The tracker · French

French Duty of Vigilance Law

In forceFrenchEntry updated September 2026

The pioneering 2017 framework for mandatory vigilance, this law legally compels large French companies to actively prevent global human rights and environmental harms, backed by fault-based civil liability and a growing history of extraterritorial enforcement.

Status
In force
Enacted
March 2017
First compliance deadline
2018
Companies in scope
French companies with 5,000 employees in France or 10,000 worldwide
Maximum penalty
Injunctions and civil damages; periodic penalty payments
Civil liability
Yes, fault-based liability for failure to establish or implement an adequate plan
Enforcement body
Civil courts, principally the Paris judicial court

Latest movement

Paris court ordered TotalEnergies on 25 June 2026 to add Scope 3 emissions to its vigilance plan, following the first damages award in March.

In plain language

What this law does

The French Duty of Vigilance Law mandates that large French companies publish and implement a comprehensive plan to identify and mitigate human rights and environmental risks across their global operations, subsidiaries, and supply chains. Unlike purely disclosure-based regulations, this law enforces strict accountability by allowing French courts to mandate plan corrections and award financial damages to victims of corporate inaction. Because the judiciary has firmly established that vague or generic plans are legally insufficient, covered companies are compelled to demand detailed, verifiable compliance data from their suppliers rather than accepting surface-level assurances. In March 2026 the Paris Judicial Court held the French parent company of the Yves Rocher group liable for union-related dismissals at its Turkish subsidiary, the first award of damages under the law, confirming that legal responsibility extends well beyond France's domestic borders.

In June 2026 the same court ordered TotalEnergies to complete its vigilance plan within six months by adding Scope 3 greenhouse gas emissions to its risk mapping and measures. The court treated climate risk as an environmental risk under the law, but it declined to set emissions targets or impose a penalty payment, and it adjourned the remaining claims to 21 January 2027. For suppliers, the ruling signals that emissions data will sit alongside human rights data in what French buyers ask for.

Obligations

What it asks of companies

  1. Published vigilance plan

    The plan must include risk mapping, assessment procedures, mitigation actions, an alert mechanism, and monitoring of effectiveness.

  2. Effective implementation

    Courts have confirmed the duty covers implementation in practice, not the mere publication of a document.

  3. Stakeholder consultation on the alert mechanism

    The alert mechanism must be developed in consultation with representative trade unions.

2017

Law adopted after constitutional review removed criminal fines

2019 to 2023

First wave of formal notices and lawsuits against energy retail and utility companies

2023

La Poste ruling set the first detailed judicial standard for plan adequacy.

12 March 2026

Paris Judicial Court held the French parent company of the Yves Rocher group liable for union-related dismissals at its Turkish subsidiary, the first award of damages under the law.

25 June 2026

Paris Judicial Court ordered TotalEnergies to complete its vigilance plan within six months by adding Scope 3 emissions, without a penalty payment; remaining claims adjourned to 21 January 2027.

2026

Docket of vigilance cases continues to grow at the Paris judicial court.

Changelog

Entry history

September 2026

Named the March 2026 Yves Rocher ruling, added the June 2026 TotalEnergies judgment, and corrected strict to fault-based civil liability.

February 2026

Case law summary refreshed with recent Paris judicial court decisions.

Trade under this regime · Regulated Trade Index

Exposed export value at full application, across the ten tracked origins · Figures come from UN Comtrade. For each country we use what its buyer markets reported importing, rather than what the country itself reported exporting, because several tracked countries report to Comtrade late or not at all. Every share is measured against that country's exports to the nine regulated markets this index tracks, not against its total exports to the world, because no reliable world total exists for countries that under-report. European Union figures add up all twenty seven member states. The European product breakdown by chapter is estimated from the four largest importers, Germany, France, the Netherlands and Italy, and scaled up to the full twenty seven member total, so it captures which products dominate without understating any single one. · methodology

$13bn
India$4.3bnVietnam$3.0bnBangladesh$1.7bnBrazil$1.7bnThailand$1.6bnIndonesia$0.9bn

Sources

Primary documents

Coverage

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