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France Article 29 of the Energy & Climate Law (29 LEC)

France Article 29 of the Energy & Climate Law (29 LEC): France’s Article 29: Enhanced ESG and Climate Disclosure for Financial Institutions

Maílis Carrilho
Written by Maílis Carrilho
Updated on December 1st, 2025

Summary

The Article 29 regime strengthens ESG, climate, and biodiversity reporting requirements for French financial institutions. Asset managers and insurers must publish annual reports detailing the integration of climate and environmental risks into strategy, governance, and risk processes. Disclosures must include portfolio GHG metrics, fossil fuel exposure, Paris alignment, and biodiversity impacts. Reports must be submitted within six months after year-end and made public. The regime complements EU SFDR and Taxonomy rules while adding national expectations. Supervisory authorities review disclosures and may impose warnings, fines, or public notices in case of non-compliance.

Details

Jurisdictions
  • France
Exemptions

Article 29 obligations are legally binding for covered financial institutions operating in France.

Criteria:

Annual ESG/climate/biodiversity transparency report.

Reporting on portfolio GHG emissions (Scopes 1, 2 and relevant 3).

Disclosure of fossil fuel exposure and alignment with climate goals.

Integration of climate and nature-related risks into governance and strategy.

Public availability of the report and submission to relevant authorities.

Exceptions:

Smaller institutions under certain size thresholds can use simplified reporting scopes.

Entities already complying with equivalent EU reporting may reuse structures and data.

Corporate (non-financial) entities are not covered by Article 29.

Deep dive

2 min read
Published Dec 1, 2025

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What’s Required

Financial institutions must publish detailed annual ESG, climate and biodiversity disclosures. Reports must explain how environmental and climate risks are integrated into strategy, governance and risk management. Required elements include: portfolio GHG metrics, alignment with the Paris Agreement, exposure to fossil fuels, principal adverse impacts, biodiversity assessments and transition/physical risk disclosure. Reports must be publicly accessible and submitted within six months after the end of the financial year.

Important Deadlines

  • Annual report due within six months after year-end.

  • Continuous publication and accessibility requirements apply year-round.


Mandatory Requirements

Article 29 obligations are legally binding for covered financial institutions operating in France.

  • Annual ESG/climate/biodiversity transparency report.

  • Reporting on portfolio GHG emissions (Scopes 1, 2 and relevant 3).

  • Disclosure of fossil fuel exposure and alignment with climate goals.

  • Integration of climate and nature-related risks into governance and strategy.

  • Public availability of the report and submission to relevant authorities.

Exceptions

  • Smaller institutions under certain size thresholds can use simplified reporting scopes.

  • Entities already complying with equivalent EU reporting may reuse structures and data.

  • Corporate (non-financial) entities are not covered by Article 29.

Current Status

  • Fully in force since 2021, Article 173 applies to financial institutions.

  • Active supervisory review by AMF/ACPR.

  • Expected to coexist with EU SFDR and CSRD.

Penalties for Non-Compliance

  • Administrative sanctions, including warnings and monetary fines.

  • Public naming in supervisory communications.

  • Possible implications for licence conditions and ESG-labelled products.

Examples of Known Violations

As of November 2025, no widely publicised enforcement cases exist; authorities mainly issue recommendations and quality reviews to improve reporting practices.

Resources


Maílis Carrilho
Added by:
Maílis Carrilho
Sustainability Research Analyst
Maílis Carrilho is a Sustainability Research Analyst (Intern) at Net Zero Compare, contributing research and analysis on climate tech, carbon policies, and sustainable solutions. She supports the team in developing fact-based content and insights to help companies and readers navigate the evolving sustainability landscape.
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Added on Dec 1, 2025 by Maílis Carrilho ·