EUROPEAN COMMISSION Luxembourg, 13.7.2022 SWD(2022) 510 final COMMISSION STAFF WORKING DOCUMENT 2022 Rule of Law Report















Country Chapter on the rule of law situation in France Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2022 Rule of Law Report

















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Abstract A comprehensive consultation process took place to identify further reforms needed to address potential issues affecting the French justice system. In this context, the judiciary, in particular the High Council for the Judiciary, made several calls for reforms, including on the accountability and protection of magistrates, and for an increase in human resources beyond the additional resources already allocated. The length of proceedings in the justice system increased, and the Ministry of Justice is evaluating further needs. The decision of the Minister of Justice to open administrative investigations against several magistrates for alleged violations of ethical obligations is being examined in Court. While some digital tools at the disposal of litigants and justice professionals continue being deployed successfully, the key ongoing projects to increase the digitalisation of civil and criminal justice have encountered difficulties in their implementation. As regards lawyers, the Law for trust in the justice system created new safeguards for professional secrecy, ethics and disciplinary procedures. The conviction of high-level corruption cases continues to bring tangible results despite challenges linked to the limited resources as well as structural weaknesses. The national anticorruption plan for 2020-2022 continues to be implemented. Rules on conflict of interest are in place and a new law was adopted for the protection of whistleblowers. A regulation of lobbying is in place, but significant concerns remain in relation to the application of these rules to all types of lobbying actors. Asset declarations are disclosed and regularly verified. The human resources of the National Commission on Campaign Accounts and Political Financing continues to be insufficient compared to its workload. The measures introduced in public procurement during the COVID-19 pandemic remain in place. France has a strong legal framework guaranteeing media freedom and pluralism, mainly due to safeguards stemming both from the Constitution and from legislation. A new independent authority - Autorité de régulation de la communication audiovisuelle et numérique (ARCOM) has been created from the merger of the Conseil supérieur de l’audiovisuel (CSA) and the online copyright authority, the Haute autorité pour la diffusion des oeuvres et la protection des droits sur internet (HADOPI), with increased powers over the entire field of audiovisual and digital content. Legal and structural safeguards ensure the independence of the French public service media. The Government has taken measures to address the increasing attacks and threats against journalists during protests or demonstrations. The persisting issue of horizontal and cross-media concentration has been examined by a Senate Commission of enquiry, which suggested a substantive revision of the existing legislation to preserve freedom of information. Challenges persist regarding the transparency of complex media ownership structures. The practice of nationwide public consultations was further reinforced and extended to other fields, including the justice system. Accelerated procedures for the adoption of laws continued to be used regularly, including for laws with a significant impact on individual freedoms. The COVID-19 pandemic emergency regime has been extended until July 2022, while the Constitutional Council defined the limits of the executive and legislative powers in this context. Independent authorities issued opinions regarding the impact of laws adopted to manage crisis situations on individual freedoms. New laws have been adopted to improve the financial environment for civil society organisations. The Law on republican principles entered into force and a number of stakeholders raised concerns as regards its potential impact on the civic space. Recommendations It is recommended to France to: ·Continue efforts to complete ongoing projects aimed at full digitalisation of civil and criminal court proceedings. ·Continue efforts to ensure adequate human resources for the justice system, including to improve its efficiency, taking into account European standards on resources for the justice system. ·Continue the effective investigation, prosecution and sanctioning of high-level corruption offences. ·Ensure that rules on lobbying activities are consistently applied to all relevant actors, including at top executive level. ·Enhance the transparency of media ownership, in particular regarding complex shareholding structures, building on the existing legal safeguards. I.Justice System The justice system is composed of two autonomous branches of courts: ordinary courts with jurisdiction in civil and criminal cases on the one hand, and administrative courts on the other hand. Both branches consist of three levels of courts, with first instance courts, courts of appeal and an upper court (the Court of Cassation and the Council of State, respectively). The Council of State also has an advisory branch that provides opinions on draft legislation, and is tasked with the management of the administrative tribunals and courts of appeal. The High Council for the Judiciary, half of whose members are magistrates elected by their peers, plays an important role in safeguarding judicial independence. It nominates candidates for top judicial functions and, as regards the appointment of judges by the Minister of Justice, issues binding opinions . The prosecution service is part of the judiciary, and falls under the authority of the Minister of Justice. The latter can give general instructions on prosecution policy but is barred from giving instructions in individual cases. In addition, the Constitutional Council is competent to verify the constitutionality of laws. France participates in the European Public Prosecutor’s Office (EPPO). Lawyers are represented by various bar associations throughout France. Independence The level of perceived judicial independence in France continues to be average among the general public and is now high among companies. Overall, 56% of the general population and 61% of companies perceive the level of independence of courts and judges to be ‘fairly or very good’ in 2022 . According to data in the 2022 EU Justice Scoreboard, no clear trend can be identified in the evolution of the perceived level of independence since 2016. The perceived judicial independence among the general public has slightly decreased in comparison with 2021 (57%), but it is higher than in 2016 (54%). The perceived judicial independence among companies has increased in comparison with 2021 (58%), as well as with 2016 (59%). The High Council for the Judiciary called for reforms to increase the accountability and protection of magistrates. On 24 September 2021, the plenary of the High Council submitted the opinion requested by the President of the Republic on the liability and protection of magistrates. It made 30 proposals around four objectives: putting ethics at the heart of the judicial function, promoting the detection of disciplinary misconduct, improving the conduct of disciplinary proceedings and the scale of sanctions, and strengthening the personal and functional protection of magistrates. Some proposals reiterate the need to adopt constitutional reforms initiated several times in the past but without success. The proposed constitutional amendments would notably transfer the power to decide on disciplinary matters regarding prosecutors from the Minister of Justice to the High Council and align the conditions for the appointment of prosecutors with those applicable to judges, thus making the opinion of the High Council binding on the Minister of Justice. On this aspect, the opinion of the High Council for the Judiciary converges with recommendations from the Group of States against Corruption (GRECO) and recent proposals by the National Conference of Prosecutors, which called for a reform of the statute of prosecutors to increase their independence. In a decision of 14 September 2021, the Constitutional Council declared constitutional the provisions allowing general prosecutors to communicate specific reports relating to ongoing legal proceedings to the Minister of Justice, as the latter may not issue any instruction to public prosecutors in individual cases even when he or she requests or receives such specific reports. In 2020 , the Minister of Justice decided, on the recommendation of his administration, to order administrative investigations against several magistrates for alleged breaches of ethical obligations, and this decision is currently being examined by the Court of Justice of the Republic (CJR). Three magistrates’ associations had filed a complaint against the Minister of Justice, alleging a conflict of interest related to his previous professional activity as a lawyer. The Minister of Justice transferred to the Prime Minister the competence to act in cases in which he was previously involved as a lawyer. On 16 July 2021, following a hearing, the CJR indicted the Minister of Justice for illegal taking of interest. The Minister of Justice was heard before the CJR and exercised his right to remain silent, as he considered that the investigation methods were not impartial . The case is still pending. The General Prosecutor decided not to refer to the CJR a third complaint lodged by a magistrates’ trade union regarding an investigation into the management of a Court of Appeal . A Law for trust in the justice system introduced new safeguards for professional secrecy, ethics and disciplinary procedures concerning lawyers. The new law adopted in December 2021 supplements the Code of Criminal Procedure by reaffirming the protection of professional secrecy both for defence and counsel activities. In particular, a judge can order a search of premises of a law firm or of a lawyer’s residence on the condition that there is a reasonable ground to suspect that the lawyer has committed or attempted to commit the offence which is the subject of the proceedings. Furthermore, the magistrate carrying out the search must ensure that the investigation does not interfere with the free exercise of the profession of lawyer and that no document pertaining to the exercise of the rights of the defence and covered by the obligation of professional secrecy is seized. The most important proposals made by the National Council of Bars, and particularly the wish to extend the provisions on professional secrecy to the counsel activities of lawyers , were included in the final version of the law. This is also in line with the preoccupations of lawyers at European level on the protection of professional secrecy. As regards disciplinary procedures, the new provisions offer more guarantees to the parties involved and leave more room for conciliation. The Disciplinary Board becomes a court, chaired by a judge in some cases. With regard to claims brought by individuals, where the nature of the complaint so permits, a conciliation procedure may be organised between the parties, with the participation of at least one lawyer. To prevent disciplinary offences, Article 42 of the law foresees the creation of a code of ethics for lawyers prepared by the National Council of Bars, thus maintaining the self-regulation of the profession as regards ethical duties.

Quality The Court of Audit highlighted difficulties in the implementation of key projects to increase the digitalisation of civil and criminal justice. Despite efforts to improve digitalisation of the justice system and some progress already made, room for improvement remains regarding the use of digital tools both within courts and the prosecution service and in electronic communication with users. In a report, presented to the Senate on 26 January 2022, and based on an assessment of the situation in spring 2021, the Court of Audit describes the delays and strategic issues encountered in the implementation of the plan to digitalise justice initiated in 2018 and makes a number of recommendations to make it more effective. The Court of Audit assesses that, at this stage, one year before the end of its implementation, the digital transformation plan started in 2018 brought mixed results and that not all objectives will be achieved. In particular, the Court of Audit noted that the key projects for digitalisation of justice, namely the Procédure pénale numérique (digital criminal procedure), Cassiopée, which is central to the digital treatment of criminal procedures, and Portalis, an ambitious project to digitalise all stages of the civil procedure , have accumulated delays and budget overruns. The Court of Audit suggests improving the governance of structuring projects to avoid delays in their implementation. The Ministry of Justice endorsed in large part the findings of the report and has already taken some measures to improve the governance of projects, for instance by systematising cost-benefit analyses. Since the analysis of the Court of Audit, other improvements have been made as regards the digital criminal procedure, for instance by relieving court officials of burdensome registration tasks and by allowing for digital communication with lawyers. However, further steps remain to be taken to follow up on the Court of Audit’s recommendations, in particular to centralise the overall monitoring of projects by reducing outsourcing, in particular project management functions, in order to retain control over the development of information systems. Digital tools at the disposal of litigants and justice professionals continue being deployed successfully. As mentioned in the 2021 Rule of Law Report, the deployment in legal aid offices of the Legal Aid Information System (SIAJ), which allows individuals to make a paperless application for legal aid, started in two pilot courts from March to October 2021 and is advancing at a steady pace. At the end of 2021, 30% of the courts were equipped, and it is planned that 90% of the courts will have the system implemented by mid-2022. It was reported that, in courts where SIAJ was already implemented, the time needed to process the legal aid application was on average reduced by two thirds. As regards the online accessibility of court decisions, all judgments delivered publicly by the Court of Cassation, the Council of State, all administrative courts of first instance and appeal, as well as the courts of appeal for civil, commercial and social litigation are now accessible through open data. Room for improvement still remains as regards the publication of other court judgments, particularly from lower court instances, and work is ongoing on the adaptation of the pseudonymisation artificial intelligence engine, for the publication of judgements of courts of first instance in commercial, civil and labour matters as well as for criminal proceedings. The resources allocated to the justice system have been increased for the second year, and magistrates have called for further efforts to continue ensuring the quality of justice. In 2020, the expenditure for the justice system was relatively low, in comparative terms, despite an increase compared to 2019. In 2022, the budget dedicated to the justice system was further increased by 3.4% as compared with 2021, thus reaching EUR 3 849 million. The budget allocated to legal aid also grew from EUR 585 million in 2021 to EUR 615.2 million in 2022. In addition, 1 414 of the short-term contractual positions created in 2021, including assistant lawyers working under magistrates, will be made permanent. However, the High Council for the Judiciary highlighted that the budget allocated by France to the justice system and the number of magistrates per inhabitant remains substantially lower than that of other European countries with a comparable GDP and called for additional regulatory safeguards to further stabilise the annual budget allocated to justice. The High Council also recommends reforming the status and the missions of the team assisting the magistrates, which would allow judges and prosecutors to focus more on their judicial functions and therefore contribute to the quality of justice. In an open letter published in a national newspaper, a large number of magistrates described the worsening working conditions in many courts, in particular because of the insufficient human resources and the comparatively excessive workload, forcing them to sacrifice quality for the sake of expediency. A comprehensive consultation on the justice system took place to identify relevant issues and reforms needed to address them. On 18 October 2021, the President of the Republic opened the Estates General of Justice. The first president and the attorney general of the Court of Cassation had previously expressed concerns about a ’systematic questioning of justice’. This nationwide consultation, associating law professionals and the general public, is aimed at taking stock of the situation of justice and formulating concrete proposals to remedy any outstanding issues. An online consultation took place and several conferences were organised. A final report was drafted by an independent committee, on the basis of the numerous contributions received and will be presented by the President of the Republic. The Law for trust in the justice system reinforces the provisions for voluntary mediation as an alternative to court proceedings. Article 45 of that law establishes a National Mediation Council whose main missions are to issue opinions and recommendations to the public authorities in the field of mediation, draft a compendium of ethics applicable to mediation, design national frameworks for the training of mediators, and make proposals on the conditions for the registration of mediators. The law also makes more effective the contracts establishing an agreement resulting from mediation, conciliation and participatory procedures in providing that, where they are countersigned by lawyers and authenticated by the registry of the competent court, transactions and other agreements reached during mediation, conciliation or participatory procedures become enforceable instruments. Promotion and incentives for using Alternative-Dispute Resolution methods are relatively developed, in comparative terms, but room for improvement remains. Efficiency The length of court proceedings in civil, commercial and administrative cases, measured in disposition time, increased sharply over the last year, with the exception of administrative cases, where the situation remained stable. In particular, the estimated time needed to resolve litigious civil and commercial cases at first instance increased from 432 days in 2019 to 637 days in 2020, one of the highest values in the EU. The number of pending court cases increased slightly but remained stable overall . The clearance rate, showing how the court system deals with caseload, decreased considerably, in particular for litigious civil and commercial cases, where it diminished from close to 100% to below 93%. As mentioned above, several judicial institutions have pointed to a need to recruit additional staff within the justice system, more particularly within courts and prosecution services , to be able to deal effectively and sustainably with the caseload. To this end, the Ministry of Justice is currently developing a measuring tool to evaluate precisely the mid and long-term recruitment needs . Moreover, 1914 contractual agents have been recruited to deal with the backlog of pending cases. The Ministry of Justice has reported that, from 2021 onwards, a significant decrease in the number of pending cases was recorded. In parallel, the National Conference of Presidents of Judicial Courts has developed and made public its own measuring tool designed to assess precisely the workload of judges by taking into account all their current attributions and missions . From the first evaluation carried out by two thirds of courts on this basis, it is argued that 1 500 additional first instance judges would be necessary to deal sustainably with the current workload, and the measuring tool developed by the Ministry of Justice would allow to refine this assessment. II.Anti-Corruption Framework Authorities involved in the fight against corruption include the French Anti-Corruption Agency (AFA, which prepares the multiannual anti-corruption plan and supports private and public legal persons on how to prevent and detect corruption), the High Authority for the Transparency of Public life (responsible for ensuring the integrity of public officials), and the Central Office for Combating Corruption and Tax Offences (a specialised police service for the investigation of economic crimes, including corruption and money laundering). The National Financial Prosecutor is competent for the investigation of high-level corruption cases. The perception of public sector corruption among experts and business executives is that the level of corruption in the public sector is relatively low. In the 2021 Corruption Perceptions Index by Transparency International, France scores 71/100 and ranks 8th in the European Union and 22nd globally . This perception has been relatively stable over the past five years. The 2022 Special Eurobarometer on Corruption shows that 64% of respondents consider corruption as widespread in their country (EU average 68%) and 7% of respondents feel personally affected by corruption in their daily lives (EU average 24%). As regards businesses, 50% of companies consider that corruption is widespread (EU average 63%) and 31% consider that corruption is a problem when doing business (EU average 34%). Furthermore, 23% of respondents find that there are enough successful prosecutions to deter people from corrupt practices (EU average 34%) , while 37% of companies believe that people and businesses caught for bribing a senior official are appropriately punished (EU average 29%) . The national anti-corruption plan for 2020-2022 continues to be implemented. The anti-corruption plan sets eight objectives that include the prevention of corruption in the organisation of two major international sport events, whose preparation is underway. The report on the final implementation of the anti-corruption plan is expected to be prepared by the Anti-Corruption Agency by the end of 2022, concurrently with the preparation of the next national anti-corruption plan (post-2022). Legislative steps have been taken to improve the legal anti-corruption framework. Following the recommendations indicated through the report delivered in July 2021 by the Law Commission of the Parliament, a new draft anti-corruption law was tabled in Parliament in October 2021, with both preventive and repressive provisions, notably on combating corruption, breach of integrity, negotiated settlements, and a register for lobbying. The conviction of high-level corruption cases continues to bring tangible results despite challenges linked to the limited resources as well as structural weaknesses. The Central Office for Combating Corruption and Tax Offences (OCLCIFF) remains responsible for investigation of high-level corruption cases. The staff available to the office (78 officers) compared to the workload (250 ongoing cases) is a point of concern. The National Financial Prosecutor’s Office (PNF) issued forty convictions in 2021, approved 12 individual appearances on prior admission of guilt (CRPC), and concluded three judicial agreements of public interest (CJIPs) (for a combined amount of fines of nearly EUR 45 million), plus two other criminal compositions. In the same year, the PNF recovered a total of EUR 173.1 million. In August 2021, the Government adopted a simplification of the public interest judicial agreements. Following a ministerial instruction to this end, the number of information feedbacks decreased (from 3 834 in 2021, to 1 854 as of April 2022). Despite the fact that in 2021 the workforce of the PNF grew from 17 to the current 18 magistrates, the recommendation of the GRECO on the PNF workforce needs to be further addressed. Structural challenges affecting the criminal process of foreign bribery, including the operations of the PNF and of the French Anti-Corruption Agency (AFA) have to be addressed. The bill adopted by the Parliament in November 2021, has raised some criticism related to the effective investigation of foreign bribery. Similarly, the legislative framework on the criminalisation of corporate liability associated to foreign bribery shows some deficiencies. The Anti-Corruption Agency continues to issue integrity guidelines for entities in both the private and public sectors. In 2021, the Anti-Corruption Agency continued to issue a series of subject-specific guidelines, including in the private sector, developed an awareness exercise on anti-corruption obligations, signed institutional memoranda of understanding, and delivered training to different stakeholders from the public and private sectors. Despite the decrease of personnel in 2021, the Agency considers the human resources available as sufficient overall. Turnover, due to rotation of seconded positions, declined. The integrity of public officials continues to be monitored by the High Authority for the Transparency of Public Life (HATVP). The HATVP continues advising on the integrity rules for public officials, including those on asset disclosure. In 2021, from the 15 574 declarations of asset and interests received, it only examined 3 150 declarations, and transmitted 11 files to the Public Prosecutor Office for further analyses of possible crimes. For the same year, the HATVP assessed around 19 000 reports on “revolving doors” (e.g. movement of professionals between the private and public sectors). While controls on the funds of politicians and political parties continue, a significant number of concerns remain as regard the application of rules on lobbying for all relevant actors, including at top executive level. In 2021, the National Commission on Campaign Accounts and Political Financing (CNCCFP) examined in total approximately 8 200 financial statements from candidates to Senate or regional elections and rejected in total 582 financial statements. for the management of the lobbying register. A GRECO recommendation on the disclosure of lobbying meetings with persons who are entrusted with top executive functions at national level remains unaddressed. While there is a new draft anti-corruption law (see above, page 10), the existing concerns on the type of lobbying activities and lobbyists remain unaddressed. The fact that the system requires the declaration of many lobbying activities (including those occurring at local level), creates a significant workload for the HATVP, which lacks human and technical resources. In 2021, a number of politically exposed persons were sentenced for tax fraud. In the first compliance report, adopted less than two years after the evaluation report, GRECO stated that nine recommendations were considered as partly implemented and that eight had not been implemented. Therefore, progress will have to be made regarding codes of conduct (for persons who are entrusted with top executive functions at national level), on the verification and accessibility of declarations of assets (of the presidential candidate, of persons with top executive functions, as well as those filed by members of the National Assembly and Senators), on conflicts of interests, as well as on examination of cases of corruption affecting members of the Government. Integrity rules for members of the Parliament and the Senate continue to be implemented. In 2021, the Commission for Ethics of the National Assembly issued 50 individual opinions, responded to about 443 requests for clarification on the use of funds during the presidential electoral campaign, and verified financial statements of members of the Parliament (150 statements for the year 2020, and 50 for 2021), where only minor violations were found. In 2021, only minor breaches of conflict of interest rules were identified. In January 2022, the Parliament adopted a new code of conduct, with amended provisions on lobbying activities. The Ethics Committee of the Senate is the body responsible for ethics of Senators. While integrity provisions are implemented across the public sector, the need to improve integrity-related security checks in the police and the disciplinary authority over judges remain. Police staff receives targeted anti-corruption training and awareness material. The national gendarmerie organises trainings on ethics for the military personnel at all levels. A Deontology Action Plan, with anti-corruption measures, is being finalised by the Inspectorate General of the Gendarmerie. Nevertheless, the GRECO recommendation to carry out security checks relating to the integrity of members of the National Police and the National Gendarmerie at regular intervals remains unaddressed. The national school of magistrates organises trainings on anti-corruption. Following a request from the President of the Republic, in September 2021 the High Council of Magistrates (CSM) issued a series of proposals on ethics. When members of the judiciary move to a new position, they must declare their assets and attend a meeting to discuss ethical conduct. However, there is no information available on the functioning of this declaration system. The GRECO recommendation calling to concentrate disciplinary authority over judges to within the Judicial Service Commission remains to be implemented. A new law has been adopted for the protection of whistleblowers. In March 2022, the Parliament adopted a new law on the protection of whistleblowers, which transposes the EU Whistleblowing Directive into national law. According to the new law, the Defender of Rights will be assigned a central and referral role on the new provisions, including the report on the functioning of the whistleblowing system. This legislative development will be used to reassess the previous GRECO recommendation to revise the protective regime for whistleblowers. In 2021, the Defender of Rights treated 81 cases of whistleblowing.

The existing anti-corruption measures for public procurement in the time of COVID-19 pandemic continue to be implemented. The sepecific guidelines issued in June 2020 by the Anti-Corruption Agency and the State Procurement Directorate continue to apply. III.Media Pluralism and Media Freedom The French legal framework concerning media pluralism is established by the Constitution and specific sectorial legislation, enforced by the independent media regulator. The Constitution protects freedom of expression and guarantees pluralism of the media. The Declaration of the Rights of People and of the Citizen recognises freedom of expression as a fundamental right. Transparency on media ownership is guaranteed by specific legislation. Legislation to transpose the Audiovisual Media Services Directive has been adopted. The independent media regulator has been redesigned for a better regulation of the online sphere. As of 1 January 2022, the media regulator Conseil supérieur de l’audiovisuel (CSA) and the online copyright authority Haute autorité pour la diffusion des oeuvres et la protection des droits sur internet (HADOPI) have merged creating a new regulator with a broader scope of competence: the Autorité de régulation de la communication audiovisuelle et numérique (ARCOM). The aim of the reform is to create a unique national regulator with increased powers (including conciliation procedures and investigative powers) over the entire field of audiovisual and digital content. ARCOM is granted with wider competences regarding content creation and obligations, copyright, combating disinformation as well as harmful online content. The ARCOM board is composed of nine members, appointed every two years by five different authorities (from the executive, legislative and judiciary) for a single, non-renewable term of six years. ARCOM’s independence is guaranteed by the same safeguards as those in place for CSA and HADOPI.The Media Pluralism Monitor (MPM 2022) considers the independence of the media regulator to be an area of very low risk. There have been no changes in the legal framework regulating transparency of media ownership since the last Rule of Law report; the issues related to horizontal and cross-media concentration persists. France has in place legal safeguards to ensure transparency of media ownership, which is guaranteed by the Law on the Freedom of Communication, the Law to Support Confidence in the Digital Economy, and the Law on the Freedom of the Press. These laws state that any editor of a broadcasting service or director of publications must keep certain information, including ownership, permanently available to the public . The MPM 2022 registers a medium risk for the transparency of media ownership, pointing to the complexity of shareholding structures in the media sector , and indicates a high degree of concentration in the French media landscape. During the presidential elections campaign, Reporters Without Borders (RSF) issued several recommendations to candidates to reinforce media freedom and called for the revision of legislation on media concentration. In November 2021 a Senate Commission of inquiry was established to examine media concentration in France and its impact on democracy. The final report of the Senate Commission was adopted on 31 March 2022. The Senate Commission suggested a complete rewriting of the Law on the Freedom of Communication which it considered has become “obsolete”, and put forward 32 proposals. The proposals included the reinforcing of the guarantees of independence and ethics, prevention of conflicts of interest in large groups and limiting vertical concentration of media ownership. Authorisations and licensing in the media sector are regulated under the Law on Freedom to Communicate. Authorisations for terrestrial television and radio broadcasting are granted by the media regulator (now ARCOM) following bid tenders and subject to the conclusion of an agreement with the media regulator, with the exception of the public national providers, France Télévisions and Radio France. The term of authorisations cannot exceed 10 years in principle but is subject to extensions and various derogations. Broadcasting services that are not subject to the authorisation – namely, those that are broadcast or distributed through a network that does not use frequencies allocated by the media regulator (cable, satellite, asymmetric digital subscriber line (ADSL), internet, telephony, etc.) – must nevertheless conclude a standard agreement or file a prior declaration with the regulator. Structural legal safeguards ensure the independence of French public service media. The French public service media (France Télévisions) is regulated by the Law on Freedom to Communicate (Law Léotard). The French state holds the entire capital of France Télévisions, which is subject to the legislation on public limited companies. According to the Law Léotard, public service media must ensure pluralism of information and independence as well as diversity of opinion, respect for human rights and democratic principles. Furthermore, when broadcasting television news, the services of France Télévisions have an independent editorial line. The MPM 2022 considers the independence of public service media governance to be an area of low risk . The governing bodies of France Télévisions are the Board of Directors and its committees, the President, and the Programme Advisory Board. The appointment procedures for the management and the boards of the public service media, laid down by the Law on Freedom to Communicate, are transparent and balanced. The President is appointed for five years by ARCOM, by a majority of its members. This appointment is subject to a reasoned decision based on criteria of competence and experience. The Board of Directors comprises, in addition to the President, 14 members; five members are independent persons appointed by ARCOM for their competence, one of whom represents the consumer protection associations. There are also safeguards in place against arbitrary dismissals. The President of France Télévisions presents an annual report on the fulfilment of the remit’s terms and conditions to the committees responsible for cultural affairs and finance of the National Assembly and the Senate. ARCOM guarantees the independence and impartiality of the public service media. In its annual activity report, ARCOM must present a report on France Télévisions’s compliance with its obligations. Attacks on and threats to the physical safety of journalists continue but the Government has taken steps to strengthen their protection. Since the 2021 Rule of Law Report, a significant number of alerts have been published for France on the Council of Europe’s Platform to promote the protection of journalism and safety of journalists. They related in particular to harassment, intimidation and attacks on physical safety and integrity of journalists. To address the tensions between the press and the police forces, following the report submitted by the Independent Commission on Press and Law Enforcement Relations, a monthly liaison committee between the Ministry of the Interior and the press was established in January 2022 to enable permanent dialogue. In parallel, a working group was set up in July 2021 dedicated to the identification of journalists for security purpose, in the context of public street events. It involved representatives of journalists and their employers, journalism associations and the Commission for the Identity Card of Professional Journalists (CCIJP). A new version of the National Law Enforcement Scheme (SNMO) was published on 16 December 2021, which recognises the special role of journalists during demonstrations. It also provides for the obligation to guarantee their security during demonstrations, including unauthorised or even prohibited demonstrations. Offences committed against journalists during demonstrations are subject to judicial proceedings, provided that they are detected or brought to the attention of the law enforcement authorities.The MPM 2022 reports a medium risk with regard to the protection of the right to information, due to criticisms related to the extension of the scope of the law on the ‘protection of trade secret’. IV.Other Institutional Issues related to Checks and Balances France is a democratic republic with a semi-presidential system of government, with a President directly elected by the people and a Prime Minister who is accountable to Parliament. The bicameral Parliament consists of the National Assembly and the Senate. Legislative proposals can originate from the Government or from members of both Houses of Parliament. The Constitutional Council scrutinises the constitutionality of laws, before or after their adoption. Independent authorities play an important role in the system of checks and balances. The practice of nationwide public consultations was further reinforced and extended to other fields, including the justice system. As mentioned above, the Estates General of Justice were conceived as a structured and open democratic debate. Both the general public and law professionals could express their views on the reforms needed in the justice system. An online consultation took place at national level , and 266 events such as debates and conferences were organised throughout the country. In parallel, until the end of January 2022, seven thematic working groups involving more than 60 justice and law professionals (including magistrates, lawyers, registry staff and university professors) were set up . The independent committee in charge of drafting the final report was entrusted with taking into account all the contributions gathered as part of this exercise to feed its evaluation. Furthermore, a new Citizens’ Participation Platform allows the public to have access to all information relating to non-compulsory citizen participation procedures carried out by the State and, where appropriate, express their interest in registering, as well as to consult citizens’ contributions and the follow-up given to them, and thus to measure the impact of their participation on public policies. In 2021, three nation-wide consultations were co-developed and co-led by the Ministry for Relations with Parliament and Citizens’ Participation and the Interministerial Centre for Citizens’ Participation (CIPC), including on the topic of discrimination and in relation to the Conference on the Future of Europe. To ensure the follow-up of proposals made in the context of this conference, a citizens’ monitoring committee, made up of 15 citizens who participated in the consultation, was created. Accelerated procedures for the adoption of laws continued to be used regularly, including for laws with a significant impact on individual freedoms. Out of 67 laws enacted between 1 July 2021 and 8 April 2022, 45 had been submitted to an accelerated procedure by the Government. As already noted in the 2021 Rule of Law Report, this procedure was repeatedly used for laws with an important impact on individual freedoms, such as the Law on the prevention of terrorism and intelligence, the Law for trust in the justice system , the Law on criminal responsibility and internal security and the Law reinforcing the tools to manage the health crisis. As regards the latter, the general assembly of the National Council of Bars issued a resolution disapproving the use of the accelerated procedure, which prevents a genuine debate and parliamentary scrutiny, to adopt a law impacting fundamental freedoms, in the absence of an imminent danger. The National Advisory Commission on Human Rights (CNCDH) reiterated its disapproval of the frequent use of this procedure outside strict emergency requirement and in areas with a direct impact on public freedoms and human rights, as it restricts significantly the parliamentary debate essential in a democracy. The emergency regime to address the COVID-19 pandemic has been extended, with the Constitutional Council defining the limits of the executive and legislative powers. The transitional regime for phasing out from the state of health emergency, introduced by the law of 31 May 2021 until 30 September 2021, was initially extended until 15 November 2021 and then until 31 July 2022. The Constitutional Council reviewed both laws before their promulgation, declared them partly unconstitutional and made important findings regarding the extent of the judicial scrutiny of such laws. In particular, in its decision on the Law of 5 August 2021, the Constitutional Council rejected the claim that the deadlines set for Parliament to examine and amend the text were too short, but also noted the limits to its constitutional power to review of the opportunity of adopting a law introducing such a regime. On the substance, the Constitutional Council highlighted that the lawmaker’s assessment was corroborated by opinions of a scientific committee required by law, and that the measures were surrounded by sufficient safeguards, with the exception of some provisions declared unconstitutional. As regards the Law of 10 November 2021, the Constitutional Council validated the extension of the emergency regime until 31 July 2022, recalling fundamental principles imposed on the lawmaker and the executive power in such a context. On substance, the possibility for school heads to access the health data of students and several government authorisations to issue new ordinances were declared unconstitutional. In its 2021 Annual Study, dedicated to the states of emergency, the Council of State pointed out that the prolonged use of such regimes destabilises the institutional balance and the democratic institutions, and made 15 proposals to better define and organise the states of emergency. On 1 January 2022, France had 25 leading judgments of the European Court of Human Rights pending implementation . At that time, France’s rate of leading judgments from the past 10 years that remained pending was at 28% and the average time that the judgments had been pending implementation was two years and 11 months . The oldest leading judgment, pending implementation for 12 years, concerns the inaction of the authorities in the execution of judiciary measures of expulsion regarding illegally occupied lands . On 1 July 2022, the number of leading judgments pending implementation has decreased to 24. Independent authorities expressed concerns regarding the impact of laws adopted to manage crisis situations on individual freedoms. In an opinion of 20 July 2021, the Defender of Rights expressed concerns on the potential impact of the laws on managing the health crisis on individual freedoms, and more particularly on the risks of discrimination and violations of children’s rights and data protection rules. With regard to the fight against terrorism, the Commission consultative des droits de l’homme (CNCDH) criticised the inclusion in ordinary law of preventive measures that were part of the law relating to the state of emergency. Initially introduced into ordinary law on an experimental basis, these measures were made permanent by the Law on the prevention of terrorism and intelligence. During a hearing with parliamentarians, the CNCDH reiterated its concern about these measures, especially given that their impact on human rights has not yet been assessed independently. As regards the Law on Global Security, which created concerns as regards the freedoms of expression and information and the right to freedom of peaceful assembly, the independent authorities pointed out that there had been no opportunity to assess its actual impact on civil society, as there were no major demonstrations or other large scale events during which the measures foreseen for could be implemented. A criminal investigation was opened into use of surveillance spyware targeting in particular journalists. It was reported that a number of French and French-based journalists and media company owners have been targeted by Pegasus and equivalent spyware surveillance software . On 19 and 20 July 2021 respectively, the media company Mediapart and NGO Reporters without Borders (RSF) lodged criminal complaints before the Paris Prosecutors’ Office , which opened an investigation on charges of invasion of privacy, interception of correspondence, fraudulent access to a computer system and criminal association. The Law on republican principles, supplementing the regulation on the activities and funding of associations, entered into force and a number of stakeholders raised concerns as regards its potential impact on the civic space. Under the Law on republican principles, associations or foundations requesting public subsidies must subscribe and comply with a ‘contract of republican commitment’, under penalty of repaying the allocated subsidies. Compliance with the ‘contract’ also becomes a condition for an association to be recognised as having a public utility. Moreover, the law extends the list of grounds for dissolution of associations by decree of the President of the Republic. The Constitutional Council censured a provision allowing the provisional suspension of an association. As to the financing of associations, in particular with a religious character, the law provides that it will be more closely monitored. The law on republican principles also modified the conditions for creating and operating religious associations, which will have to declare themselves to the prefect every five years, and reinforced their accounting obligations. A number of national and international stakeholders, including independent authorities, expressed criticism regarding the potential impact of the new provisions on the freedom of association and freedom of expression both before the adoption of the law and after its entry into force. More particularly, the CNCDH expressed preoccupations that the obligation to subscribe to a ‘contract of republican commitment’ risks creating a general climate of mistrust towards associations . Overall, the civic space in France has been assessed as narrowed . New laws have been adopted to improve the financial environment for civil society organisations. The law favouring associative commitment mitigates the financial liability of volunteer associative leaders in the event of mismanagement, by extending the ‘negligence exception’ provided for business managers. Before that, personal assets of such volunteer leaders could be seized in the event of mismanagement. Furthermore, a law to improve the cash flow of associations now allows for the keeping of the unspent surplus of a subsidy of more than EUR 23 000 under certain conditions. The new law also provides that the public authority is required to pay the subsidy within 60 days of the date of notification of the decision to award it, unless the administrative authority has set other payment dates or made the payment conditional on the occurrence of a specific event. In addition, the law allows associations of general interest or recognised as being of public utility to grant zero interest loans to other associations that are members of the same union or federation of associations. Finally, the law introduced the possibility for the Caisse des dépôts to pay a portion of the sums from accounts of associations that are no longer active for the benefit of the development of associative life. Annex I: List of sources in alphabetical order* * The list of contributions received in the context of the consultation for the 2022 Rule of Law report can be found at https://ec.europa.eu/info/publications/2022-rule-law-report-targeted-stakeholder-consultation_en .

Central Office for Combating Corruption and Tax Offences (OCLCIFF) (2022), Contribution from the Central Office for Combating Corruption and Tax Offences for the 2022 Rule of Law Report. Centre for Media Pluralism and Media Freedom (2022), Media pluralism monitor 2022 – country report on France. Civicus, Monitor tracking civic space – France https://monitor.civicus.org/country/france/ . Civil Liberties Union for Europe (2022), Contribution from the Civil Liberties Union for Europe for the 2022 Rule of Law Report. Constitutional Council, Decision No. 2021-828 DC, 9 November 2021. Constitutional Council, Decision No. 2021-927 QPC, 14 September 2021. Cooperation protocol signed between the Inter-ministerial Commission for the Coordination of Controls (CICC) and the French Anti-Corruption Agency, relating to the implementation of the Recovery and Resilience Facility signed, the European component of the plan stimulus, February 2022 https://www.agence-francaise-anticorruption.gouv.fr/fr/securisation-des-modalites-daudit-dans-cadre-facilite-pour-reprise-et-resilience Council of Bars and Law Societies of Europe (CCBE), Statement on the use of Pegasus software, 1 February 2022 https://www.ccbe.eu/fileadmin/speciality_distribution/public/documents/SURVEILLANCE/SVL_Statements/EN_SVL_20220201_CCBE-Statement-on-the-Pegasus-Scandal.pdf Council of Europe, Platform to promote the protection of journalism and safety of journalists, France https://fom.coe.int/en/pays/detail/11709510 . Council of Europe: Committee of Ministers (2010), Recommendation CM/Rec(2010)12 of the Committee of Ministers to member states on judges: independence, efficiency and responsibilities. Council of State (2021), 2021 Annual Study: Les états d’urgence: la démocratie sous contraintes, 8 July 2021 https://www.conseil-etat.fr/Media/actualites/documents/2021/09-septembre/ea21_etat-d-urgence.pdf Council of the European Union, Annex to the Council Implementing Decision on the approval of the assessment of the recovery and resilience plan for France. Court of Audit (2021), Communication to the Finance Committee of the Senate, ‘Improving the functioning of justice – stage point of the digital transformation plan of the Ministry of Justice’ http://www.senat.fr/fileadmin/Fichiers/Images/commission/finances/Controle/58-2/Plan_de_transformation_numerique_de_la_justice.pdf Defender of Rights (2021), Opinion of 20 July 2021 https://juridique.defenseurdesdroits.fr/doc_num.php?explnum_id=20864 . Defender of Rights (2022), Contribution from the Defender of Rights for the 2022 Rule of Law Report. Directorate-General for Communication (2019), Flash Eurobarometer 482: businesses’ attitudes towards corruption in the EU. Directorate-General for Communication (2020), Special Eurobarometer 502: corruption. Directorate-General for Communication (2022), Flash Eurobarometer 507: businesses’ attitudes towards corruption in the EU. Directorate-General for Communication (2022), Special Eurobarometer 523: corruption.

European Civic Forum (2022), Contribution from the European Civic Forum for the 2022 Rule of Law Report. European Commission (2020), 2020 Rule of Law Report, Country Chapter on the rule of law situation in France. European Commission (2021), 2021 Rule of Law Report, Country Chapter on the rule of law situation in France. European Commission (2022), 2022 EU Justice Scoreboard. European Court of Human Rights, judgment of 21 January 2010, Barret and Sirjean v. France, 13829/03. European Implementation Network (2022), Contribution from the European Implementation Network for the 2022 Rule of Law Report. European Network of National Human Rights Institutions (2022), Contribution from the European Network of National Human Rights Institutions for the 2022 Rule of Law Report. First President of the Court of Cassation (2022), Press release of 4 March 2022 https://www.courdecassation.fr/toutes-les-actualites/2022/03/04/communique-de-madame-chantal-arens-premiere-presidente-de-la-cour French Anti-Corruption Agency (AFA) (2021), Prevention of conflicts of interest in the company (Les contrôles comptables anticorruption en entreprise) https://www.agence-francaise-anticorruption.gouv.fr/files/2021-11/projet%20guide%20contr%C3%B4les%20comptables%20anticorruption%20en%20entreprise.pdf . French Anti-Corruption Agency (AFA) (2022) ‘In Search of Integrity’, the serious corruption prevention awareness game https://www.agence-francaise-anticorruption.gouv.fr/fr/decouvrez-en-quete-dintegrite-jeu-serieux-sensibilisation-prevention-corruption French Anti-Corruption Agency (AFA) (2022), Control the risk of impact of probity within associations and recognised foundations of public utility (Maîtriser le risque d’atteinte à la probité au sein des associations et fondations reconnues d’utilité publique) https://www.agence-francaise-anticorruption.gouv.fr/files/files/GuideArupFrup_Web.pdf . French Anti-Corruption Agency (AFA) (2022), Implementation of a corruption risk prevention system in the building and public works sector (La mise en place d’un dispositif de prévention des risques de corruption dans le secteur du bâtiment et des travaux publics) https://www.agence-francaise-anticorruption.gouv.fr/files/files/Guide_BTP_AFA_Web.pdf . French Anti-Corruption Agency (AFA), Contribution from the French Anti-Corruption Agency for the 2022 Rule of Law Report. French Government (2021), Press release of 15 September 2021, ‘Submission of the administrative investigation report concerning Édouard Levrault’ https://www.gouvernement.fr/communique/12445-remise-du-rapport-d-enquete-administrative-concernant-edouard-levrault French Government (2021), Press release of 17 April 2021, ‘Referral to the High Council for the Judiciary https://www.gouvernement.fr/communique/12235-saisine-du-conseil-superieur-de-la-magistrature French Government (2022), Input from France for the 2022 Rule of Law Report. French Ministry of Justice (2022), Contribution from the Ministry of Justice in the context of the country visit. General Assembly of the National Council of Bars (2021), Resolution of 17 September 2021 https://www.cnb.avocat.fr/sites/default/files/documents/cnb-mo_2021-09-17_secret-professionnel_boissavyadopte.pdf GRECO (2022), Fifth Evaluation Round – Compliance Report on France on preventing corruption and promoting integrity in central governments (top executive functions) and law enforcement agencies. GRECO (2022), Fourth Evaluation Round – Addendum to the Second Compliance Report on France on preventing corruption in respect of members of parliament, judges and prosecutors.

High Authority for the Transparency of Public Life (HATVP) (2022), Written contribution from the High Authority for the Transparency of Public Life (HATVP) in the context of the country visit. High Council for the Judiciary (2021), Opinion on the accountability and protection of magistrates http://www.conseil-superieur-magistrature.fr/sites/default/files/atoms/files/avis_pr_vd_internet_0.pdf High Council for the Judiciary (2021), Opinion to the President of the Republic Referral of 17 February 2021 http://www.conseil-superieur-magistrature.fr/sites/default/files/atoms/files/avis_pr_vd_internet_0.pdf High Council for the Judiciary (2021), Written contribution of the for the Estates General of Justice http://prod.conseil-superieur-magistrature.fr/sites/default/files/atoms/files/csm_egj_2022.pdf High Council of Magistrates (CSM) (2022), Contribution from the High Council of Magistrates for the 2022 Rule of Law Report. L’Opinion (2022), Dupond-Moretti to the Court of Justice of the Republic: "Everything shows your determination to smear me" (Dupond-Moretti à la Cour de justice de la République: «Tout démontre votre détermination à me salir») https://www.lopinion.fr/politique/dupond-moretti-a-la-cour-de-justice-de-la-republique-tout-demontre-votre-determination-a-me-salir . Le Figaro (2021), ‘Pegasus case: the Paris prosecutor's office opens an investigation into the espionage of journalists’ (‘Affaire Pegasus : le parquet de Paris ouvre une enquête sur l'espionnage de journalistes’) https://www.lefigaro.fr/flash-eco/affaire-pegasus-enquete-ouverte-a-paris-sur-l-espionnage-de-journalistes-parquet-20210720 Le Monde (2021), ’Call from 3000 magistrates and a hundred clerks’ (‘L’appel de 3 000 magistrats et d’une centaine de greffiers’) https://www.lemonde.fr/idees/article/2021/11/23/l-appel-de-3-000-magistrats-et-d-une-centaine-de-greffiers-nous-ne-voulons-plus-d-une-justice-qui-n-ecoute-pas-et-qui-chronometre-tout_6103309_3232.html Ligue des droits de l’homme (2022), Contribution on behalf of the European Civic Forum for the 2022 Rule of Law Report https://civicspacewatch.eu/wp-content/uploads/2022/01/France-Lay-out-done-highlights.pdf National Assembly (2021), Law Commission, Information Report No. 4325 https://www.assemblee-nationale.fr/dyn/15/rapports/cion_lois/l15b4325_rapport-information.pdf National Assembly (2022), Code of Conduct of Deputies https://www2.assemblee-nationale.fr/content/download/461868/4506828/version/1/file/code+de+d%C3%A9ontologie_actualis%C3%A9+suite+bureau+21022022.pdf National Commission on Campaign Accounts and Political Financing (CNCCFP) (2022), Contribution from the National Commission on Campaign Accounts and Political Financing (CNCCFP) for the 2022 Rule of Law Report. National Conference of Presidents of Judicial Courts (2022), Press release of 16 February 2022 https://www.cnptj.fr/abo/cnptj/media_pdf/communique_cnptj_referentiel_national_16_fevrier_2022.pdf National Conference of Prosecutors (2021), Ten proposals for the future of criminal justice https://twitter.com/conf_nat_procs/status/1479062944940011520 National Consultative Commission on Human Rights (2022), Contribution from the National Consultative Commission on Human Rights for the 2022 Rule of Law Report. National Council of Bars (2022), Resolution of 14 January 2022 https://www.cnb.avocat.fr/sites/default/files/documents/04.cnb-re_2022-01-14_ldh-txt_pjl-outils-gestion-crise-sanitaire-modifiant-code-sante-publique_fau-roquesfinal-p.pdf National Financial Prosecutor (2021), Annual Report 2021 https://www.tribunal-de-paris.justice.fr/sites/default/files/2022-01/PNF-brochure_A5-2021%5B2%5D.pdf National Financial Prosecutor (2022), Contribution from the National Financial Prosecutor for the 2022 Rule of Law Report. OECD (2021), Implementing the OECD Anti-Bribery Convention, Phase 4 Report, France https://www.oecd.org/daf/anti-bribery/France-Phase-4-Report-EN.pdf Presidency of the Republic (2021), Press release of 18 October 2021 https://www.elysee.fr/emmanuel-macron/2021/10/18/etats-generaux-justice

Reporters without Borders – France https://rsf.org/en/country/france . Reporters without Borders (2022), French presidential election – RSF’s ten proposals for journalistic freedom and independence https://rsf.org/en/french-presidential-election-rsfs-ten-proposals-journalistic-freedom-and-independence . Reporters without Borders (2022), Press release of 5 August 2021, ‘NSO/Pegasus: 17 journalists from 7 countries join the complaints filed by RSF at the UN and before the French courts’ https://rsf.org/fr/nsopegasus-17-journalistes-de-7-pays-se-joignent-aux-plaintes-deposees-par-rsf-lonu-et-devant-la Senate, Order No. 58-1100 http://www.senat.fr/role/comite_deontologie.html Senate: Senate Commission of inquiry on media concentration in France (2022), Final report http://www.senat.fr/fileadmin/Fichiers/Images/commission/affaires_culturelles/CEmedias/ESSENTIEL_cemedias.pdf . Transparency International (2022), Corruption Perceptions Index 2021. World Bank (2022), Press release, World Bank Group Debars ADP International S.A. https://www.worldbank.org/en/news/press-release/2022/01/04/world-bank-group-debars-adp-international-s-a . World Bank (2022), Press release, World Bank Group sanctions Bouygues Bâtiment International https://www.worldbank.org/en/news/press-release/2022/01/04/world-bank-group-sanctions-bouygues-b-timent-international . Annex II: Country visit to France The Commission services held virtual meetings in March 2022 with: ·Agence France Presse ·Anti-Corruption Agency ·Central Office for Combating Corruption and Tax Offenses ·Council of State ·Defender of rights ·Delegation of the Bars of France ·Ethics Commissioner of the National Assembly ·France Télévisions ·High Authority for the Transparency of Public Life

·High Council for the Judiciary ·Journalistic Ethics and Mediation Council ·Ministry of Culture ·Ministry of Justice ·National Commission on Campaign Accounts and Political Financing ·National Consultative Commission on Human Rights ·National Council of Bar Associations ·National Financial Prosecutor ·National Journalists Union ·Radio France ·Regulatory Authority for Audiovisual and Digital Communication (ARCOM) ·Reporters without Borders ·Syndicat de la Magistrature ·Union Syndicale des Magistrats * The Commission also met the following organisations in a number of horizontal meetings: ·Amnesty International ·Article 19 ·Civil Liberties Union for Europe ·Civil Society Europe