Which AI use charter should you adopt?

In France, public administrations publish their AI use charters. The interministerial digital directorate lists around thirty on its portal↗, from ministries to universities. In 2026, 75% of local authorities engaged in an AI project had started a charter or an internal reference document, according to the economic outlook report↗ by the Banque des Territoires and the Observatoire Data Publica. Companies publish few of them: we found 2.

Use came before the charters. When the Doubs Department surveyed its staff in autumn 2024, nearly a quarter of the 561 respondents said they had already used AI in their work, even though no policy had been defined.

We read 16 charters published from 2024 to 2026: 5 from the State, including the DINUM interministerial guide, 4 from local authorities, 4 from bodies with a public service mission, 1 from a university and 2 from companies. The template that follows draws on their best rules, keeping their wording where it is accurate; each article is followed by what the law and the published charters say.

None converts use into electricity or emissions. 6 mention a review, an assessment or an inventory of uses; the Doubs Department goes furthest, with a committee tasked with publishing a yearly review of AI use, based on declarations from departments.

Charters do talk about the environment, however. The Seine-Maritime public service management centre asks its staff to limit their use "to what is strictly necessary so as not to increase the carbon footprint of the institution", without planning to measure it. The industrial group LISI asks that AI costs be "tracked over time", but not its footprint. For 36% of local authorities engaged in an AI project, "environmental impact (and its difficult measurement)" is an obstacle. None of the 3 free charter templates we read online has an article on this accounting.

Half of the charters extend to service providers, partners or subcontractors. The Ministry of Culture's charter applies "to anyone, whatever their status (tenured, non-tenured, private-sector employee, service provider, intern, apprentice...)", and the recommendations of the Doubs charter are binding on "all operators appointed by the Department". To make the charter apply to a service provider, the template writes it into the provider's contract.

AI built into software in use falls within the scope: Loire Forez Agglomération chose Copilot, built into its office suite, and the Alpes-de-Haute-Provence chose Gemini, Google's assistant.

The DINUM interministerial guide, published in June 2026, reserves commercial tools for exceptions, under "two cumulative conditions: your administration explicitly authorises it; the information processed could be freely published on the Internet". The pass Culture charter allows trying a tool that has not been validated, "only after informing the IT department and the DPO, in particular by filling in a dedicated table on the intranet".

A tool used with a personal account escapes the organisation's contracts, and its use is not counted. The list of authorised tools is therefore also the first piece of the accounting in Article 10. For tools linked to email, files or internal software, the charter for State communicators asks that their access rights be "set so as to be limited to the strict operational need".

All 16 charters set this rule. The DINUM guide boils it down to one question: "Could I publish this information on a website accessible to everyone?". The Prime Minister's services spell it out: "working versions of a document that is to be published are not considered public data".

The pass Culture charter illustrates it: "every employee must behave with a non-validated GenAI as they would with a human being outside the organisation". The CNIL states in its 2024 Q&A: "In the general case, it is the user organisation that will bear legal responsibility in case of misuse of AI by its staff."

The Alpes-de-Haute-Provence put it this way: "Use AI only in my fields of competence", with the aim of "being able to take a critical look at the answers produced". Loire Forez Agglomération asks that the summary be "reread and compared with the source document". The École nationale de la magistrature writes in its charter: "No legal reasoning may be based solely on the answer of a GenAI."

The GDPR gives everyone "the right not to be subject to a decision based solely on automated processing" that significantly affects them. The AI Act classifies as high-risk the systems intended for recruitment, application screening and performance evaluation, with obligations from 2 December 2027, according to the European Commission. For an administration, an individual decision taken on the basis of algorithmic processing must already say so (Article L. 311-3-1 of the Code of Relations between the Public and the Administration).

The Seine-Maritime management centre forbids processing in an AI tool any document "related to a recruitment process or to an application, including for an internship, to the career or to the pay of a person". The pass Culture charter excludes AI from annual reviews "for the entire process".

Since 2 August 2026, the AI Act has required organisations that use AI to flag deepfakes, as well as generated texts "published with the purpose of informing the public on matters of public interest", unless they have undergone a "process of human review or editorial control" and a person bears editorial responsibility. The charters set their own, wider threshold.

The DINUM guide places the threshold at a "substantial role" for AI: no disclosure for rephrasing, a disclosure for content produced by AI, "even if adjusted afterwards". The Ministry of Culture exempts only internal documents that AI has merely formatted; the Alpes-de-Haute-Provence require the disclosure for any circulation, internal or external.

The Intellectual Property Code sets the rule: "Any representation or reproduction, in whole or in part, made without the consent of the author or their successors in title is unlawful." The Ministry of Culture recommends supplying the tools with "no content protected by intellectual property rights", so that it is not used to train models, and asks staff to refrain from distributing "content that could constitute infringements of existing works". The software company Septeo adds the case of code, which "may be protected by a licence limiting the conditions of its use".

Article 4 of the AI Act has applied since 2 February 2025 to any organisation that deploys an AI system. Revised in July 2026, it asks the organisation to take "measures to promote the development of AI literacy" among its staff, without requiring it to "guarantee a specific level of AI literacy by an individual". It does not impose training as such: the European Commission states that no mandatory training is required, that an internal record of the actions is enough, and that the enforcement rules have applied since 2 August 2026. The CNIL recommends "mandatory training before these systems are used".

11 of 16 charters commit the organisation to training. The template makes training the means of meeting Article 4, and adds the order of magnitude of the footprint, as the Shift Project asks in a note of November 2026: "All AI training must teach how to measure the footprint of AI and sober, reasoned use."

14 of 16 charters ask for sobriety, most often through small habits: better-written instructions, fewer queries or, in the pass Culture charter, "Never say 'hello', 'please' or 'thank you' to an AI". A measurement by Hugging Face researchers gives 0.245 Wh for a thank-you and the model's reply, on a small open model: one thank-you per working day would come to about 54 Wh a year.

A 5-second video clip uses as much as 330 quick questions. The default setting therefore counts for more than polite phrases. The pass Culture charter also provides for this, by asking staff to choose the "lighter" versions in the tool's settings. The hub's analysis of a year of use details these profiles.

The 1st sentence of the template is taken from the Ministry of Culture, for which the use of an AI system "cannot therefore be imposed on an official if an alternative solution exists". Several charters justify sobriety with figures that circulate stripped of their scope, and whose origin the hub has traced: a bottle of water for a reply of about a hundred words, a phone charge for an image, which uses 2.9 Wh on average, about 15% of a charge.

With the estimates of the AI Impact Database, AI use at work amounts to about 12 kgCO2e a year for an SME of 50 people, 145 kgCO2e for a company of 500 people and 1.4 tCO2e for a company of 5,000, counting server electricity only, with the world average electricity mix. A team of 10 developers working with coding agents uses 4 MWh a year, or 1.8 tCO2e, as much as or more than the everyday use of the company of 5,000 people: one hour of a coding agent uses as much as 2,240 quick questions.

The register records the country where requests are processed: the same year of an office employee emits 589 gCO2e with the world average electricity mix and 53 g with servers in France, which the hub's tool can compare.

The tools' administration consoles report numbers of users and requests, rarely the model and never where the computation takes place (our article on measuring AI in business↗) ; the hub's estimation tool converts these volumes. A company enters the result in its Bilan Carbone® (our article↗). A municipality or group of municipalities with more than 50,000 inhabitants enters it in the annual review of its responsible digital strategy, which sets its "objectives for reducing the environmental footprint of digital technology" (law of 15 November 2021, Article 35).

In May 2026, Arcep noted "a lack of transparency from model designers and AI service providers about the environmental impacts of their models", hence the annual request to suppliers. Crédit Mutuel Alliance Fédérale, in a charter of commitments to its customers, is building "a centralised database" to list its AI solutions. Recorded per person, the count would become a means of monitoring employees' activity, subject to consultation of the social and economic committee (Article L. 2312-38 of the Labour Code).

In our view at Projet Celsius, Article 10 is the first one to add to an existing charter. It asks for little (a register, an annual record and published factors) and makes it possible to check from one year to the next what the other 9 articles have changed.

In a company, a document that sets "general and permanent obligations" on discipline is an addition to the internal rules (Article L. 1321-5 of the Labour Code): it is submitted to the social and economic committee for its opinion and sent to the labour inspectorate. The committee is also consulted on "the introduction of new technologies" (Article L. 2312-8). In the public sector, the Département du Doubs presented its charter to its territorial social committee on 2 April 2026; only 26% of the authorities concerned have put AI on the agenda of social dialogue, according to the Banque des Territoires.

Several charters require a signature. Loire Forez Agglomération has each official sign its charter on taking up their post, and the Seine-Maritime management centre attaches a commitment form.