On October 25, the French government introduced its National Climate Adaptation Plan ("Plan National d'adaptation au Changement Climatique" or PNACC), proposing over 50 measures to help France prepare for climate change through the 21st century. From improving workplace conditions during heatwaves to increasing insurance transparency, this plan addresses diverse aspects of climate resilience.
Among its 51 proposals, the plan emphasizes that businesses should conduct in-depth assessments of their climate vulnerabilities. These studies could become mandatory, starting in 2025 for specific sectors.
The project will be open for public consultation for two months. These proposals may therefore be further clarified, modified, or even removed in the final document, but they already represent a strong signal to economic players.
This article summarizes the information available so far and explore how these new requirements could be implemented in practice.
Infrastructure, healthcare, "vital organizations"… Which companies will need a climate risk assessment ?
The PNACC presents a clear vision: anticipating the impacts of climate change is an essential first step in adaptation. Understanding risks can help reduce damage during extreme climate events and avoid poor decisions that could jeopardize a company.
The French National Climate Adaptation Plan aims to integrate climate adaptation into business strategies, with the first step being vulnerability studies.
Climate vulnerability studies will be required for all large companies, and as soon as next year in some sectors. The plan sets ambitious targets for the completion of these studies:
In 2025, for large companies managing transport and energy infrastructure, such as electrical grid (RTE, Enedis...), oil and gas (GRTgaz, TRAPIL...), railway (SNCF réseau, RATP...), as well as major highway, airport and port management companies.
From 2025, for healthcare, social, and medico-social facilities, prioritizing those in urban or high-risk areas. This includes more than 14.000 hospitals, elder care facilities, and other centers for vulnerable populations.
In 2026, for other "Operateurs d'importance vitale" (vital importance operators), organizations designated by military programming law as "vital to the nation’s survival." This includes over approximately 1400 critical sites across sectors like defense, major banking, essential infrastructure or food processing.
What about public organizations? Most local authorities have already conducted vulnerability analyses of their territories through local climate plans (Plan Climat-Air-Energie Territorial, PCAET), which are mandatory since 2018. By 2030, these plans and other public planning documents will need to be revised and aligned with the new climate adaptation scenario.
What will climate vulnerability studies entail?
The government’s draft provides a path forward, urging businesses to better understand their exposure to climate change and incorporate these risks into decision-making. However, specifics are limited.
PNACC vulnerability studies vs. local climate plans
Regarding the content of the studies, the climate vulnerability diagnostics required for local authorities can serve as a useful reference. A methodological framework has gradually taken shape. It addresses a wide range of topics: air and river temperatures, heatwaves, freeze cycles, precipitation patterns, torrential rain, snow, drought, river flows, floods, mudslides, land movements, soil swelling and shrinkage, forest fires, storms, high winds, cyclones, pathogen proliferation, and more.
These climate risk evaluations generally rely on biais-corrected climate projections from the DRIAS project. However, they are typically qualitative, meaning that one would rarely find 100-years rainfall volume or maximum temperature projections for 2050 or 2100 in a local climate plan. Yet, such values are essential for practical applications, such as sizing drainage systems or determining the power of cooling systems. If the PNACC vulnerability studies are to provide a solid foundation for risk reduction strategies within companies, climate impact evaluations will need to be more quantitative.
PNACC studies vs. European regulations (CSRD, taxonomy...)
Another obvious parallel to the vulnerability assessment measures proposed by the PNACC is the climate risk evaluation mandated by new European regulations.
The Corporate Sustainability Reporting Directive (CSRD) is a new European regulation that gradually introduces transparency requirements for publicly traded or large companies. The first CSRD reports, which apply only to the largest European corporations, will be published in 2025 and include an assessment of physical climate risks. Meanwhile, the European taxonomy is a classification system designed to help businesses, investors, and policymakers identify sustainable economic activities, considering climate vulnerabilities for projects with a lifespan exceeding ten years.
Both regulations are very recent, and the methodological framework is still being established. However, it’s likely that these assessments will not fully overlap with the vulnerability studies required by the PNACC:
In the CSRD and taxonomy, physical climate risk assessments are intended to inform investors and stakeholders. In the PNACC, vulnerability studies are aimed at preparing projects for adaptation and are intended for internal use.
PNACC assessments, which focus on vital infrastructure and organizations, wil probably emphasize business continuity and safety. They are likely to require a more detailed and operational approach than the CSRD, which provides an aggregated overview of risks. However, since these obligations take effect around the same time, it will be important for companies subject to these requirements to ensure consistency across different methodologies.
Scope and Scenarios
Another difference between PNACC and PCAET studies lies in geographic scope. What exactly should companies’ vulnerability assessments cover? Just the sites they directly operate? While that might be a starting point, this approach quickly shows limitations: what good is it to protect industrial sites from climate risks if their employees, suppliers, and essential services they depend on are exposed?
To effectively assess the vulnerability of vital facilities to climate risks, it will be necessary to account for indirect exposure, considering the surrounding territory and the value chain.
The question of climate scenarios used also arises. One of the objectives of the PNACC is to standardize the climate scenarios used in France around the “scenario 4°C”, which assumes an average warming of 4°C for mainland France. This scenario reflects the climate trajectory of the late 21th century based on current emission reduction policies. It may not be suitable for projects with shorter lifespans or those likely to extend beyond 2100.
The plan addresses this issue specifically for nuclear projects, stating that "for future EPR2 reactors, the latest climate models will be applied throughout the operating lifespan of the installations", meaning that, in a high-emission scenario, warming could exceed 4°C. Thus, while the 4°C scenario will likely serve as the baseline, other scenarios may also be considered based on project duration and acceptable risk levels.
Is your organization affected by these new requirements? Start today by testing our free app to access local climate projections based on the "scénario 4°C" from the French Reference Pathway for Climate Change Adaptation.
Want to take it further? We can help. A pioneer in climate risk assessment in France, Callendar specializes in developing accessible solutions to anticipate the effects of climate change on a local scale. Contact us to discuss your project!