- 1Regulatory framework: 4 years for private-sector BEGES, 3 years for the public sector, annually under CSRD, and annually for a voluntary SBTi commitment too.
- 2Repeating a full assessment every year means paying €10,000 to €30,000 excl. VAT again each year and overwhelming the CSR team.
- 3Three cases justify an annual assessment: CSRD, a public SBTi commitment, an activity with high variability.
- 4A full assessment every 3 to 4 years plus a light update of 2 to 4 days: far cheaper for equivalent management.
- Must a Bilan Carbone® be repeated every year?
No, unless the CSRD or SBTi requires it.
- Private-sector BEGES: every 4 years. Public-sector BEGES: every 3 years.
- The CSRD and SBTi, however, require an annual update.
- For an SME acting voluntarily: a full assessment every 3-4 years + 2 light updates.
A provider may say that an assessment must be repeated every year. That is true for some companies and an outright waste for many others. The frequency depends on the regulatory framework that applies to you.
1What the regulatory requirements say
Start with BEGES, France's reference framework since 2010, revised by Decree No. 2022-982 of July 2022. Two regimes coexist, with two different frequencies.
Every year is not for everyone
Four regimes, four frequencies - from legal requirements to practice.
Private companies with more than 500 employees (250 in French overseas territories): publication every 4 years, with an associated transition action plan. This frequency was retained in the 2022 revision. There is no requirement to produce an updated assessment between publications, but an internal annual update is increasingly the norm for effective management.
Public-law legal entities (the State, regions, departments, municipalities with >50,000 inhabitants, EPCI, public establishments with >250 staff): publication every 3 years. The frequency is tighter than for the private sector because the public sector is considered to have a duty to lead by example.
The second framework that changes everything is CSRD. Limited by the Omnibus I Directive to companies with more than 1,000 employees and €450 million in turnover, it requires annual climate reporting in the sustainability statement. This reporting relies on a GHG inventory that therefore needs updating each year, including material scope 3, which is the case in almost every situation.
Finally, for companies committed to an SBTi pathway (Science Based Targets initiative, the reference framework for aligning reduction targets with the Paris Agreement), the requirement is also annual monitoring of the GHG inventory, made public each year alongside progress achieved, and a target review at least every 5 years. This is a contractual commitment to the initiative rather than a legal requirement.
2What sound practice recommends
Beyond strict compliance with the legislation lies a more significant question: how frequently does a Bilan Carbone® remain useful for management?
Do not repeat an assessment for its own sake
An in-depth assessment every 4 years, two light updates in between - the right cost/usefulness ratio.
A Bilan Carbone® is a management tool, rather than a compliance deliverable. For data to remain usable, an assessment becomes "dated" after 3 years. After 4 years, emission factors have changed (the ADEME Base Empreinte is updated twice a year), activity boundaries have changed and suppliers have turned over: the assessment no longer reflects reality.
For an SME seeking to manage its decarbonisation effectively, the frequency becoming established in the French market is as follows:
- Year 1: initial full assessment, scope 1 + 2 + 3, a costed action plan
- Years 2 and 3: light update (scope 1 + 2 necessarily, scope 3 for material emission categories), monitoring of key indicators
- Year 4: another full assessment, revision of the action plan based on results achieved
This approach, "a full assessment every 4 years, with light updates in between", fits the BEGES frequency and operational common sense. The cumulative cost is substantially lower than for a full annual assessment, since the intervening years require only 2 to 4 consultant-days, for equivalent management quality.
3The three cases where an annual update is justified
Case 1: you are subject to CSRD. There is no choice: it is annual, with demanding data traceability and external assurance requirements. If you have not already done so, you need to systematise collection with a dedicated tool and repeatable procedures.
Case 2: you have launched an SBTi pathway or a public net-zero commitment. In both cases, credibility rests on the ability to demonstrate progress every year. An annual inventory becomes the norm, and SBTi requires annual publication of emissions and progress against targets.
Case 3: your activity has high variability. A company whose emissions vary substantially with turnover, weather, energy mix or supplier structure needs more frequent measurement. In industry in particular, an assessment that ignores annual fluctuations soon loses its relevance.
4How to alternate full assessments and light updates effectively
A familiar mistake keeps recurring: a company enthusiastically wants to repeat a full assessment every year from its first exercise. In most cases, this is a poor allocation of resources, and the trap is expensive.
We saw a service-sector SME order three assessments in two years: a first at €14,000 excl. VAT, an "update" at €11,000 excl. VAT the following year, then a complete revision at €16,000 excl. VAT to meet the requirements of a first client. Total over 24 months: €41,000 excl. VAT, with an action plan never implemented because the CSR team spent all its time producing subsequent assessments. A three-year cycle would have cost half as much and delivered a better operational result.
The right sequence for an SME seeking effective management without becoming overwhelmed by measurement rests on three rules.
- Full assessment only every 3 or 4 years, aligned with the BEGES frequency, to review the method and boundaries
- Light update between assessments, focused on scope 1 + 2 and the 2-3 material scope 3 emission categories identified: 2 to 4 consultant-days, no more
- 80% of CSR time devoted to decarbonisation measures, rather than measuring them: the value lies in the action plan that follows, rather than the assessment that precedes it
This approach will be reinforced by the technical trend: automated collection tools are advancing rapidly, and an annual Bilan Carbone® update for an SME should cost substantially less than today (automatic feeds from ERP systems, supplier invoices, accounting management systems). The marginal effort of an annual update will become so small that it will become the de facto norm.
5The right frequency for your regime
The frequency follows from the regime rather than a general rule. Under CSRD or SBTi: annual, as a contractual requirement. Under private-sector BEGES: a 4-year minimum, with a light update halfway through to maintain active management without paying again for a full engagement. Under public-sector BEGES: 3 years, with the same alternating approach. Without a requirement: a three-year cycle is sufficient to build a meaningful pathway, and the 80% of CSR effort must go into action rather than measurement.
The cycle then needs aligning with your situation: regulatory deadlines, client requirements, team maturity. This is where the right provider makes a difference: it builds a sequence with you that lasts 4 years, rather than selling you an assessment every year.
