Inspections of Organisations

One of AFA’s main areas of activity remained monitoring compliance with the 2016 Law on Transparency, the Fight against Corruption and the Modernisation of Economic Life (Loi relative à la transparence, à la lutte contre la corruption et à la modernisation de la vie économique; hereinafter, Sapin II).

In 2025, AFA launched 18 new inspections of public-sector organisations: 8 concerned local authorities and entities, while 10 concerned central government bodies and entities under their supervision. Since 2018, the Agency has initiated a total of 119 such inspections.

Ten new inspections were launched in respect of private-sector companies. Following completed inspections, the Director of AFA issued five warnings and referred one case to the Sanctions Committee (Commission des sanctions). Since 2017, the Agency has initiated 175 inspections of economic operators.

According to AFA, the anti-corruption compliance programmes of companies subject to Article 17 of Sapin II* are gradually improving. However, the measures adopted often remain too general and do not sufficiently take account of the risks specific to each organisation.

In particular, corruption risk maps may be based on overly general scenarios, codes of conduct may lack practical examples, and training may fail to reflect the specific work of employee groups most exposed to corruption risks. Other common shortcomings include incomplete third-party assessments, insufficiently developed anti-corruption measures within accounting controls, and weak mechanisms for internally monitoring the effectiveness of compliance programmes.

AFA separately analysed compliance with French legislation by nine French subsidiaries of foreign automotive groups. The Agency found that their anti-corruption programmes were often developed at parent-company level and were not fully adapted to the requirements of French law. For example, some organisations did not have a separate risk map covering their operations in France. In seven of the nine companies, codes of conduct had been issued by foreign parent companies without sufficient adaptation to French law, while internal audits conducted by the parent companies rarely covered compliance with the specific obligations imposed by Sapin II.

Reports of Violations

In 2025, AFA received 2,257 reports of potential violations, almost three times the 802 reports received a year earlier. However, only 242 reports, or 11% of the total, were considered admissible and within the Agency’s remit.

Most of them, 76%, concerned public-sector organisations, including local authorities. A further 19% related to companies.

Following their review, 18 cases were referred to prosecutors and 41 reports were forwarded to other public authorities and professional bodies. A further 57 reports were sent to AFA departments for use in inspections, advisory activities and analytical work.

Judicial Public Interest Agreements

The Agency also continued to monitor organisations’ efforts to bring their compliance programmes into line with legal requirements under Judicial Public Interest Agreements (conventions judiciaires d’intérêt public – CJIPs).

Since 2017, 27 such agreements have been concluded in cases involving breaches of probity. In 17 cases, companies undertook to implement a programme to bring their anti-corruption systems into compliance with legal requirements under AFA’s supervision. The total amount of fines imposed under these agreements approached €2.5 billion.

In 2025, new three-year programmes were provided for in agreements with the Paprec and Klubb groups, as well as with Exclusive Networks and Surys.

First Decision to Impose Fines

After the report was published, on 9 July 2026, AFA’s Sanctions Committee imposed financial penalties for breaches of Article 17 of Sapin II for the first time in its practice. It was also the first time that fines were imposed directly, without a prior order requiring the company to bring its anti-corruption programme into compliance with the law. In the cases considered previously, AFA had first requested such an order, with financial penalties contemplated only in the event of non-compliance.

The proceedings arose from an inspection of Company V. and the entities under its control, conducted between June 2024 and July 2025. AFA found breaches of seven of the eight obligations imposed by Article 17 of Sapin II.

In particular, the group lacked an adequate corruption risk map, comprehensive procedures for assessing customers, suppliers and intermediaries, accounting controls designed to prevent corruption, training for employees most exposed to corruption risks, and a system for internally monitoring and evaluating the measures adopted. In addition, the code of conduct and the related disciplinary procedures did not apply to employees of one of the subsidiaries.

The company did not dispute that the relevant requirements had not been met when the inspection was completed, but relied on its subsequent remediation of the deficiencies. According to the company, the principal measures needed to bring the system into compliance with the law had been implemented by December 2025.

A notable aspect of the case was the Committee’s express finding that, where the Director of AFA applies directly to the Committee for the imposition of a fine, the existence of the breaches must be assessed as at the date on which the inspection was completed, rather than the date on which the case is decided. Subsequent remediation may be taken into account when determining the amount of the penalty, but it does not preclude liability.

The Committee also confirmed that the Director of AFA may refer a case for the imposition of a fine without first requesting an order requiring the company to bring its anti-corruption compliance programme into line with the law. In the Committee’s view, compliance orders and financial penalties are independent measures, and the law does not prescribe a mandatory sequence in which they must be applied.

As a result, both the company and its director, Mr S., were held liable. The Committee took into account that he was the founder of the group, chairman of the company, its principal shareholder and chairman of the supervisory board, and was therefore in a position to ensure timely compliance with the statutory requirements.

The company was fined €350,000, while its director was fined €60,000. The decision was published in anonymised form: the Committee considered that, given the nature and sensitivity of the company’s sector of activity, disclosing the company’s name and the identity of its director could cause them disproportionate harm.

*Part I of Article 17 of the Law on Transparency, the Fight against Corruption and the Modernisation of Economic Life requires the directors of companies employing at least 500 people, as well as companies belonging to a group whose parent company is registered in France and whose total workforce is at least 500, provided that the company’s turnover or the group’s consolidated turnover exceeds €100 million, to implement measures designed to prevent and detect acts of corruption or influence peddling committed in France or abroad. Part II lists the measures that must be implemented.