Your French customer has sent you a compliance questionnaire. Here is what the law requires of them — and what they need from you.
The Loi de Vigilance (Duty of Vigilance Law) has been in force in France since March 2017 — making France the first EU country to adopt a mandatory supply chain due diligence law, six years before Germany's LkSG. It requires large French companies to map, assess, and address human rights, health and safety, and environmental risks across their own operations, subsidiaries, and established commercial relationships. If you supply goods or services to a large French company, they are legally required to assess you as part of their vigilance plan. Your response to their questionnaire forms part of that plan — which can be scrutinised by courts, NGOs, and trade unions.
Key regulations in France — Loi de Vigilance Supplier Guide
Loi de Vigilance — French Duty of Vigilance Law
The Loi de Vigilance requires companies with 5,000 or more employees in France, or 10,000 or more worldwide including subsidiaries and subcontractors, to establish, implement, and publish an annual vigilance plan (plan de vigilance). The plan must cover the company's own operations, its subsidiaries, and its established commercial relationships — including direct suppliers and subcontractors. It must include five elements: risk mapping, risk assessment procedures, appropriate mitigation actions, a whistleblowing mechanism, and a monitoring scheme. The law covers human rights, fundamental freedoms, health and safety, and environmental risks.
Paris Courts — Vigilance Law Enforcement
The Loi de Vigilance is enforced through civil litigation in the Paris courts. Any person with a legitimate interest — an NGO, trade union, or affected community — can bring a claim against a covered company for failure to establish, implement, or publish an adequate vigilance plan. In December 2023, a company was convicted under the law for the first time. High-profile cases against Total (climate change), EDF (environmental impacts), and Casino (Amazon deforestation) have established that French courts will scrutinise the adequacy of vigilance plans in detail, including the quality of supplier assessments.
CSDDD — EU Corporate Sustainability Due Diligence Directive
France's Loi de Vigilance was the direct model for the EU's CSDDD. As CSDDD is transposed across all EU member states, French buyers will face stricter and more standardised obligations — and their suppliers will face a wave of CSDDD-driven questionnaires from buyers across the entire EU. Suppliers who can already respond to Loi de Vigilance questionnaires will be well positioned for this expansion.
What this means for you as a supplier
You are not directly regulated by the Loi de Vigilance. But your French buyer is. The law requires them to assess their established commercial relationships — which includes you as a supplier. A non-response or a weak response means your buyer cannot demonstrate adequate risk assessment in their vigilance plan. French courts have already ruled that inadequate plans expose companies to civil liability. NGOs and trade unions can bring claims. Your compliance evidence is part of your buyer's legal defence — and your absence from their records is a gap they cannot afford.
Key dates
27 March 2017
Loi de Vigilance comes into force — France becomes first EU country with mandatory supply chain due diligence
Annually
Vigilance plan published with the company's annual report — supplier assessments must be current
December 2023
First conviction under the Loi de Vigilance — companies now face real legal exposure for inadequate plans
2024–2025
Paris Court of Appeals rulings on Total and EDF cases — scope of 'established commercial relationships' being defined
July 2029
CSDDD Phase 1 — EU-wide supply chain due diligence for largest companies; French buyers already ahead of the curve
2029
CSDDD Phase 3 — companies with ≥1,000 employees; all EU buyers in scope
Which companies are required to comply
The Loi de Vigilance applies to companies with 5,000 or more employees in France, or 10,000 or more worldwide including subsidiaries and subcontractors, for at least two consecutive financial years. This covers the largest French companies — Airbus, BNP Paribas, Carrefour, Danone, EDF, L'Oréal, LVMH, Michelin, Renault, Société Générale, Total, and several hundred others. Foreign companies with French subsidiaries meeting these thresholds are also in scope.
As a supplier, you may not meet these thresholds yourself — and you are not directly regulated by the law. But the companies buying from you almost certainly do. The law explicitly requires covered companies to assess their "established commercial relationships" — a term the Paris courts have interpreted broadly to include regular suppliers and subcontractors at multiple tiers.
What your French buyer's questionnaire will ask
The Loi de Vigilance requires a five-element vigilance plan. Questionnaires sent to suppliers typically map onto these five elements. The law covers a broader range of topics than LkSG — it includes environmental risks alongside human rights and health and safety.
Risk mapping (cartographie des risques)
Your buyer must identify and prioritise risks across their supply chain. They will ask you to describe your operations, sector, geography, and any known risk factors — forced labour, child labour, environmental impacts, health and safety incidents. Your answers feed directly into their risk map.
Human rights & fundamental freedoms
A written policy covering forced labour, child labour, freedom of association, non-discrimination, and fair wages. Evidence that the policy is communicated to your workforce and applied in practice. The Loi de Vigilance covers fundamental freedoms more broadly than LkSG.
Health & safety
Workplace safety policies, incident records, and relevant certifications (ISO 45001 or equivalent). Evidence that safety standards apply to all workers including temporary, agency, and contract staff. The law explicitly includes health and safety as a core due diligence area — not just an add-on.
Environmental risks
Evidence of environmental management practices — waste, emissions, water, biodiversity. ISO 14001 or EMAS certification is useful evidence. The Loi de Vigilance covers environmental risks alongside human rights, unlike LkSG which focuses primarily on human rights. Buyers in sectors with environmental exposure (energy, agriculture, chemicals, construction) will ask detailed environmental questions.
Whistleblowing mechanism (dispositif d'alerte)
A formal process for workers, subcontractors, and stakeholders to raise concerns without fear of retaliation. This may be an internal channel or a third-party service. Your buyer must demonstrate that their supply chain has accessible reporting mechanisms — they will ask whether you have one.
Your own supply chain due diligence
Evidence that you assess your own suppliers and subcontractors for human rights, health and safety, and environmental risks. The Paris courts have interpreted 'established commercial relationships' to extend beyond direct suppliers — your buyer must show they have checked whether their suppliers manage their own supply chains responsibly.
Court cases — why your buyer takes this seriously
Unlike LkSG (which is enforced by a regulatory authority, BAFA) or the Norwegian Transparency Act (enforced by Forbrukertilsynet), the Loi de Vigilance is enforced through civil litigation. Any NGO, trade union, or affected community with a legitimate interest can take a covered company to the Paris courts for failing to establish, implement, or publish an adequate vigilance plan.
This creates a different kind of pressure on your buyer. It is not just about passing a regulatory audit — it is about being able to demonstrate in court that their vigilance plan was adequate and that their supplier assessments were thorough. The first conviction under the law came in December 2023. High-profile cases include:
Climate change — NGOs challenged the adequacy of Total's vigilance plan regarding climate risks in its supply chain. Paris Court of Appeals ruled in 2024.
Environmental impacts — case concerning the adequacy of EDF's vigilance plan regarding environmental risks in its supply chain.
Amazon deforestation — NGOs challenged Casino's vigilance plan regarding deforestation risks in its Brazilian beef supply chain.
What happens if your response is inadequate
- →Your buyer cannot demonstrate adequate risk assessment in their vigilance plan — creating a gap that NGOs and trade unions can exploit in court
- →The Loi de Vigilance requires your buyer to take appropriate mitigation actions for identified risks — which may mean requesting remediation from you, or replacing you with a supplier who can demonstrate compliance
- →If a court case is brought against your buyer and their vigilance plan is found inadequate, they face civil liability — including injunctions and damages
- →Reputational exposure is significant — Loi de Vigilance cases are public and attract media attention, particularly in sectors with environmental or human rights risks
- →As CSDDD comes into force, the same questions will arrive from buyers across all EU member states — not just France
How the Loi de Vigilance differs from LkSG
| Aspect | Loi de Vigilance (France) | LkSG (Germany) |
|---|---|---|
| In force | March 2017 | January 2023 |
| Threshold | 5,000 employees in France or 10,000 worldwide | 1,000 employees in Germany (from 2024) |
| Scope | Own operations, subsidiaries, established commercial relationships (multi-tier) | Own operations and direct suppliers (indirect suppliers in specific circumstances) |
| Topics covered | Human rights, fundamental freedoms, health & safety, environment | Human rights and specific environmental obligations |
| Enforcement | Civil litigation — NGOs, trade unions, affected communities can sue | Regulatory — BAFA audits and fines |
| Annual obligation | Vigilance plan published with annual report | Annual due diligence report published |
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
Received a Loi de Vigilance questionnaire?
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