HSEES deadline checklist for September 2026

September 2026 brings several key HSE and energy deadlines: lightning risk, PFAS fees, hydroelectric facilities, and OPERAT reporting. Here are the obligations to anticipate.

Marie Faucon
Consultante HSE
Publication : 
14.09.2026
Table of Contents
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🔎 Key takeaways

  • Lightning risk : As of September 1, 2026, certain 3xxx ICPE facilities must comply with new requirements, including lightning technical studies, maintenance, and periodic inspections.
  • Hydroelectricity : Facilities with a capacity exceeding 4,500 kW are transitioning from the concession regime to an authorization regime, pending the expected implementing legislation.
  • PFAS : Certain authorized ICPE facilities discharging more than 100 g of PFAS per year are now subject to the new fee.
  • OPERAT : Entities subject to the Tertiary Eco-Energy scheme must report their 2025 energy consumption by September 30, 2026.

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

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09/01/2026: Lightning risk obligations for certain 3xxx facilities

For authorized facilities under headings 3110 to 3260, 3410 to 3510, 3550, 3610, 3670, and 3700 for which the complete authorization application was submitted before September 1, 2022, and which were not otherwise subject to these provisions as of August 31, 2022, the lightning-related provisions of the decree of October 4, 2010—excluding the lightning risk analysis (ARF) requirement—apply as of September 1, 2026. These provisions include conducting a lightning technical study (ETF), maintaining an inspection and maintenance log, and performing periodic inspections.

As a reminder, the requirement to conduct a lightning risk analysis (ARF) has been in effect since September1 , 2024.

09/01/2026: End of concessions for hydroelectric facilities

Hydroelectric facilities with a capacity > 4,500 kW are now subject to authorization, replacing the historical concession regime.

Please note that we are still awaiting the implementing decrees.

09/01/2026: New PFAS fee

Certain facilities subject to the ICPE authorization regime are now subject to the PFAS fee if they discharge more than 100 grams of PFAS per year directly into the natural environment or via a collection network.

For more information: link to Isabelle’s article

09/30/2026: Deadline for declaring energy consumption on the OPERAT platform

Those subject to the Eco Energie Tertiaire scheme (Tertiary Decree) must declare their annual energy consumption for 2025 on the OPERAT platform.