CSRD in France: Implementation Status, Scope and Assurance Rules

France is the EU country furthest down the CSRD road and the country where the current statutory text is furthest out of sync with what the EU directive now requires.

France was the first member state to transpose the CSRD, through Ordonnance n° 2023-1142 of 6 December 2023. That ordinance is still in force, with the amendments made by the ratifying law and by the Stop-the-Clock transposition in 2025. What has not happened yet is a French retransposition of the substantive Omnibus. For now, French statute still describes a Wave 2 that the EU has already narrowed.

This guide sets out what the French CSRD regime actually says today, where it diverges from the amended EU directive, and the practical consequences for in-scope French companies, their consultants and their assurance providers.

Last reviewed: 18 October 2026. French transposition of the substantive Omnibus (Directive (EU) 2026/470) is pending. Verify the current position before relying on anything here for a filing decision.

Where the French legislation actually stands

Transposition was done through a stack of instruments, not a single Act.

• Ordonnance n° 2023-1142 du 6 décembre 2023 relative à la publication, au contrôle et à l'accessibilité de certaines informations de durabilité et aux obligations environnementales, sociales et de gouvernement d'entreprise des sociétés commerciales. This is the core text, inserted into the Code de commerce.
• Loi n° 2024-537 du 13 juin 2024 (loi "attractivité") ratifying the ordinance and making targeted fixes.
• Décret n° 2023-1394 du 30 décembre 2023 and the accompanying Arrêté fixing the application dates per wave and the detail of the OTI regime.
• Loi n° 2025-391 du 30 avril 2025 transposing Directive (EU) 2025/794 — the Stop-the-Clock Directive — pushing back the Wave 2 and Wave 3 first-application dates.

What has not happened — at the time of writing — is a French retransposition of Directive (EU) 2026/470, the substantive Omnibus adopted on 24 February 2026, published in the OJEU on 26 February 2026 and in force since 18 March 2026. France has until 19 March 2027 to transpose it. Until then, the French statutory thresholds, the French scope test and the French carve-outs are still the pre-Omnibus ones carried through Stop-the-Clock. For the EU-level detail of what has changed, see our Omnibus guide.

A drafting detail that matters

The reporting duty sits mainly in the Code de commerce, Livre II, Titre II, with the operational provisions grouped around Articles L.232-6-3 and L.233-28-4 for consolidated groups, and the implementing detail in the Partie Réglementaire (R. series) added by the 30 December 2023 decree. The assurance regime sits in a separate limb — Articles L.821-54 and following for the sustainability endorsement of commissaires aux comptes, and the OTI framework in the same book.

The practical consequence: a French CSRD question almost always needs two reads — one in the ordinance (what has to be reported) and one in the decree (how, by whom, by when). An adviser who quotes only one is quoting half the regime.

Who is in scope under French law today

Under the French text as it stands, mandatory scope follows the pre-Omnibus wave architecture, with Stop-the-Clock dates:

• Wave 1 — large public-interest entities and parents of large groups above 500 employees. First financial year opening on or after 1 January 2024, reports in 2025.
• Wave 2 — other large undertakings exceeding two of the three criteria (250 employees, €25M balance sheet, €50M net turnover) at individual or group level. First financial year opening on or after 1 January 2027 (Stop-the-Clock postponement, from the original 2025).
• Wave 3 — listed SMEs. First financial year opening on or after 1 January 2028 (Stop-the-Clock postponement).
• Wave 4 — large non-EU parent groups with significant EU activity, through an EU subsidiary or branch. First financial year opening on or after 1 January 2028.

The Omnibus substantive directive has already narrowed the EU mandatory scope to undertakings exceeding both more than 1,000 employees and more than €450 million net turnover for financial years beginning on or after 1 January 2027. France has not transposed that narrowing yet.

The in-force mismatch

The gap between the French statute and the amended EU directive is not academic. On the French text, a Wave 2 undertaking with 600 employees and €200 million turnover enters mandatory scope at FY 2027. On the EU directive as amended, it does not. Two practical consequences:

• For the Wave 2 cohort that drops out at EU level but not yet at French level: plan on the EU direction of travel, but document the French position you take and when you took it. If the French retransposition arrives late in 2026 or in 2027, your decision will have been made under a text that no longer stands. A written note of the assumptions behind your scoping decision is the audit trail your assurer will ask for.
• For undertakings that are in scope under both texts: nothing changes. The size test is cumulative, the scope test is tighter not looser, and the reporting duties under the ordinance continue to apply.

The Portail RSE (portail-rse.beta.gouv.fr) tracks the French position and should be re-checked before relying on any threshold answer for a filing decision.

What French Wave 1 companies actually did for FY 2024

France had a live CSRD duty in FY 2024, which Germany and the Netherlands did not. CAC 40 and SBF 120 Wave 1 reporters filed their first full ESRS sustainability statements with their 2024 annual reports, published in Spring 2025. The AMF's end-2024 and 2025 recommendations frame what the regulator looked for on first application: a readable double materiality assessment, explicit disclosure of material topics and the IROs behind them, and a clear link between material topics and the data points reported.

Early assurance work ran against the French OTI/CAC framework (see below). Where sustainability information had previously been reported under the DPEF regime (déclaration de performance extra-financière, Code de commerce Art. L.225-102-1 as amended by the Grenelle II lineage), the DPEF duty was replaced by the CSRD sustainability statement — not run in parallel. Companies that had been using GRI or an in-house framework needed to pivot to the ESRS structure.

For a working glossary of the standards themselves, see our ESRS standards guide.

Where the report sits, and where it is filed

Under the ordinance, the French sustainability statement is published as an identifiable section inside the rapport de gestion (for a single undertaking) or the rapport sur la gestion du groupe (for a consolidated group). It is not a standalone sustainability report sitting beside the management report, and separate publication outside the rapport de gestion does not discharge the obligation.

Filing follows the ordinary French annual-filing channel:

• Greffe du tribunal de commerce, electronically, together with the annual accounts and the management report (Articles L.232-21 to L.232-23 Code de commerce).
• AMF supervision for market-listed issuers, who publish the sustainability section as part of the rapport financier annuel. The AMF's periodic recommendations now explicitly cover the CSRD disclosures and will shape enforcement priorities.
• Format: the French regime followed the ESEF/XHTML preparation route for the management report with digital tagging of the sustainability information. The Omnibus opened a permanent disclosure solution member-state option — prepare the authoritative report normally, convert to the electronic format for publication. Whether France will take that option up on retransposition is open. Our XBRL and digital tagging guide covers the common mechanics.

Language: French is the default

For a French company filing in France, the authoritative language of the rapport de gestion is French. A translation may accompany the filing; it does not replace it. A listed issuer's financial communications in other languages do not discharge the French filing duty.

For French subsidiaries of international groups, the practical answer is almost always a French-language sustainability section in the rapport de gestion of the French entity, aligned with but not identical to the parent's group-level sustainability statement. The alignment work and the French drafting are usually the two separate workstreams a consultant is asked for.

Assurance: OTI or commissaire aux comptes

This is where the French regime diverges most sharply from Germany, and where the ordonnance made a deliberate choice.

Limited assurance, and it stays there. The step-up to reasonable assurance has been dropped by the Omnibus directive. The Commission is to adopt harmonised limited assurance standards by 1 July 2027. Our assurance guide covers what limited assurance actually involves.

Two kinds of provider may sign the opinion. France took the member-state option that Germany did not. The sustainability assurance can be given by:

• a commissaire aux comptes (CAC) who holds the visa de durabilité — the sustainability endorsement — recorded with the Haute Autorité de l'Audit, or
• an Organisme Tiers Indépendant (OTI), accredited by the COFRAC under NF EN ISO/IEC 17029 for the sustainability engagement.

The CAC route is the natural extension of the French statutory audit. The OTI route is the continuation of the pre-CSRD DPEF verification regime, where OTIs had been the designated verifiers since 2017. In practice, the shortlist in a tender today includes both, and the choice between them has become one of the first substantive decisions in a CSRD programme.

Oversight: H2A. The Haute Autorité de l'Audit (H2A), successor to the H3C from 1 January 2024, supervises both CACs and OTIs for the sustainability engagement, including the sanctions regime. The CNCC's professional guidance for CACs taking on the sustainability endorsement is the companion document for the CAC side.

Independence rules. As under the EU directive, the independence rules apply to the OTI or CAC performing the sustainability assurance. If you want a dry run on the file without engaging your assurer, that is a different conversation — see pre-assurance for how that engagement is scoped so it does not touch the statutory role.

Penalties and enforcement

The French penalty architecture is lighter at the headline level than Germany's but carries personal criminal exposure that the German one does not. Three layers to be aware of:

• Civil / administrative fines. Up to €75,000 for individuals and €375,000 for legal entities for failure to publish the sustainability information required by the Code de commerce (Art. L.822-40 and the related provisions).
• Criminal liability for knowingly publishing or presenting materially false sustainability information, by analogy with the long-standing financial-information offences. The French regime is one of the few in the EU that reaches into personal criminal liability for sustainability misstatements.
• AMF supervision for market-listed issuers, with its own sanction powers under the Code monétaire et financier. The AMF's enforcement priorities for sustainability reporting are set out in its yearly recommendations and have been visible in its reviews of FY 2024 CAC 40 reports.

For a comparative view across member states, see CSRD penalties and non-compliance.

What French companies should do now

1. Re-test whether you will still be in scope under the Omnibus. Run the 1,000-employee and €450 million turnover test at group level for financial years beginning on or after 1 January 2027. If you drop out under the amended EU directive but not yet under French law, write up the position and the date you took it.
2. Decide between CAC and OTI deliberately, not by default. The CAC with visa de durabilité has the ready-made integration with your financial audit. The OTI brings a longer sustainability track record from the DPEF years. Put both in the tender and compare on the sustainability work plan, not on familiarity.
3. Keep the ESRS discipline from your FY 2024 report, even if Omnibus narrows the required set. The simplified ESRS Set 1 (expected in late 2026) will drop data points but will not change the structure of the sustainability statement. Rebasing is work; starting over is more.
4. Verify where your sustainability section lives in the rapport de gestion. A number of early FY 2024 reports published a standalone sustainability report alongside the rapport de gestion — the French regime does not permit that as a discharge of the obligation. Confirm placement with your CAC/OTI early.
5. Track Portail RSE and H2A guidance for the retransposition of the substantive Omnibus and the Commission's limited-assurance standards due by 1 July 2027.

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Getting this right in a jurisdiction where the statute is in force but out of sync with the amended EU directive is exactly the kind of problem where local experience pays for itself. Browse the CSRD and sustainability consultants listed in France, or read our guide on how to hire a CSRD consultant.