New national climate change adaptation plan could step up physical climate risk assessments for French companies
- tlaconde
- Oct 28, 2024
- 7 min read
Updated: Apr 11
On March 10 2025, the French government published its Third National Climate Adaptation Plan ("3e Plan National d'adaptation au Changement Climatique" or PNACC3), 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 the 51 measures in the PNACC, several concern the assessment of companies' vulnerabilities: the government wants to make it compulsory for them to better anticipate the climate risks weighing on their activities.
These measures are already a strong signal for economic players. This article summarizes the information available so far and explore how these new requirements could be implemented in practice.
This article was originally published when the PNACC was put out to consultation in October 2024. It has been updated following publication of the final version on March 10, 2025 to take account of clarifications and amendments made in the meantime.
Transport, utilities, healthcare… Which companies will need a climate risk assessment ?
The content of the PNACC reveals a clear vision: anticipating the impacts of climate change is an essential first step in adaptation. The idea is that knowing the risks is a crucial first step to avoid them (for example, avoiding a bad decision that could endanger the company) or mitigate them (limiting damage during extreme climate events, etc.).
Measure 33 of the PNACC notes that to "reduce the impacts of extreme events and avoid unprofitable investments that can sometimes jeopardize an entire economic model, it is essential that companies develop adaptation plans based on studies of the vulnerability of their activities to climate change."
The National Climate Change Adaptation Plan (PNACC) therefore aims to integrate climate change adaptation into business strategies through vulnerability studies. These should primarily concern managers of critical infrastructures or public services:
For transportation (Measure 30): evaluations have already been carried out or are underway for the road network, train stations and railways, regional and urban public transport services, ports, waterways, and airports... They will need to be completed and/or brought into compliance with the Reference Trajectory for Climate Change Adaptation in the coming months.
For energy systems (Measure 31): studies are planned on the vulnerability of the oil and gas pipeline network, as well as an update of studies already carried out by RTE on the impact of climate change on the electrical system balance. Particular emphasis seems to be placed on renewable production (wind, solar...), networks (electricity transport and distribution) and water resources.
For the healthcare system (Measure 29): an analysis of the exposure of health, social, and medico-social facilities to climate change will be carried out in 2025. This represents nearly 15,000 sites, including hospitals, nursing homes, vocational rehabilitation centers, shelters, reception centers... This evaluation aims to identify the most vulnerable locations, on which more in-depth studies will be launched.
For schools: in collaboration with the rectorates, the prefectures are responsible for identifying schools "particularly threatened by coastal erosion, rising waters, flooding, or other extreme climate risks."
The companies concerned are not all listed, but examples include RTE, Enedis, GRTgaz, TRAPIL (which operates the French pipeline network), SNCF Réseau, RATP, Aéroports de Paris, motorway concessionaires (Eiffage, Vinci, Abertis...), port management companies, and major heating networks. In total, tens of thousands of sites will need to be evaluated in the coming months.
As highlighted in our contribution to the public debate on the PNACC, it is therefore particularly important to have effective solutions for conducting these studies.
Weakening of obligations for other critical companies
For other companies, the final version of the PNACC is somewhat scaled back compared to the draft published in the fall. The controversies on the CSRD has had an impact... And it is true that there is a risk of redundant, incompatible evaluations.
The draft put up for consultation in 2024 stipulated that "these [climate vulnerability] studies will gradually become mandatory for large companies and strategic enterprises." The final version only envisions a "reflection on the gradual introduction of an obligation to conduct a vulnerability study and develop an adaptation plan."
The step back is particularly noticeable for the so-called "Organismes d'Importance Vitale" (Vital Importance Organizations). OIVs are organizations designated by the French Military Programming Law as "vital to the nation's survival." The list is, of course, confidential, but it is known to include nearly 1,400 sites, or "vital importance points," across the territory, operated by approximately 250 vital importance operators. OIVs range from the weapons industry to major banks, including major infrastructures (water, energy, transport...), some agri-food industries, and key healthcare facilities.
The PNACC draft stipulated that OIVs should assess their vulnerability to climate change before 2026 (though to be honest, the biggest surprise was that such an obligation didn't yet exist). The final version merely announces the transposition into French law of Directive 2022/2557 on the resilience of critical entities. This directive stipulates, among other things, that "Member States shall ensure that critical entities take appropriate and proportionate technical, security and organisational measures to ensure their resilience, [...] duly considering disaster risk reduction and climate adaptation measures".
The obligations for hazardous installations ( ICPE and Seveso sites) are also vague: the PNACC stipulates that hazards must be aligned with the TRACC, but the methodology remains to be defined (Measure 19).
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.
What should the climate vulnerability studies required by the PNACC Include? What scope and scenarios should they cover? In the absence of specific details, we can make some assumptions.
PNACC vulnerability studies vs. local climate plans
Following the introduction of an obligation to produce Territorial Climate-Air-Energy Plans (PCAET) in 2018, most local authorities have already conducted an analysis of their territory's vulnerability to the effects of climate change. PCAETs, like other public planning documents (SRADDET, SRCAE, SCoT, PLUi, SDAGE...), will need to be aligned with the new reference scenario for adaptation by 2030.
The climate vulnerability diagnostic required from local authorities as part of the PCAET can serve as a source of inspiration. 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 duture EPR2 reactors should “take into account the future climate over the expected lifetime of the plant” - which in a high emissions scenario could lead to warming in excess of 4°C. The project even specified that “the latest climate models” should be taken into account, i.e. CMIP6, whereas TRACC is based on CMIP5.
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!