Last modified 20 July 2026

Artificial Intelligence in France

Appointed supervisory authority in France

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Law / proposed law in France

Regulation (EU) 2024/1689 of the European Parliament and of the Council on harmonised rules on artificial intelligence (EU AI Act) was published in the Official Journal of the European Union on 12 July 2024. It entered into force on 1 August 2024, although many of its provisions come into force on specific dates:

2 February 2025: General provisions and provisions relating to prohibited AI practices and AI literacy (Chapter 1 and Chapter 2).
2 August 2025: Provisions relating to general-purpose AI (GPAI) models (e.g. generative AI).
2 August 2026: Most other provisions (including requirements for Annex III high-risk AI systems).
2 August 2027: Provisions relating to high-risk AI systems that are safety components of products or products themselves (i.e. AI systems covered by Annex I).

A new EU Product Liability Directive, Directive (EU) 2024/2853 of the European Parliament and of the Council of 23 October 2024 on liability for defective products (Product Liability Directive), was published in the Official Journal of the European Union on 18 November 2024 and entered into force on 8 December 2024. Member States have until 9 December 2026 to implement the Product Liability Directive into national law. The Product Liability Directive modernises the EU-level strict product liability regime, preserving the core principles of the previous law while adapting to new technologies by extending the scope to include software and AI. This regime is still limited to certain types of damages and applies only to consumers and other natural persons.

As part of its Digital Omnibus package, the European Commission has proposed amendments to the EU AI Act. While the Act’s core structure remains unchanged, the revisions aim to make compliance more amenable to businesses including shifting the burden of the AI literacy requirement, expanding reliefs for SMEs and "small mid-caps" and providing a new exemption from EU database registration. The proposals also suggest a delay in the applicability for rules for high-risk AI systems and some transparency requirements. Further updates are expected later in 2026 as the proposal makes its way through the European legislative process.

AI compliance in France

In France, the main applicable rules related to AI consist in the EU AI Act as it is a text with direct application into the French legislative framework without need for transposition. In addition, the French Parliament has issued a few laws imposing specific rules when dealing with AI in certain cases, and France is developing its national framework required for the national implementation and enforcement of the EU AI Act.

Law no. 2023-451 of 9 June 2023 on the regulation of commercial influence on social networks (French Influencer Law) imposes requirements on influencers to include warning notes on images modified by AI.

Law no. 2024-449 of 21 May 2024 on the digital space (French Digital Space Law) introduces a new criminal offence for persons who publish deepfakes of other persons in a way that modifies their image and/or voice without their consent.

The Draft Law of 18 February 2026 containing various provisions for alignment with European Union law (DDADUE) is expected to designate the competent authorities responsible for the supervision and enforcement of the Regulation and establish the corresponding national enforcement framework.

The Product Liability Directive has not yet been transposed into French law. France is preparing the implementing measures and is participating in the European Commission's expert group on the transposition of the Directive. According to the French Government, consultations with stakeholders from the main affected sectors have been conducted as part of the preparation of the national implementing measures. Given the Directive's maximum harmonisation approach and the autonomous nature of the strict liability regime, a dedicated implementing instrument is envisaged. The transposition deadline remains 9 December 2026. Pending transposition, the existing French strict liability regime for defective products (Articles 1245 to 1245-17 of the French Civil Code, which implement Directive 85/374/EEC) remains applicable.

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Regulatory guidance / voluntary codes

Regulatory guidance / voluntary codes in France

In order to ensure the consistent, effective, and uniform application of the EU AI Act across the European Union, the European Commission has adopted some guidelines (that are non-binding since only the Court of Justice of the European Union has authoritative interpretation powers) on the following provisions of the text:

Prohibited AI practices, on 4 February 2025 (however, the Commission has not yet formally adopted them); and
Definition of an AI system, on 6 February 2025 (however, the Commission has not yet formally adopted them).

Further guidelines on high-risk AI systems are expected, and are currently under consultation. The Commission is also expected to provide harmonized standards and common specifications for both high-risk AI systems and general-purpose AI models, providing organizations with further tools which provide a presumption of conformity.

The Commission released the final version of its general-purpose AI Code of Practice on 10 July 2025, and followed it up by publishing Guidelines on the scope of obligations for general-purpose AI model providers on 18 July 2025.

The Commission has also released the first draft of its Code of Practice on Transparency of AI-Generated Content. The Code is planned to be finalized by June 2026. If approved, the final code will be a voluntary tool for providers and deployers to demonstrate compliance with their obligations for marking and labelling AI-generated content under the EU AI Act.

Under the EU AI Act, providers of AI systems that do not fall under the high-risk classification, as well as deployers, have the possibility to adopt voluntary codes of conduct (Article 95) in order to adopt, on a non-binding basis, technical solution and industry best practices. Because of this, it is expected that the AI office will issue further codes of conduct for this (which will be distinct from the GPAI Code of Practice and the Code of Practice on Transparency).

To provide organisations with support identifying and implementing AI literacy initiatives, the Commission launched a repository of AI literacy practices. The repository was updated in November 2025 to improve the searchability of practices.

In May 2024, the Council of Europe published a Framework Convention on Artificial Intelligence and Human Rights, Democracy and the Rule of Law (Framework). It is an international, legally binding treaty aiming to ensure that activities within the lifecycle of AI systems are fully consistent with human rights, democracy and the rule of law, whilst being conducive to technological progress and innovation.

AI compliance in France

In France, many governmental reports and independent authorities’ guidelines have been issued on AI. The main ones impacting the AI framework are as follows.

In September 2017, Deputy Cédric Villani was tasked with leading a mission to implement a French and European AI strategy. This mission was presented in a report named ‘Making sense of artificial intelligence’ (Villani Report), which covers various aspects of AI, including economic policy, research, employment, ethics and social cohesion. Additionally, five annexes focus on the risks and opportunities of AI in specific areas: education; health; agriculture; transport; and defence and security. This report led to the French government building a national AI strategy in 2018, which was last updated on 7 February 2025.
In June 2020, the French Banking Authority (ACPR) issued a study on the 'Governance of artificial intelligence algorithms in the financial sector’ (ACPR AI Governance Study). This study highlights the need for AI algorithm evaluation and governance.
In February 2026, the French Autorité des Marchés Financiers (AMF), the authority in charge of regulating the French financial market, published an in-depth study over the uses, benefits and risks associated with artificial intelligence by financial market participants. The study highlights the importance of robust AI governance frameworks while noting that regulated entities increasingly rely on internal AI policies addressing data governance, human oversight, transparency and compliance with emerging AI-related regulatory requirements.
On 7 April 2022, the French national advisory commission on human rights (CNCDH) issued an ‘Opinion on the impact of AI on fundamental rights’ (CNCDH Opinion), which urges public authorities to establish a strong legal framework for AI. The document highlights how algorithms can perpetuate human biases and recommends measures for ensuring algorithmic transparency and fairness.
On 13 March 2024, the French Artificial Intelligence Commission (governmental body) published a report 'AI: our ambition for France' (French AI Commission Report) containing 25 recommendations to make France a major player in the AI technological revolution, notably by facilitating access to personal data (in particular health data) and adopting an ‘AI exception’ for public research.
On 28 November 2024, the French Senate’s Office for the Evaluation of Scientific and Technological Choices (OPECST) issued a wide‑ranging report called ‘ChatGPT, and after? Assessment and perspectives of artificial intelligence’ that traces the evolution and mechanics of AI (from symbolic systems to deep learning and Transformer‑based ‘foundation models’), assesses economic, societal, cultural, and security implications, benchmarks France’s national AI strategy against roughly 20 other jurisdictions, and surveys emerging models of national, EU, and global governance. The report culminates in 18 recommendations, including several to be advanced at forthcoming international AI fora, emphasising innovation, risk management, transparency, and democratic oversight to ensure AI serves the public interest while safeguarding sovereignty and fundamental rights (Senate Report).

The French national data protection authority (CNIL) has issued non-binding AI fact sheets (CNIL AI Fact Sheets) that focus on the development phase of AI systems and models and highlight the necessity to comply with privacy requirements during all stages of the development of AI systems. CNIL has also built tools and best practices to be followed for AI tools and models to be used in compliance with privacy laws, e.g., the risk assessment before the use of an AI system (CNIL AI Risk Assessment). In addition, the CNIL has published guidance on the use of generative AI systems with a related Q&A (CNIL Generative AI Guidance) that aims to help organisations deploy such systems responsibly.

The French agency on security of IT systems (ANSSI) published guidance on 29 April 2024 setting out security recommendations for generative AI systems (ANSSI Generative AI Security Guidance). This guidance sets out good practices to implement on the three stages of generative AI lifecycle: training; integration and deployment; and operational production. Such practices should be adapted to the choice of providers (for hosting, training, testing, etc.) and the sensitivity of the data used, as well as the criticality of the intended use case of the AI system.

On 12 July 2024, the French Competition Regulator (Autorité de la Concurrence) issued an opinion on the competitive functioning of the generative artificial intelligence sector. This opinion focuses on strategies by major digital players to consolidate market power in the design, training, and specialisation of large language models. Following this opinion, the Authority announced that it is opening an ex officio investigation to analyse the competitive functioning of the conversational agents (or chats) sector. The Authority also intends to examine the new issues that are emerging, particularly those linked to the use of conversational agents in the online retail sector, also referred to as ‘agentic commerce’, by launching in 2026 a public consultation.

The French High Council for Literary and Artistic Property (CSPLA), which acts as an observatory for the exercise and enforcement of copyright and neighbouring rights, was tasked with clarifying the EU AI Act transparency requirements for AI model providers (Article 53). Its findings were made public via a report published on 11 December 2024 (CSPLA Report).

In 2025, the CIGREF (a non-profit association bringing together major French companies and administrations) issued a set of five guides focusing on helping large organisations adopt AI responsibly and in compliance with the EU AI Act, offering practical guidance on key obligations, governance structures, legal issues, and contractual impacts. They also provided best practices and enterprise feedback on generative AI adoption, highlighting organisational readiness, risks, and responsible use patterns.

In February 2026, the French Government’s Information Service (SIG) published practical guidance for public sector communications teams on the responsible use of generative AI. It focuses on transparency, human oversight, data protection, accessibility, intellectual property and digital sovereignty.

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Appointed supervisory authority

Appointed supervisory authority in France

European Level

The European Commission established the European AI Office (AI Office) on 24 January 2024. The AI Office is a European Commission function and forms part of the Directorate-General for Communications Networks, Content and Technology; it must therefore operate in accordance with the Commission's internal processes. The AI Office is responsible for assisting the European Commission with the oversight, monitoring and enforcement of requirements for GPAI models and systems. It is primarily made up of hired full-time staff from a range of backgrounds such as technology specialists, economists, policy specialists and lawyers.

In addition, the European Artificial Intelligence Board (AI Board) has also been established. The AI Board's core responsibility is to advise and assist the Commission and Member States to facilitate the consistent and effective application of the EU AI Act. The AI Board will include a representative from each Member State and the AI Office and the European Data Protection Supervisor shall participate as non-voting observers.

Member State Level

Article 70 of the EU AI Act concerns the designation of national competent authorities by EU Member States. It specifies that each Member State shall establish or designate as national competent authorities at least one notifying authority and at least one market surveillance authority for the purposes of the general supervision and enforcement of the EU AI Act. Where multiple market surveillance authorities are appointed, one of the market surveillance authorities must act as the single point of contact. The authorities must operate independently and without bias. Member States were required to notify the Commission of their appointed authorities and publicly available information on how to contact them by 2 August 2025. The designation of national authorities has been slower than expected, which may affect early enforcement consistency.

Supervisory authority in France

France has moved to draft a national law to designate enforcement and oversight powers for the EU AI Act. The French model is decentralised, with multiple market surveillance authorities split by sector and type of AI system addressed in the EU AI Act. For instance, prohibited AI systems relating to emotion recognition in the workplace and education institutions will be enforced by the French data protection supervisory authority (the CNIL) and high-risk AI systems related to medical devices by the ANSM, France’s National Agency for the Safety of Medicines and Health Products (ANSM).

The framework is complex but looks to uphold the intent of the legislation, which is similar in nature to product-based regulation. To help companies navigate this complex framework, the DGE has published a diagram (see here). The DGCCRF (Direction générale de la concurrence, de la consommation et de la répression des fraudes), notably in charge of fair market practices, consumer protection, and product safety across France, will be responsible for coordinating the market surveillance authorities and will, in this capacity, serve as the single point of contact pursuant to EU AI Act Article 70.2. In parallel, the DGE (a French government agency under the Ministry of the Economy) will continue to support the strategy around the implementation of this text and represent France within the AI Office. Finally, an advanced pooling of expertise and technical tools in AI and cybersecurity is being implemented by the Digital Regulation Expertise Center (PEReN) and ANSSI to support authorities in their missions to monitor the compliance of AI systems.

As of July 2026, the legislative process implementing the formal designation is still ongoing.

With respect to the deadlines set by the EU AI Act:

France has not met the 2 August 2025 deadline for Member States to designate their national competent authorities (notifying authorities and market surveillance authorities), to communicate them to the Commission and to make their contact details publicly available (Article 70(2)). The DGE and the DGCCRF published the proposed governance scheme, together with public contact details, on 9 September 2025, but the formal designation requires the adoption of the DDADUE, which remains pending before French Parliament, therefore formal designation is now expected in the course of 2026.
No public information has been released confirming that France submitted the report required under Article 70(6) on the financial and human resources of its competent authorities by 2 August 2025.
There was no official confirmation that France has established an AI regulatory sandbox within the meaning of Article 57(1) of the EU AI Act. Given that the DDADUE has not yet been enacted, it appears unlikely that an operational AI regulatory sandbox will be in place by the 2 August 2026 deadline. The CNIL has, however, run sector-specific ‘sandbox’ support programmes since 2021, which may serve as a basis for the future French AI regulatory sandbox.

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Definitions

Definitions in France

AI System

Article 3(1) of the EU AI Act defines an 'AI system' as follows:

"a machine-based system that is designed to operate with varying levels of autonomy and that may exhibit adaptiveness after deployment, and that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments".

The EU AI Act uses a technology neutral definition, focusing on the effect of the system rather than the techniques used. There are several key features of the definition which, acting together, distinguish the AI system from more traditional software systems. The central characteristics are the level of autonomy and adaptiveness in how the system operates and the ability for the system to infer how to generate outputs. So, an AI system must be able to operate independently at some level (like many existing technologies) but must also be able to apply logic to draw conclusions from data it is given. It may also adapt after deployment, in effect by continuing to "learn". These features are more akin to human capability than traditional technology systems, which operate using more fixed and pre-determined paths to process data. These outputs must influence physical or virtual environments, whether by making decisions or through other means.

The EU AI Act also sets out specific rules for GPAI models. GPAI models differ from AI systems; they can be an essential component integrated into an AI system, but do not themselves constitute an AI system until further components are added (such as an interface). For more information, please see Controls on generative AI.

Provider

Article 3(3) of the EU AI Act defines a 'provider' as follows:

"a natural or legal person, public authority, agency or other body that develops an AI system or a general-purpose AI model or that has an AI system, or a general-purpose AI model developed and places it on the market or puts the AI system into service under its own name or trademark, whether for payment or free of charge".

Those falling within this definition as a ‘provider’ have significant responsibility for ensuring compliance with the EU AI Act, and so identifying the provider will be crucial for businesses and may well influence their choice of business/deployment model.

The provider is responsible for putting the AI on the market either by making it first available in the market or directly puts the AI into use for its own purposes and under its own name or trademark. An organisation may also become a downstream provider if it makes substantial modifications to a system or changes its intended purpose (Article 25(1)). Guidance from the European Commission is expected on what counts as a “substantial modification”. At this stage, the only conclusive criteria is that such modification must not have been foreseen by the provider in the initial conformity assessment carried out by the provider.

Payment is not relevant, which will impact GPAI models supplied onto the market on an open source or under free commercial terms.

Definitions in France

In the CNIL AI Fact Sheets, the CNIL considers it likely that AI providers creating training databases are acting as data controllers, unless an AI provider entrusts the database creation to a third party – in which case, the AI provider is the data controller only if it reuses the existing database for its own purpose. If, on the contrary, the AI providers develop an AI system on behalf of customers (being deployers) under their instructions, it is more likely that they will be deemed data processors. In any event, the CNIL reminds that a case-by-case analysis should be conducted.

Deployer

Article 3(4) of the EU AI Act defines a 'deployer' as follows:

"a natural or legal person, public authority, agency or other body using an AI system under its authority except where the AI system is used in the course of a personal non-professional activity".

In simple terms, a 'deployer' is an entity that uses an AI system other than for personal, non-professional use. Although the burden of responsibility on a deployer is not as great as on 'providers', there are still obligations that it must fulfil.

Note that the EU AI Act also implements requirements for organisations performing other roles (as distributor, importer, product manufacturer, and authorised representative). Together with the deployer and provider, such organisations are referred to as 'operators' of AI. Importantly, the same operator may qualify simultaneously as more than one of these roles if they meet the respective conditions. For instance, it is possible to be both the provider and the deployer of an AI system at the same time.

Prohibited activities

Prohibited activities in France

Certain AI practices are banned outright under Article 5 of the EU AI Act due to their potential for harm and ethical concerns. These prohibitions aim to protect EU citizens from the most intrusive and potentially abusive uses of AI.

Under Article 5, these uses and technologies include:

Subliminal techniques: Deploying subliminal techniques or techniques that are manipulative or deceptive and have the effect or objective of materially distorting those people by impairing their ability to make an informed decision, causing them to make a decision they would not otherwise have taken, in a manner that causes significant harm to them or others (or is reasonably likely to).
Exploiting vulnerabilities: Exploiting vulnerabilities of specific groups due to age, disability, or social or economic situation – as with subliminal techniques, this must have the effect or objective of materially distorting behaviour and cause significant harm to them or others (or be reasonably likely to).
Social scoring: Evaluating or classifying natural persons or groups based on their social behaviours or personality characteristics (known, inferred or predicted) leading to either or both, unfavourable treatment of them or others in social contexts unrelated to the context in which the data was originally gathered or that is unjustified or disproportionate to their social behaviour or its gravity.
Crime profiling: Assessing the risk of an individual committing a crime, based on the profiling of that person and assessing their personality traits (as opposed to using such systems to support a human assessment of the involvement of a person).
Facial recognition databases: Creating or expanding facial recognition databases through untargeted scraping of facial images from the internet or CCTV footage.
Inferring emotions: Inferring emotions in workplaces and educational institutions (except for medical or safety reasons).
Biometric categorisation: Categorising natural persons based on their biometric data to deduce or infer sensitive information about them (i.e. their race, political opinions, trade union membership, religious or philosophical beliefs, sex life or sexual orientation) except where based on lawfully acquired datasets (including in law enforcement).
Biometric identification: Engaging in ‘real-time’ biometric identification systems in publicly accessible spaces for law enforcement purposes, except under specific exempt circumstances.

Prohibited activities in France

In France, the CNCDH Opinion recommends to ban: (i) the use of choice interfaces whenever their purpose or effect is to manipulate users to their detriment by exploiting their vulnerabilities; (ii) all types of ‘social scoring’ implemented by public authorities or by any company, public or private; and (iii) the use of emotion recognition technologies, except for their use when they are intended to reinforce the autonomy of individuals, or more broadly the effectiveness of their fundamental rights.

High-risk AI

High-risk AI in France

Article 6 of the EU AI Act sets out classification rules for high-risk AI systems, stating that high-risk AI systems fall within two categories: (i) safety components of products or products themselves regulated by existing EU product safety laws (listed in Annex I, e.g., medical devices, automotive AI); or (ii) used in specified areas (listed in Annex III), namely:

Critical infrastructure: AI systems used as safety components in the management or operation of critical digital infrastructure, road traffic, or the supply of water, gas, heating or electricity.
Education and vocational training: AI systems that determine access to education or training or otherwise impact a person's future opportunities and career development and AI systems used for monitoring and detecting prohibited behaviour during tests.
Employment and worker management: AI systems used in hiring (including the placement of targeted job advertisements), performance evaluation, promotion or termination decisions.
Access to essential private and public services: AI systems that evaluate eligibility for essential public services, such as social security and healthcare as well as AI systems for evaluating and classifying emergency calls and dispatching emergency services. Additionally, AI systems used to evaluate creditworthiness or during the risk assessment and pricing of life and health insurance.
Law enforcement: AI systems used by law enforcement for risk assessments, predicting criminal activities (the risk of individuals becoming victims of crime, risk of (re-)offending or otherwise during criminal investigations), for polygraphs (i.e. 'lie detectors' or similar tools), and assessing reliability of evidence.
Border control and migration: AI systems used to assess visa applications, asylum claims, and border security including for polygraphs (i.e. 'lie detectors' or similar tools) and for detecting, recognising or identifying individuals in migration contexts.
Judicial and democratic processes: AI systems assisting judicial authorities with researching and interpreting facts and the law and applying the law to a set of facts. As well as AI systems used for influencing the outcome of elections or referendum or voting behaviour.
Biometric identification and categorisation: AI systems that perform remote biometric identification are used to categorise individuals based on biometric data or other sensitive or protected attributes, and AI systems used for emotion recognition purposes.

These systems must adhere to stringent requirements to ensure they do not pose unacceptable risks or operate in a manner that protects individuals' rights and safety. The classification emphasises the importance of high standards and accountability in deploying AI in sensitive and impactful areas.

The European Commission has the power to amend the above-mentioned categories of high-risk AI systems including to modify any existing use cases or add new ones (Article 7(1) of the EU AI Act).

Where an AI system falls into one of the two categories above-mentioned but does not pose significant risk of harm to health, safety or fundamental rights, the operators of such AI systems are relieved from the requirements imposed for high-risk AI systems (except for the EU database registration). However, to benefit from such exemption, a thorough assessment must be documented and strict conditions must be met (however these conditions are currently difficult to interpret, and further guidelines from the Commission are expected).

High-risk AI in France

In France, the ACPR AI Governance Study has highlighted the necessity that credit scoring, anti-money laundering and customer protection AI systems are evaluated in a way that they ensure: (i) appropriate processing of data; (ii) performance; (iii) stability; and (iv) explainability. To do so, financial institutions must take care, from the design of algorithms onwards, to integrate operational teams, have human verification of the decisions, implement strong security measures, validation processes and to conduct regular audits.

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Controls on generative AI

Controls on generative AI in France

General-Purpose AI Models

Article 3(63) of the EU AI Act defines a GPAI (general-purpose AI) model as an:

"AI model, including where such an AI model is trained with a large amount of data using self-supervision at scale, that displays significant generality and is capable of competently performing a wide range of distinct tasks regardless of the way the model is placed on the market and that can be integrated into a variety of downstream systems or applications, except AI models that are used for research, development or prototyping activities before they are placed on the market."

GPAI models are versatile and can be applied across various domains and contexts. The Act sets requirements to ensure that these specific models, due to their broad applicability and the wide range of tasks they can complete, adhere to high ethical and safety standards. Please note that not all AI models are GPAI models, and the EU AI Act only regulates the latter.

Generative AI guidance in France

In France, the CSPLA Report specifies how AI model providers should publish a policy of compliance with European copyright law respecting the authors’ opt-out principle, and to make available to rights holders and the public a sufficiently detailed summary of the content used to train AI models. Templates have been provided for these summaries but have not been kept in the final version of the GPAI Code of Practice.

The Senate Report highlights that today’s AI ecosystem includes ‘more or less open’ models, a distinction that has become central to regulatory debates because openness affects transparency, auditability, and safety oversight. It explains that the EU AI Act now regulates not only AI uses but also foundation models (i.e., GPAI models) themselves, introducing a stricter regime for those deemed systemic‑risk models, due to their scale, dual‑use potential and difficulty to supervise. The report emphasises that generative AI still suffers from core reliability issues (e.g., hallucinations, opacity, and multi‑layered bias) which persist even with mitigation techniques such as Retrieval‑Augmented Generation (RAG), positioning these technical limitations as key reasons regulators now impose model‑level obligations, in addition to downstream application controls.

With regard to privacy aspects, the CNIL Generative AI Guidance provides recommendations on how to ensure privacy safeguards when using generative AI, including: start with specific needs rather than deploying AI without clear purpose; define allowed and prohibited uses, especially regarding personal data; acknowledge system limitations and risks; choose secure deployment methods, preferably using local, specialised systems; train end users on proper usage and risks; and implement appropriate governance ensuring GDPR compliance with all stakeholders involved.

General-Purpose AI Models with Systemic Risk

Article 3(65) of the EU AI Act defines 'systemic risk' as:

"a risk that is specific to the high-impact capabilities of general-purpose AI models, having a significant impact on the Union market due to their reach, or due to actual or reasonably foreseeable negative effects on public health, safety, public security, fundamental rights, or the society as a whole, that can be propagated at scale across the value chain".

Article 51 of the EU AI Act classifies a GPAI as having systemic risk if it has high impact capabilities (this is currently when the cumulative amount of computation used for training is greater than 10 to the power of 25 floating point operations but also through other indicators and benchmarks) or based on a decision of the Commission.

Systemic risk involves the broader, cumulative impact of GPAI models on society. This encompasses scenarios where GPAI models could lead to significant disruptions or risks, necessitating a regulatory focus to prevent widespread adverse effects and ensure resilience across sectors. In view of the higher risks, the Act sets additional requirements for GPAI models with systemic risk.

Importantly, the requirements of a GPAI model / system (i.e., without a specific use case) and the requirement of an AI system based on its risk profile (depending on the use case at stake) can be cumulative. For instance, if the provider of a GPAI model integrates its model in a high-risk AI system, then the rules for both GPAI models and high-risk AI systems should be complied with.

Enforcement / fines

Enforcement / fines in France

The EU AI Act enforces compliance through a structured framework of fines and sanctions, varying in severity based on the nature of the non-compliance.

For non-compliance with prohibited AI practices, fines can reach up to EUR 35 million or 7% of the total worldwide annual turnover, whichever is higher.

This includes practices like manipulative AI systems, exploiting vulnerabilities, social scoring by public authorities, and unauthorized biometric identification in public spaces.

Breaches of high-risk AI system requirements can incur fines up to EUR 15 million or 3% of the total worldwide annual turnover.

These requirements include risk management, data governance, technical documentation, transparency, and cybersecurity. Other non-compliance issues, such as providing incorrect or misleading information, can result in fines up to EUR 7.5 million or 1% of the total worldwide annual turnover. This applies to breaches not covered by the highest or significant sanctions.

In France, the rules on penalties applicable to infringements of the EU AI Act had not been laid down, nor notified to the Commission, by the 2 August 2025 deadline set by Article 99 of the EU AI Act (read with Recital 179). The national penalty and enforcement provisions are contained in Article 24 of the DDADUE. The French penalty framework is accordingly expected to be adopted, implemented and notified to the Commission in the course of 2026.

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User transparency

User transparency in France

Article 50 of the EU AI Act sets out transparency obligations for providers and deployers of certain AI systems, including the following:

Providers of AI systems must ensure that natural persons using an AI system must be informed that they are interacting with an AI system unless this is obvious to the natural person (this obligation excludes AI systems authorised by law to detect, prevent, investigate or prosecute criminal offences).
Providers of AI systems must ensure that the synthetic outputs of the AI system are marked in a machine-readable format and detectable as artificially generated or manipulated (excluding AI systems authorised by law to detect, prevent, investigate or prosecute criminal offences) and must process data in accordance with other relevant EU laws.

Criminalization of unauthorized deepfakes in France

Please note that the French Digital Space Law criminalizes the publication of deepfakes of other persons in a way that modifies by AI their image and/or voice without their consent. An offender may face imprisonment (up to one year) and financial penalties (up to 15,000 euros). Such penalties increase when deepfakes are shared through online platforms or involve sexually explicit content.

Deployers of emotion recognition or biometric categorisation systems must inform the affected natural persons.
Deployers of AI systems that generate or manipulate image, audio or video content constituting deep fakes must disclose that the content has been artificially generated or manipulated.

User transparency in France

Please note that the French Digital Space Law criminalises the publication of deepfakes of other persons in a way that modifies by AI their image and/or voice without their consent. An offender may face imprisonment (up to one year) and financial penalties (up to EUR 15,000). Such penalties increase when deepfakes are shared through online platforms or involve sexually explicit content.

Please note that the French Influencer Law imposes requirements on influencers to include warnings on images that have been modified using AI. Modified images using filters or AI must include ‘retouched images’ or ‘virtual images’ labels.

In France, the CNCDH Opinion recommends extending the EU AI Act transparency obligations in order to systematically inform people when they are exposed to or required to interact with an AI system and, when they are the subject of a decision, that this decision is based in part or in full on algorithmic processing even when undertaken by private organisations (and currently in France, this information requirement related to AI decision-making only applies with respect to public bodies).

Also, the Senate Report flags multiple transparency‑adjacent issues such as: (i) the black box / explainability issue, which underpins the difficulty of understanding model reasoning, motivating transparency and interpretability requirements in policy frameworks; and (ii) deepfake watermarking/labelling, by noting however that the increasing policy push for watermarking or equivalent measures enables users to recognise synthetic media.

Fairness / unlawful bias

Fairness / unlawful bias in France

At its core, the EU AI Act is driven by the imperative to safeguard the fundamental rights of EU citizens. The rapid advancement of AI technologies has introduced significant benefits but also potential risks, such as biases in decision-making systems and privacy infringements. The AI Act aims to mitigate these risks by establishing clear rules that ensure AI systems respect the rights enshrined in the EU Charter of Fundamental Rights. This focus on human-centric AI seeks to enhance trust and acceptance among the public, thereby promoting wider adoption of AI technologies in a responsible manner.

Within the EU AI Act, non-discrimination and fairness is incorporated withing the following:

Recital 27 includes seven principles for trustworthy AI including ensuring that AI systems are developed and used in a way that includes diverse actors and promotes equal access, gender equality and cultural diversity, while avoiding discriminatory impacts and unfair biases that are prohibited by Union or national law.
Article 10 sets out data and data governance requirements for high-risk AI systems and includes a requirement to examine and assess possible bias in training, validation and testing data sets.
Deployers are required to ensure that any input data is relevant and sufficiently representative in view of the intended purpose of the high-risk AI system (Article 26(4)).

The Framework addresses the issue of bias (most notably in paragraphs 27-37 relating to ‘Non-bias and non-discrimination') and highlighted that AI has the potential to create and reinforce biases and that bias and discrimination by AI can cause manifest harm to individuals and to society. The European Parliament stated that regulation should encourage the development and sharing of strategies to counter these risks, including debiasing datasets in research and development and by the development of rules on data processing. The European Parliament also considered this approach to have the potential to turn software, algorithms and data into an asset in fighting bias and discrimination in certain situations, and a force for equal rights and positive social change.

Guidance on fairness / unlawful bias in France

The CNCDH Opinion considers that AI systems inherit biases from two sources: development process and training data. These biases self-reinforce and amplify automatically, creating systematic discrimination. According to the CNCDH Opinion, continuous monitoring and adjustment are essential to prevent AI systems from perpetuating discrimination against marginalised communities.

In addition, the Senate Report discusses how multi-layer bias (through real data and programming choices) is linked to unequal or distorted outputs and polarised ‘economy of attention’, reinforcing the policy need for bias detection/mitigation obligations (data governance, testing, documentation) within the EU framework.

Human oversight

Human oversight in France

Human oversight is crucial for preventing and mitigating risks associated with the AI system's operation. Providers must also ensure that operators are adequately trained to oversee the AI system, understand its functionalities, and respond appropriately to any issues. Effective human oversight enhances the safety and reliability of high-risk AI systems, ensuring they operate within acceptable parameters and can be controlled in case of unexpected behaviour or malfunctions.

Article 14 of the EU AI Act deals with human oversight, stating that providers must implement measures to ensure effective human oversight of high-risk AI systems. This involves designing the system with mechanisms that allow human operators to monitor, intervene, and deactivate the AI system if necessary. Providers of high-risk AI systems are required to ensure that systems falling under their responsibility are compliant with this requirement (Article 16(a)) and to include the human oversight measures within the "instructions for use" for the high-risk AI system (Article 13(3)(d)).

In addition, deployers of high-risk AI systems are required to comply with the providers 'instructions for use' and to assign human oversight to persons that have the necessary competence, training and authority as well as necessary support (Article 26(1) and (2)).

Finally, recital 27 of the EU AI Act includes seven principles for trustworthy AI including ensuring that AI systems apply human agency and oversight.

This means that AI systems are developed and used as a tool that serves people, respects human dignity and personal autonomy, and that is functioning in a way that can be appropriately controlled and overseen by humans.

Guidance on human oversight in France

The CNCDH Opinion recommends implementing supervision of the AI system, according to a procedure that may vary according to the risks of infringement of fundamental rights as identified by a prior impact risk assessment. This process should help maintain ongoing vigilance from the AI system user with regard to the effects of the system and its potential discriminatory effects.

The CNIL AI Risk Assessment provides elements about human oversight to prevent systematic errors and misuse. It specifies that organisations must implement clear, effective, and sustainable measures for human intervention and data controllers should establish a framework ensuring these oversight conditions are met.

The Senate Report strongly approves the EU approach to human oversight measures and the need for governance so that AI complies with human rights through education and oversight capacities built across society, pointing to the role of human control over system deployment and use. In its EU governance chapter, it welcomes positively institutional set‑ups and soft‑law instruments (e.g., AI Pact) designed to structure oversight and accountability around model and system risks, consistent with human‑in‑the‑loop expectations under the risk‑based scheme it presents.

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Key contacts

Key contacts in France

Jonathan Rofé

Partner

DLA Piper

Paris

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European Level

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Supervisory authority in France

As of July 2026, the legislative process implementing the formal designation is still ongoing.

With respect to the deadlines set by the EU AI Act:

France has not met the 2 August 2025 deadline for Member States to designate their national competent authorities (notifying authorities and market surveillance authorities), to communicate them to the Commission and to make their contact details publicly available (Article 70(2)). The DGE and the DGCCRF published the proposed governance scheme, together with public contact details, on 9 September 2025, but the formal designation requires the adoption of the DDADUE, which remains pending before French Parliament, therefore formal designation is now expected in the course of 2026.
No public information has been released confirming that France submitted the report required under Article 70(6) on the financial and human resources of its competent authorities by 2 August 2025.
There was no official confirmation that France has established an AI regulatory sandbox within the meaning of Article 57(1) of the EU AI Act. Given that the DDADUE has not yet been enacted, it appears unlikely that an operational AI regulatory sandbox will be in place by the 2 August 2026 deadline. The CNIL has, however, run sector-specific ‘sandbox’ support programmes since 2021, which may serve as a basis for the future French AI regulatory sandbox.

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