French BEGES 2026 for companies with 50-500 employees: obligation or preparation?

Quick answer. As of 17 May 2026, the French BEGES is not mandatory based solely on a headcount of 50 to 500 employees in metropolitan France. Article L229-25 of the French Environmental Code targets private legal entities with more than 500 employees in metropolitan France (more than 250 overseas). A 50-500 employee SME may nevertheless be required to produce a BEGES under pressure from a CSRD customer, a bank or a public tender. Since the Green Industry Act of 23 October 2023, the non-publication penalty has been raised to EUR 50,000 (EUR 100,000 in case of repeat offence).

The French greenhouse-gas emissions inventory (BEGES) is governed by Article L229-25 of the Environmental Code, supplemented by Decree no. 2022-982 of 1 July 2022, which made Scope 3 mandatory from 1 January 2023. Three texts now structure the 2026 exercise:

1. Article L229-25 of the Environmental Code: defines who is subject (threshold of 500 employees in metropolitan France, 250 overseas) and the frequency (4 years for companies, 3 years for local authorities).
2. Decree no. 2022-982 of 1 July 2022: extends the BEGES to significant indirect emissions under Scope 3 and requires a published transition plan.
3. Law no. 2023-973 of 23 October 2023 (Green Industry Act): strengthens penalties and the effectiveness of inspections by the regional environmental authority (DREAL).

For companies with 50 to 500 employees, the question is no longer purely regulatory. Recently, the CEO of a 180-employee industrial SME (Ile-de-France region, automotive subcontracting) approached us after its main customer (a listed group subject to CSRD) demanded a Scope 1+2+3 carbon footprint within 9 months, under penalty of being delisted as a supplier. The SME had no legal BEGES obligation, but it did have a de facto contractual obligation.

The BEGES obligation is assessed at the level of the legal entity (SIREN), not by establishment. The table below cross-references headcount, status and 2026 applicability.

Freshness note: updated on 17 May 2026. Any future extension of scope (notably via a possible European Omnibus revision or a post-COP national decree) should be verified on Legifrance.

The BEGES relies on the internationally recognised breakdown of the GHG Protocol into three scopes. Since the decree of 1 July 2022, all three scopes must appear in the regulatory BEGES, with Scope 3 coverage of at least 80% of significant categories.

The BEGES must also include a transition plan setting out reduction targets, resources mobilised and planned actions. Without a transition plan, the filing on the ADEME platform can be rejected.

Below is the method we apply at Hayot Expertise for SMEs moving to the regulatory BEGES or seeking a reliable voluntary carbon footprint.

1. Frame the organisational perimeter: legal entity (SIREN), covered sites, operational or financial control approach, justified exclusions.
2. Choose the reference year: most recent closed financial year with reliable data (12 months of energy invoices, analytical purchasing accounts, HR data).
3. Collect primary data: energy invoices, vehicle fleet and mileage, French Chart of Accounts classes 60-61-62 for purchases, HR data on commuting, weighed waste.
4. Apply ADEME Base Empreinte® emission factors 2026: public reference version, updated annually; document every trade-off between monetary and physical factors.
5. Build the transition plan: reduction trajectory consistent with a climate scenario (ideally aligned with SBTi or the French National Low-Carbon Strategy), 3 to 5 quantified levers, multi-year budget.
6. Publish on bilans-ges.ademe.fr: legal entity account, filing of the methodological file and the transition plan, consistency check by the DREAL.

BEGES SME preparation checklist#

• define the legal entity and perimeter (SIREN, sites, justified exclusions);
• choose a reference year with robust data, representative of the activity;
• collect energy (12 months of invoices), fleet (registration documents and km), purchases (general ledger classes 60-61-62), fixed assets (account 21), waste, upstream/downstream freight, business travel and commuting;
• identify the 5 to 8 significant categories representing at least 80% of the total;
• document each assumption and emission factor (source, version, date);
• build a quantified 5-year reduction plan with budget and KPIs;
• publish the BEGES and its transition plan on bilans-ges.ademe.fr;
• update the inventory every 4 years and the steering indicators every year.

Before 2023, the penalty regime for an unpublished BEGES was considered weakly dissuasive (EUR 10,000, rarely enforced). Law no. 2023-973 of 23 October 2023 on green industry has profoundly changed that balance.

Inspection is carried out by the DREAL at regional level. The appointment by the DGEC of agents dedicated to BEGES compliance from 2024 has multiplied reminder letters to non-publishing reporting entities.

Crossing the 500-employee threshold during a financial year. The company has a period to publish its first BEGES after crossing (usually understood as 12 months following the close of the financial year that crossed the threshold). We recommend anticipating 12 to 18 months upstream to collect a reliable reference year.

Group with several subsidiaries above 500 employees. The 2022 decree authorises consolidated publication by distinct legal entity (different SIRENs) for all French activities, provided the methodology, perimeter, emission factors and reference year are consistent.

French subsidiary of a foreign group. Only the French SIREN counts. A French subsidiary of 600 employees belonging to a 20,000-employee American group is subject to the BEGES. Conversely, a French subsidiary of 80 employees in a 5,000-employee Asian group is not required, unless the parent company requests it for its own consolidated reporting.

50-500 employee SME supplier to a large CSRD group. The obligation is contractual, not legal. The SME must provide at least Scopes 1 and 2 (often in kgCO2e per unit sold) and an estimate of the upstream Scope 3 categories requested by the customer (most often purchases, freight, travel). The inventory can be simplified but must remain traceable.

Articulation of BEGES, VSME and CSRD. The BEGES feeds ESRS E1 (climate change) of the CSRD for groups subject to the obligation. For voluntary SMEs, the voluntary VSME standard (Voluntary SME standard) published by EFRAG in December 2024 offers a lighter framework that reuses BEGES data without imposing the same depth as the full ESRS.

• Scope 3 underestimated or forgotten. The most frequent mistake: purchases (PCG class 60), often the first emissions category for a tertiary or industrial SME, are forgotten or estimated using a crude monetary factor.
• Undocumented reference year. Without a stable reference year, it is impossible to measure a credible reduction trajectory.
• Empty transition plan. A BEGES without a quantified target or budget is now flagged by the DREAL.
• Confusion between BEGES, carbon footprint and product carbon footprint. The BEGES is the French regulatory framework. The carbon footprint is a method (often that of the Association Bilan Carbone, under ABC licence). The product carbon footprint (LCA) follows ISO 14067 and is not a BEGES.
• Outdated emission factors. The ADEME Base Empreinte changes every year; using a 2022 version in 2026 exposes the company to challenge by a statutory auditor or customer.
• Unstable perimeter from one inventory to the next. Changing the perimeter between two exercises makes any comparison impossible and distorts the tracking of the transition plan.
• Unfunded reduction promises. Announcing a -40% target in 2030 without a corresponding CAPEX budget legally weakens the company.

Across the BEGES review missions we have conducted in 2024 and 2025 for SMEs and mid-caps, nearly 6 out of 10 inventories presented at least one major weakness: Scope 3 coverage below 80% without justification, undocumented emission factors, a transition plan reduced to intentions without a budget, or a perimeter incompatible with the declared SIREN.

At Hayot Expertise, as a chartered accountant registered with the Order, we treat the BEGES as a fully fledged regulatory statement. Our reference method runs over 6 weeks for an SME of 100 to 500 employees:

• Weeks 1-2: scoping and collection of primary data (energy, fleet, purchases, fixed assets) from your analytical accounts and your FEC (French standard accounting export).
• Weeks 3-4: application of ADEME Base Empreinte® 2026 factors, calculation of the three scopes, identification of significant categories.
• Week 5: construction of the transition plan with your management team (3 to 5 quantified levers, CAPEX, trajectory).
• Week 6: drafting the report, filing on bilans-ges.ademe.fr and preparing customer/bank communication.

This accounting-CSR combination is rare: most carbon consultancies have no access to accounting entries, and most accounting firms do not apply the GHG Protocol. Our positioning reconciles carbon data and financial data, and turns the BEGES into a budgeting tool (energy, fleet, purchases, freight).

Hayot Expertise advice. If your SME is approaching 500 employees or facing pressure from a large CSRD customer, do not wait for a formal notice to act. A defensible BEGES is prepared 12 to 18 months before the first mandatory filing. Coupled with a Power BI dashboard connecting carbon data and gross margin, it becomes a strategic decision-making tool, not an administrative constraint.

To position the BEGES in the wider 2026 ESG ecosystem, see our complementary French analyses: carbon footprint and competitive advantage, CEO CSRD playbook, VSME 2026 SME guide, ESG reporting in 2026, CSRD double materiality analysis and Grand Paris ZFE 2026 and company fleet. To structure the engagement, see our CSR and CSRD reporting, statutory audit, outsourced CFO for SMEs and our CSR and sustainability reporting sector pages.

Does a 80-employee SME have to prepare a BEGES in 2026?#

No, based solely on its headcount in metropolitan France. Article L229-25 targets legal entities with more than 500 employees in metropolitan France and more than 250 employees overseas. An 80-employee SME in metropolitan France is therefore not required to publish a regulatory BEGES in 2026. It may, however, be required by a CSRD customer, a bank or a public tender demanding a carbon footprint.

What is the exact threshold for the BEGES obligation?#

The legal threshold is more than 500 employees in metropolitan France and more than 250 employees in French overseas regions and departments for private legal entities. State services, local authorities with more than 50,000 inhabitants and certain public bodies with more than 250 staff are also concerned. Headcount is assessed at the level of the legal entity (SIREN), not by establishment.

Is Scope 3 mandatory in the BEGES in 2026?#

Yes. Since Decree no. 2022-982 of 1 July 2022, applicable from 1 January 2023, reporting organisations must include significant indirect emissions from Scope 3. Expected coverage is at least 80% of significant categories: purchases, upstream and downstream freight, business travel and commuting, use of sold products, end-of-life. Before 2022, Scope 3 was recommended but not mandatory.

What are the penalties for non-publication of the BEGES?#

Since Law no. 2023-973 of 23 October 2023 on green industry, the maximum fine for non-preparation or non-submission of the regulatory BEGES is EUR 50,000 (compared with EUR 10,000 previously), raised to EUR 100,000 in case of repeat offence. The BEGES must be filed on the public platform bilans-ges.ademe.fr and inspection is carried out by the DREAL.

How often must a BEGES be published?#

Every 4 years for subject private companies and every 3 years for local authorities and public bodies. Publication is made on the official ADEME platform, accompanied by the transition plan setting out the objectives, resources and emission reduction actions.

What is the difference between BEGES, carbon footprint and CSRD reporting?#

The BEGES is the French regulatory framework based on Article L229-25 of the Environmental Code, limited to Scopes 1, 2 and significant Scope 3. The carbon footprint is a broader methodology (often that of the Association Bilan Carbone) used to build the BEGES but which can also be voluntary. CSRD reporting is a separate European directive, based on the ESRS standards, covering all ESG themes including climate (ESRS E1). BEGES data feeds ESRS E1 but does not replace it.

Does a French subsidiary of a foreign group have to prepare a BEGES?#

Yes, as soon as it crosses the threshold of 500 employees in metropolitan France (or 250 overseas), regardless of the nationality of the group. The perimeter is assessed at the level of the French legal entity. For groups, the 2022 decree authorises consolidated publication by distinct SIRENs for all French activities, subject to methodological consistency.

How should the BEGES be prepared if the SME expects to cross the 500-employee threshold within 2 years?#

Anticipate 12 to 18 months before crossing. Year N-2: scoping the perimeter, choice of reference year, first collection of energy and fleet data. Year N-1: extension to purchases and freight to launch Scope 3. Year N: first complete BEGES with transition plan. Filing within 6 months following the actual threshold crossing avoids any risk of penalty and provides time to consolidate emission factors.

• The legal BEGES threshold is 500 employees in metropolitan France and 250 overseas (Article L229-25 Environmental Code). SMEs with 50-500 employees are not required by their headcount alone.
• Scope 3 has been mandatory since 1 January 2023 (Decree no. 2022-982 of 1 July 2022) with minimum coverage of 80% of significant categories.
• Penalties have been multiplied by 5 since the Green Industry Act of 23 October 2023: EUR 50,000 (EUR 100,000 in case of repeat offence).
• Frequency: 4 years for companies, 3 years for local authorities, filed on bilans-ges.ademe.fr with a mandatory transition plan.
• A 50-500 employee SME under CSRD customer pressure must anticipate: a voluntary carbon footprint, even simplified, secures strategic contracts and bank financing.
• A defensible BEGES is built like an accounting statement: stable perimeter, documented emission factors, quantified transition plan, traceability of trade-offs.

Official sources#

• Legifrance - Article L229-25 of the French Environmental Code
• Legifrance - Decree no. 2022-982 of 1 July 2022 on greenhouse-gas emissions inventories
• Legifrance - Law no. 2023-973 of 23 October 2023 on green industry
• French Ministry for Ecological Transition - Greenhouse-gas emissions inventories (BEGES)
• ADEME - Official Bilans GES platform
• Bpifrance - Mandatory GHG inventory (BEGES): why and how to prepare it
• economie.gouv.fr - Everything you need to know about CSRD