1. What is the current legal landscape for Class Actions in your jurisdiction?

The reform of the French class action regime by the Law of 30 April 2025 (the “DDADUE Law”) marks a turning point in the development of collective redress in France. One year after its adoption, the framework has been further clarified through several implementing decrees and is already producing tangible effects in terms of litigation strategy and case activity. While the system retains its civil law foundations and structural safeguards, it now presents a more accessible, centralised and potentially impactful mechanism. For companies, this evolution requires a recalibration of both risk assessment and defence strategies.

The French class action mechanism, initially introduced by the Hamon Law of 17 March 2014, was originally limited to consumer law. It was subsequently extended to additional areas, including public health, discrimination, environmental protection, data protection, real estate leases and administrative litigation. However, this incremental expansion resulted in a fragmented system governed by multiple procedural regimes, which ultimately was rarely used by the authorized claimants’ organizations. As such, since 2014, “only” thirty-nine class actions were filed, with two findings of liability and four settlements, illustrating the limited practical impact of the mechanism. This was highly criticized by the claimants’ representatives while, to be fair to companies, merely reflected the fact that there are many other ways to try to have their liability recognized in France. I therefore dare say that a new regime was not necessary.

The DDADUE Law restructures this landscape by introducing a unified regime applicable across all sectors. This reform eliminates the previous fragmentation and significantly broadens the scope of collective redress. Class actions may now be brought regardless of the nature of the harm and can pursue either injunctive relief, compensation, or both simultaneously. The dual purpose of class actions is now generalised.

The implementing decrees adopted throughout 2025 provide essential clarification. Decree No. 2025-653 centralises jurisdiction by granting exclusive competence to eight designated judicial courts, including Paris, Lyon, Marseilles and Lille. This concentration of jurisdiction is intended to foster judicial specialisation and consistency in decision-making. Decree No. 2025-734 further strengthens judicial control by empowering courts to swiftly dismiss manifestly unfounded or abusive claims and to address conflicts of interest affecting claimants.

The reform also introduces a public registry of class actions, managed by the Ministry of Justice, thereby enhancing transparency and visibility. In parallel, Decree No. 2025-1191 clarifies the accreditation process for associations and imposes strict financial disclosure obligations, particularly regarding third-party funding. These transparency requirements aim to preserve the independence of claimant entities while facilitating access to funding.

Recent case law illustrates the immediate impact of the reform. Although decided under the former regime, the May 2025 decision against Cise Réunion—concerning non-compliant drinking water—represents a landmark ruling and signals a greater judicial willingness to engage with the merits of such claims. At the same time, new actions brought under the reformed framework, such as the class action against Stellantis relating to defective airbags and the environmental claim initiated by the NGO Respire against the French State, demonstrate the expanded ambition of claimant organisations.

2. What three essential pieces of advice would you give to clients involved in Class Actions matters?

Against this evolving backdrop, companies must first place renewed emphasis on compliance and early risk identification. The removal of most substantive limitations on class actions means that any systemic breach—whether relating to consumer practices, ESG commitments, product safety or data protection—may now give rise to collective proceedings. Businesses should therefore strengthen internal monitoring systems and conduct regular audits in areas where large groups of stakeholders may be affected.

Secondly, a strategic focus on the liability phase of proceedings is essential. Under the French system, this initial stage is decisive, as it determines not only whether the defendant is liable, but also defines the class, the criteria for inclusion and the categories of compensable harm. The example of the Stellantis litigation illustrates how claimants are now leveraging the new regime to seek compensation for broader categories of harm, including non-pecuniary losses such as anxiety and inconvenience. A robust defence at this stage may significantly limit subsequent exposure.

Thirdly, companies must integrate reputational considerations into their litigation strategy. The increased visibility of class actions—driven by the public registry, court-ordered publicity measures and heightened media attention—amplifies their potential impact beyond financial liability. Effective coordination between legal, compliance and communication teams is essential to manage stakeholder expectations and mitigate reputational risks.

3. What are the greatest threats and opportunities in Class Actions law in the next 12 months?

The first year following the reform confirms that class action activity in France is entering a phase of acceleration. Several claimant organisations have explicitly adapted their litigation strategies to take advantage of the new framework, including by delaying filings until the DDADUE Law entered into force. The current level of activity is therefore likely to represent only an initial phase.

The most significant threat lies in the expansion of class actions into ESG-related areas. The first environmental class action, brought in January 2026 against the French State for alleged failures in air quality management, illustrates the growing importance of such claims. Similar actions targeting industrial pollution, climate-related obligations, and environmental compliance are already being prepared.

Product liability and consumer protection remain central risk areas, as illustrated by the Stellantis case. The broadened scope of recoverable damages encourages claimants to pursue more complex and higher-value claims. Employment-related disputes, particularly those involving systemic discrimination, are also expected to emerge as a significant source of future class actions.

At the same time, opportunities arise from the increased clarity and predictability of the new framework. The centralisation of jurisdiction and the development of specialised judicial expertise are expected to contribute to more consistent case law. This will enable companies to better anticipate litigation outcomes and refine their defence strategies.

Furthermore, while civil fines introduce an additional layer of risk, the continued application of the principle of full compensation should ensure that damages remain strictly linked to actual harm. This preserves a degree of financial predictability absent in jurisdictions permitting punitive damages.

Finally, the structured framework for settlement, combined with judicial oversight, provides an effective mechanism for resolving disputes while controlling litigation risk and preserving business relationships.

4. How do you ensure high client satisfaction levels are maintained by your practice?

Providing clear, actionable advice is critical. This involves translating complex procedural developments—such as the implications of the new decrees, the role of specialised courts, or the impact of the public registry—into practical recommendations. Clients particularly value the ability to anticipate developments, including emerging trends in ESG litigation or evolving claimant strategies.

Responsiveness and transparency are equally important. Class actions often span several years, with multiple procedural phases and potential appeals. Regular communication, structured reporting and proactive updates help ensure that clients remain informed and engaged throughout the process.

A multidisciplinary approach further enhances client satisfaction. The intersection of class actions with regulatory enforcement, ESG considerations, and reputational issues requires coordinated expertise across legal, compliance and communication functions. This integrated approach is particularly valuable in high-profile cases.

Finally, there is a need to always think about the big picture. It is very rare that a class action is launched in Europe while no class action is launched in the United States and Canada. There is a need to have a coordinated and coherent approach of multiple actions against the company to avoid situations where a position in one jurisdiction could lead to a disaster in another.

5. What technological advancements are reshaping Class Actions law and how can clients benefit from them?

Technological developments are increasingly shaping both the conduct and the strategy of class action litigation. For defendants, advanced data analytics and artificial intelligence tools enable efficient management of large-scale evidence, facilitate document review and support predictive modelling of litigation outcomes.

These tools are particularly valuable in cases involving systemic practices, where identifying patterns and assessing exposure across large datasets can be decisive. Predictive analytics can also inform settlement discussions by providing more accurate estimates of potential liability under different scenarios.

On the claimant side, technology plays a key role in facilitating the mobilisation of class members and the organisation of claims. Digital platforms allow associations to reach a broader audience, increasing participation rates in opt-in proceedings and enhancing the overall effectiveness of class actions.

The introduction of a public registry of class actions makes it easier for potential claimants to identify ongoing proceedings. At the same time, digital disclosure requirements regarding litigation funding enhance oversight and reduce the risk of conflicts of interest.

From a preventive perspective, companies can leverage technology to strengthen compliance and risk management. Automated monitoring systems, enhanced data protection tools and real-time reporting mechanisms enable early detection of potential breaches, reducing the likelihood of collective litigation.