La Poste ruling requires a vigilance plan to identify risks and track action
The Paris Court of Appeal affirmed an injunction requiring La Poste to complete specified elements of its 2021 vigilance plan. The ruling addresses the plan’s content and implementation, including risk mapping and monitoring, rather than awarding damages or imposing automatic liability for subcontractor harm.
- Development
- 17 June 2025
- Published
- 29 October 2026
- Sources checked
- 29 October 2026
First merits ruling by the specialized chamber
On 17 June 2025, the specialized chamber 5-12 of the Paris Court of Appeal issued its first merits ruling on a corporate vigilance plan. In union proceedings concerning La Poste, it affirmed the 5 December 2023 first-instance injunction requiring the company to complete aspects of its 2021 plan. The decision concerns whether the plan met statutory expectations for vigilance, rather than whether La Poste must pay damages for every harm connected with a subcontractor. The court’s release identifies the injunction and the four areas requiring completion.
The appeal judgment focused on the content and implementation of the plan. The operative directions addressed risk mapping, assessment of subcontractors in relation to identified risks, consultation with unions on the alert mechanism, and establishment of a real monitoring system. These requirements connect the plan’s risk identification to steps for assessing business relationships, receiving alerts and tracking action. The judicial decision record identifies the judgment in the union case.
Four concrete elements of the plan
The first direction concerned a risk map capable of identifying and analyzing risks. The second required subcontractor assessment tied to those risks, rather than an assessment detached from the map. Third, La Poste was required to consult unions about the alert mechanism. Fourth, the company had to put in place a monitoring system capable of following the measures taken. Together, the directions address both the design of a plan and how it is used over time.
The case’s procedural history matters. The challenged plan was La Poste’s 2021 vigilance plan, and the first-instance injunction came in December 2023. The appellate decision affirmed that injunction in June 2025. It therefore reviews a specific plan and order, rather than announcing that every company’s plan is deficient or setting out a universal checklist divorced from the statutory context.
The scope of the injunction
Our analysis: The decision gives concrete content to the obligation to establish and implement a vigilance plan by linking its components. Risk mapping informs which subcontractors require attention; consultation informs how alerts operate; monitoring provides a way to track whether measures are actually carried out. The court’s directions concern the plan’s completeness and operation, not automatic liability for any injury in a subcontracting chain.
That boundary is important for remedies. Affirming an injunction to complete a plan is not an award of damages, nor does it impose strict liability for every subcontractor’s conduct. It is a compliance order directed to La Poste’s plan. The ruling’s value lies in specifying what the court required in this case while leaving separate questions of harm, causation and compensation to their own legal analysis. The appellate court’s account confirms the limited operative directions.