France’s duty of vigilance law of 2017 requires companies with at least 5,000 employees in France, or 10,000 worldwide, including subsidiaries, to publish and implement a vigilance plan covering human rights, health and safety and the environment in their own activities, subsidiaries, subcontractors and suppliers. The plan contains a risk map, assessment procedures, mitigation actions, an alert mechanism and monitoring. Suppliers receive the questionnaires and audits that follow from it.
What the law requires
France’s duty of vigilance law, Law 2017-399 of 27 March 2017, now article L225-102-4 of the Commercial Code, requires large companies to draw up, publish and implement a vigilance plan. The plan must identify risks and prevent serious harm to human rights and fundamental freedoms, to people’s health and safety, and to the environment, arising from the company’s own activities, the companies it controls, and the subcontractors and suppliers with which it has an established commercial relationship.
Which companies are covered
A company is covered if, at the end of two consecutive financial years, it employs at least 5,000 people itself and in its direct and indirect subsidiaries with their head office in France, or at least 10,000 people itself and in its subsidiaries in France and abroad. A few hundred groups fall in scope. Their suppliers, in France and abroad, do not have a plan of their own to publish, but they are part of the plan of each customer that is covered.
The five measures of a vigilance plan
The plan must contain:
- A risk map that identifies, analyses and ranks the risks.
- Procedures to regularly assess the situation of subsidiaries, subcontractors and suppliers against that map.
- Appropriate actions to mitigate risks or prevent serious harm.
- An alert mechanism to collect reports of existing or potential risks, set up with the representative trade unions.
- A system to monitor the measures and assess how effective they are.
Publication and enforcement
The plan and a report on its implementation are published and included in the management report. Anyone with an interest can send the company a formal notice to comply; after three months without response, they can ask a court to order it. A company can also be held liable for damage that a proper plan would have prevented. Since 2021 the Paris judicial court hears all these cases. Its first ruling on the merits, in December 2023, ordered a company to complete its risk map and its alert mechanism.
What the EU directive changes
The EU Corporate Sustainability Due Diligence Directive, as amended in 2026, applies to companies with more than 5,000 employees and €1.5 billion turnover from 26 July 2029. France has to bring its law in line by 26 July 2028. Until then the French law applies as it stands, and its thresholds, based on headcount only, catch some groups the EU directive does not.
What suppliers are asked
Companies covered by the law pass their risk assessment on to their suppliers: codes of conduct to sign, questionnaires on working conditions, health and safety, the environment and ethics, requests for an EcoVadis rating, and audits for high-risk categories. A supplier that keeps its policies, accident and training figures and environmental data in one place answers each customer faster and more consistently.
Doing it in Greener Ahead
Greener Ahead does not draw up vigilance plans. Sustainability reporting in Greener Ahead prepares a VSME report with your policies, workforce, health and safety and environmental figures, ready to share with customers, for €995 per year. Carbon accounting calculates your carbon footprint and lets you send requests to your own suppliers, for €1,495 per year. Both have unlimited users and a free 14-day trial without a card. Check the pricing page for current details.
The vigilance plan at a glance
The main rules of article L225-102-4.
| Rule | What it means |
|---|---|
| Who | At least 5,000 employees in France or 10,000 worldwide, with subsidiaries, two years running |
| Covers | Own activities, controlled companies, subcontractors and suppliers with an established relationship |
| Risks | Human rights and fundamental freedoms, health and safety, the environment |
| Content | Risk map, assessment procedures, mitigation, alert mechanism, monitoring |
| Publication | Plan and implementation report in the management report |
| Enforcement | Formal notice, court order and liability, before the Paris judicial court |
What a supplier should have ready
These answer most vigilance questionnaires.
- Written policies on human rights, health and safety, the environment and ethics.
- Accident and training figures for the last two years.
- Your energy use and carbon footprint.
- A way for workers to raise concerns.
- A list of your own main suppliers by country.
Sources and scope
- Légifrance: Law 2017-399 of 27 March 2017 on the duty of vigilance
- EUR-Lex: Directive (EU) 2026/470 amending the sustainability reporting and due diligence directives
These resources explain a preparation workflow. Check your selected standard and recipient requirements before sharing your report.
Joost ThissenFounder
