PNACC 3: what obligations do businesses face?

Adaptation to climate change has long taken second place to mitigation and its emission reduction targets set by the national low-carbon strategy. The 3rd National Climate Change Adaptation Plan, published on 10 March 2025, is an attempt to close this gap. It organises the country's preparation for warming of +4 °C in 2100 in metropolitan France.

For an SME director or QSE manager, three categories matter: what is mandatory, what makes funding conditional and what remains an incentive. Across PNACC 3's 52 measures, these categories do not overlap, and the most binding of the three does not feature in the plan.

The plan's structure and the climate trajectory underpinning it come first.

15 areas and 52 measures: what PNACC 3 contains

France is on its third adaptation plan, following those of 2011 and 2018-2022. The third changes scale: for the first time it is based on a quantified warming trajectory, the TRACC, preparing mainland France for +2 °C in 2030, +2.7 °C in 2050 and +4 °C in 2100 compared with the pre-industrial period, above the global average because continents warm faster than the ocean. Since Decree No 2026-23 of 23 January 2026, this trajectory has been written into the Environmental Code and is gradually becoming binding on impact assessments, natural risk prevention policies and infrastructure standards. We used it to calculate the exposure of France's 35,191 municipalities by 2050.

What each area covers

• Area 1, protecting the population. Weather alerts, crisis management, health, housing. Flagship measure: strengthening the Barnier Fund for natural risk prevention.
• Area 2, resilience of territories, infrastructure and essential services. Incorporating the official trajectory into planning documents, networks and service continuity.
• Area 3, adapting human activities. The area concerning businesses, agriculture, tourism and the timber sector.
• Area 4, protecting natural and cultural heritage. Forests, water, biodiversity, heritage sites.
• Area 5, mobilising the nation's active forces. Training, research, finance, cooperation.

The action count varies across official documents, from "more than 200" in March 2025 to 341 sub-actions in the June 2026 review. The number of measures, however, does not change: 52.

2The area 3 measures aimed at businesses

Area 3 of the plan brings together measures 33 to 41. Three concern non-agricultural businesses, three others agricultural and forestry sectors, the final two tools and data, and only one creates an obligation, restricted to a narrow scope. Measures 34 and 35, discussed below, use financial incentives.

Measure 33: vulnerability study and adaptation plan

The plan distinguishes three groups. Large energy and transport groups were to complete a vulnerability study by the end of 2024, a deadline already passed when the plan was published, then an adaptation plan in 2025. Operators of vital importance fall under European Directive 2022/2557 on the resilience of critical entities. All other businesses are encouraged to adopt a plan, with ADEME and Bpifrance support.

The planned monitoring indicator is the share of target businesses with a study and a plan. These 2024 and 2025 milestones are behind us, and none of the official publications consulted gives this rate. As for the measure's resources, the factsheet lists amounts "to be defined from 2027".

Measures 36 to 38: agriculture, agri-food and forestry

Agricultural and agri-food sectors are preparing adaptation roadmaps with a mandatory water component. Since 2023, crop insurance has been based on a three-tier scheme, and animal transport is subject to mandatory restrictions during heatwaves. The timber sector works over a longer horizon, through to 2100, because of forestry cycles.

Measure 41: making climate data available

This measure, led by the Directorate General of the Treasury, Banque de France and DGEC, plans to provide businesses with the climate tools and data needed for their risk analyses. It is the logical counterpart to reporting obligations: documenting physical risk by site requires usable projections at a finer scale than the region.

3The obligation already applying is the heat decree

For an industrial SME, a hospital or a construction business, the most tangible regulatory constraint in 2026 is outside the adaptation plan. It is in the Labour Code.

The heat decree of 27 May 2025

Decree No 2025-482 of 27 May 2025, which entered into force on 1 July 2025, creates Articles R. 4463-1 to R. 4463-8 of the Labour Code. It requires a heat risk assessment, indoors and outdoors, linked to Météo-France's alert thresholds. When the response involves cooling equipment, the regulatory timetable for refrigerants constrains the choice of equipment.

• Prevention measures to implement: changes to processes, moving workstations to cooler areas, adjusting working hours, shading and insulation, suitable protective equipment, employee training.
• Cool drinking water near workstations, with a minimum of 3 litres per day per worker on construction sites.
• Under a red alert: daily risk reassessment and mandatory suspension of work if measures taken are insufficient to protect employees carrying out physical work at high temperatures.
• Prohibition on exposing under-18s to extreme temperatures.

This legislation is enforced by the labour inspectorate, whereas measure 33 merely encourages SMEs to adopt an adaptation plan.

Any site whose activity involves physical work or poorly insulated premises falls within the decree's scope. Future heat exposure becomes a compliance parameter, and using air conditioning is not the only response: passive and low-energy cooling solutions fall among the measures listed in the decree, which mentions shading, insulation and moving workstations.

4The plan seeks to make public money conditional on adaptation

Measure 34: reviewing funding schemes

This measure does not take the form of an obligation. Measure 34 plans a review of ADEME, France 2030 and Bpifrance schemes to incorporate adaptation, with an assessment expected by the end of 2025 and changes from 2026. Regions are invited to do the same for their own funding.

Above all, the same measure plans to make short-time working conditional on a business commitment to adaptation, with a deadline in the second quarter of 2025. Access to an employment support scheme would therefore depend on documented adaptation work. That deadline has passed and no implementing legislation has been published to date, which also applies to the assessment of funding schemes expected by the end of 2025.

This approach directly concerns businesses already using public funding for the transition, whether Diag Décarbon'Action or regional schemes. An application documenting a complete climate trajectory, mitigation and adaptation, starts with an advantage over one addressing emissions alone. Public funding to watch: budgets for the two main adaptation funds, the Green Fund and Barnier Fund, fall in the 2026 budget, increasing competition between applications and making the initial assessment all the more decisive.

The plan intends to make tourism investments conditional in 2027

Measure 35 goes further for one sector. Mountain range authorities are drawing up strategic adaptation plans under the 2021 Climate Act, and the plan intends to make tourism investments conditional on alignment with these plans in 2027. The associated vulnerability observatory has €300,000 over 3 years.

5Where a physical exposure assessment starts

Public data are enough for the first pass

An initial exposure assessment requires no proprietary data. Localised climate projections are public on the DRIAS portals; impacts on water resources are available through the Explore2 project, completed in 2024, which projects summer flows falling by around 30% by the end of the century and the proportion of dry watercourses rising from 15% to 25%. Risk zoning is available on Géorisques.

Météo-France provides ClimaDiag Commune, a free service producing a summary of around ten pages per municipality across the three TRACC horizons, covering climate, natural risks, health, agriculture and tourism. It is the least costly starting point for a given site, and our municipality exposure map helps locate it among metropolitan France's 35,191 municipalities.

A physical exposure assessment is scoped like a carbon assessment for an industrial SME, with costs comparable in scale to those of a Bilan Carbone®. Public funding can still be combined, and measure 34 of the plan points towards better funding for this type of work. For a healthcare establishment, the approach connects with a hospital climate strategy, where continuity of care during heatwaves is already an operational issue.

Exposure is assessed at the address

Heat and cooling capacity, water stress for processes, flood exposure for stocks and insurability: these parameters vary between municipalities and sometimes between neighbourhoods. This is the same level of detail as a Bilan Carbone® for an industrial site, with the same data collection challenges.

The reasoning extends along the value chain. A sole supplier based in a municipality highly exposed to fires or low river flows affects business continuity, and this exposure can be mapped like scope 3 emissions.

The connection to CSRD and Bilan Carbone®

Businesses still subject to CSRD after Omnibus must document their physical risks by site and time horizon. TRACC becomes the common reference for these analyses in France, and how this connects to Bilan Carbone® is teams' first question. The two exercises measure different things: one concerns what the business emits, the other what it experiences.

6Key takeaways

• PNACC 3 has 52 measures in 5 areas, published on 10 March 2025, with 18 ministries involved. The number of actions varies across documents; the number of measures does not.
• The trajectory underpinning it has been in the Environmental Code since 23 January 2026, without being automatically enforceable. It becomes binding as planning documents, impact assessments and sector standards are revised.
• The plan imposes no direct obligation on SMEs. The binding obligation targets large energy and transport groups and operators of vital importance.
• The legislation actually constraining an SME is the heat decree of 27 May 2025, applying since 1 July 2025, with 4,500 inspections in the first year.
• The main measure is financial. The plan intends to make public funding, short-time working and, for mountain tourism, public investment support from 2027 conditional on adaptation, with no implementing legislation to date.
• Resources do not match the announcements. Green Fund from 2.5 billion in 2024 to 650 million in commitments in 2026, Barnier Fund from 300 to 287.4 million.

A business wanting to address the issue in the right order starts with its physical exposure, site by site, using publicly available free data. It then identifies the consequences for asset sizing, supply chain continuity and reporting obligations. To understand how a territory undertakes the same work at its own scale, we have described the method and available tools.

Further resources

Frequently asked questions

1Is my business required to draw up an adaptation plan?

No, unless you are a large energy or transport group, or an operator of vital importance. For these organisations, PNACC 3 planned a vulnerability study by the end of 2024 and an adaptation plan in 2025. For all other businesses, the plan is an incentive. However, businesses subject to CSRD must document their physical risks by site, which requires the same work under another name.

2What is TRACC and since when has it been enforceable?

The reference warming trajectory for adaptation sets the levels France is preparing for: +2 °C in 2030, +2.7 °C in 2050 and +4 °C in 2100 for mainland France, compared with the pre-industrial period. It was written into the Environmental Code by Decree No 2026-23 of 23 January 2026. It is not automatically enforceable: it becomes binding as planning documents and sector standards are revised.

3What exactly does the heat decree of 27 May 2025 say?

It requires every employer to assess heat risk, indoors and outdoors, based on Météo-France's alert thresholds. It requires cool drinking water near workstations, with a minimum of 3 litres per day per worker on construction sites, suitable prevention measures and, under a red alert, daily risk reassessment with suspension of work if those measures are insufficient. It has been in force since 1 July 2025.

4Is PNACC 3 funded?

Partly, and the budget trajectory is falling. The Green Fund falls from €2.5 billion in 2024 to 650 million in commitment authorisations in the 2026 budget. The Barnier Fund, raised to 300 million in 2025, returns to 287.4 million in 2026. The High Council on Climate considers known funding insufficient and notes that very few measures in the plan indicate the amounts allocated to them.

5What is the difference between mitigation and adaptation?

Mitigation reduces greenhouse gas emissions to limit warming: this is the purpose of a Bilan Carbone® and the national low-carbon strategy. Adaptation prepares a business or territory for the effects of warming already under way: heat, drought, flooding, coastal inundation. The two exercises are complementary and use different data, but meet in the assessment of sites and the value chain.

6Where can I find climate projections for my municipality free of charge?

Météo-France offers ClimaDiag Commune, a free service producing a summary of around ten pages per municipality across the three TRACC horizons, with five themes: climate, natural risks, health, agriculture and tourism. The DRIAS and DRIAS-Eau portals provide detailed projections, and Géorisques lists regulatory natural and technological risk zones.

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