French "Warming Trajectory" for Climate Change Adaptation Purposes – JD Supra

On January 23, 2026, the French government adopted a decree and a ministerial order regarding the “reference warming trajectory for adaptation to climate change.” The purpose of this new regulation is to identify a likely global warming scenario for different time horizons in the near and longer term.
The new Reference Warming Trajectory is embedded in the Environmental Code so that it can gradually be referenced in future relevant planning and sectoral documents. For mainland France, a trajectory of + 2°C by 2030 compared to the pre-industrial era, + 2.7°C by 2050, and + 4°C by 2100 is defined. Other “trajectories” are identified for French oversea territories such as French West Indies in the Caribbean Sea, Tahiti, as well as islands in the Indian Ocean. 
The trajectory does not indicate that the additional warming is either acceptable or desirable. Other French and EU regulations still call for climate mitigation to reduce global warming “well below” 2 degrees as stated in the Paris Agreement. However, the publication of the January 23, 2026, regulation is a reality check. 
The Reference Warming Trajectory is set for adaptation measures, not mitigation measures. The French government believes that it is reasonable to predict, or at least prepare for, such additional degrees and the consequences thereof in terms of urban planning or other organizational measures. For instance, it may be taken into account in environmental impact studies for projects, to assess how they will fare in the long term in a context of global warming. However, the French government indicated that the trajectory is automatically enforceable. It will be necessary to adopt additional regulations or standards to include the trajectory in public tender procedures or planning tools for companies. 
The government indicated that it would also update a 2019 ministerial decree defining sea-rise hazard and river-flooding risks to be taken into account in the course of environmental assessments. The regulation also has a significant impact on new projects and redevelopment in coastal or river-bank areas. Also, the Reference Warming Trajectory will be updated when relevant, based on the Intergovernmental Panel on Climate Change, or IPCC, studies. 
The Reference Warming Trajectory may have an impact on sustainability reports large French companies file under the Corporate Sustainability Reporting Directive, which has been transposed under French law (in its “pre-Omnibus” version). Pursuant to reporting standards ESRS E1-2 and E1-3, reporting companies must describe the policies they adopted to manage their material impacts, risks, and opportunities related to climate change adaptation, as well as associated actions and the resources allocated for their implementation.
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.
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