French Duty of Vigilance: LdV Supply Chain Law¶
Since the French Duty of Vigilance Law came into force in 2017, NGOs and affected communities have filed multiple high-profile lawsuits — against TotalEnergies over its Tilenga oil project in Uganda and Tanzania, against EDF over a wind farm affecting indigenous communities in Mexico, and against BNP Paribas over fossil fuel financing. In 2023 alone, four new LdV cases were filed in French courts. None resulted in an operational suspension order, but each forced the defendant company to publicly disclose and — in some cases — substantially revise its vigilance plan. The law is no longer a dormant obligation. It is being actively litigated.
The French Duty of Vigilance Law (Loi de Vigilance — LdV, Law No. 2017-399) was the first mandatory human rights and environmental due diligence law in Europe. It requires large French companies to establish, publish, and implement a vigilance plan covering their own operations, those of their subsidiaries, and those of their suppliers and subcontractors. On the Sustalium platform, we now hear from French procurement teams asking suppliers to provide structured ESG and supply chain data specifically to feed into the parent company's vigilance plan — and if a supplier cannot produce the data, they get replaced.
Who Does the LdV Apply To?¶
The LdV applies to any company headquartered in France that meets either of these thresholds:
- 5,000 or more employees within the company and its French subsidiaries (direct and indirect)
- 10,000 or more employees within the company and its subsidiaries worldwide (direct and indirect)
There is no revenue threshold. The threshold is purely headcount-based, and it includes employees of direct and indirect subsidiaries globally.
While the legal obligation formally sits with the parent company, the practical effect cascades down the entire supply chain. French parent companies must disclose supply chain risks in their public vigilance plans — and that disclosure requirement compels them to demand data, certifications, and audit results from every tier of supplier.
What the LdV Requires¶
The vigilance plan must include five mandatory components:
1. Risk Mapping¶
A detailed mapping of human rights, health and safety, and environmental risks across the company's own operations, its subsidiaries, and its entire supply chain. This is not a high-level summary — it must identify specific risk categories linked to specific geographies, suppliers, and operational contexts. For a retail company, this means mapping conditions at garment factories in Bangladesh. For an electronics manufacturer, it means mapping cobalt and mica mining in the Democratic Republic of Congo.
2. Regular Assessment Procedures¶
Documented procedures for regularly assessing the situation of subsidiaries, subcontractors, and suppliers based on the risk mapping. This includes defined assessment methodologies, assessment frequency, and documented follow-up on findings.
3. Appropriate Mitigation Actions¶
Specific actions to mitigate identified risks and prevent serious harm to human rights, health and safety, and the environment. If your risk mapping flags forced labor at a Tier 3 raw material supplier, your plan must describe what you are doing about it — not just that you identified it.
4. Whistleblowing Mechanism¶
A mechanism for collecting alerts and reports of existing or potential risks, developed in consultation with employee representative organizations. This must be accessible to employees, subcontractor workers, and affected communities — not just internal staff.
5. Monitoring and Evaluation¶
A system for monitoring the effectiveness of the measures implemented and evaluating their results. This creates an obligation for continuous improvement, not just a one-time compliance exercise.
Enforcement: From Compliance Paper to Court Orders¶
The LdV is not a paper obligation. It includes a specific enforcement mechanism (Article L. 225-102-5 of the French Commercial Code) that allows any interested party to bring a claim before the French courts if a company fails to establish, publish, or implement a vigilance plan.
French courts can:
- Issue a formal notice (mise en demeure) requiring compliance within a defined period
- Order the company to publish and implement a compliant vigilance plan
- Impose periodic penalty payments (astreintes) until compliance is achieved
- Order the suspension of business activities linked to identified risks
High-profile cases have already set precedents:
- TotalEnergies — challenged over its Uganda/Tanzania oil project (Tilenga/EACOP), with claims that its vigilance plan inadequately addressed human rights and environmental risks
- EDF — challenged over a wind farm project in Mexico affecting indigenous communities
- Suez — challenged over water management operations in Chile
- Teleperformance — challenged over working conditions in call centers
- BNP Paribas — challenged over financing of fossil fuel projects
The EU-Wide Connection: CSDDD¶
The LdV is now effectively complemented by the EU Corporate Sustainability Due Diligence Directive (CSDDD), which applies similar requirements across all EU Member States with broader scope (companies with 1,000+ employees and €450M+ revenue). French companies already complying with LdV have a head start, but CSDDD expands the obligation to thousands more European companies. The direction of regulation is clear: mandatory human rights and environmental due diligence across the supply chain is becoming the baseline, not a leadership position.
How Sustalium Supports LdV Compliance¶
For suppliers selling into French (and increasingly European) supply chains, the message from buyers is increasingly blunt: produce your ESG and supply chain data, or lose the contract.
Sustalium's ESG and supply chain compliance platform helps both the reporting parent company and the supplier side of the LdV equation:
- Supplier Data Collection Portal: Suppliers can upload their social audit reports (SMETA, BSCI, SA8000), environmental certifications, conflict mineral declarations, and human rights policies into a structured profile that buyers can access — replacing ad hoc email requests and static spreadsheets.
- Risk Mapping Templates: Structured templates aligned to LdV's five mandatory plan components help French parent companies document their risk mapping, assessment procedures, mitigation actions, whistleblowing mechanism, and monitoring system in a single, auditable dossier.
- Multi-Framework Integration: Because LdV compliance overlaps with CSRD reporting, CSDDD due diligence, and EUDR deforestation requirements, Sustalium maintains your supply chain data once and maps it across multiple regulatory frameworks — eliminating duplicate data collection.
- Audit-Ready Evidence: All supplier certifications, audit reports, and risk assessments are stored in a time-stamped, audit-ready format for the full retention period required by the vigilance plan.
Respond to French Buyer LdV Requests with Confidence
Whether you are a French parent company building your vigilance plan or a supplier receiving LdV data requests from French customers, stop managing supply chain due diligence through emails and spreadsheets.
With Sustalium, build your LdV compliance dossier for just €10 per document.
Frequently Asked Questions¶
Does the LdV apply to non-French companies?
The legal obligation applies only to French-headquartered companies meeting the employee thresholds. However, any supplier (regardless of location) selling to a covered French company will be subject to contractual LdV-related data demands — and may be deselected if they cannot comply.
How is LdV different from the EU CSDDD?
The LdV was the first mandatory human rights due diligence law and served as a model for CSDDD. Key differences: LdV has lower employee thresholds (5,000/10,000 vs. CSDDD's 1,000 + €450M revenue), was enforceable earlier, and includes a specific French court enforcement mechanism. CSDDD broadens the obligation across the EU.
What happens if a supplier refuses to provide LdV data?
A supplier cannot be directly sued under the LdV, but the French parent company can be. This creates strong incentives for the parent company to terminate relationships with non-responsive suppliers and replace them with suppliers that can provide the required due diligence data.
Is LdV compliance a one-time exercise?
No. The law requires annual publication and continuous monitoring. The vigilance plan must be updated to reflect new risks, new suppliers, new geographies, and new business activities. Courts have explicitly rejected static, copy-paste plans as non-compliant.
Last updated: July 15, 2026