2026 overview of HSE obligations for companies in France: what executives need to keep in mind

In HSE terms, 2026 is not a “revolutionary” year, but it is a year when several topics become impossible to ignore: the concrete implementation of reforms already underway, rising climate-related risks (heat), tighter rules on certain substances, and environmental obligations that translate into day-to-day operations.

Here are the items that, from a leadership perspective, should be at the very top of your list.

DUERP: more than ever a management tool (and evidence if something goes wrong)

The DUERP (single risk assessment document) is mandatory from the very first employee. It must be updated at least annually in companies with at least 11 employees (and after any significant change or new information). A point that is often overlooked: the digital submission portal provided for in the regulations was still not available (based on the latest widely cited public status), which increases the importance of your own internal archiving and communication process.

Executive involvement: don’t delegate “the DUERP” as if it were just a file. Ask for a quarterly update: major risks, actions, delays, and trade-offs.

Chemical risk / CMR: stronger traceability and new OELs

The decree of 4 April 2024 strengthens the traceability of workers’ exposure to CMR agents (carcinogenic, mutagenic, or reprotoxic), with structured requirements (including a list of workers likely to be exposed) and entry into force in mid-2024. In addition, the EU has lowered limit values for lead and introduced rules for diisocyanates, with a transposition deadline of 9 April 2026.

Executive involvement: include chemical risk in your “Executive Committee” risk reviews if you have workshops, maintenance, surface treatment, adhesives/resins, etc. This is typically an area where accidents are rare… but legal and health risks are significant.

Heat at work: a strengthened framework since July 2025

Since 1 July 2025, the Labour Code has included reinforced prevention obligations during periods of intense heat, including risk assessment and measures to be implemented. The thresholds defining “intense heat episodes” are linked to weather alerts (order of 27 May 2025).

Executive involvement: require an operational “heat plan” (working hours, water, breaks, adaptations, instructions, right to raise alerts, field checks). Heat is a safety risk (accidents) as well as a health risk.

Prevention Passport: a very concrete HR/HSE milestone in 2026

The rollout of the Prevention Passport continues: since 1 September 2025, training providers declare first-aider (SST) training, and the employer portal opens from 16 March 2026 for employer declarations.

Executive involvement: this is an opportunity to restore order in the governance of authorizations/permits/training and to secure traceability.

Environment: waste, biowaste, PFAS… operations are catching up with strategy

Source separation of biowaste has been generalized since 1 January 2024 (professionals and households): many companies still have not embedded it properly on their sites. And since 1 January 2026, the PFAS law provides for progressive bans on certain products (depending on categories), potentially affecting procurement, R&D, product compliance, and suppliers.

Executive involvement: run a quick “procurement/supplier scan”: substances, products, waste streams, channels, traceability. This is not a nice-to-have—it’s business continuity.