French HATVP Opens Register on Transparency of Foreign Influence Activities

Law no. 2024-850 of July 25, 2024, aimed at preventing foreign interference in France, entrusted the High Authority for Transparency in Public Life (HATVP) with the task of maintaining a register of foreign influence activities, which came into force on October 1, 2025. This system aims to enhance the transparency of foreign influence activities carried out in France.

France has strengthened its defenses against foreign interference by adopting the law of July 25, 2024 (the Law), which was supplemented by an implementing decree of July 31, 2025 (the Decree), designed to reinforce the protection of national sovereignty and the security of its institutions, as well as instituting penal sanctions in the event of non-compliance. 

The Law provides for the creation of a register on the transparency of foreign influence activities, accessible to the public from October 1, 2025, managed by the HATVP, and taking the form of the “Argos” teleservice. Persons acting on behalf of a foreign principal, with the exception of posted diplomats, must declare their activities influencing French politics. 

Scope of the Law

The Law provides for the establishment of a register aimed at regulating foreign influence activities and enhancing their identification.

The reporting obligations of the new register apply to natural persons or legal entities that:

• act on the instructions of, or at the request or under the direction or control of, a foreign principal; and
• carry out one or more actions intended to:
  • influence (a) public decision-making, in particular the content of a law, regulatory act, or individual decision; (b) the conduct of public policies at local or national level; or (c) the conduct of France’s European or foreign policy;Article 18-11-I of Law no. 2013-907 of October 11, 2013. or
  • promote the interests of the foreign principal or those of a foreign power.

Foreign principals listed in article 18-11-II of Law no. 2013-907 of October 11, 2013, are foreign powers (excluding European Union Member States), legal entities controlled or majority-financed by such a power, and foreign political parties (excluding those from European Union Member States). Duly authorized members of the diplomatic and consular staff stationed in France, as well as members of a foreign state, when acting within the scope of their duties, are expressly excluded from the scheme.

Article 18-11.-I. of the Law lists all types of influencing actions that fall within the scope of the Law,Article 18-11, I of Law no. 2013-907 of October 11, 2013. and more specifically includes actions designed to influence public decision-making, by: 

• coming into contact with certain elected officials or public decision-makers (e.g., declared candidates in a national or European election, the leader of a political party, ministers, ministerial advisors, the Head of State or members of parliament, as well as a former President of the Republic, a former member of the government, or a former deputy or a former senator within a period of five years from the end of such former deputy or former senator mandate or the cessation of their functions).Listed in Article 18-11, 1° of Law no. 2013-907 of October 11, 2013: “Member of the Government, Member of Parliament, Senator or their collaborators, as well as a former member of the Government, President of the Republic, Member of Parliament or Senator within five years from the end of their term or the cessation of their duties, a collaborator of the President of the Republic, a director general, secretary or member of a board or commission vested with sanctioning powers by an independent administrative authority or an independent public authority, any other person holding a position or performing duties at the discretion of the Government for which they were appointed by the Council of Ministers, holders of a position as president of a regional council, a public official appointed.” In contrast to the interest representative (lobbying) regime, (i) the list of actions corresponding to an entry into communication is broader, (ii) there is no criterion of initiative on the part of the foreign influence actor, and (iii) there is no minimum number of actions required to be subject to the registration and declaration obligation; and/or
• carrying out any communication action aimed at the public; and/or
• collecting funds or making payments without consideration.

Coordination With the Register of Interest Representatives

The same person may meet the conditions of being both a lobbyist and a foreign influence actor, in which case they must register in both registries.

When the same action falls under both regimes, a coordinationArticle 18-17 of Law no. 2013-907 of October 11, 2013. is provided by the legislator with the register of interest representatives, as the latter partially overlaps with that of foreign influence actors acting on behalf of a foreign principal. 

A person simultaneously covered by both registers is deemed to have fulfilled all their declaratory obligations once they have provided the information required by HATVP for the register on the transparency of foreign influence activities. 

In the event of failure to comply with the obligations to declare in the register of interest representatives and the register of foreign influence actors, the Law does not provide for a system of cumulative penalties, but for the exclusive application of the penalties provided for foreign influencers.

Establishment of the Register of Foreign Influence Activities

Starting October 1, 2025, registration in the register is mandatory within 15 working days of the first foreign influence activity.Decree no. 2025-733 of July 31, 2025 on the transparency of influencing activities carried out on behalf of a foreign principal.

Once registered, individuals must report on any foreign influence activities carried out since October 1, 2025, on a quarterly basis. The first activity reporting campaign began online on January 1, 2026, and covers actions carried out in the last quarter of 2025. 

This declaration applies to communications with a public decision-maker, communications aimed at the public, and fund-raising operations or payments without consideration. 

Finally, once a year, and within three months of the end of the financial year, the persons concerned must declare the number of people involved in lobbying activities, the profit generated by these activities for each foreign principal, and, depending on the type of action in question, declare certain additional information, in particular: 

• For communication with a public decision-maker:
  • indicate the surname, first name, and position of the persons contacted, as well as the date of contact;
  • specify the title, purpose or reference of the public decisions, or public policies on which the influencing actions focused;
  • describe the objective pursued by these influencing actions; and
  • indicate the total amount of expenditure incurred for these influencing actions, as well as the breakdown by foreign client.
• With regard to communication initiatives aimed at the public:
  • specify the type of influencing actions undertaken, with reference to the list annexed to the decree, and their completion date; and
  • give details of the information communicated during influencing actions and, where applicable, the types of documents distributed.
• For transactions involving the collection or payment of funds for no consideration:
  • provide a list of fundraising and fund disbursement operations, including the date and location of each operation;
  • indicate the total amount of payments or funds collected, and the breakdown by operation; and
  • for each unrequited payment of funds, list the beneficiaries of the payments, with additional details if the beneficiary is a natural or legal person.

Information on influencing activities remains public for a period of five years from the date of publication by the HATVP. The first annual declaration will take place from April 1, 2026.

HATVP Control Measures

Formal Notice and Penalty Payment

The HATVP ensures compliance with the obligations to be implemented; it therefore may, on its own initiative or following a report, give formal notice to any person for whom it finds serious grounds for believing that they fall within the scope of persons subject to declaration.Articles 8 and 9 of Decree no. 2025-733 of July 31, 2025. Such persons must submit, within one month, any information or document necessary for the HATVP to carry out its mission, without being able to invoke professional secrecy. The HATVP is also empowered to carry out on-site inspections at the business premises concerned, with the authorization of the liberties and detention judge of the Paris judicial court and in the presence of a judicial police officer. During these controls, its agents may demand and obtain the communication of any useful document, whatever its medium or location, in order to facilitate their control mission.Article 10 of Decree no. 2025-733 of July 31, 2025.

The person required to declare must submit their observations or come into compliance within the one-month notice period. If, at the end of this period, the situation has not been rectified, HATVP may, on its own initiative or following a report, send a formal notice to the person concerned, who then has two months to comply. 

If the person has not complied by the end of the deadline, HATVP may impose a fine of up to €1,000 per day, notified in the same way. After inviting the person to present their observations on the penalty payment, the HATVP will proceed with its liquidation, taking into account the person’s behavior and the circumstances of the case. The formal notice and payment of penalty may be made public by the HATVP.

Referral for Opinion

The HATVP can also be consulted on the qualification to be given to the activity of an individual or legal entity. The HATVP, or by delegation, its chairman, delivers its opinion within two months of receiving the information it has requested from the natural or legal person in question. This period may be extended by two months by decision of its chairman, after informing the referrer.

Penalties for Failure to Declare

Failure to comply with registration requirements can result in penalties of up to three years’ imprisonment and a €45,000 fine for individuals, and a €225,000 fine for companies. Additional penalties include exclusion from public contracts, prohibition from receiving public aid, or publication of the conviction.Article 18-16 of Law no. 2013-907 of October 11, 2013.