The French government signed Decree No. 2026-636 on July 16, 2026, giving legal force to the third Stratégie nationale bas-carbone (SNBC 3) adopted on July 15, 2026. The decree was published in the Journal officiel (JORF n°0166) on July 18, 2026 and entered into force the next day, July 19, 2026. It sets binding national carbon budgets of 342, 262 and 194 Mt CO2e per year for 2024-2028, 2029-2033 and 2034-2038, and confirms a 50% cut in territorial greenhouse-gas emissions by 2030 against 1990. For climate-strategy leads at large French listed companies, and for Article 29 LEC investors whose alignment disclosures must reference this trajectory, SNBC 3 is now the benchmark against which transition plans and audit-ready targets are set.
What does Decree 2026-636 actually change?
The decree converts SNBC 3 from policy framing into carbon-budget ceilings France must not exceed. Article 2 revises the budgets for the two current five-year periods to 342 Mt CO2e per year for 2024-2028 and 262 Mt CO2e per year for 2029-2033, and fixes a new ceiling of 194 Mt CO2e per year for 2034-2038, all excluding carbon sinks. It is taken in application of articles L. 221-1 A and following of the Code de l'environnement, and Article 1 adopts the full SNBC 3 document set as France's official mitigation policy. The Ministère de la Transition écologique confirms the SNBC is one of three pillars of the Stratégie française pour l'énergie et le climat (SFEC), alongside the Programmation pluriannuelle de l'énergie (PPE) and the Plan national d'adaptation au changement climatique (PNACC), revised every five years.
Article 3 also allocates those ceilings by activity domain. For 2024-2028 the indicative annual shares are 116 Mt CO2e for transport, 51 for buildings, 75 for agriculture, 56 for industry, 30 for energy production and 14 for waste. Those sector figures are the numbers auditors and sector associations will test corporate and branch plans against.
Who has to align, and why does the carbon footprint matter now?
The decree's publics concernés name the State, local authorities, public-law entities and entire economic sectors, but the material compliance pull lands on large companies and institutional investors. SNBC 3 makes France the first country to set a quantified target for its carbon footprint, covering emissions embedded in imported goods, with a 71% to 79% reduction by 2050 against 2010. That extends the strategy beyond territorial emissions to the value chains of manufacturers and retailers selling into France. Named exposed actors include TotalEnergies, Saint-Gobain, Air Liquide, Vinci, Renault and Stellantis France on the corporate side, and Article 29 LEC institutional investors Amundi, AXA IM and BNP Paribas Cardif on the asset-manager side, together with their CAC and OTI assurance providers.
How does SNBC 3 connect to CSRD, BEGES and Article 29 LEC, and by when must teams react?
The carbon budgets are the reference trajectory auditors check when they assess the credibility of corporate transition plans. Under the BEGES regime (Article 75 of Loi n. 2010-788, Grenelle 2), large companies must publish a greenhouse-gas emissions report; under CSRD/ESRS E1, listed companies must disclose transition plans and targets; under Article 29 LEC (Decree 2021-663), asset managers and insurers must publish Paris-alignment trajectories. Each of these regimes now reads against the SNBC 3 ceilings, so a target that was aligned under SNBC 2 may no longer be. The seven strategic objectives of SNBC 3, including halving territorial emissions by 2030, reaching neutrality in 2050, and reducing the carbon footprint, set the cap that sectoral decarbonisation plans must fit under.
Action timing is immediate for internal recalibration: the decree is already in force since July 19, 2026. External disclosure timing follows the next filing cycle. Article 29 LEC and CSRD climate reports for financial year 2026 are typically due by 30 June 2027, so boards and assurance providers need the SNBC 3 ceilings locked into target models well before that cut-off. Continuous, per-jurisdiction monitoring is what surfaces a JORF carbon-budget revision the day it publishes, before the next reporting pack is frozen.
| Period | Annual ceiling (Mt CO2e) | Status under Decree 2026-636 |
|---|---|---|
| 2024-2028 | 342 | Revised |
| 2029-2033 | 262 | Revised |
| 2034-2038 | 194 | New |
Take advantage of this real-time watch
Verify whether published Scope 1, 2 and 3 targets and Article 29 LEC alignment disclosures still fit under the revised ceilings, brief audit and investor-relations teams on the footprint scope, and lock the sectoral allocations from Article 3 into the next board pack. Obsidian keeps the SNBC / carbon-budget file current as France updates it, so compliance teams act on the decree rather than discovering it at filing time.
