France R&C Strategic Report
Risk, compliance and whistleblowing in FranceSince 2021, the French R&C environment has been defined by the maturation of Sapin II requirements and the full integration of the EU Whistleblower Protection Directive. These regulations have driven significant operational investment, visible in the high-performance metrics tracked below. Maintaining compliance leadership requires translating these operational gains into resilient, proactive risk mitigation.
Methodology
This report provides a comprehensive, data-driven strategic analysis of the evolution of the Risk & Compliance (R&C) landscape in France over a five-year window, from 2021 through 2025. This analysis is a synthesis of proprietary NAVEX incident management data and global perception benchmark data.
The objective is to provide executive leadership with a quantified and longitudinally tracked assessment of R&C program maturity, operational performance, and strategic risk exposures. We combine long-term incident trends with current program perception to identify the disconnect between program sophistication and strategic focus. The report is organized into two main parts: a time-series analysis of trends (2021-2025) and a comparative geographical review.
All the data and insights featured in this report come from Whistleblowing & Incident Management Benchmark reports (2021-2024) and State of Risk & Compliance reports (2023-2025).
Key results
Main metrics highlighting the state of whistleblowing in France (based on 9,234 reports collected in 2024 by NAVEX).
- 0.54
Reports per 100 employees
+42.1% in 1 year
- 55%
Substantiation rate
2nd highest amongst main markets
- 76
Days for case closure
+20 days since 2021
Yearly comparison
This part dissects the French R&C journey from 2021 to 2025, revealing distinct phases of development. The period from 2021-2023 was marked by a rapid operational response to new whistleblowing requirements, evidenced by metrics from the NAVEX Whistleblowing & Incident Management Benchmark reports.
From 2023-2025, the focus shifted, according to NAVEX State of Risk & Compliance benchmark data, toward program optimization and away from foundational risk management, creating significant compliance blind spots.
Analysis: The 8-point increase in the Optimizing category, coupled with a total of 65% of programs in the Managing/Optimizing stage in 2025, validates France as a high-maturity environment ready to move beyond foundational compliance
Analysis: The data reveals a significant and accelerating potential operational decline since 2022. The 2024 median of 76 days is the highest in the four-year period, representing a total increase of 20 days since the stable 2021-2022 period. This suggests investigative capacity is struggling to keep pace with the high report volume, transforming what should be a highly performing function into a critical operational lag.
Analysis: The 42.1% surge in Reports per 100 Employees from 2023 to 2024 indicates a strong recovery from the 2023 dip, suggesting heightened employee confidence in the confidentiality and non-retaliation promise of the system.
Analysis: The 14-point spike in 2023 marks a significant report quality leap, followed by a modest gain in 2024. The current 55% Substantiation Rate suggests a pairing of high-quality reports and targeted investigative functions.
Analysis: The 13-point surge in DEI and the slight increase in EHS training demonstrate a strong cultural pivot towards social and environmental responsibilities. This new focus on social risks appears to have created a trade-off in the technical/regulatory domain, where Data Privacy dropped by 12 points since 2023, falling from 51% in 2024 to 34% in 2025.
Unlike Data Privacy, Cybersecurity remains relatively stable at 54% (a minor 3-point decline). This difference suggests that organizations may be consolidating technical training due to emerging threats like AI risk management (which showed 77% engagement in 2024). This potential merger of data security, privacy, and emerging technology topics, combined with the new priority for social issues, has left dedicated Data Privacy training critically underrepresented, creating an exposure gap in a core GDPR compliance area.
Analysis: The 19-point drop means that 54% of French respondents are not reviewing the essential cybersecurity posture of their third parties, making the supply chain one of the greatest unmanaged external risk.
Analysis: The reduction in external measures (regulatory and media) is a success. However, the 3-point rise in executive misconduct damage may suggest an organizational priority shift away from a proactive, cultural focus (see Page 8) towards reactive compliance, indicating potential cultural drift at leadership level.
Geographical comparison
This second part benchmarks France’s R&C program against key global counterparts (Germany, U.K., U.S., and Europe average). This comparison leverages both the long-term incident data and the latest program perception data to highlight areas of competitive advantage and critical lag.Analysis: In 2025, France’s self-reported maturity is 7 points ahead of the U.S. and European average. This indicates a high level of confidence in the program’s design, but this self-reported perception does not guarantee superior operational speed or risk mitigation performance.
Analysis: The median closure time of 76 days in 2024 is now the second slowest among its major peers, with Germany having a slightly faster Case Closure Rate of 66 days. France’s average case closure time is only slightly faster than the U.K. at 82 days, and slightly slower than the overall European average of 69 days.
Analysis: The 55% Substantiation Rate in 2024 is the second highest among all compared jurisdictions, confirming France’s leading performance in incident triage and investigative quality. France maintains a strong lead, sitting 11 points ahead of the U.K. (44%) and 10 points above both the U.S. and the Europe average (+8 points). The significant acceleration observed since 2023 means French organizations are highly effective at confirming violations and filtering out non-material reports, making this a core competitive strength of the national R&C environment.
Analysis: France’s 2024 volume (0.54) is below the Europe average (0.67) and significantly lower than Germany (0.71), indicating a need for targeted internal communication campaigns to drive participation, despite the high quality of reports.
Analysis: France trails Germany by a massive 17 points and Europe average by 9 points. This 46% figure confirms the third-party supply chain as a critical, unmanaged risk that is competitively disadvantaged compared to peers.
Analysis: French organizations prioritize data privacy training 14 points less than their U.K. and 22 points than German peers, creating a significant, self-inflicted regulatory gap in a core legal area.
Conclusion and strategic recommendations
Summary of findings (2021-2025)
The analysis reveals a five-year narrative of French R&C excellence in investigative quality, but a significant challenge in operational speed and strategic prioritization. The Whistleblowing & Incident Management Benchmark data presents a mixed operational picture: Report and investigative quality remains high (55% substantiation rate), but the program is bottlenecked. Case closure time has increased to 76 days, making France the second slowest among its major peers.
Concurrently, the State of Risk & Compliance survey data highlights a priority shift, specifically away from ethical culture towards compliance with all applicable laws/regulations (the only remaining high-ranking priority at 60%). This shift is accompanied by a large 19-point drop in third-party cyber screening focus.
Key advice
- Resolve the operational lag: Evaluate your program, and as needed, address the 20-day average increase in Case Closure time, which is currently four days slower than the EMEA average. The focus must be on re-engineering the investigation process and/or allocating capacity to regain competitive speed.
- Reverse the strategic priority shift: Rebalance executive focus to increase the prioritization of ethical culture and risk management. The current focus on reactive legal compliance leaves the organization vulnerable to internal, preventable misconduct, as evidenced by the rise in executive misconduct.
- Close the technical risk gap: Companies should take immediate, targeted action to close the competitive gaps in technical governance:
- Third-party cyber screening: Companies should assess their current third-party cyber screening policies to mitigate critical supply chain risk.
- Data privacy training: Companies should review and increase dedicated data privacy training resources to target closing the substantial 22-point gap with peers in this core GDPR area.
Outlook for the future
2026 and beyond
The five-year trend data provides a clear path forward for the French Risk & Compliance function. While programs are successfully maturing, the primary challenge for 2026 is sustained operational and strategic focus.
The 2026 imperative: Capacity and culture
The core issue entering 2026 is a significant performance gap. The compliance program may be highly effective at filtering and confirming genuine misconduct, a proven strength shown by the high substantiation rate. However, the process of investigating and closing those confirmed cases is critically slow: the median case closure time has grown to 76 days.
A strategic drift compounds this operational bottleneck. Recent program perception surveys indicate the executive focus is shifting away from proactively cultivating a strong ethical culture towards simply meeting minimum legal compliance requirements.
This combination creates an unmanaged risk profile:
- Regulatory exposure: The neglect of core technical areas, such as third-party cyber screening and dedicated data privacy training, leaves organizations exposed to major, preventable regulatory action (like severe GDPR fines) and supply chain breaches.
- Operational liability: The slow closure time extends the organization’s exposure to confirmed misconduct, increasing the potential damage, liability, and cost associated with each incident.
The way forward
Success in 2026 and beyond requires the executive team to close this performance gap through targeted resource deployment. Risk-tailored resource allocation must define the next phase of Risk and Compliance program development and maturity.
This means leadership must take ownership of three actions:
FAQ: Benchmark data disclosures
What requirements or limits did we take into consideration with the Whistleblowing & Incident Management benchmark?
Insights come from data reported by French companies, regardless of their report locations, representing a small cohort. Europe figures include all of Europe (UK etc.).
What requirements or limits did we take into consideration with the State of Risk & Compliance benchmark?
Year on year, the data is collected from survey respondents and is anonymized. Insights come from data reported by France-based respondents, representing small cohorts that change each year.
Meet the authors
Isabella Oakes
Data Scientist Specialist
NAVEX
Alexandre Bougherara
Content Marketing Manager
NAVEX
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