French CSR obligations 2026: CSRD, BEGES, Equality Index

Quick answer. As of May 2026, CSR obligations for French companies rest on four pillars: the CSRD (only wave 1 enforced after the Omnibus package of 26 February 2025), the BEGES carbon report from 500 employees in mainland France (Article L. 229-25 of the Environmental Code), the Professional Equality Index from 50 employees, and contractual obligations flowing down the value chain. Penalties reach EUR 50,000 for CSRD breaches and 1% of payroll for Equality Index breaches.

The French CSR landscape has profoundly changed between 2023 and 2026. Directive (EU) 2022/2464, known as CSRD (Corporate Sustainability Reporting Directive), was transposed into French law by Ordinance no. 2023-1142 of 6 December 2023 and Decree no. 2023-1394 of 30 December 2023, codified at Articles L. 232-6-3 and R. 232-8-1 et seq. of the French Commercial Code. The CSRD definitively replaces the former DPEF (Non-Financial Performance Declaration, ex-Article L. 225-102-1 of the Commercial Code).

The initial timetable provided for four progressive waves. The Omnibus sustainability simplification package presented by the European Commission on 26 February 2025 disrupted that timetable: two-year postponement for waves 2 and 3, thresholds raised to 1,000 employees and EUR 50 million in net turnover, and a reduction in the number of ESRS data points. Final texts are expected in spring 2026, after the European trilogue.

At Hayot Expertise, we recently supported an industrial mid-cap of 380 employees that had committed EUR 90,000 to consulting fees to prepare its CSRD report for the 2025 financial year. The Omnibus postponement turned this obligation into a useful voluntary exercise: its customers, themselves subject to wave 1, continue to require ESRS indicators through their supplier questionnaires. Regulatory compliance becomes a commercial asset.

Wave 1 of the CSRD remains fully applicable. It covers public interest entities (companies listed on a European regulated market, credit institutions, insurance undertakings) exceeding 500 employees over two consecutive financial years. These companies published their first sustainability report for financial year 2024, in April or May 2025 depending on their closing date.

The CSRD sustainability report must be drawn up in accordance with the ESRS (European Sustainability Reporting Standards) published by EFRAG and integrated into the management report. It is subject to limited assurance issued by the statutory auditor or by an accredited independent third-party body (OTI).

The Greenhouse Gas Emissions Assessment (BEGES) is the oldest CSR obligation embedded in French law. Article L. 229-25 of the French Environmental Code, introduced by the Grenelle II Act of 12 July 2010 and extended by the Climate and Resilience Act of 22 August 2021, requires publication of a BEGES every four years for the following private legal entities:

1. Companies with more than 500 employees in mainland France.
2. Companies with more than 250 employees in French overseas regions and departments.
3. Public legal entities with more than 250 staff.
4. The State and local authorities with more than 50,000 inhabitants.
5. Since 1 January 2023: companies with more than 50 employees benefiting from France Relance recovery plan aid.

The BEGES mandatorily covers scopes 1 and 2 and must be accompanied since 2023 by a transition plan (Article 244 of the Climate Act). Scope 3, long optional, becomes mandatory under the CSRD report for companies subject to ESRS E1.

The three carbon footprint scopes#

• Scope 1: direct emissions from fossil fuel combustion (boilers, owned vehicle fleets, industrial processes, refrigerant leaks).
• Scope 2: indirect emissions linked to purchased energy consumption (electricity, steam, district heating and cooling).
• Scope 3: other indirect emissions across the upstream and downstream value chain (purchased goods and services, upstream and downstream transport, business travel, capital goods, waste treatment, use and end-of-life of sold products).

The BEGES is filed on the bilans-ges.ademe.fr platform operated by ADEME and is publicly accessible.

The Professional Equality Index for women and men, known as the Pénicaud Index, was introduced by the Future Career Act no. 2018-771 of 5 September 2018. Any company with at least 50 employees must calculate and publish its index before 1 March each year, based on the previous year's data.

The index is scored out of 100 points and is broken down into five indicators for companies with more than 250 employees, four for those with 50 to 249 employees. Indicators cover the pay gap, individual increase gaps, the percentage of women increased upon return from maternity leave, and the number of women among the ten highest-paid employees.

A score below 75 points triggers an obligation to put in place corrective measures published and negotiated within three years. If no progress is achieved within three years, the DREETS may impose a financial penalty of up to 1% of gross annual payroll. A score below 85 points also requires setting quantified progress targets.

Subsidiaries of groups subject to the CSRD#

A French subsidiary whose parent consolidates a CSRD report at group level can be exempted individually from publishing its own sustainability report, subject to three cumulative conditions (Article L. 233-28-4 of the Commercial Code): effective inclusion in the consolidated scope, publication of a reference in its management report, and public accessibility of the group's report. This exemption removes duplication but does not exempt the entity from BEGES, Equality Index and BDESE obligations, which remain autonomous.

Mainland companies of 250 to 499 employees#

These companies fall into a grey zone. Wave 2 postponed to 2027 by the Omnibus, BEGES not required in mainland France, but subject to the Equality Index, BDESE and often to CSR questionnaires from their customers. Our recommendation: launch a structured voluntary CSR approach in 2026 to capitalise on work already done and anticipate wave 2.

Associations and foundations#

Associations exceeding Commercial Code thresholds (250 employees, EUR 50 million in revenue or EUR 25 million in balance sheet) potentially fall within CSRD scope if listed (rare) or issuing securities. Public utility foundations remain subject to their own transparency obligations. Equality Index and BEGES thresholds apply on the same basis as for companies.

Holdings and family wealth structures#

A pure holding without employees is not directly subject to social obligations (Index, BDESE) but may be subject to the CSRD if it consolidates a group exceeding CSRD thresholds. Family holdings owning industrial SMEs must organise to collect non-financial data from subsidiaries if they consolidate a single report.

At Hayot Expertise, we observe three key dynamics in 2026.

First, the trickle-down effect remains massive despite the Omnibus postponement. CSRD wave 1 entities (CAC 40, SBF 120, listed mid-caps) continue to pass structured ESRS questionnaires to their suppliers, including SMEs of 50 employees. An industrial SME of 75 employees, an aerospace Tier-1 subcontractor, recently engaged us after receiving a 180-indicator ESG questionnaire conditioning the renewal of its contract. This contractual pressure has no direct legal basis but immediate economic impact.

Second, financial penalties remain rarely activated but are intensifying. The Equality Index penalty (1% of payroll) was imposed 27 times in 2024 according to the Ministry of Labour's report. The EUR 50,000 BEGES fine (EUR 100,000 for repeat offences) is starting to be enforced by the DREAL. CSRD fines (EUR 50,000 for failure to publish) will become fully operational from financial year 2025 controlled in 2026.

Third, the cost of inaction now exceeds the cost of compliance. Beyond sanctions, companies without a structured CSR approach lose access to financing (banks now integrate ESG criteria into their pricing grids), attractiveness (73% of candidates consider CSR policy according to several 2025 HR studies) and commercial competitiveness. An initial CSR audit at EUR 10,000 is quickly amortised.

Hayot Expertise advice. If your company exceeds 50 employees and has not yet engaged in a structured CSR approach, start by diagnosing the applicable legal obligations (Index, BEGES, BDESE) before any voluntary initiative. Our experience shows that 60% of SMEs discover non-compliance on existing obligations, which it is a priority to regularise before any investment in voluntary CSRD reporting or in a B Corp label.

• Do not confuse legal and contractual obligations. A customer's ESG questionnaire does not carry the same legal weight as an Article of the Commercial Code. The response must be proportionate and negotiated.
• Do not relay repealed DPEF obligations. The DPEF no longer exists for CSRD-subject companies and was never mandatory for unlisted SMEs. Some online resources still mention outdated thresholds.
• Check the Omnibus postponement effective date. Until the European trilogue has adopted the final texts (expected spring 2026), the initial calendars remain legally applicable.
• File the BEGES on time. The report must be submitted to bilans-ges.ademe.fr before the end of the fourth year following the previous report. Any delay is sanctionable.
• Do not neglect the transition plan. Since 2023, a BEGES without an associated transition plan is non-compliant and exposes the entity to the EUR 50,000 penalty.

• CSRD wave 1 maintained: listed PIEs > 500 employees, FY 2024 published in 2025.
• Waves 2 and 3 postponed to 2027 and 2028 by the Omnibus package of 26 February 2025.
• Mandatory BEGES from 500 employees in mainland France, 250 overseas, 50 if France Relance beneficiary. Penalty: EUR 50,000.
• Equality Index from 50 employees, publication before 1 March each year. Penalty: up to 1% of payroll if < 75 points without correction within 3 years.
• Dominant contractual trickle-down: SMEs outside CSRD scope receive ESRS questionnaires from their large customers.
• Support cost: initial diagnosis EUR 8-18k, BEGES EUR 12-25k, voluntary CSRD reporting EUR 30k and above.

Official sources#

• Directive (EU) 2022/2464 — CSRD (EUR-Lex)
• European Commission — Omnibus sustainability simplification package (26 February 2025)
• AMF — Sustainability reporting and CSRD
• Légifrance — Article L. 229-25 of the Environmental Code (BEGES)
• French Ministry of Ecological Transition — GHG reports (BEGES)
• French Ministry of Labour — Professional Equality Index
• Légifrance — Ordinance no. 2023-1142 of 6 December 2023 (CSRD transposition)