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Exhibit 8.1 LIST OF SUBSIDIARIES OF VIVENDI UNIVERSAL As of December 31, 2004, 437 companies were consolidated or equity accounted Set forth below
are the names of certain of the subsidiaries which carry on a substantial portion of Vivendi
Universals lines of business. The names of various subsidiaries, including subsidiaries
conducting operating activities of Vivendi Universals various businesses domestically and
internationally, have been omitted. None of the foregoing omitted subsidiaries are considered to
be material in relation to Vivendi Universals statement of financial position and operations. Country ofIncorporationCanal+ GroupGroupe Canal+ S.A.
    
    FranceCanal+ S.A.
    
    FranceCanalSatellite S.A.
    
    FranceStudioCanal S.A.
    
    FranceMultiThématiques(a)
    
    FranceUniversal Music GroupUniversal Studios Holding I Corp.
    
    USAUniversal International Music B.V.
    
    NetherlandsUniversal Music (UK) Holdings Ltd.
    
    UKUniversal Entertainment GmbH
    
    GermanyUniversal Music K.K
    
    JapanUniversal Music France S.A.S.
    
    FranceUniversal Music Group, Inc.
    
    USAUMG Recordings, Inc.
    
    USAVivendi Universal Games
    
    USASFR Cegetel GroupSFR
    
    FranceCegetel S.A.S.(b)
    
    FranceMaroc Telecom S.A.(c)
    
    MoroccoMauritel
    
    MauritaniaNBC UniversalUniversal Studios Holding I Corp.
    
    USANBC Universal
    
    USAOtherVivendi Telecom International S.A.
    
    FranceElektrim Telekomunikacja(d)
    
    PolandVivendi Universal Publishing S.A.
    
    FranceUGC
    
    France
  (a)
    
    In February 2005, Canal+ Group and Lagardère Group ended their participation in
MultiThématiques (that is now owned 100% by Canal Group) and Lagardère Thématiques(b)
    
    In May 2005, Cegetel and Neuf telecom announced their merger plan to form Neuf Cegetel, which
will be 28% owned by SFR (corresponding to a 15.62% interest for Vivendi Universal through its
55.8% ownership in SFR) and equity-accounted. This transaction is subject to approval from
personnel representatives of both Neuf Telecom and Cegetel and from competition and regulatory
authorities.(c)
    
    As of December 31, 2004, Vivendi Universal owned a 35% interest in Maroc Telecom, the Kingdom
of Morocco holds 50.1% and the remaining 14.9% is held by private investors following an IPO which
led to the simultaneous listing of Maroc Telecom shares on the Casablanca and Paris stock exchanges
in December 2004. On November 18, 2004, Vivendi Universal and the Kingdom of Morocco agreed to the
acquisition by Vivendi Universal of 16% of Maroc Telecoms capital. Under the terms of the
agreement, Vivendi Universal acquired, indirectly through Société de Participation dans les
Télécommunications (100% subsidiary of Vivendi Universal), an additional 16% stake in Maroc
Telecom. This acquisition, completed on January 4, 2005, allows Vivendi Universal, a strategic
partner holding the operating control of Maroc Telecom since the beginning of 2001, to increase its
stake from 35% to 51% and, thus, to perpetuate its control over the company. The stake held by the
Kingdom of Morocco decreased from 50.1% to 34.1%.(d)
    
    Please refer to Item 18  Financial Statements  Note 7.3.