On October 8, 2026, France's Label ISR committee opened a public consultation on the first référentiel extending the Investissement Socialement Responsable (SRI) label to private equity funds, adapting the six-pillar ESG architecture already applied to securities and real estate to unlisted companies. The consultation runs until November 19, 2026, after which the committee will revise the draft and submit it for the approval of the Minister of the Economy.
French private-equity asset managers (sociétés de gestion de capital-investissement) seeking the label must review the draft six-pillar framework, its pre-investment ESG due diligence, E, S and G and climate exclusions, shareholder engagement and portfolio ESG tracking, and submit their consultation contributions by November 19, 2026, or forfeit the ability to obtain the Label ISR for their funds once adopted. The label is voluntary, so non-compliance carries no legal penalty, but managers without it lose a recognized ESG differentiator that institutional limited partners use to screen French PE allocations.
What does the draft référentiel change for private equity?
The draft is the first Label ISR référentiel dedicated to capital-investissement and to the unlisted companies, principally PME and ETI, that PE funds finance. It keeps the six-pillar architecture and the same E, S and G exclusion criteria as the existing securities and real-estate référentiels, and requires a complete ESG analysis with particular attention to climate issues, ambitious shareholder engagement policies, portfolio ESG tracking over time, and investor disclosure.
What is specific to private equity is the weight the draft référentiel places on pre-investment due diligence and ongoing dialogue. Because a société de gestion takes a capital stake, sits on governance bodies and holds the position for years, the framework frames ESG as a long-term relationship with each portfolio company rather than a screening at entry. It also builds in a progression logic of measurable objectives, improvement plans and tracked results, and adapts its indicators to the data granularity that PME and ETI actually report.
Who is exposed to the new Label ISR framework?
French PE asset managers who want to label their funds are the primary addressees. Behind them, institutional limited partners allocating to French PE funds use the Label ISR as a quality screen, so the framework reshapes the criteria those LPs will apply. AFNOR Certification, the body that audits and certifies labeled funds, must gear its reviews to the new référentiel once adopted.
The financed companies are exposed too. The PME and ETI in PE portfolios become subject to the new ESG due diligence and engagement expectations, which will reach them through their investors' investment and monitoring processes. The draft was built with market input through a dedicated sub-committee bringing together sociétés de gestion, France Invest, the AFG, certificateurs and label committee members.
What must asset managers do before November 19, 2026?
The consultation is open until November 19, 2026, and the committee invites sociétés de gestion, investors, financed companies, certificateurs, experts and associations to submit observations through the consultation form. Contributions filed by that date are the chance to shape the final requirements before the committee revises the draft and submits it for ministerial approval.
In parallel, managers should prepare the internal capability the framework will demand: pre-investment ESG due diligence procedures, shareholder engagement policies, portfolio-level ESG tracking with measurable objectives, and the data flows needed to feed them from PME and ETI reporting. The application date is not yet set, because it depends on the post-consultation revision and ministerial approval, but the consultation window is when the requirements themselves can still move.
| Step | Date or status |
|---|---|
| Public consultation opens | October 8, 2026 |
| Consultation closes, contributions due | November 19, 2026 |
| Committee revises the draft | After consultation, date not set |
| Ministerial approval | Pending, date not set |
What happens if a fund does not obtain the label?
Because the Label ISR is voluntary, missing it triggers no fine or sanction. The consequence is commercial: a fund without the label sits outside a recognized ESG quality screen that French retail and institutional investors, and the LPs allocating to PE, use to tell structured ESG approaches apart from marketing claims.
Check whether your funds fall under the capital-investissement scope, read the draft référentiel against your current ESG due diligence and engagement practices, and brief your investment and portfolio-management teams before the November 19, 2026 deadline. Obsidian's continuous, per-jurisdiction monitoring surfaces consultations like this the moment they open, and follows this one through to the label's ministerial approval.
