Yes, there is a class action mechanism in France. It was, at first, introduced into French law in 2014, for consumer law matters only (Law no. 2014-344, referred to as the “Hamon Law”). It was then extended to health and cosmetics, discrimination (in particular in the workplace), the environment and the protection of personal data in 2016. Since 2018, class actions could also be brought in the field of real property lease (through consumer law class actions). Class actions could also be brought in administrative matters (i.e. actions against the French State).

Under the regime developed based on the Hamon Law, class actions in France were therefore limited to some areas (thereafter the “Former regime”) and there were some limitations as to whom could initiate such claims and how.

In order to implement the EU Directive 2020/1828 on representative action, the Law dated 30 April 2025 “containing various provisions for adaptation to European Union law in economic, financial, environmental, energy, transport, health and movement of people matters” (called “Law DDADUE”) has been passed.

This Law, published in the Official Journal on 2 May 2025, creates a unified class actions regime which extends the scope of compensable damages to all types of harm, “regardless of their nature,” and generalizes the dual purpose of class action, which may aim to compensate for the harm suffered or to terminate a breach (or both at the same time).

Contrary to the Former regime where provisions existed in different codes, depending on the topic at stake, there is now one single regime provided in one single law (thereafter the “New regime”).

Under the New regime, Class actions can only be brought by approved and representative legal entities (associations, most of the time). Under specific circumstances, the Public Prosecutor may also bring a claim. In the scope of cross-border representative action, entities which have been qualified by their Member State of origin may bring a class action.

The New regime has been adopted to transpose into French law the EU Directive on representative actions but it goes further than that. Indeed, the French class actions regime has been considered as inefficient due to the low number of class actions having led to the recognition of the liability of defendants since its creation in 2014. As a consequence, the goal of the New regime is to provide a more accessible regime. Some procedural rules have therefore been changed in order to “facilitate” the launch of such claims and a new civil fine has been created to allow the Courts to sanction even more defendants who are found liable.

The New regime applies to any action brought after the publication of the law DDADUE, with the exception of the provisions relating to civil fines, which apply only to actions where the event giving rise to the defendant’s liability occurred after the publication of the law.

As explained in question 1, a class action mechanism was introduced into French law through the Hamon Law, in 2014 and was limited to class actions for consumer law matters only. Over the years and through different laws, the class action mechanism has been open to other matters such as health, discrimination, environment or personal data, each matter operating according to its own rules and specific characteristics.

This fragmented regime has been considered ineffective, due to complex procedural rules and a historically low “success” rate for plaintiffs (“success” being considered by the French State as companies being found liable). As a consequence, the New Regime adopted on April 30, 2025 aimed at simplifying the class actions mechanism in France and at transposing the EU Directive 2020/1828.

Since 2014, according to the French Observatory of Class Actions, 39 class actions have been filed before French courts on the basis of the former regime: two of them led to a company being found liable (it is being specified that an appeal is pending for at least one of these cases) and four others resulted in a settlement between the parties.

More than half of the class actions (21) were consumer issues targeting mainly the financial, service provision and real estate sectors. The remaining cases are divided among administrative claims against public authorities (7 cases), discrimination (mainly work discrimination) disputes brought by labor unions (6 cases), public health claims (3 cases), data privacy litigation (2 cases).

Since the entry into force of the New regime, three class actions have been launched. Amongst these three recent class actions, three related to consumer issues and one to environmental issue, which is the first environmental class action launched in France.

Generally speaking, many more mass claims/joint actions (i.e. individual claims filed against the same defendant , then managed together by the Court) are launched in France. We observe a lot of joint actions in the toxic tort, product liability and employment matters.

In terms of types of claims which are most prevalent, the Former regime shows that most of the claims were related to consumer law and employment/discrimination issues. Under the Former regime, there has never been a class action relating to environment matters for instance in France. This is what has been highly criticized by the French National Assembly and contributed to enacting the New regime.

Since the implementation of the New regime, three class actions have been launched in France. One of these claims is the first class action in environmental litigation and was brought against the French state. The two other claims relate to consumer law matters. .

Regarding the Courts that are most prevalent, we observe that under the Former regime, most of the claims were brought before the Paris Courts, then before the Nanterre Courts and the Lyon Courts. However, class actions were also brought before the Lille, Nancy, Saint-Denis de la Réunion or the Pau Courts for example.

Under the New regime, the Decree No. 2025-653 grants jurisdiction for class actions to only a few Courts in France. Therefore, class actions will be concentrated before eight Judicial Courts (Bordeaux, Lille, Lyon, Marseille, Nancy, Paris, Rennes, and Fort-de-France), which now have exclusive jurisdiction to handle those cases. This being said, the Paris Judicial Court is expected to remain the most prevalent Court, given the concentration of corporate headquarters and government institutions in the French capital.

Under the New regime, the class action is an action brought by a claimant (i.e. organizations approved for this purpose (except for class actions to have a breach stopped which are open to non-approved organizations complying with specific criteria) or trade unions) on behalf of several natural or legal persons placed in a similar situation due to the same breach or a breach of the same kind of its legal or contractual obligations committed by a person acting in the exercise or on the occasion of its professional activity, by a legal person governed by public law or by a body governed by private law entrusted with the management of a public service.

There is no specific trigger for commencement of class actions under French law except the large number of persons considering being the victim of the same defendant and for the same reason. This explains why the class actions that have mostly been launched in France related to issues affecting consumers or employees. The fact that a class action was launched in the United States or anywhere else in the world has not been a trigger so far in France for the launch of a local class action. It has however been a real trigger for mass claims/joint claims as described in answer to question 3. This may change with the New regime.

Class actions do not interact with regulatory enforcement findings. These are different and independent procedures meaning that claimants do not have to wait for any decisions or authorizations to bring a claim.

However, under the New regime, class actions based on competition law are limited to follow-on proceedings which means that in this case, the liability of a company can only be established if it is based on a final decision rendered by a competent national or European Union authority or court. The claim can only be brought within 5 years of the said decision.

Moreover, if a regulator investigates a matter or a company and publicizes it, its findings can be used by the claimants in the class action as evidence to support the breach that they are alleging.

For example, the association UFC-Que Choisir has brought a class action against a bank. Prior to this class action, the bank had been sanctioned by the Autorité des Marchés Financiers (“AMF” – French authority controlling the financial markets). In the scope of the class action, the association required the Court to grant it access to the AMF file. According to the French Observatory of Class Actions, the Paris Civil Court granted UFC-Que Choisir access to the AMF investigation file.

This being said, the interactions may become more significant with the New regime. Indeed, the Public Prosecutor or the Government (depending on the type claim) can decide to participate in pending class actions launched to require the Court to order a civil fine against the defendant should it be found liable. The amount of the civil fine can reach double the profit made for a natural person and five times the same profit for a legal entity. The Public Prosecutor will also be allowed to be at the origin of a class action aimed at ending a breach. This will likely change the dynamics of this legal field.

Under the Former regime, the conduct and causes of action depended on the type of class action at stake. Class actions in health matters could only be brought when a breach of legal or contractual obligations was committed by a producer or supplier of some products. Class actions in consumer law could only be brought when a breach has been committed by a professional regarding the sale of goods or the provision of services, or when a breach has been committed regarding the rental of real estate or by anti-competitive practices. Class actions in environmental matters could only be brought for a violation of legal obligations or the failure to comply with legal obligations relating to the protection of nature and the environment. Class actions for discrimination could be brought for discrimination related to the individual characteristics of individuals (origin, gender, family situation, opinion or physical appearance, for example) or committed by a public or private employer. Class actions relating to data protection matters could be brought based on a breach of Law no. 78-17 relating to data processing, files and freedoms (such as a security breach of an operator or one of its subcontractors).

Under the New regime, these categories does not exist anymore. Class actions can be brought to obtain either the end of a breach or compensation of any loss suffered as a result of that breach, or both.

The only exception under the New regime relates to public health matters, which can only be brought for breaches of obligations committed by a producer, a supplier of specific health product, or a service provider using such products.

Under the Former regime, there were limitations in the types of claims that could be brought on a collective basis. For some topics, it was not possible to launch a class action for instance. For others, only a few authorized organizations (e.g. consumer class actions) could launch such claims.
These limitations were also based on the matter at stake (data protection, discrimination, health etc..), the type of remedies that could be sought by the claimants and the conducts and causes of actions that could be the basis of a class action.

Under the New regime, all limitations almost disappear. This was the main objective of the DDADUE Law. For example, one could see a limitation when reading the types of claims a trade union can launch on behalf of employees, while in fact, it is not. The DDADUE Law specifies that the trade union can launch class actions:

• In the fight against discrimination;
• With regard to the protection of personal data;
• Or when it seeks to put an end to an employer’s failure to fulfil its obligations or to compensate for damage caused by this failure to several persons placed under the authority of this employer.

Although this could sound as a limitation, this provision extends the scope of the class action relating to the workplace as the Former regime limited it to discrimination, while now, there are two more causes of actions possible.

The only two remaining limitations are:

• Competition law class actions as only follow-on actions are authorized under the class action mechanism,
• Public health claims which are restricted to breaches committed by producer or supplier.

No, class actions cannot be brought by individuals, consumers or companies.

Under the Former regime, class actions could only be brought by an approved organization, such as associations or trade unions (notably for the class action for discrimination at work). The conditions for the organization to be approved varied depending on the type of class action. For example, for consumer law class actions, only 15 consumers’ associations that are officially listed and authorized to bring class actions could launch such claims, while for environment class actions, the association must have been an environmental protection association that was existing for at least three years and that had a statutory activity dedicated to the environment, an association defending victims of physical injury or an association defending the economic interests of its members. The pool of organizations was therefore larger for environment class actions than it was for consumers class actions.

Under the New regime, the conditions are unified. Approved associations have standing. The administrative authority delivers approval when the association is a regularly declared non-profit association which complies with the following conditions:

• Has completed a 12-month activity before applying for the approval,
• Its statutory purpose is to defend interests that have been adversely affected,
• Is not subject to insolvency when applying for the approval,
• Is independent and not influenced by persons having a financial interest in the launch of the class action,
• Makes publicly available information about its statutory purpose, its activities, its main sources of funding and its organization.
• The authorization provided by the administrative authority can be withdrawn by the latter at anytime, if one of the conditions is not met anymore.

Non-profit organizations that have been duly registered for at least two years, have been actively and publicly engaged in their activities for twenty-four consecutive months, and whose statutory purpose includes the defense of the interests in question also have standing, without approval, but only for proceedings for the cessation of a breach. The following specific class actions can be brought by trade unions:

• For the fight against discrimination,
• With regard to the protection of personal data;
• Or when the class action seeks to put an end to an employer’s failure to fulfil its obligations or to compensate for damage caused by this failure to several persons placed under the authority of this employer.

Class actions for failure to comply with legal or contractual obligations under the Labor Code can only be brought by trade unions.

European qualified entities proving their registration on the official list published in the official journal of the European Union also have standing. They can bring claims before French courts to seek injunctive relief or to claim civil liability and seek compensation for the damages suffered by represented group.

A new major change introduced by the New regime is that in France, the Public Prosecutor can now bring class actions to obtain the end of a breach.

As stated in the previous question, a class action can be brought by organizations registered in France but also, for some cases, by European qualified entities registered on the official list published in the official journal of the European Union. Moreover , group members can join the group no matter their nationality or their place of residence as long as they meet the criteria to be part of the group, as set out by the Court.

No, such limitations do not exist under French class action mechanism, whether the Former or the New regime, as long as there are at least two persons in the class and that the class members comply with the requirements to be part of the class at stake, as defined by the Court.

Sourcing a class in France is regulated, primarily because the French mechanism is an opt-in system. Therefore, the class is limited to members which have joined the class only.

In addition, the Judge ruling on the liability of the defendant can order publicity measures, made at the expense of the claimant. The goal of such publicity is to have the people who have interest in the class action be aware of it and its status.

With regard to the Courts’ jurisdiction under the Former regime, Article 849 of the French Code of Civil Procedure provides that the Court having jurisdiction is the Civil Court of the defendant’s domicile or, if the defendant is not in France, the Paris Civil Court. This was the Court-jurisdiction principle applicable under the Former regime.

Under the New Regime and more specifically Decree No. 2025-653 of July 16, 2025, there is an exclusive jurisdiction to handle class actions of the Bordeaux, Lille, Lyon, Marseille, Nancy, Paris, Rennes and Fort-de-France Judicial Courts. This is a major change compared to the Former regime.. The idea behind this change is likely to organize and provide additional means to these specific Courts so that they can handle such specific claims.

There are no jurisdictional obstacles to class actions in France but a procedure must be followed. Failing such, it can lead to the inadmissibility of the claim.

In addition to the procedure to follow, it must be complied with all rules of civil procedure: with regards notably to the form and content of the writ of summons and the statute of limitation. With regard to the latter, there is no specific statute of limitation for class actions, which is therefore the same than in standard procedures. The statute of limitation is of five years following the occurrence of the damage i.e., the date on which the holders of the right to bring the claim become aware or should have become aware of the facts enabling them to exercise this right (Article 2224 of the French Civil Code).

Note that under the Former regime, the claimants had to send a prior notice to the defendant that they would file a class action should its answer to the claimants’ claims not be satisfactory in the time-being. This obligation has been stricken off in the New regime, except for employment law, where a formal notice to cease the alleged breach is still required before initiating proceedings

Under the Former regime, France was an opt-in jurisdiction. Each person willing to join the action brought by an association had to take active steps to join the group.

Under the New regime, the situation is more subtle, depending on the type of class action launched:

– Class action to obtain the end of a breach: the claimant will request to the Judge the cessation of a behavior. If the Judge orders it, all the people suffering from this behavior will consequently benefit from the cessation of the breach without having to take part in the class action.

– Class action to obtain compensation of the loss suffered: the Judge will first rule on the liability of the defendant and define the criteria for inclusion in the group. Then all the people meeting these criteria for inclusion will be able to opt-in, and take part to the class action.

To formally start a class action, the qualified claimant must serve a writ of summons on the defendant and formally file it before one of the eight specifically designated Judicial Courts.

The requirement to send a prior formal notice has been abolished to “facilitate” the launch of class actions, except for employment law matters.

When the class action is launched to obtain the cessation of a breach, the claimant is not required to establish either harm to the class members or the defendant’s intent or negligence.

If the Court finds that there has been a breach, it will order the defendant to cease the breach and to take, within a period to be determined, all appropriate measures to that end. The Court can also order a penalty payment, to be paid to a fund dedicated to the financing of class actions.

The Court can further order all appropriate interim measures to put an end to the alleged breach, within a specific time limit, in order to prevent imminent damage or to put an end to a manifestly unlawful disturbance.

When the class action is launched to obtain compensation of the loss suffered, there are several procedural steps that will occur. The first one is the judgment on the liability of the defendant. During this step, the Court will rule on the liability but will also:

• define the group of people in respect of whom the defendant is liable,
• set out the criteria for inclusion in the group,
• determine the losses to be compensated for each of the categories of persons making up the group it has defined.

The Judge also determines the deadline to opt-in to the class action and the deadline for the defendant to pay the damages.

When he/she has enough information or elements to do so, the Judge also determines the amount or all the elements allowing the assessment of the damages likely to be compensated, for each of the categories of persons constituting the group that it has defined (which must be comprised between 2 months and 5 years) from the judgment.

The Court will finally determine the deadline for the defendant held liable to pay the members of the class.

Normal civil procedure rules such as status of limitation or the notification of the summons still apply.

Procedurally, the New regime mainly follows the same principles inherited from Law No. 2014-344 of March 17, 2014 (Law “Hamon”): the principle of the defendant’s liability is first ruled on before defining, where applicable, the scope of persons eligible for compensation. The Judge then orders that the decision be made public in order to invite those eligible for compensation to join the previously defined group, within a period that can range from two months to five years.

A few notable procedural developments should be mentioned:

• the generalization to all matters of the possibility of directly bringing a class action against the insurer of the party responsible;
• the elimination of the obligation to provide prior formal notice;
• the possibility for the pre-trial judge to take useful interim measures to cease the alleged breach in the event of imminent damage or manifestly unlawful disruption;
• the jurisdiction of only specifically designated courts;
• the possibility for the public prosecutor to launch a class action to end a breach;
• the creation of a national register of class actions within the Ministry of Justice

The New regime also provides for the possibility for civil or administrative courts to impose a civil fine (uninsurable) on professionals who commit fraudulent misconduct that has caused serial damage.

The answer varies depending on the complexity of the case and the judge appointed, knowing that we only have very limited examples to rely on to answer this question. However, these cases could be quite long as the Court can give up to 5 years to opt-in a class actions. Then appeals can be lodged. Although the New regime aims at accelerating the process by creating specialized courts and globally removing the pre-litigation requirements, these cases could easily run for 5 to 10 years.

Under the Former regime, types of remedies available in the scope of class actions depended on the matter of the class action.

Under the New regime, the scope of available remedies has been significantly broadened. Claimants can now obtain the cessation of a breach, and all types of damages can be fully compensated as long as they are proved.

Beyond financial compensation, it is now possible to seek injunctive relief and interim measures, civil fines against the defendant (maximum 50,000 Euros for individuals and up to five times of the profit realized).

The measure of damages in class actions is strictly governed by the fundamental principle of full compensation of French civil liability. The objective is to restore the claimants to the position in which they were before the breach occurred. Claimants receive the exact compensation for the actual damage suffered and nothing more or less.

For class actions, the Court will define specific categories of victims and for each category, determine either a fixed amount of compensation or the formulae to be used to calculate the individual loss.

Punitive damages are not available under French law as a matter of principle. In France, damages are based on the principle of full compensation: the victim must receive a compensation that corresponds exactly, that is no more and no less, to the damage sustained.

However, under the New regime, two types of “civil fines” have been created. First, a civil fine of up to 50,000 Euros may be imposed by the Judge on either the claimant or the defendant who in a dilatory or abusive manner, prevented the conclusion of a settlement on the basis of the judgment ordering the collective proceedings for the liquidation of damages.

Second, for intentional breaches committed to generate a profit causing serial damages, a fine can be ordered and reach up to double the profit realized for individuals and up to five times the profit realized for legal entities. This is the closest mechanism to punitive damages in France but is very different as it does not benefit the claimants directly, rather a fund dedicated to financing future class actions.

Before the new Decree No. 2025-653, claims were brought before various Courts depending on the defendant’s location. However, with this new decree, the only Courts which will have jurisdictions to rule on class actions are the Judicial Courts of Bordeaux, Lille, Lyon, Marseille, Nancy, Paris, Rennes, and Fort-de-France.

Regarding the number of judges, because class actions in France are heard before judicial courts, the general rule of the French Code of Judicial Organization apply. There can be one to three judges standing.

No, class actions are not subject to juries. In France, juries only exist for proceedings relating to certain types of criminal offences.

Yes, French law encourages amicable dispute resolution. Under the New regime, parties can decide to enter into mediation in order to reach their settlement which must be submitted to the judge’s approval no later than the deadline given to the public to opt-in the group. The period to reach a settlement is therefore timely framed.

Yes, there is. The Judge must approve (homologation) the settlement reached by the parties. The Judge will reject the settlement if it considers that the interests of the parties and the members of the class are not sufficiently preserved. It can also invite the parties to negotiate again the settlement within a maximum period of 2 months.

If no settlement is found, the Judge will calculate the remaining amounts of damages to be paid.

No, there is no prescribed procedural obligation to undertake alternative dispute resolution outside of the court system, prior a class action.

Parties can choose to reach a settlement, but they are under no obligation to do so. In fact, the New Regime abandoned the general obligation to provide a prior formal notice before filing a class action to attempt to settle.

A notable exception remains for labor law claims where the claimant must request the employer to cease the alleged breach, triggering a mandatory six-month discussion period before the matter can be brought before courts.

Approved associations often rely on their own resources or member fees. However, the New regime explicitly allows for third-party litigation funding.

To prevent conflict of interest and ensure independence, the claimant must disclose its primary sources of funding to the court. The Court ensures that the funder does not unduly influence the claimant’s legal strategy.

Yes, to prevent conflicts of interest and ensure the independence of qualified entities, French law imposes strict transparency and structural restrictions on third-party funding.

Regarding substantive restrictions, the third-party funder is strictly prohibited from exercising any influence over the association’s legal strategy or the conduct of the litigation.

Regarding financial transparency, Decree No. 2025-1191 of December 10, 2025, which came into force at the beginning of 2026, imposes strict public disclosure requirements. No later than the day the action is filed, the entity must make detailed information publicly available, notably on its website. It must list its mains third-party funders (excluding standard membership due for trade unions) if they meet any of the following criteria:

• The funding amount exceeds 20,000 Euros over twelve consecutive months,
• The sponsor is among the 10 largest funding sources of the previous years,
• If the sponsor represents more than 5% of the entity’s annual resources.

For each of these relevant funders, the entity is legally required to disclose:

• The funder’s exact identity (corporate registration details for companies, or name and profession for individuals) and the exact amount or valuation of the funding received,
• Their essential characteristics of the fundings contracts, including their duration, their nature, the funder’s remuneration, and the main obligations of the parties.

This public information must be updated annually until the end of the proceedings.

Among the 42 class actions that have been brought in France since 2014, 23 of them related to consumer matters, 6 of them were brought in discrimination matters (mainly in the workplace), 3 of them were brought in health matters, 2 in data protection matters, 7 actions were brought in administrative matters and the latest one was brought in environmental matters for the first time in 2025.

Therefore, based on the area of law, the top three emerging business risks on which class actions are focused are:

• Consumer law
• Discrimination
• Public health and Environmental matters, which are now an effective risk.

Based on the type of facts resulting in a class action, the class actions are focused on the following issues:

• Monetary issues (e.g. unlawful clauses charging fees, unjustified charging of fees when returning rented phones, buyer protection fees on a website),
• Discrimination (e.g. mainly in the workplace (between men and women or against unionists for example), ethnic profiling in police controls)
• Product related issues (misleading practices, defective products, notably medical products).

It ought however to be noted that these risks have been identified based on the data published by the French Observatory of Class Actions and that most of these actions have not led to any final finding of liability.

For example, in January 2022, Sanofi was found liable by the Paris Civil Court. In this class action brought in the health area, Sanofi’s liability was sought as the association alleged that the Dépakine (a medicinal product) caused physical malformations and neurodevelopmental disorders in utero in fetuses of pregnant women having been treated with this medicine. This case is the first one in the scope of which the liability of a company has been acknowledged by a Court in France. However, both parties lodged an appeal against this decision which is therefore not final.

Therefore, the top three emerging business risks that are the focus of class actions are, to date, more alleged risks than risks that led to final effective condemnations.

However, on May 27, 2025, the Saint-Denis de la Réunion Judicial Court ordered Cise Réunion (water utility company in the Reunion Island) to pay damages to its customers for distribution the ground that it would have disturbed water in a way that failed to meet health standards. Although this decision was rendered under the former class action mechanism, it marks the first class action ruling in France relating to drinking water quality and will probably influence similar class actions launched under the new mechanism.

Looking ahead, we could reasonably think that the first action brought in environmental matters will lead to a rise in ESG related class actions.

The New regime is seen as an opportunity for claimants to claim for larger condemnations, which is an evolution that claimants wanted. Indeed, associations strategically waited for the new law to be implemented before starting an action. A prime example is the NGO Respire, which waited for the entry into force of the DDADUE law to launch a class action against Stellantis regarding the Takata airbags.

However, the most significant trend is the rise of ESG-related issues, which are now the source of multiple types of claims in France, whether against the French State, governmental agencies and local authorities or companies. This trend has now officially reached the collective redress mechanism, as demonstrated by the very first environmental class action launched recently and the recent condemnation of a company for public health issues, signaling a major shift in litigation risks.

The most significant development over the next twelve months will likely be the expansion of class actions into new substantive areas under the DDADUE framework. Environmental claims (targeting chronic industrial contamination and breaches of EU air-quality standards) and product-liability disputes involving mass-market consumer goods, such as household appliances or electronic devices affected by recurring defects, are the most advanced, with several organizations already securing accreditation, exploring third-party funding options and broadening the scope of recoverable losses ahead of formal filings. Notably, these claimant entities have been transparent about the fact that their litigation architecture is being deliberately constructed around the new procedural tools made available by the reform.

Employment discrimination, particularly systemic pay inequalities and barriers to career progression, greenwashing, misleading ESG disclosures and large-scale data-protection breaches are widely seen as the next wave once courts clarify key procedural aspects of the new regime. Several NGOs and associations have already publicly indicated their intention to target financial institutions and major corporates on these grounds. The visible pipeline of claims in preparation suggests that current activity is only an opening phase, making early assessment of class-action exposure a strategic priority for businesses.

Regarding the toxic tort claims, we do not expect a similar trend. Such complex claims are predominantly managed by the plaintiffs’ Bar, who remain structurally prohibited from launching class actions themselves under French law.

The last year has been a fruitful year in terms of ESG matters in the scope of class actions.

Indeed, the Saint-Denis de la Reunion Court condemned the company Cise Reunion (on the basis of the Former regime) for distributing drinking water that failed to meet health standards.

In addition, the first environmental matter class action has been brought on January 23, 2026 against the French state for the pollution of the air. The Respire organization launched a class action before the Paris Administrative Court. The organization is suing the French State for its alleged failure to “comply with the 2008 European directive and the complete lack of a credible plan to meet the European targets set for 2030” (in particular in relation to nitrogen dioxide (NO2) thresholds). The Respire association requires the Court to order the French State to cease its breach and to take the necessary measures within six months. This injunction is accompanied by a request for a periodic penalty payment that would not be paid to the association, but to a fund to support class-action lawsuits.

As a new regime just entered into force after years of discussions and because this new regime implements the EU Directive, no other reform is expected to date.