By Marc Barennes* and Agathe Missakian**
In 2025, France adopted a modified group action framework, which entered into force on 3 May 2025.[1] Article 16 of the Law No. 2025-432, as supplemented by three successive decrees (hereafter the “Decrees”), establishes a unified set of rules for group actions (hereafter the “Group Action Law”) in France.[2]
The Group Action Law overhauls the group action framework established by Law No. 2014-344, commonly known as the “Loi Hamon” (hereafter the “Hamon Law”),[3] and finally transposes the European Union Representative Actions Directive (hereafter the “RA Directive”)[4] into domestic law, albeit after the May 2023 transposition deadline.
The French legislator had already amended the Hamon Law three times.[5] In practice, the Hamon Law produced disappointing results: Between 2014 and 2020, only 39 group actions were brought, and almost all of them have failed.[6]A 2020 report drafted by two Members of Parliament assessing group actions attributed this failure to, inter alia, excessive procedural rigidity, restricted standing, and the lack of proper funding options.[7]
The process of reforming the Hamon Law, which ultimately led to the adoption of the Group Action Law, wavered between a technical transposition of the RA Directive and a broader overhaul of collective actions.[8] The French Senate mainly worried that extending standing could encourage “frivolous” litigation and harm businesses.[9] The Group Action Law reflects a compromise, which makes its wording complex.[10] The Decrees and a Ministerial Guidance, however, partly clarify several points, particularly regarding funding.[11]
Until the adoption of the Group Action Law, group actions were governed by fragmented and distinct legal sets of rules, scattered across multiple codes and sectors (e.g., health,[12] environment,[13] employment,[14] data protection,[15] and housing[16]). The Group Action Law therefore unifies sector-specific class actions under a single set of rules to improve access to justice.[17]
The Group Action Law creates a common framework allowing a limited number of claimants to bring an action on behalf of multiple legal or natural persons, in a similar situation, caused by a breach of legal or contractual obligations.[18]
Group actions which are brought on behalf of a multitude of victims serve three purposes: (i) to stop an unlawful conduct for the future via an injunction, (ii) to obtain compensation for harm suffered, or (iii) to pursue both an injunction and compensation for harm.[19]
This article seeks to evaluate whether the Group Action Law successfully addresses the shortcomings of the Hamon Law and to determine the new risks and the new opportunities it entails for businesses whether they are authors or victims of an infringement for which a group action may be brought, in particular in case of a competition law infringement.
In essence, we find that the Group Action Law has four main implications for businesses. Firstly, it allows businesses to seek compensation through a group action for all types of harm, thereby creating a new collective redress avenue in France, in particular for harm resulting from anticompetitive conduct, the recovery of which was, in practice, excluded under the Hamon Law. Secondly, it extends group actions to all areas of law, well beyond the field of consumer law, thereby significantly increasing businesses’ exposure to collective litigation, in particular in cases of competition law infringements. Thirdly, it expressly recognises third-party litigation funding, which will facilitate the emergence of large-scale funded group actions and enable businesses to access such funding more easily. Fourthly, it significantly strengthens the deterrent effect of group actions through the combination of injunctive relief and the civil fine, which will, on the one hand, increase the financial and reputational stakes associated with group actions and, on the other hand, create stronger incentives for businesses to settle disputes at an early stage, especially in cases of competition damages claims.
Part I of this article provides an overview of the scope of the Group Action Law which has become a cross-cutting framework. Part II examines how the Group Action Law can be applied in practice. Despite some of its shortcomings, it establishes a far more efficient collective redress mechanism than the one set out by the Hamon Law. Part III seeks to determine the potential impact of the Group Action Law on businesses, as it paves the way for mass litigation in previously underexposed sectors, particularly in BtoB, where group actions are expected to grow quickly and on a large scale.
I. From a Limited to a Cross-Cutting Group Action Framework
Without a doubt, the Group Action Law represents a decisive evolution in the field of French collective redress, significantly enhancing access to justice by allowing claimants to act on behalf of businesses (A). Group actions are no longer confined to specific sectors, as the Group Action Law establishes a comprehensive framework (B).
A. A Broader Access to Group Actions
The Group Action Law marks a significant evolution from the Hamon Law as group actions can be brought on behalf of legal persons, including businesses, which considerably widens the possibilities for victims to initiate a group action in France.
Under the Hamon Law, group actions were consumer-protection actions[20] as only a limited number of nationally representative consumer associations[21] could bring claims,[22] on behalf of consumers.[23] As a result, fewer than 50 actions were filed between 2015 and 2025,[24] and legal persons—such as small businesses, or franchisees—were excluded and had to rely on other collective mechanisms.[25]
By contrast, the Group Action Law substantially broadens standing,[26] to address the Hamon Law’s weaknesses,[27] by establishing two distinct but complementary mechanisms: damages actions and injunction actions.[28]
Damages actions are subject to stricter controls because they involve compensating harm, whereas injunction actions are procedurally more accessible as they “only” aim at stopping an ongoing conduct without having to define a strict group of victims as is the case for damages actions.[29]
As an example, a group of victims seeking compensation will have to band together behind a non-profit association, registered for at least 12 months to obtain prior approval from the “Direction Générale de la Consommation et de la Répression des Fraudes” (the French Directorate General for Competition, Consumer Affairs and Fraud Control, hereafter the “DGCCRF”).[30] By contrast, to seek an injunction, victims can act without a prior approval provided that the association satisfies a minimum activity of 24 months.[31]
The Group Action Law therefore gives access to collective litigation to a wider range of groups of victims.
For consumers, qualified entities from other EU Member States (“EU Qualified Entities”)[32] may initiate proceedings in France on their behalf within the scope of Annex I of the RA Directive which excludes notably health law and labour law.[33]
For labour relations, representative trade unions[34] may initiate proceedings in additional sectors compared to the Hamon Law, notably relating to personal data breaches or employer practices affecting multiple employees.[35]
For businesses, although initiating a group action under the Group Action Law remains largely “association-based” as individuals cannot bring group actions on their own,[36] it opens opportunities as legal persons may participate in collective proceedings through representative entities.
For instance, under the Hamon Law, companies harmed by cartel infringements, unfair contractual practices, or platform abuses generally relied on individual claims or private coordination mechanisms, such as a transfer of claims either to a special purpose vehicle (“SPV”) or to a fiducie (French trust-like structure).[37]
The Group Action Law also allows these victims to act through an association and to share litigation costs collectively.[38]In this regard, it is worth highlighting that the Group Action Law does not replace other mechanisms allowing companies to act together, it offers an additional means to do so, as no provision in the Group Action Law prohibits other collective action mechanisms.
In sum, listed qualified entities can bring both damages and injunctions actions, namely approved associations, representative trade unions, EU Qualified Entities, and farmers’ or fishers’ unions, whereas the Public Prosecutor and non-approved associations, following strict statutory requirements, can intervene as claimants in injunction actions only.[39]
By extending group actions to legal persons and broadening standing requirements, the Group Action Law fundamentally changes the scope of French group actions as collective litigation no longer concerns consumer disputes exclusively and may support large-scale BtoB proceedings.[40]
B. A Unified Scope for Group Actions
Under the Hamon Law, group actions relied upon fragmented sector-specific frameworks[41] limited to specific categories of infringements, whereas the Group Action Law establishes a unified mechanism applicable across all areas of law.
For instance, an infringement of the EU Artificial Intelligence Act[42] (“AI Act”) could serve as the basis to initiate a group action.[43]
The Group Action Law nevertheless accommodates two exceptions, (i) for violations related to heath products,[44] and (ii) for anticompetitive practices.[45]
The Group Action Law considerably broadens the substantive scope of group action in two ways.
Firstly, the Group Action Law widens the range of actionable conduct, as it covers both mass torts and all types of contractual infringements,[46] whereas the Hamon Law limited group actions to specific sectoral violations.[47]
For instance, under the Hamon Law, consumer law group actions remained limited to breaches arising from the sale of goods, services, or rental contracts.[48] Several sectors therefore remained effectively excluded, including banking and investment services.[49]
By contrast, the Group Action Law adopts a broader approach by allowing actions based on breaches committed in the course of professional activity. [50] Banks, insurance companies,[51] digital platforms, and certain public entities may therefore face group actions more frequently.[52]
Secondly, the Group Action Law extends compensation to all categories of harm, including reputational and non-material harm, whereas, under the Hamon Law, compensation was limited depending on the applicable law. For instance, in consumer matters, claimants could only recover material losses.[53]
The Group Action Law will also increase claimants’ incentives to initiate group actions based on anticompetitive practices which were de facto precluded under the Hamon Law as economic harm could not be recovered.[54]
Overall, the Group Action Law transforms the French group action legal framework from a narrow consumer-protection mechanism into a broader cross-sector framework capable of supporting large-scale claims, particularly in BtoB disputes.
II. The Comprehensive Enforcement of Group Actions
From a procedural standpoint, the Group Action Law has streamlined the procedures,[55] as no prior notice is required[56]and exclusive jurisdiction[57] is assigned to eight designated Civil Tribunals, ensuring greater judicial expertise in complex matters and improved consistency[58] in decision-making.
Appeals are centralised before the Paris Court of Appeal, facilitating the development of specialised case law. Similarly, the Paris Civil Tribunal has exclusive jurisdiction[59] where the defendant is domiciled abroad or has no known residence in France, which is particularly relevant to ensure that group actions involving foreign defendants are heard by a centralised court.
The competent Tribunal may also dismiss unmeritorious claims at the outset, but the Council of State has not published the decree detailing its modalities.[60]
The Group Action Law establishes a comprehensive enforcement system, where damages actions focus on compensating victims by aggregating claims (A) and injunction actions are procedurally easier to bring and aimed at acting quickly (B), whereas the Hamon Law did not always allow victims to seek the latter.[61] Funded actions, and the creation of a punitive mechanism also strengthens its deterrence (C).
A. Damages Actions: A Collective Compensation of Victims
The Group Action Law allows victims, whether companies or consumers, to seek damages collectively.[62]
The procedure under the Group Action Law is relatively lengthy, following two phases — identical to the ones provided for by the Hamon Law[63] — consisting of, first, establishing the defendant’s liability and, second, organising the compensation of damages.
In the first phase, based on the evidence provided by the Claimant, the competent tribunal assesses the defendant’s liability, defines the group and types of harm suffered.[64] It sets a period during which victims may join the action, commonly called an opt-in period— ranging from 2 months to 5 years,[65] compared to a maximum of 6 months under the Hamon Law — as well as deadlines for the defendant to pay damages and for unsatisfied claimants to bring further actions. It may also decide to secure part of the sums.[66]
In the second phase, the competent Tribunal organises compensation. It may allow an individual compensation, with each group member negotiating separately, [67] or, at the claimant’s request, a collective procedure[68] under which the claimant negotiates an agreement directly with the defendant on behalf of the group. The competent Tribunal must approve any agreement, and if none is reached, victims may pursue individual claims.[69]
For instance, consumers may create an association to seek damages where a company misrepresents a product’s environmental impact. Once the association is approved and liability is established, similarly affected consumers may opt into the group. The competent Tribunal may then allow the approved association to manage compensation collectively or leave claims to be pursued individually.[70]
The collective procedure is relatively long but to avoid delays, the competent Tribunal may impose a fine[71] for any dilatory conduct and sets a cut-off date — no earlier than six months after the initial decision — after which it resumes control of the process.[72] Any sums awarded are collected and distributed through the “Caisse des dépôts et consignations” (the French Deposits and Consignments Fund, hereafter the “CDC”).[73]
A key exception[74] to this streamlined procedure is related to anticompetitive practices: the claimant must await the outcome of administrative proceedings, as under the Hamon Law. The competent Tribunal may only establish liability on the basis of a prior decision by a competition authority or the European Commission which is no longer subject to appeal as regards the establishment of the infringement (“Follow-on Requirement”).[75]
The “Follow-on” Requirement delays the use of group actions but, for instance, a consumer-association, the CVCL, has already initiated a group action on the basis of the European Commission’s 2024 App Store[76] infringement decision, showing the immediate impact of the Group Action Law.
Overall, the Group Action Law provides a structured tool for collective compensation.
B. Injunction Actions: A Group Action to Stop Unlawful Conduct Swiftly
The Group Action Law also allows a claimant, such as a non-approved association, acting on behalf of victims of a breach, to seek injunctions to quickly stop unlawful conducts.
The conditions are less strict than for damages actions.
First, claimants are not required, before initiating proceedings, to identify a group of similarly affected victims, whereas the Hamon Law limited injunctions to certain sectors[77] and required claimants to identify individual cases to support the claims.[78]
Second, claimants need not establish intent or negligence on the part of the defendant, [79] only to demonstrate a breach of a legal or contractual obligation.[80] The existence of an unlawful practice justifies in itself an injunction action.
The practical value of the Group Action Law is illustrated by the injunction action brought by the Association Antoine Allénobefore the Paris Judicial Court on 21 April 2026.[81] The association seeks to ban the marketing in France of nitrous oxide canisters on the basis of several unfair commercial practices.
The Antoine Alléno case demonstrates the preventive value of injunction actions as a private enforcement tool where public authorities have not intervened effectively. The association was able to act swiftly because injunction actions do not require the association to have prior DGCCRF approval, to have identified individual victims, or to bring proof of individual harm.
The Group Action Law therefore allows ongoing unlawful conduct to be challenged before harm becomes more widespread.
One issue under the Hamon Law was that defendants could raise multiple preliminary objections, and in practice, many group actions stopped at the admissibility stage.[82] The Group Action Law therefore strengthens the powers of the competent Tribunal to expedite proceedings.[83]
Moreover, the competent Tribunal may order provisional measures[84] to stop the breach and require publicity, while filtering manifestly unfounded claims[85] and managing conflicts of interest with third parties.[86]
If the competent Tribunal finds that a breach has occurred, it orders the defendant to cease the conduct and to take all necessary measures to that end, where appropriate subject to penalty payments.[87]
The injunction action also produces an important procedural effect for individual damages actions. If a claimant brings an injunction action, the limitation period applicable to individual damages actions stops running for the same infringements.[88] The injunction action preserves the rights of potential victims to seek damages while the proceedings are pending, thereby facilitating subsequent individual claims arising from the same breaches.
This underscores the practical importance of giving adequate publicity to the proceedings at an early stage, so that affected individuals are made aware that their rights are being preserved. It also illustrates how damages actions may follow on an injunction action, making the Group Action Law a comprehensive mechanism.
One uncertainty remains for anticompetitive practices,[89] as the competent Tribunal must establish a breach has occurred which could mean injunction actions are also limited by a Follow-on Requirement. In practice, if the competent Tribunal awaits a prior decision, it will limit the effectiveness of injunction action for anticompetitive infringements.[90]
For all the other infringements, the Group Action Law provides businesses with access to swift relief.
C. A More Deterrent and Financially Viable Group Action
The Group Action Law strengthens the deterrent effect of group actions by addressing two structural weaknesses of the Hamon Law: the absence of sustainable funding mechanisms and financial sanctions.[91]
Firstly, the Group Action Law explicitly recognises and regulates third-party litigation funding,[92] addressing the ambiguity under the Hamon Law regarding whether funders could recover profits. [93] Under the Hamon Law, financial constraints also often blocked associations from pursuing complex group actions.[94]
Funders can support group actions,[95] provided they do not influence the proceedings in a way that could harm the individuals being represented.[96] They are commonly remunerated through a percentage of damages if the action succeeds.[97] Conflicts of interest can be raised by the Defendants as grounds for inadmissibility[98] of the claims, but such conflicts can be managed through efficient TPLF agreements addressing issues such as the possibility for victims to drop a case or settle.[99]
However, Decree No. 2025-1191 imposes strict transparency requirements: funders contributing over €20,000[100] must be listed on the beneficiary’s website before the action is launched and updated annually, [101] including their identities, contributions, and key contract terms.[102] This requirement can be a challenge to secure funding, but only key contractual terms must be published.[103]
Secondly, the Group Action Law introduces a “sanction civile” (a “Civil Fine”), targeting deliberate and profitable wrongdoing that causes collective harm.[104] It can reach up to twice the unlawful gain for individuals and five times for legal entities, and is uninsurable.[105] Proceeds are intended to contribute to the funding of a dedicated Group Action Fund.[106]
Not all claimants can request the Civil Fine, only the Public Prosecutor before a Civil Tribunal or a State representative before an Administrative Tribunal can do so. While practical uncertainties remain,[107] the Group Action Law strengthens both the economic viability and the deterrent effect of group actions and helps correct the economic imbalance between victims and large corporate defendants.
A public fund partly funded by the Civil Fine and penalties is created, providing more direct support for group actions than under the Hamon Law, where such funds went to the Treasury.[108] Details on its operation and which associations will benefit remain unclear.[109]
In practice, the Antoine Alléno case[110] will serve as a test for the Civil Fine mechanism. By expressly inviting the Public Prosecutor to intervene and request a Civil Fine,[111] the association has underscored the decisive role of prosecutorial discretion in triggering this sanction. More broadly, it illustrates how claimant representatives may use media coverage and public pressure to encourage defendants to engage in settlement discussions at an earlier stage.[112]
The combination of the injunction action and the Civil Fine introduces both financial and reputational risks for defendants.
By increasing the expected cost of unlawful conduct and non-compliance, the Group Action Law strengthens the preventive and deterrent effect of group action.
III. The Impact of the Group Action Law on Businesses
The Group Action Law creates a clear dual effect for businesses as it increases the opportunities to obtain compensation and the risk of being exposed to such claims. It creates new opportunities for victims to act collectively, without displacing other existing mechanisms (A), alters defendants’ exposure by improving the economic viability of collective claims (B) and is likely to affect settlement dynamics (C).
A. Opportunities for Businesses to Act Collectively
One of the main impacts of the Group Action Law is to offer to businesses a real choice between individual and collective actions. In this respect, group actions are not intended to replace traditional mechanisms, but rather to complement them.[113]
Alternative procedures remain, for instance, an assignment of claims[114] which can offer an efficient route to damages, if the victims do not want to act through an association and want to transfer their claims to a third party.
This complementarity is particularly important for anticompetitive practices as victims of cartels or abuses of dominance typically face the same obstacles: high litigation costs, complex economic evidence, lengthy proceedings, and, in certain sectors, the risk of commercial retaliation.[115]
Group actions address these constraints as businesses who are victims of an infringement can pool resources. For instance, at the liability stage of a damages action, liability of the defendant is determined based on the aggregated evidence submitted by the claimant, instead of each victim supporting its own burden of proof.[116]
Victims also minimise the risk of retaliation, as the association acts on behalf of multiple victims, reducing the visibility and vulnerability of any single claimant in an individual litigation.[117]
For instance, in supply chain contexts involving an abuse of dominance, if several suppliers act collectively, it becomes significantly more difficult for a dominant distributor to target an individual company for retaliation.
However, group actions require coordination. Companies participating in a group action do give up a degree of autonomy over the conduct of the proceedings to a third party.[118] This specificity is not unique to group actions.
For instance, in case of a transfer of claims to a special purpose vehicle (“SPV”) victims give up their rights to the SPV which then controls the claim.[119]
In some cases, individual mechanisms remain preferable. They may offer more speed, confidentiality, or strategic control.
This logic can also be observed in other areas of law. For instance, in labour law,[120] group actions allow claims for breaches of an employer’s legal or contractual obligations. However, they do not replace traditional trade union actions such as the “action syndicale”,[121] which enable unions to seek the cessation of unlawful conduct or to defend the collective interests of the profession, but do not provide individual compensation to employees.[122]
Victims also have the option to act elsewhere in Europe. For instance, victims of a cartel infringement, may decide to act in the Netherlands,[123] rather than bring a damages action in France because the opt-in mechanism means individuals must manifest themselves to be included in the group.[124]
An additional feature of the Group Action Law is that designated Civil Tribunals have exclusive jurisdiction to deal with groups actions, rather than commercial ones.[125] This centralisation may improve consistency and therefore justify a group action rather than an assignment of claims.
For instance, following the “cartel des compotes” decision of the French Competition Authority,[126] Commercial Tribunals in Paris, Lyon and Marseille adopted different approaches in comparable actions, leading to divergent assessments of harm and quantum.[127]
By contrast, the designation of specialised Civil Tribunals may reduce such discrepancies. They already handle complex damages claims, particularly in areas such as personal injury.[128] They may therefore be better equipped to assess economic harm in competition cases.
One limit is that for competition law follow-on action, the competent Tribunal is likely to be bound by the findings of the prior infringement decision, in particular as regards the existence and scope of the infringement. The number of damages awarded could therefore be limited by the prior decision.141
The Group Action Law does not fundamentally transform private enforcement, but it makes collective redress more accessible. As a result, group actions are likely to become a regular feature of litigation.
B. Economically Viable Group Actions
If the Group Action Law is to function in practice, TPLF is indispensable.[129]
The express recognition of TPLF is one of the most important aspects of the Group Action Law as it directly addresses a key limitation of the Hamon Law: the absence of a viable economic model for long, document-heavy, expert-driven actions.[130]
Group actions are viable because they can be funded. Damages actions for small claims in quantum but with many victims are therefore made possible where individual actions would not be profitable.[131] In this respect, the availability of TPLF alters the cost-benefit analysis for potential victims wishing to initiate a group action. [132]
By externalising a significant share of litigation costs and risks, TPLF makes participation in group actions economically viable, particularly where individual claims would otherwise be too small to justify standalone proceedings.[133]
For instance, for anticompetitive practices, damages actions typically require complex economic analysis, the quantification of loss, and detailed assessments of pass-on and causation. Without adequate funding, these constraints may deter victims from bringing claims altogether.[134]
Although TPLF is subject to transparency requirements under Decree No. 2025-1191, these do not appear sufficient to discourage TPLF in practice.[135] This decree does not require full disclosure of the complete TPLF agreements, as it only refers to “key contractual terms”.[136]
This transparency requirement may nonetheless have strategic implications. For instance, defendants may seek to raise objections including allegations of conflicts of interest or challenges to admissibility.[137] More broadly, transparency may affect settlement dynamics, as it provides defendants with partial visibility over the claimant’s financial capacity and room for negotiation.
However, the Group Action Law remains relatively permissive. It does not impose caps on returns, nor does it subject funders to specific requirements in terms of capital adequacy, registration, or supervision.[138] Transparency therefore does not constitute a barrier to funding, although funding agreements must be carefully drafted to avoid unnecessary admissibility challenges.[139]
As a result, TPLF is likely to develop because it allows claims to be sustained over time. For instance, damages actions are lengthy and resources intensive. This results in prolonged exposure for victims who must be able to sustain extended proceedings, starting with creating an association, getting it approved, then waiting for the two phases of a damages action.[140]
For anticompetitive infringements, this is especially true as claimants will have to wait for a prior infringement decision by a competition authority or a court to act.[141] Once the infringement has been established, the collective action can focus on causation, pass-on, quantum, and the identification of victims, thereby reducing evidentiary uncertainty.
Overall, the Group Action Law makes litigation more economically viable and increases the likelihood of claimants bringing group actions. It enables funded claims to be sustained over time thereby increasing the potential exposure of defendants.
C. Stronger Settlement Pressure and Increased Exposure
The Group Action Law is likely to increase settlement pressure and change the position of defendants.
Group actions as set out by the Group Action Law remain different from US-style class actions.[142] Defendants do not face punitive or treble damages under which claimants may recover three times the amount of their actual loss in antitrust litigation.[143]
However, the Group Action Law brings French group actions closer to such deterrence-oriented mechanisms.
Firstly, the introduction of an opt-in system facilitates the aggregation of claims on an unprecedented scale, no longer limited to consumer-law claims. Multiple losses can therefore be combined into a single coordinated action, significantly increasing defendants’ potential exposure and enhancing victims’ bargaining power.
For instance, instead of facing multiple individual claims following a cartel, claims may be aggregated into a single coordinated action, thereby increasing the total value at stake.
Secondly, and most importantly, the defendant may face a Civil Fine which may reach up to five times the undue gain obtained thanks to the infringement. The possibility of requesting the Public Prosecutor to ask the competent Tribunal to impose a Civil Fine introduces a sanction that goes beyond the mere compensation of victims’ harm.
Unlike compensatory damages, the Civil Fine serves a punitive and deterrent function and creates an additional financial risk that defendants are likely to seek to avoid. As the Civil Fine cannot be insured, it is likely to become a significant factor in defendants’ compliance and litigation strategies and encourage settlements.
While neither the opt-in system nor the Civil Fine is equivalent to treble damages, their combined effect is to increase the financial consequences of unlawful conduct and to strengthen the deterrent function of private enforcement.
More broadly, regulatory and judicial decisions are likely to operate as “claim triggers”. Once a precedent in a similar case establishes the defendant’s liability, claimants may initiate a group action, thereby amplifying litigation risk for defendants.
For instance, the French consumer association CLCV has launched a group action on behalf of consumers based on the European Commission’s Spotify v. Apple decision.[144] Although initially consumer-focused, the same theory of harm may be replicated in BtoB contexts, demonstrating the scalability of group actions. A finding of infringement upstream may therefore give rise to successive claims by direct purchasers, indirect purchasers, or other affected operators relying on the same factual and legal basis.
Although France remains an opt-in jurisdiction, its wider scope—including legal entities—may encourage forum shopping and increase companies’ exposure compared to more restrictive regimes, such as Germany’s where only SMEs can be compensated.[145]
This effect is reinforced by the opening of the mechanism to EU qualified entities.[146] Foreign organisations may bring claims in France where divergences in funding regimes make it more attractive. In particular, as TPLF is permitted in France but restricted in some Member States, EU qualified entities may choose to litigate in France on behalf of claimants located elsewhere, thereby increasing defendants’ exposure.
The defendant will therefore face more reputational pressure. Group actions are likely to attract media attention, while the transparency mechanisms introduced by the Group Action Law, including publicity measures and the creation of a register of ongoing actions, may facilitate public exposure. [147] This visibility can encourage additional victims to come forward and allow similar theories of harm to be replicated across sectors.
As observed in Italy in an action brought against the Dutch company Philips, the mere existence of a credible collective mechanism may encourage defendants to engage earlier and more proactively in settlement discussions.[148] Two associations alleged that Philips’ respirators released harmful chemicals due to degrading PE-PUR foam, affecting more than 1.2 million users and giving rise to claims estimated at €84 billion. This action followed a USD 1.1 billion settlement in the United States in which Philips did not admit liability, illustrating that collective actions may generate independent legal exposure across jurisdictions, even after prior settlements.[149] For anticompetitive practices, settlement pressure may be particularly significant as a damages action can only be initiated after the infringement itself is no longer open to dispute.
Taken together, these elements suggest that the Group Action Law may significantly increase litigation exposure for companies, not only by facilitating domestic claims but also by positioning France as an attractive forum for cross-border group actions.
Conclusion: a real or limited surge in group actions in France?
While certain barriers remain, the main structural constraints of the Hamon Law have largely been removed. Group actions are not only accessible to consumers but also to companies, which creates the conditions for a more frequent use of the mechanism. It is therefore likely that, once stakeholders—particularly companies, associations, and funders—fully grasp the potential of the Group Action Law, and once its practical implementation is clarified, the number of group actions will increase significantly in France.
* Marc Barennes is a partner with Geradin Partners and a member of the Paris and New York bars. He is involved in bringing several collective actions in France.
** Agathe Missakian is an élève-avocat (trainee lawyer) with Geradin Partners.
[1] Law No. 2025-391 of 30 April 2025, related to various provisions for adaptation to European Union law in economic, financial, environmental, energy, transport, health, and free movement of persons matters, Link.
[2] Decrees No. 2025-653 of 16 July 2025, Link, No. 2025-734 of 30 July 2025, Link, and No. 2025-1191 of 10 December 2025, Link.
[3] Law No. 2014-344 of 17 March 2014 related to consumers (the Hamon Law), Link.
[4] Directive EU No. 2020/1828 of the European Parliament and of the Council of 25 November 2020 on representative actions for the protection of the collective interests of consumers, Link.
[5] Law No. 2016-41 of 26 January 2016 on the modernization of the French health-care system, Link, Law No. 2016-1547 of 18 November 2016 on the modernization of justice in the twenty-first century, Link, and Law No. 2018-1021 of 23 November 2018 on the evolution of housing, urban planning, and digital technology, Link.
[6] Council of State (“Conseil d’État”), No. 406517 of 9 February 2023, Avis sur une proposition de loi relative au régime juridique des actions de groupe, Link.
[7] V. Legrand, Droit de la consommation : a‑t‑on sauvé l’action de groupe?, Actu‑Juridique, 28 May 2025, Link; and National Assembly, Report No. 3085, P. Gosselin and L. Vichnievsky, 11 June 2020, Rapport sur le bilan et les perspectives des actions de groupe, Link.
[8] National Assembly, Report No. 1198 of 1 April 2025, Link; contra M. Lartigue, Le CNB veut replacer l’avocat au cœur de l’action de groupe, Gazette du Palais, No. 445, 14 February 2023, Link.
[9] Senate, Proposition de loi relative au régime juridique des actions de groupe, 6 February 2024, Link.
[10] The Group Action Law consists of a single article 16 with seventeen sub parts.
[11] Ministerial Guidance (“Circulaire”), No. CIV/09/2025 of 1 August 2025, Link, and Decree No. 2025-734 of 30 July 2025, op. cited 2.
[12] Article L. 1143-1 Public Health Code, Link.
[13] Article L. 142-2 Environnement Code, Link.
[14] Article L. 1134-6 Labour Code, Link.
[15] Law No. 2018-1021 of 23 November 2018 on the evolution of housing, urban planning, and digital technology, Link.
[16] Law No. 2016-1547 of 18 November 2016 on the modernization of justice in the twenty-first century, Link.
[17] Senate, Proposition de loi relative au régime juridique des actions de groupe, 6 February 2024, Link.
[18] Article 16-I-A Group Action Law, op. cited 1.
[19] Article 16-I-A Group Action Law, op. cited 1.
[20] National Assembly, Report No. 1198 of 1 April 2025, Link.
[21] Article L. 811-1 Consumer Code, Link. Consumer is meant here as “natural persons acting outside their professional or commercial activities” as per the introductory article of the Consumer Code, Link.
[22] These rules were set out in Law No. 2016-41 of 26 January 2016 on the modernization of the French health-care system, Law No. 2016-1547 of 18 November 2016 on the modernization of justice in the twenty-first century, and Law No. 2018-1021 of 23 November 2018 on the evolution of housing, urban planning, and digital technology, op. cited 7. In public health law, standing was granted to approved associations within the healthcare system. Under environmental law, standing extended to associations whose statutory purpose included the defence of victims of bodily injury or the protection of their members’ economic interests, as well as to approved environmental protection associations. In data protection law, actions could be brought by associations duly registered for at least five years whose statutory purpose included the protection of privacy or personal data, in addition to nationally representative and approved consumer defence associations and representative trade unions of employees or civil servants. In anti-discrimination matters, standing was conferred on associations duly registered for at least five years and active in combating discrimination or working in the field of disability, as well as on associations duly registered for at least five years whose statutory purpose included the defence of an interest adversely affected by the alleged discrimination.
[23] Ibid, op. cited 10.
[24] Ibid, op. cited 25. Of the 39 group actions initiated, most are still pending and only five have resulted in a settlement.
[25] M. Barennes, The bundling of claims in cartel damages litigation – Germany v. Netherlands v. UK v. Italy v. France, Bureau Brandeis, 24 January 2022, Link.
[26] Article 16-I-C, Group Action Law, op. cited 1. Injunction actions can be initiated by two more claimants, namely the Public Prosecutor and non-approved associations.
[27] S. Amrani-Mekki, Il faut admettre le procès pilote, Le Monde du Droit, 9 December 2025, Link.
[28] Article 16-I-A §2 Group Action Law, op. cited 1.
[29] Article 16-I-C, Group Action Law, op. cited 1.
[30] Article 16-I-C-4 Group Action Law, op. cited 1.The DGCCRF can grant approval to any duly registered non-profit association that (i) has carried out effective and public activities for at least twelve consecutive months, (ii) pursues a statutory purpose related to the interests defended, (iii) is not subject to insolvency proceedings, (iv) operates independently from external economic interests, and (v) transparently discloses its purpose, funding, and governance. The DGCCRF has 3 months to reply and grant approval. The approval is granted for 5 years.
[31] Article 16-I-C-2 Group Action Law, op. cited 1. The conditions are for the association: to be a duly registered non-profit association that (i) has been regularly declared for at least two years, (ii) has carried out effective and public activities for twenty-four consecutive months, and (iii) pursues, as a statutory purpose, the defence of the interests at stake.
[32] Article 6 RA Directive transposed in Article 16-I-C-3 Group Action Law, op. cited 1.
[33] Article 16-X-A Group Action Law, op. cited 1.
[34] Unions can act if they are representative either at firm level (Article L.2122-1 Labour Code), at sectoral branch level (Article L.2122-5 Labour Code), or at national and interprofessional level (Article L-2122-9 Labour Code), as per Article 16-I-F Group Action Law, op. cited 1. The “representativeness of unions is determined according to cumulative criteria, including respect for republican values, independence, financial transparency, a minimum of two years’ existence within the relevant professional and geographic scope (…), the level of support in accordance with Articles L. 2122-1, L. 2122-5, L. 2122-6, and L. 2122-9, influence primarily measured by activity and experience, and membership numbers and contributions,” as per Article L. 2121-1 Labour Code, Link. A class action may also be brought by representative unions, and by representative unions of Judges of the Civil order, within the meaning of Article L. 221‑1 of the General Public Service Code, Link.
[35] Article 16-I-F Group Action Law, op. cited 1.
[36] Article 16-I-A §2 Group Action Law, op. cited 1. In practice, many European Member States also restrict standing, but some impose less stringent limitations. For example, under the Dutch class action law, a foundation (“Stichting”) can bring opt-out collective damages claims on behalf of a group. Article 3:305:a Dutch Civil Code, Link.
[37] Article 2011 French Civil Code, Link. See, op. cited 27.
[38] Article 16-I-C-4 § 2 Group Action Law, op. cited 1. See Part II on the limitations related to anticompetitive infringements.
[39] Article 16-I-C-4 Group Action Law, op. cited 1.
[40] Article 16-I-A Group Action Law, op. cited 1.
[41] Ibid, op. cited 5, Law No. 2016-41 of 26 January 2016 on the modernization of the French health-care system, Link, Law No. 2016-1547 of 18 November 2016 on the modernization of justice in the twenty-first century, Link, and Law No. 2018-1021 of 23 November 2018 on the evolution of housing, urban planning, and digital technology, Link.
[42] Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence and amending Regulations (EC) No 300/2008, (EU) No. 167/2013, (EU) No. 168/2013, (EU) 2018/858, (EU) 2018/1139 and (EU) 2019/2144 and Directives 2014/90/EU, (EU) 2016/797 and (EU) 2020/1828 (Artificial Intelligence Act), Link.
[43] Article 16-I-A Group Action Law, op. cited 1. In our view, obligations arising from EU regulations fall within the notion of “any breach of a contractual or legal obligation”, given that EU regulations are directly applicable in the legal orders of Member States.
[44] Health products mentioned in Section II of Article L. 5311-1 Public Health Code, Link. Health-related group actions apply only to breaches by a manufacturer or supplier of health products -listed by the Public Health Code- of their legal or contractual obligations may be subject to a group action.
[45] Article 16-VIII Group Action Law, op. cited 1.
[46] Article 16-I-A Group Action Law, op. cited 1, by defining actionable conduct as “any breach of a contractual or legal obligation”.
[47] Namely consumer law, public health, discrimination, data protection, and environmental law, op. cited 10.
[48] Article L. 623-1 Consumer Code, Link.
[49] Paris Civil Tribunal, UFC c/ Natixis Asset Management, 3 April. 2024, No. 18/02914, Link. Groupe action brought by UFC Que Choisir against Natixis, where the financial product at issue was deemed not to qualify as a “service”.
[50] Article 16-I-A Group Action Law, op. cited 1. This is regardless of the type of violation or the identity of the defendant. The Group Action Law applies to “the same breach”, or “a breach of the same nature”. The terms “of the same nature” could imply a diversity of breaches or a potential repetition.
[51] The term professional activities could exclude certain types of agreements such as Securities or some prudential matters. See, T. De Bovis, Class action in the USA vs. EU representative actions: A cultural clash, 1 September 2025, Concurrences No. 9-2025, No. 128538, Link.
[52] Article 16-I-A Group Action Law, op. cited 1.
[53] Ibid, op. cited 50.
[54] Ibid, op. cited 50.
[55] Article 16-V Group Action Law, op. cited 1. Administrative tribunals have jurisdiction, following the same set of rules. The term “Tribunal” hereafter to both civil and administrative order.
[56] Article 16-F Group Action Law, op. cited 1. Prior to bringing a group action based on a breach of the Labour Code, the claimant must formally request the employer to cease the alleged breach. The employer must inform the works council and unions within one month and, upon request, enter into discussions to remedy the situation. The group action may be filed six months after the request or upon employer’s refusal.
[57] Article L. 211-15 Civil Organisation Code, Link. Any non-designated tribunal must declare itself incompetent (Article 76 Civil Procedure Code, “CPC”), if the defendant is a public person as the administrative order has jurisdiction under the same rules. If the issue involves two civil tribunals courts, it is no longer an obligation (Article 77 CPC), Link.
[58] A. Predal, A. Riquier, Actions de groupe et pratiques anticoncurrentielles, Lamy Concurrence, 29 January 2026, Link. They argue that the positive impact courts specialization had for competition law will be similar for group action under the Group Action Law.
[59] Article 849 Civil Procedure Code (“CPC”) unchanged by Law the Group Action Law and its implementing decrees.
[60] Article 16-I-G Group Action Law, op. cited 1.
[61] Article L.623‑1 Consumer Code, op. cited 50, allowed only damages actions in consumer law matters. A similar provision but not identical, allows consumer associations to request that a contractual term be declared null and void in all similar contracts concluded with the same professional and to require that consumers be informed at the professional’s expense. Article L.621‑8 § 2 Consumer Code, Link.
[62] Article 849-11 CPC, Link. The writ of summons must contain individualized cases demonstrating that at least more than one victim is affected, so that the Tribunal can then define a group at a later stage. The writ of summons must contain individual cases to support the claim otherwise the action may be declared inadmissible.
[63] Article L. 623-1 Consumer Code, op. cited 50.
[64] Article 16-III-A-1 Group Action Law, op. cited 1.
[65] Article 16-III-A-1 Group Action Law, op. cited 1. Group membership operates under an opt-in system: individuals must actively apply for compensation, either directly to the defendant or through the claimant, who is thereby empowered to act on their behalf.
[66] Article 16-III-A-1 Group Action Law, op. cited 1.
[67] Article 16-III-A-2 Group Action Law, op. cited 1. The competent Tribunal mandates the claimant to represent the members who have opt-in the group, but they can rather choose to seek damages directly from the defendant.
[68] Article 16-III-A-1 Group Action Law, op. cited 1. The Group Action Law excludes bodily injuries from this procedure.
[69] Article 16-III-B-2 Group Action Law, op. cited 1. The Tribunal must certify this agreement (‘homologation”). It can refuse to do so if the interests of the parties and group members appear insufficiently protected and may refer the parties back to negotiations for a further period of two months.
[70] Ibid, op. cited 70.
[71] Article 16-III-B-2 Group Action Law, op. cited 1. A civil fine of up to 50,000 euros may be imposed on either the claimant or the defendant if they have, in a delaying or abusive manner.
[72] Article 16-III-B-2 Group Action Law, op. cited 1. The judgement suspends the statute of limitations for individual claims.
[73] Article 16-III-A-3 Group Action Law, op. cited 1
[74] Ibid, op. cited 70, See Health-Products carve-out.
[75] Article 16-VII Group Action Law, op. cited 1. The Group Action Law mentions“[une décision qui] n’est plus susceptible de recours pour la partie relative à l’établissement des manquements”.
[76] CLCV, Communiqué de presse, 24 November 2025, Link. See comment in A. Predal, A. Riquier, Actions de groupe et pratiques anticoncurrentielles, Lamy Concurrence, 29 January 2026, Link. They argue that since the European Commission’s decision is under appeal before the General Court of the European Union, the action is unlikely to be successful in the short term before the European Court of Justice issues a ruling on the establishment of the infringements.
[77] Article L.623‑1 Consumer Code, Link, allowed only damages actions. A similar provision, Article L.621‑8 § 2 Consumer Code, Link, allows consumer associations to request that a clause be declared null and void in all similar contracts concluded with the same professional and to require that consumers be informed at the professional’s expense.
[78] Article 849-11 CPC, Link. Op. cited 78.
[79] M. J. Azar Baud, Le renouveau de l’action de groupe : entre ambitions réformatrices et échecs structurels, RTD S, No. 12, 10 December 2025, Link. The Hamon Law did not require the claimant to prove such an intent at the admissibility stage. We understand this to mean simply that the defendant will not be allowed to raise this specific point in order to reject the claim at the outset.
[80] Article 16-I-A Group Action Law, op. cited 1.
[81] Association Antoine Alléno, Communiqué de presse, 21 April 2026, Link.
[82] Le Club des juristes, Pour un traitement rationnel des litiges sériels – De l’action de groupe au procès pilote, 10 December 2025, Link.
[83] Article 16-II-B Group Action Law, op. cited 1. More specifically, the juge de la mise en état, (the “Case-Management Judge”).
[84] Article 16-II Group Action Law, op. cited 1.
[85] C. Lèguevaques, Encore un effort pour doter la France d’une véritable « class action » efficace, Actu-Juridique, 23 March 2023, Link.
[86] Article 16-I-G Group Action Law, op cited 1 and 849-2-1 CPC, Link. For instance, a third-party litigation funder.
[87] Article 16-II Group Action Law, op. cited 1. The sums of which are allocated to a fund dedicated to financing group actions.
[88] Article 16-IX Group Action Law, op. cited 1. The limitation period resumes, for a period no shorter than six months, only once the injunction decision becomes final or any settlement agreement is approved.
[89] Article 16-VII Group Action Law, op. cited 1.
[90] Article 16-VII Group Action Law, op. cited 1. See Mathilde Cayot, La “nouvelle” action de groupe “concurrence”, chronique d’un échec annoncé ?, 1er décembre 2025, Concurrences No. 12-2025, Link.
[91] National Assembly, No. 3085, P. Gosselin et L. Vichnievsky, op. cited 24, mentions states that the State allocation went from EUR 3.64M in 2014, to EUR 2.83M in 2019. It also mentions that six associations had declared that they lacked proper funding.
[92] European Legal Institute, Principles of ELI regarding third-party litigation funding, 2021, Link. TPLF is defined by the European Legal Institute as “an arrangement whereby a third party, that is a person or entity who has no other connection to the dispute, finances some or all of the legal costs of a party to the dispute being disputed in litigation or arbitration in exchange for a share (whether fixed or by way of percentage) of the proceeds of the successful claim.”
[93] Association Professionnelle de Réassurance Française (APREF), Action de groupe, October 2025, Link. Class actions already carry a high degree of legal uncertainty, which makes any limitation on the recoverability of funder remuneration a challenge. Op. cited 97.
[94] A “question to the government” in December 2022, mentioned a total budget for all 15 approved associations of less than EUR 1.4M for 2022, Link.
[95] European Justice Forum, Opinions on the French decree implementing the 2026 class action regime, 20 March 2026, Link.
[96] Article 16-I-D Group Action Law, op. cited 1. For example, it is strictly prohibited for a third-party funder to be a direct competitor of the defendant.
[97] M. Barennes, M. Sousa Ferro, How to choose a litigation funder: A funding seeker’s perspective. Concurrences No. 2-2023, Link.
[99] Ibid, op. cited 95.
[100] Decree No. 2025-1191 of 10 December 2025, op. cited 2, see Article 2.
[101] Decree No. 2025-1191 of 10 December 2025, op. cited 2.
[102] Ibid, op. cited 112, namely, name, registered office, and identification number (RCS or equivalent).
[103] European Justice Forum, op. cited 95.
[104] N. Crouy-Fournier, L’entrée de la faute lucrative et sa sanction confiscatoire dans le Code civil : une innovation courageuse, JCP G, No. 36, LexisNexis, 2025, p. 1449, Link.
[105] Ibid, op. cited 104.
[106] Article 1254 Civil Code, Link. The Civil Fine can be requested only for actions in which the event giving rise to the defendant’s liability occurred after the 3 May 2025. Article 16-X-F Group Action Law, op. cited 1.
[107] G. Loisseau, R. Olivier, Une nouvelle génération d’action de groupe en droit du travail, RJS 1/26, CMS, January 2026, Link.
[108] National Assembly, No. 3085, 11 June 2020, op. cited 24.
[109] Article 16-II Group Action Law, op. cited 1.
[110] S. Amrani Mekki, Action de groupe : un moyen efficace de lutte contre le fléau du gaz hilarant ?, 24 April 2026, Link.
[111] Association Antoine Alléno, Communiqué de presse, 21 April 2026, Link.
[112] Ibid, op.cited 109.
[113] A. Fabre, L’action de groupe en droit du travail : nouveau départ ? : Lexbase Social, October 2025, No. 1016, Link.
[114] Article 1321 Civil Code, op. cited 25. An assignment of claim (“cession de créances”) allows victims to transfer their rights to compensation to a legal vehicle that brings proceedings in its own name. This mechanism enables rapid implementation, without requiring administrative approval or a specific representative structure, while offering confidentiality and attractiveness for TPLF.
[115] Ibid, op. cited 84.
[116] Article16-III Group Action Law, op. cited 1.
[117] R. Morenon, Group action in France, a tool for defending you rights collectively, March 2026, Link.
[118] Ibid, op. cited 25.
[119] Ibid, op. cited 116.
[120] Ibid, op. cited 112.
[121] Article L. 2132-3, Labour Code, Link. Actions syndicales allow trade unions to bring proceedings to stop employer misconduct and/or to claim damages in the interest of the profession, but do not permit unions to obtain individual remedies on behalf of employees.actions syndicales L.2132-3, Code du travail) which allow unions to stop employer misconduct and/or to claim damages for the “profession”, but they cannot provide individual remedies to employees.
[122] Ibid, op. cited 112.
[123] Wet afwikkeling massaschade in collectieve actie (“WAMCA”), 1 January 2020, Link. The WAMCA is a collective action mechanism which allows representative organisations to bring claims for damages on behalf of a group of affected parties. It includes an opt-out mechanism, meaning that individuals falling within the defined class are automatically included in the proceedings unless they expressly choose to exclude themselves within a specified period.
[124] Article16-III Group Action Law, op. cited 1.
[125] Ibid, op. cited 76.
[126] French Competition Authority, Decision 19-D-24, 18 December 2019, Link.
[127] Vertice, French courts ruled on two follow-on actions brought by Carrefour group, following the “Compote Cartel”, 26 January 2026, DLC, Link.
[128] Article L. 211-4-1 Code of Civil Organisation. See L. Vogel, Pourquoi l’action collective de l’Association des franchisés du groupe Carrefour n’aurait pas dû être rejetée et quelles solutions demeurent possibles?, May 2026, Link. In which they argue that arbitration clauses should not be enforceable against third parties to a contract such as an association under the Group Action Law in contrast with the precedent AFC v. Carrefour, Paris Court of Appeal, No. 25/12103, 13 May 2026.
[129] European Justice Forum, Opinions on the French decree implementing the 2026 class action regime, 20 March 2026, Link.
[130] Ibid, op. cited 10.
[131] Deminor, Litigation Financing – How Companies Can Enforce Their Legal Claims without Burdening the Balance Sheet. News & Insights, 18 December 2024,Link.
[132] M. Humphery-Jenner, Incentive Contracting in the shadow of litigation risk, Journal of Banking and Finance, No. 171, February 2025, Link. Group actions are likely to be pursued by business claims where potential compensation justifies the cost and risk of litigation
[133] AGEFI, l’industrie du financement du contentieux, January 2026. Link ; contra Global Post, Class Actions, 26 January 2026, Link.
[134] Ibid, op. cited 132.
[135] Decree No. 2025-1191 of 10 December 2025, see Article 2, op. cited 2.
[136] Ibid, op. cited 128.
[137] Osborne Clarke, New Potential Areas of Litigation in France Could Follow Directive (EU) 2020/1828 on Collective Redress, Osborne Clarke Insights, 4 November 2025, Link.
[138] Ibid, op. cited 110.
[139] See op. cited 60. A. Predal and A. Riquier argue that the publicity measure is too stringent.
[140] Article 16-VII Group Action Law, op. cited 1.
[141] Article 16-III Group Action Law, op. cited 1
[142] AGEFI, l’industrie du financement du contentieux, January 2026. Link ; contra Global Post, Class Actions, 26 January 2026, Link.
[143] This mechanism is primarily associated with U.S. antitrust law, where it serves both a compensatory and deterrent function by increasing the financial consequences of unlawful conduct. “The Antitrust Treble Damages Remedy,” William Mitchell Law Review 9, no. 2 (1983), Link.
[144] CLCV, Communiqué de presse, 24 November 2025, Link.
[145] Clyde & Co, New Law on Representative Actions in Germany, Insights, 17 October 2023, Link. Under the Verbraucherrechtedurchsetzungsgesetz, Only small businesses, that employ fewer than 10 people and whose annual turnover or annual balance sheet do not exceed EUR 2 million are treated as consumers which can opt-in.
[146] Article 16-I-X Group Action Law, op. cited 1.
[147] Article 16-IV Group Action Law, op. cited 1. A register of group actions is maintained on the Ministry of Justice website, listing all pending actions before judicial and administrative courts. It provides essential information, including the identity of parties, the nature of the alleged breach, the harm claimed, and elements demonstrating similarity among affected members.
[148] ADUSBEF and GJN filed a case against the Dutch company Phillips on 27 June 2024 in Milan, where Philips’ Head of Quality for Europe is based. CPAP Europe, Class Action, 27 June 2024, Link.
[149] Osborne Clarke, New Potential Areas of Litigation in France Could Follow Directive (EU) 2020/1828 on Collective Redress, Osborne Clarke Insights, 4 November 2025, Link.
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