2 to FY 2027.
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.
Who has to report under CSRD in France after the Omnibus changes?
Companies with more than 1,000 employees and net turnover above €450 million. The Omnibus I directive (in force 18 March 2026) raised the thresholds from the earlier “2 of 3” size test and removed listed SMEs from scope, so roughly 90% of previously in-scope entities drop out. Large public-interest entities already reporting continue; other in-scope companies report for FY 2027, published in 2028.
Does this mean smaller French businesses can ignore CSRD?
Not entirely. Businesses below the thresholds are not CSRD filers, but large clients, investors, banks, and insurers request sustainability data for their own reporting. Omnibus I caps those requests at the VSME data points for partners with fewer than 1,000 employees, which makes the voluntary SME standard the practical format for answering them.
What French resources exist to help me prepare?
Examples include France’s Portail RSE, which lets companies complete all VSME indicators online, Bpifrance webinars on sustainability readiness, ADEME’s “Pilotage RSE” portal, and regional chambers of commerce that offer diagnostics. These programmes provide templates, training, and diagnostic tools.
Will the reporting standards (ESRS) change again?
The revised, simplified ESRS were adopted as a delegated act on 3 July 2026 and are in the Parliament and Council scrutiny period. They apply from FY 2027, with early adoption possible for FY 2026. Only ESRS 2 stays mandatory for every reporter; topical standards apply where material. Businesses answering supplier requests do not need to wait: collecting core data now makes any future disclosure easier.
Key Terms
- CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464) requiring detailed sustainability disclosures by large companies.
- Omnibus I – EU simplification directive (Directive (EU) 2026/470, in force 18 March 2026) that raised CSRD thresholds to 1,000 employees and €450m turnover and removed listed SMEs from scope.
- VSME – Voluntary Sustainability Reporting Standard for SMEs, offering proportionate disclosure modules; adopted as the Voluntary Standard (VS) delegated act on 3 July 2026.
- ESRS – European Sustainability Reporting Standards that underpin CSRD disclosures for in-scope 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 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 Directive – Directive (EU) 2025/794 (April 2025) that postponed the second and third CSRD reporting waves 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 a business, often the source of CSRD data requests.
Conclusion and Next Steps
For companies still in scope, France offers a clear legal picture: the ordinance sets the framework, Law no. 2025-391 sets the FY 2027 date, and the simplified ESRS adopted in July 2026 define the content. The priority now is the double materiality assessment and reliable data systems ahead of the first FY 2027 report.
For everyone else, the pressure arrives through the value chain rather than the law. Focus on a handful of metrics this year, structure them with the VSME standard, and use French support programmes such as Portail RSE, Bpifrance, and ADEME. With a clear structure and consistent effort, readiness becomes a commercial advantage rather than an obstacle.