Insurance & Pensions in France

Key dates

2025

- First wave (NFRD reporters: large listed/public interest entities >500 employees) publish CSRD reports for FY2024

2026

- Large EU companies (previously planned for FY2025) deferred to 2028 for FY2027 reporting

2028

- Listed SMEs report for FY2026 (deferred from 2027)

2029

- Final wave including certain non-EU firms; CSDDD applies from July 26, 2029

Suggested considerations

• Review EFRAG/EC guidance and FAQs for ESRS implementation; conduct double materiality assessment to identify material ESG topics.
• Map and collect ESG data (GHG emissions Scope 1-3, value-chain impacts) with audit trails; develop Paris-aligned transition plans.
• Integrate sustainability into management reports with digital tagging (XBRL/ESEF); secure limited third-party assurance.
• Strengthen data governance, test processes, and monitor updates from EFRAG/EC/AMF.

What changed

• - EFRAG and the European Commission have published specific implementation guidance and FAQs to operationalize CSRD reporting using ESRS, focusing on double materiality assessments, climate...
• CSRD replaces the NFRD with broader scope (quadrupling affected companies to ~50,000), mandatory digital tagging (ESEF/XBRL), limited third-party assurance (phasing to reasonable), and integrated...
• Recent amendments defer timelines for certain waves, adjust scope thresholds, add exemptions, cap value-chain disclosures, and refine assurance standards.

Key dates

October 24, 2022

- AMF requests suspension of ORPEA's financial instruments before market opening

October 26, 2022

- Trading resumes upon market opening following ORPEA's disclosure of conciliation procedure and financial restructuring plan

November 8, 2022

- Q3 2022 revenue announcement (after market close)

November 15, 2022

- ORPEA to present detailed transformation plan to market

December 31, 2022

- Anticipated asset impairment recognition date

Suggested considerations

• *For ORPEA (and comparable listed companies):
• *Immediate disclosure obligations: Publish a Regulated Information Service (RIS) announcement under MAR Article 17 disclosing all material information regarding financial difficulties, covenant breaches, and restructuring plans before trading resumes.
• *Ongoing periodic updates: Provide quarterly updates on conciliation procedure progress, covenant amendment status, and asset disposal program execution.
• *Governance remediation: Establish or strengthen disclosure committees with clear protocols for identifying and escalating material information within 24-48 hours of discovery.
• *Creditor communication: Maintain transparent dialogue with financial creditors regarding covenant amendments and restructuring timelines.

What changed

• The AMF's suspension order represents a temporary halt to all trading in ORPEA's financial instruments across regulated markets.
• Financial covenant breaches: The company faced potential acceleration of €3.3 billion in financing lines due to anticipated breaches of "R1" and "R2" financial covenants.
• Asset impairments: Anticipated write-downs at December 31, 2022, related to a stalled real estate disposal program.
• Debt restructuring needs: €4.3 billion in unsecured debt requiring conversion or restructuring.

Key dates

July 2022

- AMF submits response to EFRAG consultation on draft ESRS. https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf

2024

- First CSRD application for FY 2024 reports (large public-interest entities). https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf

2025

- ESRS adoption by European Commission (first set covering SFDR needs). https://www.amf-france.org/sites/institutionnel/files/private/2022-07/AMF%20appendix%20to%20position%20paper%20on%20EFRAG%20consultation%20July%202022.pdf

2027

- Potential application of simplified ESRS (per EC quick fix hints). https://www.gibsondunn.com/efrag-releases-draft-simplified-european-sustainability-reporting-standards-esrs/

TBD (post

2025); - EC Delegated Act on simplified ESRS, subject to 2-month EU Parliament/Council scrutiny. https://www.efrag.org/en/news-and-calendar/news/efrag-provides-its-technical-advice-on-draft-simplified-esrs-to-the-european-commission

Suggested considerations

• Monitor ESRS evolution: Track EFRAG/EC updates on final standards, focusing on AMF priorities like materiality guidance and ISSB mapping.
• Enhance materiality processes: Develop/improve double materiality assessments, preparing guidance integration.
• Align reporting systems: Map ESRS to SFDR/Taxonomy data; test proportionality phased rollouts (e.g., climate first).
• Engage stakeholders: Participate in ongoing consultations (e.g., EFRAG connectivity); benchmark against ISSB for interoperability.

What changed

• This is a consultation response, not a final rule, but AMF highlights these priorities for ESRS development:
• International interoperability: Convergence with ISSB standards to avoid duplication and meet investor needs across jurisdictions.
• Proportionality in disclosures: Gradual implementation, prioritizing climate standards, balancing stakeholder needs with issuer costs, and ensuring SFDR coverage.
• Materiality focus: Enhanced guidance on materiality assessments, centering company-led analysis without presuming topics' materiality upfront.
• EU consistency: Avoid duplicating info from SFDR, Taxonomy, and other regs; rely on existing concepts.

Suggested considerations

• For Users and Rated Entities: Although the 2022 Call for Evidence is closed, monitor ESMA's ongoing RTS consultations (closed 20 June 2025) and Commission feedback; assess internal ESG data reliance for SFDR/Taxonomy alignment and update policies for new disclosure requirements.
• All Affected Firms: Map ESG rating dependencies in investment processes, train compliance teams on upcoming rules, and engage in industry feedback to influence final RTS adoption expected post-Q4 2025.
• AMF Stakeholders: Although dated, the notice encouraged French market input; now pivot to compliance readiness for 2026 application.

What changed

This AMF notice itself introduces no new regulatory changes; it promotes responses to ESMA's 2022 Call for Evidence, which gathered market insights to support the European Commission's July 2021 sustainable finance strategy. However, it highlights the push for a European framework on ESG ratings, including transparency on methodologies, conflict-of-interest management, internal controls, and dialogue with rated companies—elements now codified in the ESG Ratings Regulation effective 2 January 2025 (application from 2 July 2026).