Adopted by the Government on November 14, 2025, the 2025-2029 national multi-year plan to fight corruption (“the 2025-2029 plan”), drawn up by the French Anti-Corruption Agency (AFA) in accordance with Decree No. 2017-329 of March 14, 2017, extends and strengthens the guidelines of the first 2020-2022 national multi-year plan to fight corruption (“the 2020-2022 plan”) (I). It comprises 36 measures and is structured around four strategic pillars concerning public (II) and economic (III) actors, as well as the international dimension (IV).
1. An internal and international context characterized by numerous expectations
Initially planned and announced for the period 2024-2027, the new anti-corruption plan was delayed by almost two years, finally being adopted on November 14, 2025.
Enriched by a public consultation carried out in the fall of 2023 and developed following “in-depth” interministerial work, this plan comes at a time when the parliamentary evaluation of the so-called Sapin 2 law had called for more assertive political leadership. It also comes in the wake of recent mixed international assessments of France’s anti-corruption measures and a 2024 corruption perception index that is lower than in previous years, due to a lack of real structural responses to crucial issues and a national anti-corruption plan that is “up to the challenge.”
The Phase 4 monitoring report of the OECD Working Group on Bribery of March 18, 2024, highlighted the progress made by France since the Phase 3 report in 2012, but also the need to strengthen the resources of specialized services, clarify the liability of legal entities, and ensure the independent enforcement of the offense of bribery of foreign public officials.
At the same time, the compliance report of the Council of Europe’s Group of States against Corruption (GRECO) for the 5e evaluation cycle (prevention of corruption and promotion of integrity in high-level executive and law enforcement positions), published on April 10, 2024, found that only two of the eighteen recommendations made in 2020 had been fully implemented, calling for further progress in the prevention of conflicts of interest, transparency of the executive branch, and strengthening of law enforcement resources. The situation in France on this issue was reviewed very recently at the last GRECO plenary meeting in November 2025, and a new compliance report accompanied by a press release will be published shortly.
The 2025-2029 plan, which demonstrates a genuine commitment to public education and clarity, opens with an overview of “breaches of integrity” (corruption offences) in order to better understand this complex phenomenon and target measures more effectively, which is a new approach compared to the 2020-2022 plan.
It is structured around four areas: strengthening the fight against corruption within the state administration, supporting local authorities, protecting economic actors, and fighting corruption at the international level.
II. Strengthening integrity requirements in the state administration and local authorities
A. Strengthening an already established framework within the State
The 2025-2029 plan marks a strengthening of the fight against corruption and breaches of integrity within the state administration, whereas the 2020-2022 plan focused mainly on training and raising awareness among public officials and supporting the rollout of anti-corruption programs across all ministries.
The dedicated focus is structured around five objectives. First, it aims to ensure the implementation of robust mechanisms to prevent “breaches of integrity” (corruption offences) at all levels of public action (objective 1). It then aims to strengthen the fight against corruption linked to organized crime (objective 2). It seeks to improve the detection of breaches of integrity (objective 3) and consolidate criminal prosecution (objective 4). Finally, it recommends improving knowledge of corruption and raising public awareness (objective 5).
This plan is therefore more ambitious than the previous one, as evidenced in particular by its first measure, which strengthens the steering of anti-corruption policy (considered a “priority”) through the establishment of a dedicated interministerial committee (measure 1).
Other major measures are also noteworthy. First, the 2025-2029 plan requires all government agencies, particularly those with sovereign powers, to put in place comprehensive and robust systems for preventing and detecting breaches of integrity (measure 2).
In addition, it should be noted that the 2025-2029 plan takes into account Law No. 2025-532 of June 13, 2025, which aims to fight more against drug trafficking. Parliamentary work has highlighted an increased risk of corruption linked to organized crime, to which the plan responds with a set of targeted measures: identification of emerging risks and modes of action through interministerial monitoring (measure 8), identification and securing of sensitive files (measure 9), consolidation of anti-corruption measures in ports and airports (measures 10 and 11), enhanced screening of exposed agents (measure 12), and improvement of the collection and protection of reports (measure 13).
The enforcement component, already present in the 2020-2022 plan but limited to an assessment of the existing situation, is also being stepped up. The 2025-2029 plan provides for strengthening the resources of investigative services (measure 18), a measure recommended by the OECD and GRECO, both of which call for increased resources for specialized services. However, the 2025-2029 plan also aims to increase the consistency and effectiveness of criminal policy through a general circular (measure 19). It also recommends improving the judicial public interest agreement (CJIP) mechanism, in particular by extending it to “new integrity offenses” (without specifying what these would be) and adapting the duration of compliance programs to enable the AFA to work on a longer-term basis (measure 20). Finally, it suggests ensuring better follow-up of requests for international mutual assistance in this area, particularly with regard to the restitution of ill-gotten gains (measure 21).
B. Structured and more demanding support for local authorities
The 2020-2022 plan provided for support for large local authorities, targeting regions, departments, and municipalities exceeding certain population thresholds, as well as joint associations exercising sensitive technical powers.
It should be noted that since then, GRECO has launched a 6th evaluation cycle in 2025 focusing specifically on the prevention of corruption and the promotion of integrity at the “sub-national” level, which is a first in the field of international evaluations, and that France will therefore soon be evaluated on this subject with regard to its local authorities.
It is in this new context that the 2025-2029 plan fits in, strengthening local mechanisms and seeking to enable the consistent application of prevention rules throughout the country. The new plan first aims to clarify the legal framework applicable to local authorities in order to better manage the criminal risk weighing on public decision-makers (measure 24). It then organizes enhanced operational support for elected officials and local government employees, in particular through practical tools developed by the AFA (measure 25). Finally, it introduces increased monitoring of local authorities’ compliance with their obligations in terms of preventing and detecting breaches of integrity, with a particular focus on transparency requirements (measure 26).
III. Enhanced development of the anti-corruption framework for economic actors
A. From the implementation of the anti-corruption standard to the requirement for effectiveness
The 2020-2022 plan aimed, on the one hand, to help companies, in conjunction with professional federations, to prevent the risks of corruption by disseminating the French anti-corruption standard and providing training appropriate to their size and resources, as well as to sector-specific issues. On the other hand, it was intended to facilitate access to financing and credit for French companies by promoting the French anti-corruption standard among investors and public and private credit institutions, both national and international.
The 2025-2029 plan marks a major shift: it is based on the observation that the Sapin 2 law has greatly improved detection and prevention mechanisms in large companies, encourages the continuation of actions already underway, and places particular emphasis on supporting mid-sized companies and SMEs in this area. This change responds to the recommendations of the OECD, whose Phase 4 report (2021) highlighted the need to improve internal compliance measures, and to the AFA’s recent assessments of the implementation of the Sapin 2 law.
Measure 28 thus strengthens the monitoring of compliance with Article 17 of the Sapin 2 law for large companies, but is not limited to the scope of the entities subject to it: it aims more broadly to support companies of all sizes, particularly mid-sized companies and SMEs, in consolidating their prevention mechanisms in order to ensure the operational effectiveness of the systems in place. This support also involves improving the skills of legal and accounting professionals, whose enhanced training is an essential lever for supporting the entire economic fabric in the implementation of proportionate and effective measures.
Finally, in line with the wishes already expressed by the AFA, the plan announces the international promotion of the anti-corruption framework for businesses, in support of fairer competition between economic players.
B. Better consideration of emerging risks
Another new feature is the inclusion of emerging risks in the new plan – a concept absent from the 2020-2022 plan – which now takes into account threats related to organized crime, insider networks, and transnational financial flows. This new feature follows on from the joint press release issued by the AFA and the AMF in July 2025, which warned of insider networks seeking to corrupt holders of privileged information in order to carry out illegal transactions on the financial markets.
In this sense, measures 29 and 30 aim to better anticipate criminal risks and support companies facing complex international environments.
The approach is therefore no longer solely preventive, as in the 2020-2022 plan: it aims to be resolutely proactive and responsive, incorporating the criminal, transnational, and geopolitical dimensions of breaches of integrity.
IV. Strengthening the internationalization of anti-corruption policy
French anti-corruption policy has an international dimension in several respects. France must comply with international standards and is subject to regular evaluations, while also participating in the promotion of these standards, particularly through its current strategy of influence through law (2023-2027). In addition, the fight against corruption has a renewed geopolitical dimension. What is more, the ongoing negotiations on an anti-corruption directive offer hope for a more harmonized framework within the EU.
The 2020-2022 plan focused on coordinating transnational cases and harmonizing sanctions, as well as mobilizing French expertise to support foreign authorities and promote the fight against corruption in multilateral forums.
The 2025-2029 plan places international action as a broader strategic focus, in a context where corruption is presented as a systemic global issue, representing nearly 5% of global GDP.
Measures 31 to 33, dedicated to the European Union, aim to involve France in the development of a coherent anti-corruption strategy, to strengthen the transparency of institutions, and to integrate the fight against corruption more strongly into external action, particularly in accession processes.
Finally, measures 34 to 36 support the overall anti-corruption policy by providing for the strengthening of the implementation of international conventions, support for multilateral organizations, and technical cooperation, in line with France’s Anti-Corruption Strategy in its cooperation action 2021-2030 and in application of the United Nations Convention against Corruption, known as the Merida Convention.
