European Member States and UK
French Duty of Vigilance Law
Loi de Vigilance · France
Plain-language summary
The French Duty of Vigilance Law (Loi relative au devoir de vigilance) was the first national law in Europe to require large companies to conduct due diligence across their supply chains and to create civil liability for failures of vigilance. Enacted in 2017, it established a model that has since influenced both the EU CSDDD and national legislation in Germany, Norway, and the Netherlands.
The law requires covered French companies to publish and implement a "plan de vigilance" covering their own activities, subsidiaries, subcontractors, and suppliers with whom they have an established commercial relationship. The plan must identify serious risks to human rights, fundamental freedoms, health, safety, and the environment, and include specific measures to prevent and mitigate those risks.
The distinctive feature of the French law is its civil liability provision: any person with a legitimate interest can bring a claim before a French court seeking damages if they can show that a company failed to fulfil its vigilance obligations and that this failure caused harm. Several cases are currently before French courts, with implications for how the law applies to global supply chains.
Key obligations
- 1
Publish a vigilance plan
Companies must publish an annual plan identifying risks and describing measures to identify and prevent serious violations of human rights and environmental standards.
- 2
Risk mapping
The plan must include a risk map identifying and prioritising risks across operations, subsidiaries, and established commercial relationships.
- 3
Regular assessment procedures
Companies must establish procedures to regularly assess subsidiaries, subcontractors, and suppliers with whom they have an established commercial relationship.
- 4
Appropriate actions to mitigate risks
The plan must describe specific actions taken to mitigate identified risks across the supply chain.
- 5
Alert and monitoring mechanism
Companies must implement an alert mechanism to collect reports from persons facing or witnessing serious violations, and a system to monitor its effectiveness.
Implementation timeline
March 2017
Law enacted
The Loi de Vigilance was promulgated after a lengthy legislative process.
March 2018
First vigilance plans due
Covered companies published their first vigilance plans.
2026-05
Court of Cassation ruling on expanded interpretation
The Court of Cassation issued a significant ruling upholding an expanded interpretation of the established commercial relationship concept, potentially extending obligations to a broader set of supply chain relationships.
Change log
The Court of Cassation upheld a lower court ruling that the concept of "established commercial relationship" under the Duty of Vigilance Law should be interpreted broadly to include indirect commercial relationships where the company exercises significant commercial influence. This ruling has significant implications for how far down supply chains French companies must exercise vigilance.
Official sources
- Official text Loi no. 2017-399 relative au devoir de vigilance Legifrance