EHS & CSR 2026: regulatory calendar, past and upcoming deadlines

What EHS and CSR obligations must you comply with in 2026? Between new regulations, past deadlines, and delays related to the Omnibus directive, get up to speed on the calendar and the actions you need to anticipate.

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Publication : 
15.01.2026
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🔎 Key takeaways

  • Several major 2026 deadlines have already passed (prevention passport, solar carports, waste transfers, OELs for acrylonitrile and benzene, CBAM, EmpCO, energy audits, and PFAS labeling): the question is no longer "how to anticipate" but "are you compliant?"
  • November 21, 2026 : ban on plastic waste exports to non-OECD countries.
  • January 1, 2027 : operational launch of the EPR scheme for professional packaging.
  • CSRD and CS3D have been postponed by the European Omnibus package: do not base your 2026-2027 budgets on the old deadlines.

Please note: This article concerns French legislation. The requirements described may not apply in other countries.

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2026 is a pivotal year for EHS and CSR compliance, but it reads differently depending on whether you look at it from January or November. Some obligations are already in effect and are being audited now; one final deadline is approaching by the end of the year, while other obligations have been postponed; a third set has been pushed back by the Omnibus reform and should no longer drive your short-term decision-making. We have structured this calendar so you can immediately distinguish between the three.

On the same topic: replay of the mid-year Tennaxia webinar on 2026 EHS regulations. Need help with your EHS regulatory monitoring or CSR consulting? Contact us.

1. Climate, Energy, and Buildings

✅ In effect since July 1, 2026: green parking lots (APER law)

Check now: if your outdoor parking lot, existing as of July 1, 2023, reaches 10,000 m² or more, the obligation has applied since July 1, 2026, except for specific schedules for parking lots managed under concession or public service delegation. At least half of the parking area must be shaded according to one of the methods provided for by the APER law.

Three options are permitted:

  • solar carports integrating renewable energy production over the entire shaded area;
  • a hybrid solution, with carports covering at least 35% of the area to be equipped and green solutions shading the rest;
  • a renewable energy production system without carports, provided it achieves equivalent production.

Parking facilities between 1,500 m² and 10,000 m² have a deadline of July 1, 2028. The law provides for exemptions, particularly in cases of technical, safety, architectural, or heritage constraints, or if the cost of the work is economically unfeasible. Certain deferrals are also possible under specific conditions; these do not constitute a general extension of the deadline.

✅ In effect since October 11, 2026: Lowering of the energy audit threshold

What you need to do before October 11, 2026: complete your first energy audit (or implement an Energy Management System, EnMS) if your average annual final energy consumption is 2.75 GWh or more. This threshold replaces the previous criteria (250 employees, turnover > €50M, balance sheet > €43M) and brings a new group of companies into the regulatory scope. Audits must be renewed every 4 years.

Beyond mere compliance, the audit becomes a genuine tool for managing your energy costs in a context of volatile prices.

Looking ahead to 2027-2028

  • October 11, 2027 : Companies with consumption of 23.6 GWh/year or more must implement an Energy Management System (EnMS) certified by an accredited body (via ISO 50001 or equivalent, unless exempt as companies already ISO 14001 certified with a compliant energy audit, or under an energy performance contract). Preparation must begin in 2026.
  • January 1, 2028 : Commercial, industrial, office, warehouse, school, hospital, or covered parking buildings (existing as of July 1, 2023) with a footprint of at least 500 m² must incorporate renewable energy production or green roofing. Exemptions exist for technical, safety, architectural, heritage, or economic reasons. Application criteria are to be specified by decree; specific provisions also apply to certain ICPE facilities. These should be included in your multi-year investment plans.

→ Need a helping hand with your regulatory monitoring? Rely on the EHS regulatory monitoring from Tennaxia.

2. Chemical Risks, Health, and HR

✅ In effect since March 16, 2026: The prevention passport

Since March 16, 2026, employer access to the prevention passport has been open. Until December 31, 2026, you must declare mandatory regulatory training and training required for positions necessitating employer authorization or certification. Also, ensure that training providers declare the training for which they are responsible. This system makes data centralization mandatory (the end of isolated Excel spreadsheets between EHS and HR) and protects both the employee's career path and your company in the event of a dispute: traceability of certifications, proof of training in case of an accident, and simplified skills transfers.

Check with your HR department to ensure this matter has been addressed.

✅ In effect since April 2026: Stricter OELs for acrylonitrile and benzene

Decree No. 2024-307 of April 4, 2024 (transposing EU Directive 2022/431) set two upcoming deadlines: since April 5, 2026, the OEL for acrylonitrile (CAS 107-13-1, CMR 1B) has been mandatory — 1 mg/m³ over 8 hours, 4 mg/m³ over 15 minutes — with mandatory annual testing by a COFRAC-accredited body. Since April 6, 2026, the final OEL for benzene has been reduced to 0.2 ppm (0.66 mg/m³ over 8 hours), down from the 0.5 ppm allowed during the 2024 transition period. If your 2026 measurement campaigns for either substance have not yet been completed, this should be a priority.

✅ In effect since October 23, 2026: PFAS labeling for firefighting equipment

As of October 23, 2026, all stocks of firefighting foam (excluding portable extinguishers) and any waste containing it must bear a visible, legible, and indelible label if the PFAS concentration reaches 1 mg/L: "WARNING: Contains per- and polyfluoroalkyl substances (PFAS) at a concentration equal to or greater than 1 mg/L for the sum of all PFAS."

Want to learn more? Check out our article on the ban on PFAS in firefighting foams.

3. Waste and EPR schemes

✅ In effect since May 21, 2026: Transboundary waste shipments

European Regulation 2024/1157 has been largely applicable since May 21, 2026: the relevant procedures are now digitized via the European DIWASS platform. Since that date, exports of plastic waste to third countries are subject to a prior notification and consent procedure. As of November 21, 2026, exports of plastic waste to non-OECD countries will be prohibited. A European platform now centralizes the digital declaration for every shipment.

Waste type Authorized destination Digital obligation Non-compliance risk
Non-hazardous plastics OECD areas only Mandatory EU platform Heavy financial penalties
Hazardous waste Non-OECD ban Digital declaration Administrative penalties
Metals OECD / non-OECD subject to conditions Computerized tracking Delays and penalties
Paper/cardboard OECD / non-OECD subject to conditions Digital traceability Customs disputes

⏳ January 1, 2027: EPR scheme for professional packaging

The entry into force of the EPR for professional packaging, originally scheduled for July 2026, has been postponed to January 1, 2027. Verify your status as a producer (as defined by the PPWR regulation) and whether your packaging is considered professional (scope decree). If you are a producer, you must either implement an approved individual system or join an eco-organization that holds approval for professional packaging. Map your waste streams to optimize your contribution costs.

To watch

  • Healthcare waste (DASRI) : digitizing consignment notes on the Trackdéchet platform has been possible since June 2023 but remains optional pending the legislation that will make it mandatory.

4. Classified installations (ICPE) and industrial emissions

✅ In effect since January 1, 2026: digitization of ICPE accident and incident reports

Operators of ICPE facilities must report accidents or incidents resulting from the facility's operation that could affect protected interests to the classified installations inspectorate via the online procedure on the platform service-public.gouv.fr. For an accident, the operator must also send a report to the prefect and the inspectorate. For an incident, a report is submitted upon the inspectorate's request. Certain confidential information or data relating to specific facilities will continue to be submitted in non-digital form.

✅ In effect since September 1, 2026: monitoring of PFAS in aqueous discharges from certain ICPE facilities

As of September 1, 2026, PFAS monitoring procedures apply to facilities covered by the ICPE headings targeted by the decree of June 25, 2026, and subject to the fee for water pollution by PFAS. Depending on the case, this monitoring is based on self-monitoring or measurement campaigns. Check the requirements applicable to your facility.

⏳ Strengthened IED Directive: initial provisions transposed, timeline to follow

The IED 2.0 Directive (EU 2024/1785) was to be transposed by July 1, 2026. The date for full French transposition remains uncertain at this time. A public consultation by the ministry concluded on May 3, 2026, regarding a draft decree covering waste incineration and co-incineration. A decree concerning waste treatment facilities was published on June 18, 2026. This publication transposes certain provisions of the IED 2.0 Directive for the activities concerned; it does not mean that the entire French transposition is complete. Once fully transposed, the directive will expand the scope (including intensive livestock farming) and require an audit of the environmental management system before July 1, 2027.

To watch

  • ICPE battery heading : work is underway to create a new heading 2926, specifically to regulate certain activities involving the assembly, recycling, reconditioning, and treatment of battery waste. At this stage, no effective date has been announced.

5. CSR, Communication & Governance

✅ In effect since January 1, 2026: definitive phase of the CBAM

The Carbon Border Adjustment Mechanism (CBAM) entered its definitive phase on January 1, 2026, for six product categories (steel, aluminum, cement, fertilizers, hydrogen, and electricity—567 codes in total, with steel accounting for over 70% of the value of the trade involved). Simple reporting is no longer enough: the definitive regime requires the actual purchase of carbon certificates. Certificate sales begin in February 2027. For 2026 imports, the first declaration and the surrender of the corresponding certificates must be completed by September 30, 2027. In 2026, a single threshold of 50 tonnes of CBAM goods applies to affected importers: check whether your company falls within the scope of this obligation and, if so, consider incorporating this customs carbon cost into your procurement decisions now.

✅ In effect since September 27, 2026: implementation of the EmpCO anti-greenwashing directive

The EmpCO directive (EU 2024/825) has been in effect since September 27, 2026. Generic environmental claims such as "carbon neutral" or "eco-friendly" are prohibited unless they are based on recognized and relevant excellent environmental performance. Certain climate neutrality claims based on carbon offsetting are also prohibited for products. Back up your messaging with official certifications (Ecolabel) and life cycle assessments.

CSRD: what has changed with the Omnibus package

The Omnibus package has modified both the timeline and the scope of the directive. Directive (EU) 2025/794, transposed into French law by Law No. 2025-391 of April 30, 2025, has postponed certain deadlines. The Omnibus Directive I (EU) 2026/470 subsequently narrowed the scope of the CSRD.

  • Starting from financial years beginning in 2027, the new European rules target companies exceeding both 1,000 employees and €450 million in net turnover.
  • Listed SMEs are no longer within the scope of the CSRD under these rules.
  • Companies that remain subject to the requirements starting from the 2027 financial year will publish their first report in 2028. For the 2025 and 2026 financial years, the directive allows Member States to exempt certain companies that do not meet these thresholds; their situation depends on the applicable national measures.

In practical terms, if you are a mid-sized company that expected to have to publish in 2027, first check whether you remain within the revised scope: under the new thresholds, some companies may fall out of scope, while those that remain will publish their report for the 2027 financial year in 2028. Collecting ESRS data remains a project that is better structured in advance rather than in a rush.

CS3D/CSDDD: the due diligence obligation also postponed

The same logic applies to the CS3D : The Omnibus I Directive (EU 2026/470) has modified the timeline and scope of the CSDDD. At the European level, member states must transpose the new provisions by July 26, 2028; they will apply starting July 26, 2029. The revised scope targets companies exceeding both 5,000 employees and €1.5 billion in net turnover. Affected companies are already mapping their supply chain risks, and SMEs are receiving compliance questionnaires from their clients; a CSR consultant can help you structure these responses without waiting for the legal deadline.

Summary Timeline

Status Deadline Topic Requirement
✅ In force 16 March 2026 Occupational health & safety Employer access to the prevention passport
✅ In force 5 April 2026 Chemical risks Binding OEL for acrylonitrile
✅ In force 6 April 2026 Chemical risks Final OEL for benzene (0.2 ppm)
✅ In force 21 May 2026 Waste & shipments New EU rules on transboundary shipments of waste
✅ In force 1 July 2026 Climate, energy & buildings Solar canopies/greening on 50% of car parks ≥ 10,000 m²
✅ In force 1 January 2026 Climate & carbon Definitive (paid) phase of CBAM
✅ In force Immediate ICPE & industrial risks Dematerialization of accident/incident reports
✅ In force 27 September 2026 CSR & communication Application of the EmpCO anti-greenwashing directive
✅ In force 11 October 2026 Climate & energy Mandatory energy audit from 2.75 GWh/year
✅ In force 23 October 2026 Chemical risks PFAS labeling of firefighting foams ≥ 1 mg/L
⏳ Upcoming 21 November 2026 Waste Ban on plastic waste exports to non-OECD countries
⏳ To verify 1 July 2026 (deadline passed) ICPE & industrial emissions Transposition of the revised IED directive. To date, partial transposition, with full transposition to be confirmed.
⏳ Upcoming 1 January 2027 Waste & EPR Operational start of EPR for commercial packaging
📅 2027-2028 26 July 2028 CSR & Governance National transposition of CS3D/CSDDD (Omnibus postponement)
📅 2027-2028 11 October 2027 Energy & Buildings Mandatory certified EnMS from 23.6 GWh/year
📅 2027-2028 1 July 2027 ICPE Mandatory EMS audit (IED directive)
📅 2027-2028 1 January 2028 Energy & Buildings Solarized/green roofs ≥ 500 m²
📅 2027-2028 26 July 2029 CSR & Governance CS3D application for groups > 5,000 employees (Omnibus postponement)
📅 2028 2028 CSR & Governance CSRD Wave 2 publication (2028 on FY 2027) — Omnibus postponement
🔍 Under monitoring — ICPE & industrial risks Section 2926 dedicated to batteries (under consultation)
🔍 Under monitoring — Waste & traceability Dematerialization of healthcare waste (DASRI) (optional for now)

Frequently Asked Questions

What EHS and CSR obligations for 2026 are still pending at the end of 2026?

The next upcoming deadline is November 21, 2026, when exports of plastic waste to non-OECD countries will be prohibited. The Extended Producer Responsibility (EPR) scheme for professional packaging will become operational on January 1, 2027.

Is the CSRD mandatory in 2026 for non-listed companies?

Not being listed is not enough to determine if a company is affected. Some non-listed companies may fall under obligations applicable in 2026, while other deadlines have been postponed. For financial years starting on or after January 1, 2027, the new European rules target companies exceeding both 1,000 employees and €450 million in net turnover.

What changes with the CS3D in 2026?

Nothing immediate for companies: national transposition has been postponed to July 26, 2028, and application for large groups to July 26, 2029.

Who is affected by the requirement for solar carports in parking lots?

Outdoor parking lots of 10,000 m² or more that existed as of July 1, 2023, must have half of their area equipped with solar panels as of July 1, 2026, unless a legal exemption has been granted.

Conclusion

2026 has been a year of regulatory transition, but not in the way it is often presented: some obligations are already behind you and are currently being verified, another deadline is coming up on November 21, while the EPR for professional packaging has been postponed to January 1, 2027, and the most significant projects (CSRD, CS3D) have actually been pushed back by the Omnibus reform. The real risk today is not missing an upcoming deadline, but continuing to manage your budgets based on an obsolete calendar. Take stock of your EHS, CSR, and carbon compliance now, rather than waiting until 2027.

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Sources and References