France has a substantive public framework for transparency in the representation of interests, based primarily on disclosure obligations imposed on interest representatives and on the public register maintained by the High Authority for Transparency in Public Life (HATVP).
This audit addresses a narrower question: the degree to which France has implemented GRECO Recommendation vi within the Fifth Evaluation Round. The recommendation includes, in particular, two requirements: regular disclosure by persons entrusted with top executive functions of the identity of interest representatives they meet and the subjects discussed, and the registration of interest representatives irrespective of which party initiated the contact.
The analysis confirms that the French framework already provides substantial information to the public. It nevertheless identifies a structural difference between the disclosure obligations imposed on interest representatives and the recipient-side disclosure expected from persons entrusted with top executive functions. It also finds that the “à son initiative” criterion remains part of the ordinary framework governing the representation of interests.
In light of the law currently in force and GRECO’s latest official compliance follow-up, all three elements examined in the audit are assessed as not implemented:
R01 — regular disclosure of the interest representatives met by persons entrusted with top executive functions: NOT IMPLEMENTED.
R02 — regular disclosure of the subjects discussed during those contacts: NOT IMPLEMENTED.
R03 — neutrality of the ordinary framework with regard to which party initiated the contact: NOT IMPLEMENTED.
The audit nevertheless takes account of developments already introduced or proposed in France. The transparency regime applicable to foreign influence constitutes a distinct but relevant development. HATVP has also recommended removing the initiative criterion, while Proposition de loi No. 1516 provides, among other measures, for communications to be covered whether initiated by the interest representatives or not and for an increase in the frequency of disclosures.
These elements demonstrate a documented reform trajectory, without altering the assessment of the law currently in force as of the data cut-off date.
Data current as of 30 September 2026.
Translation of the original French version. The original French version is authoritative.