What is the mandatory carbon footprint in 2026?
The carbon footprint is an exhaustive and quantified inventory of greenhouse gases (GHGs) emitted by an organization over a calendar year. While the term “Bilan Carbone” was originally a trademark registered by ADEME (now managed by the Association for Low Carbon Transition), French law uses the official term of BELGIANS.
A definition broadened by the reform
Traditionally, the mandatory balance sheet focused on direct emissions. However, since the 2022 decree and the 2025 adjustments, the diagnosis can no longer ignore the indirect impact.
The 2026 carbon balance must imperatively reflect:
- Direct emissions (Scope 1): combustion of fixed or mobile sources (boilers, fleet of thermal vehicles).
- Indirect emissions linked to energy (Scope 2): consumption of electricity, heat or cold.
- Significant indirect emissions (Scope 3): this is where the biggest legislative change lies. Scope 3 encompasses the entire value chain, from the purchase of raw materials to the treatment of end-of-life products.
History and evolution: key regulatory dates
To understand the 2026 requirement, you have to go back in time to legislation that has continued to accelerate.
- 2010: the Grenelle II Act. It is laying the first stone by making BEGES mandatory for large companies and local authorities. The objective was then to raise awareness.
- July 1, 2022: Decree No. 22-982. This text marks a historic turning point by making the inclusion of Scope 3 mandatory for companies subject to BEGES. It also tightens sanctions.
- 2024-2025: the entry into force of the CSRD. This European directive replaces the NFRD and imposes standardized sustainability reporting at the EU level, including carbon data audited by independent third parties.
- 2026: regulatory maturity. All companies with more than 250 employees (according to CSRD criteria) must now integrate their carbon data into a single management report.
Who is concerned? Does my business have to do a carbon footprint?
This is the central question for any CSR manager or SME/ETI manager. In 2026, the thresholds were refined to leave no large structures behind.
Private companies and associations
In France, the historical threshold of the Environmental Code still applies, but it is supplemented by European thresholds:
- More than 500 employees: strict obligation to publish a BEGES including the 3 scopes every 4 years.
- Special case of the Overseas Territories: the threshold is lowered to 250 employees to take into account the local economic fabric and the climate vulnerability of these territories.
- CSRD criteria (2026): if your company meets 2 of the following 3 criteria: +250 employees, +25 M€ in balance sheet, +50 M€ in turnover, you are required to provide integrated annual carbon reporting.
The public sector: the exemplarity of the State
The law does not give gifts to public institutions:
- Public institutions: Threshold of 250 agents. The publication should be done every 3 years.
- Territorial authorities: all municipalities or groups of more than 50,000 inhabitants are subject to the exercise.
Consolidation for groups
The law now allows groups to publish a consolidated carbon balance. This avoids the multiplication of reports for each subsidiary, provided that the scope covers all the entities submitted. It is a strategic opportunity to share data collection costs.
Expert advice: even if you are an SME with 100 employees who are not subject, your clients (subject to the CSRD) will require your data for their Scope 3. Anticipating is a question of commercial survival. To understand how to start painlessly, read our article: Carbon footprint in business in 2026: understand everything.
The scope of application: focus on mandatory Scope 3
The obligation to integrate Scope 3 is the most impacting measure in recent years. Why? Because on average, it represents 60% to 90% of total emissions of a service or industrial company.
What the law requires to include in Scope 3:
- Purchases of goods and services: every euro spent with a supplier generates a carbon debt.
- Transport (Freight): the movement of goods upstream (suppliers) and downstream (customers).
- Waste: the impact of the end of life of products and operational waste.
- The use of the products sold: If you sell electrical appliances, their future energy consumption is your legislative responsibility.
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Scope 3 is the real driver of transformation. To master this complexity, consult our dedicated file: Reducing Scope 3 emissions: the real challenge of decarbonization.
Methodology and content: how to carry out a compliant assessment?
The law does not simply require figures; it imposes methodological rigor based on the standards of ADEME and the Ministry of Ecological Transition (Beges-r method).
The compliance steps
- Definition of the organizational perimeter: which subsidiaries? What geographic sites?
- Choice of the reference year: It's the starting point for measuring your progress. In the event of a merger/acquisition, the law requires recalculation to maintain data consistency.
- Activity data collection: It is a question of transforming liters of diesel, kWh or tons of steel into tons of CO2 equivalent.
- Use of emission factors: the law recommends the use of ADEME Footprint Database.
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The Transition Plan: the obligation to act
Carrying out an assessment without an action plan is now considered a failure. Your document should include:
- Quantified reduction goals.
- An implementation schedule.
- An evaluation of the effectiveness of past actions.
Publication, transparency and sanctions
In 2026, the “carbon police” became a reality. The transparency obligations aim to feed into the national database managed by ADEME.
Where to post?
The BEGES must be filed on the computer platform for GHG emissions assessments. This database is public: customers, investors, investors, NGOs and future candidates can consult it.
The new sanctions schedule
The days of symbolic fines are over. Failure to comply with the obligation to draw up a balance sheet or transition plan may result in:
- €10,000 fine by default.
- €20,000 in case of recidivism.
- Exclusion of public procurement: More and more tender clauses incorporate BEGES/CSRD compliance as an eligibility criterion.
Best practices: turning the law into an opportunity
For CSR managers, compliance should not be a simple check box. It is a management tool.
Our advice for 2026:
- Digitize your collection: In 2026, using Excel spreadsheets is risky and time-consuming. Software solutions make it possible to centralize data in real time and facilitate auditing.
- Name a carbon referent: the transversality of the subject requires clear governance involving financial management, purchasing and logistics.
- Engage your suppliers: since Scope 3 is mandatory, help your suppliers decarbonize to reduce your own emissions.
- Communicate transparently: an “imperfect” but honest record is better than an absence of publication or suspicious greenwashing data.
A low-carbon future imposed by law
The 2026 legislation marks the end of the volunteering era. The companies that have mastered their carbon footprint obligations today are the ones that will still be there tomorrow. The legal framework (BEGES, CSRD, Scope 3) is only a reflection of the climate emergency: measuring to reduce, and reducing to survive in a low-carbon economy.
As transition experts for over 15 years, we see that compliance is the best driver of innovation. Don't think of the carbon footprint as a tax, but as a dashboard for your future resilience.
