Universal Registration
Document 2025

including the annual financial report

ELECTRICITY? IT’S ONLY THE BEGINNING.

This Universal Registration Document (URD) was filed on 31 March 2026 with the French Financial Markets Authority (AMF), as the competent authority under Regulation (EU) 2017/1129, without prior approval pursuant to Article 9 of said Regulation.

This Universal Registration Document may be used for the purposes of an offer of securities to the public or the admission of securities to trading on a regulated market if it is supplemented by a securities note and, if applicable, a summary and any amendments made to the Universal Registration Document. The set of documents formed thereof is approved by the AMF in accordance with EU Regulation 2017/1129.

This document is a translation in English of the official version of the Universal Registration Document issued in French and is available on the Company's website (https://www.edf.fr/investors) as well as on the AMF's website (https://www.amf-france.org) All possible care has been taken to ensure that the translation is an accurate presentation of the original. However, in all matters of interpretation of information, views or opinions expressed therein, the original French language version of the document takes precedence over this translation.

• (1) Consolidated scope. Counted per site.
• (2) EDF SA scope excluding French overseas and Corsica.
• (3) Group scope.
• (4) Consolidated data for the Group scope.
• (5) Group scope. Pipeline excluding capacity under construction. All projects in the prospection phase from 2020 onwards are included in the pipeline.
• (6) Operated under concession by Enedis.

• (1) Specific CO₂ emissions due to heat and electricity generation. Group scope.
• (2) BearingPoint Customer Relation Podium Award – 2025.
• (3) Projects over €60 million in accordance with the Equator Principles – Group scope.
• (4) MyEDF Group internal survey.
• (5) Group scope.
• (6) Lost Time Incident Rate for Group employees and contractors.
• (7) Consolidated other external expenses.
• (8) Consolidated taxes other than income taxes.
• (9) Consolidated personnel expenses (excluding capitalised production held in inventory).

A simplified organisation chart of the Group at 31 December 2025 is presented below. The percentage given for each entity (subsidiary or sub-group of subsidiaries) corresponds to the ownership interest held directly or indirectly in the capital. The values given are rounded. The companies or groups of companies included in the Group’s scope of consolidation are indicated in section 6.1 “Consolidated financial statements at 31 December 2025”, note 24 “Main entities in the scope of consolidation”. Changes in the scope of consolidation in 2025 are discussed in section 6.1 “Consolidated financial statements at 31 December 2025”, note 3.1 “Changes in the scope of consolidation”.

• (1) Coentreprise de Transport d’Électricité (CTE), the company that holds 100% of RTE.
• (2) On 31 December 2025, EDF Holding SAS, EDF Immo, Société C3 and EDEV were merged into EDF International (renamed EDF Holding on 1 January 2026).
• (3) In September 2025, EDF Renewables changed its name to EDF power solutions.
• (4) On 28 January 2026, IZIVIA changed its name to EDF business services.
• (5) See section 6.1 “Consolidated financial statements at 31 December 2025”, note 13.4 “Non-controlling interests (minority interests)”.
• (6) See section 6.1 “Consolidated financial statements at 31 December 2025”, note 11 “Investments in associates and joint ventures”.

Electrification, a pillar of competitiveness, sovereignty and decarbonisation

The fight against climate change is the defining challenge of our generation. Current policy projections predict +2.5°C to 2.9°C global warming by 2100⁽¹⁾, but it is generally recognised that global carbon neutrality must be achieved by 2050 to limit warming to 1.5°C and respect the Paris Agreements.

In Europe, the “Green Deal” developed in 2020 and the European Commission’s “Fit for 55” climate package provide the framework for measures enabling the European Union to achieve carbon neutrality by 2050. The recovery programmes that followed the Covid pandemic further reinforced the priority given to the climate. Also, in the context of global energy market disruptions caused by the war in Ukraine, the “REPowerEU” programme announced by the European Commission in 2022 seeks to address the additional challenges of resilience, competitiveness and sovereignty in this energy transition.

Among the priority focuses of the new European Commission appointed in 2024, decarbonisation and competitiveness of the European Union have been strongly reaffirmed. The electrification of energy uses in all countries is one of the main levers for achieving European decarbonisation commitments, complementing the priority development areas of renewables and energy efficiency. In addition to the target of a -55% reduction in CO₂ emissions by 2030, the Commission proposed a European target of a -90% reduction in carbon emissions by 2040; the European legislative process to validate this target is currently underway.

In France, electricity accounts for just over 10% of CO₂ emissions (as opposed to 40%⁽²⁾ worldwide). France’s Climate and Energy Law of 8 November 2019 places the reduction of greenhouse gas emissions at the heart of French energy policy. The goal is “to become carbon-neutral by 2050, by cutting greenhouse gas emissions more than sixfold”.

The EDF group is acting to accelerate the electrification of uses, by replacing fossil fuels in major energy-consuming sectors (transport, construction, industry), and by providing support for new electrical uses (data centres).

The availability and competitiveness of low-carbon electricity generation by EDF make France attractive for electricity-consuming sectors and will continue to do so in the future. This electricity is an asset for industrial players in all regions and therefore for the country’s sovereignty.

EDF’s goal is to make a success of the energy transition by providing its customers with an abundant supply of reliable, competitive, sovereign and decarbonised electricity.

France’s multi-year energy programme (PPE)

On Friday 13 February 2026, the French government published a decree setting out the new Multi-Year Energy Plan (PPE) covering the next ten years.

This PPE comes against a backdrop of overcapacity in the French electricity system: demand remains 6 to 7% below its pre-Covid level, due notably to the still insufficient electrification of fossil fuel-based uses. At the same time, generation capacity increased in 2025 with the connection of nearly 7GW of renewable energy, including 5.7GW of solar power, further widening the gap between supply and demand. In this context, the PPE aims to balance long-term needs  —  including a structural increase in electricity demand estimated at around +150TWh by 2035, mainly as a replacement for fossil fuels  —  with the short-term situation, which is characterised by sluggish consumption.

The PPE3 makes electrification the central lever for competitiveness, sovereignty and decarbonisation (by accelerating the shift from fossil fuels to electricity). It includes adjustments to the development of renewables (solar, offshore and onshore wind power) given the delay in the electrification of uses.

The Group is fully committed to this PPE3:

• for the electrification of end-use sectors with all downstream industries already on board, with the objective of contributing to the creation of 150TWh of additional electricity demand by 2035 compared with 2023, primarily by replacing carbon-intensive energies; and
• for low-carbon generation through the EPR2 construction programme, extended reactor lifespans, and the revival of investment in hydropower, whilst ensuring that expertise in renewable energy is maintained. This comprehensive trajectory should make it possible to secure a competitive, reliable, sovereign and low-carbon electricity mix.

Against a backdrop of increasing electricity uses, the EDF group has one of the largest power generation fleets in the world with some of the lowest CO₂ emissions, thanks to the share of nuclear and renewable energy in its energy mix. The Group aims to maintain the generation activity of its nuclear fleet, to green its thermal power generation, and to continue the expansion of renewable energies in France and around the world. It is also preparing for the nuclear power of the future with the EPR2 and the development of SMRs (Small Modular Reactors).

• * Direct carbon emissions related to generation, excluding the life cycle analysis of generation plants and fuel.

The strengths of the generation fleet

The Group’s generation fleet has significant strengths:

• a diversity of generation facilities, providing adequate coverage of EDF’s downstream portfolio needs (end users, sales to alternative suppliers, sales on the wholesale markets, etc.). The guiding principle for managing use of the various plants in the fleet is prioritising the facilities with the lowest variable costs;
• a nuclear fleet of 57 reactors in France⁽²⁾ and 9 reactors in operation in the United Kingdom;
• construction of EPR-type reactors worldwide;
• control of the entire life cycle of nuclear generation facilities: design, operation, and decommissioning;
• implementation of actions aimed at improving the power plants’ technical performance and extending their operating lifespan;
• 95% of the fleet’s generation produces no CO₂ emissions⁽³⁾ thanks to the predominance of nuclear power and hydropower;
• a geographical position at the intersection of electricity exchanges between the European continental plate and the “electricity peninsulas” (Italy, Spain and the United Kingdom).

Details of the EDF fleet in mainland France

With total installed capacity of 86.4GW in mainland France⁽⁴⁾ at 31 December 2025, EDF’s power plants produced 419TWh⁽⁵⁾ in mainland France in 2025. The principal components of this generation fleet at 31 December 2025 were as follows:

• 57 pressurised water reactors (PWRs). Their power generation capacity ranges from 900MW to 1,620MW, and their average age (excluding Flamanville 3) is 40 years. See also section 1.4.1.1.2 “Nuclear power generation in France”;
• 19 thermal units in operation. See section 1.4.1.2 “Thermal generation in mainland France”;
• 424 hydropower plants, with an average age of 80 years⁽⁶⁾. See section 1.4.1.3.1 “Hydropower generation in France”;
• other hydropower plants owned by the Group’s subsidiaries: ÉS, SHEMA Group, CERGA and RKI (on the Rhine, owned 50-50 with German energy company EnBW) and the Franco-Swiss entities of Chatelôt and Émosson.

• (1) See section 3.2.2.1.2.4 “Invested resources and current and future expenditures related to the climate change objective” and section 6.1 “Consolidated financial statements at 31 December 2025”, note 19.4 “Low-carbon investments”.
• (2) After the permanent shutdown of the two reactors at Fessenheim and connection of the Flamanville 3 reactor to the electricity grid.
• (3) Direct CO₂ emissions related to generation, excluding the life cycle analysis of generation plants and fuel.
• (4) Excluding Corsica and French overseas départements and regions.
• (5) Including pumped-storage hydropower.
• (6) Sliding 1-year arithmetic mean for a constant fleet, recalculated in 2021; no new facilities commissioned or declassified in 2025.

EDF SA’s installed capacity and output in mainland France – 2025

Installed capacity

Expressed in megawatts of maximum capacity coupled to the network.

• (1) Excluding Corsica and overseas départements and regions, i.e. 778.2MW in 2025.
• (2) Excluding Corsica and overseas départements and regions, i.e. 439MW in 2025, including marine energy: 240MW.
• (3) Excluding Flamanville 3 (1,620MW).

Electricity output

• (1) Excluding Corsica and overseas départements and regions, i.e. 1.3TWh in 2025.
• (2) Excluding Corsica and overseas départements and regions, i.e. 1.1TWh in 2025.
• (3) Including pumped-storage hydropower.
• (4) Including Flamanville 3 (2.2TWh).

NB: figures are rounded.

1.4.1.1    Nuclear power generation

1.4.1.1.1    Nuclear organisation and governance

The EDF group will have a major role to play in relaunching the nuclear programme, and a new organisation for nuclear operations was put in place with effect on 1 January 2026. This change aims to group know-how and skills by major discipline, industrialise methods to improve performance, and strengthen cross-functionality in the Company. Nuclear operations are now structured around five Divisions and one unit:

• the Project Ownership for New Nuclear Division, which is responsible for the strategic management of new nuclear programmes;
• the Industrial Projects and Partnerships Division, which is the prime contractor for new nuclear projects;
• the Nuclear Engineering Division, which carries out cross-functional engineering assignments to service the existing fleet and New nuclear projects;
• international nuclear development, authority on technical matters and products, and responsibility for planning remain with the Strategy, Technologies, Innovation and Development Department;
• the Nuclear and Thermal Generation Division, which is responsible for the operation, maintenance and dismantling of existing nuclear and thermal fleets and newly-commissioned projects in France. It continues to roll out the Grand Carénage industrial refurbishment programme and the START programme⁽¹⁾;
• the “Industry and Services” unit, which manages operational activities involving design and studies, manufacturing and industrial services for nuclear steam supply systems, fuel, instrumentation and control (Framatome) and turbines (Arabelle Solutions).

1.4.1.1.2    Nuclear power generation in France

The electricity generated by EDF in France from its fleet of nuclear power plants represented 89.1% of its total electricity output in 2025⁽²⁾.

1.4.1.1.2.1    EDF’s nuclear fleet in France and its operation

EDF’s PWR fleet in operation is divided into four series of available power generation capacity. The French nuclear fleet consists of 57 reactors in operation⁽³⁾, located on 19 sites owned by EDF. Its total authorised capacity was 62,990MW at 31 December 2025. With an average age (excluding Flamanville 3) of around 40 years, it is within the average range of nuclear fleets installed worldwide.

• (1) The final power will be known after the start-up tests.

• (1) A transformation programme launched in 2021, focused on regaining industrial control of unit outages, which began its second phase (“START Season 2”) in 2026.
• (2) EDF SA in mainland France, including pumped-storage hydropower.
• (3) Including the Flamanville 3 EPR.

The commissioning dates of EDF’s reactors and the dates of their last 10-year inspection (VD - visite décennale), based on the post-inspection coupling date, were as follows as at 31 December 2025:

At the end of 2025:

• in the 900MW series, 25 of the 32 reactors had completed their fourth 10-year inspection. The fourth 10-year inspections of Cruas 3, Saint-Laurent 1, Blayais 4 and Cruas 1 were completed in 2025;
• in the 1,300MW series, 19 of the 20 reactors had completed their third 10-year inspection (including Penly 2 in 2025). The third 10-year inspection of Golfech 2 is currently being conducted;
• in the N4 series, all 4 reactors had completed their second 10-year inspection;
• for Flamanville 3, the reactor was connected to the national electricity grid on 21 December 2024. After this initial coupling, in accordance with the start-up procedure, the testing and grid connection and disconnection phases continued throughout 2025, and the reactor reached full power on 14 December after obtaining authorisation from the ASNR to exceed the 80% threshold on 12  December 2025. The Group has set the start date for Flamanville’s initial full inspection at 26 September 2026, for a provisional duration of 350 days.

Nuclear power allocation contracts

In the 1970s and 1980s, EDF developed industrial cooperation with European nuclear operators, in the form of nuclear power allocation contracts linked to reactors in EDF’s French nuclear fleet.

Under these contracts, a share of the capacity of the reactors concerned is reserved for the co-contracting parties, in exchange for payment of a corresponding share of the reactors’ overheads (construction costs, annual operating costs, decommissioning costs, local taxes and specific nuclear taxes, etc.); these parties are sold the same share of the power generated by these reactors at the variable cost of the fuel (including front-end and back-end costs) throughout their operating lifespan.

As of 31 December 2025, 10 of EDF’s nuclear reactors were concerned by contracts of this kind (up to 1GW) with the following European energy companies:

• Cattenom 1-2: EnBW (5%);
• Bugey 2-3: Électricité de Laufenbourg⁽¹⁾ (17.5%);
• Tricastin 1 to 4: Electrabel⁽²⁾ (12.5%);
• Chooz B1-B2: Luminus, an EDF subsidiary in Belgium (3.3%).

EDF has also entered into a second type of nuclear power allocation contract concerning a fleet of power plants (totalling some 2GW). In these contracts, the term and the contribution to overheads remain linked to clearly identified reactors, but the total volume of power sold at variable fuel cost is determined by the availability of a broader baseline fleet of power plants, applied to the share of capacity reserved for the co-contracting parties for the reactors in question. These contracts mainly concern the following reactors:

• Chooz B1-B2 (the first N4 reactors): Electrabel (21.7%);
• Cattenom 3-4: Électricité de Laufenbourg (7.8%) and the Swiss electricity group CNP (21.8%).

The contracting parties in both types of contract shared the industrial risks with EDF during the development of the fleet. They now bear risks associated with the power plants’ current operation, but have no operational role.

Operation of the nuclear fleet

Nuclear power is a means of generation with a low (mainly fuel-related) variable cost, that represents less than 30% of operating costs⁽³⁾. The main competitive levers of the nuclear fleet during its operating phase are thus the energy output and the optimisation of fixed operating and maintenance costs. The levers relating to the fuel cycle are described in section 1.4.1.1.2.3 “The challenges of nuclear operations”.

Generation cycle and scheduled outages

EDF must address the challenges of strong seasonal variations in consumption in France due to high sensitivity to temperatures, while managing availability of maintenance resources and efficient use of reactor fuel.

EDF has therefore adopted 12-month and 18-month generation cycles for its fleet, distributed as follows at end-2025:

• * The four reactors at the Bugey power plant.

Each generation cycle consists of a period when the reactor is in operation, and then an outage period during which a portion of the fuel is replaced. Two types of scheduled outages take place in alternation at the end of each operating cycle:

• simple refuelling outages, with a standard duration of approximately 40 days. The principal operation is unloading the spent fuel and reloading the new fuel. Certain tests and maintenance operations are also carried out;
• partial inspections, with a standard duration⁽⁴⁾ of around 85 days, dedicated to refuelling and maintenance.

Every ten years, each reactor is shut down in order to carry out a 10-year inspection⁽⁵⁾, and a safety review to assess the facility’s compliance with the rules applicable to it and update the assessment of the risks or issues associated with facility for the protected interests listed in Article L. 593-1. This review notably considers the condition of the facility, the experience gained during its operation, new developments in know-how, including knowledge on climate change and its effects, and the rules applicable to similar facilities. The risk assessment takes into account the consequences of climate change for the external attacks included in the assessment. The 10-year inspection lasts around 180 days⁽⁶⁾ on average. The duration varies according to the works and maintenance programme, and the series concerned.

The programme for a 10-year inspection comprises:

• unloading of spent fuel and reloading of fresh fuel, as at every outage;
• hydropower testing of the primary circuit, containment leakage testing, and inspection of the reactor vessel;
• modification work recommended by periodic reviews;
• other specific maintenance operations, particularly renovation or replacement of major components.

After each 10-year inspection, the ASNR must give its approval to restart the reactor for the next cycle and state its position on continuing operation for another 10 years, issuing technical recommendations if necessary.

Flamanville 3 is expected to generate around 14TWh during the cycle starting after the first nuclear reaction. After this first generation cycle, the reactor will undergo its first full inspection.

• (1) Axpo Group.
• (2) Engie Group.
• (3) Operating costs are defined as follows: fuel costs (including back-end fuel cycle expenses), operating expenses (purchases and external services, personnel expenses) and maintenance costs (expenses and investments). They do not include investments related to construction or decommissioning expenses.
• (4) The standard durations are realistic optimised benchmark durations defined by outage type, taking account of past experience. The planned duration of shutdowns varies around the benchmark depending on the programme of work to be carried out.
• (5) Pursuant to Article L. 593-18 of the French Environment Code.
• (6) The “normal” duration excluding special and/or extreme cases.

Operation of EDF’s nuclear fleet

Owing to their low variable cost, nuclear generation facilities are primarily used for baseload generation. They are used just after run-of-river hydropower and other unavoidable renewable energy generation, as well as energy purchased under purchase obligations from distributed electricity producers. In 2025, the low level of domestic consumption and the increase in renewable generation, partially offset by an increase in exports, once again led to use of the reactors’ flexibility capacities. High seasonal variations in consumption in France and the substantial demand during the winter months mean that scheduled nuclear fleet outages must be concentrated mainly between April and October.

On 20 February 2025, EDF’s Board of Directors authorised the signature of contractual documentation to start the experimental phase of the irradiation service agreed between the French State, the CEA and EDF⁽²⁾. This phase will last as long as necessary for EDF to study the feasibility of the service, which will have no impact on the operation or electricity generation purpose of the power plant concerned; it will remain governed by the regime for civil nuclear facilities. This irradiation service could potentially also be used in medicine or the aerospace industry.

Generation in 2025

Nuclear generation output stood at 373TWh for 2025, up by 11.3TWh compared with 2024 (361.7TWh). This increase was achieved by an improved performance on unit outages and good industrial management of inspections and the remaining stress control repair work.

2025 technical performance

The impact of the stress corrosion issue on nuclear generation was minimal in 2025 compared to previous years, as the action plan was completed thanks to industrialisation of the related technical and organisational work.

The START transformation programme, launched in 2021 with a focus on regaining industrial control of unit outages, continues to bear fruit: the average length of unit outage extensions is following a trajectory comparable to 2024. In the 2025 campaign, for 23 out of 42 completed outages recoupling took place before the target date, compared to 17 out of 41 for a comparable period in 2024. In view of its results, the START programme will enter a second phase in 2026.

The best 10-year inspection performance of the year was at Cruas 3, completed 16 days ahead of schedule. The best performances on partial inspections were at Paluel 4 in the 1,300MW series, completed 17 days ahead of schedule, and at Tricastin 1 in the 900MW series, completed 20 days ahead of the provisional schedule. Dampierre 2 and Saint Laurent B2 achieved the best refuelling outages, completed 11 days faster than initially planned.

However, during the 2025 campaign two reactor outages significantly overran their provisional duration (> 28 days). The reactors at Gravelines 2, Nogent 1, Belleville 2, Gravelines 1 and Chooz B1 were affected by design-critical technical hazards, while Golfech 2 was affected by industrial action. The recoupling of Belleville 2, Gravelines 1, Chooz B1 and Golfech 2 was postponed to 2026.

Nuclear generation output expressed in annual energy volume provides the basis for calculating a generation rate for the whole French nuclear fleet. This rate is defined as the ratio of energy generated to the theoretical maximum energy (the volume that would be generated by year-round operation at the installed capacity). It is also known as the load factor (“Kp”). It is calculated by multiplying two other factors (Kp = Kd × Ku):

• the availability factor (“Kd”) (ratio of available energy⁽³⁾ to theoretical maximum energy, i.e. the volume that would be generated by year-round operation at the installed capacity). The Kd depends on outage durations, and is therefore impacted by the standard durations and the work programmed for outages;
• the utilisation factor (Ku) (ratio of energy generated to available energy). The Ku reflects environmental, regulatory and labour constraints, system services supply, and optimisation carried out by EDF (via fuel and modulation).

The Kp factor of 69% is at a good level. It results from a Kd of 76.9% and a Ku of 89.7%.

Flamanville 3 EPR

The reactor was coupled to the national electricity grid on 21 December 2024. After this first coupling, in accordance with the start-up procedures, several test phases were undertaken:

• the 25% power test phase and the ASNR authorisation obtained on 31 January 2025 to exceed that threshold;
• the BAS 108 test, which consists of voluntarily cutting off external sources, carried out on 23 May 2025;
• the start of tests at 60% power from 29 May 2025 and the remainder of this test phase on 12 November, with an anti-islanding test carried out on 7 November 2025;
• the start of tests at 80% power from 12 November 2025, which led to the ASNR issuing authorisation on 12 December 2025 to bring the reactor to 100% power. This milestone was reached on 14 December 2025;
• the start-up programme is continuing with equipment testing at full power, taking readings and verifying that everything is working properly. The power is varied to continue the tests at different power levels.

• (1) The French Nuclear Safety and Radiation Protection Authority (ASNR) was officially created on 1 January 2025, the effective date of Law 2024-450 of 21 May 2024 on the organisation of governance of nuclear safety and radiation protection to meet the challenge of revitalising the nuclear industry.
• (2) See EDF’s press release of 18 March 2024 “EDF responds to the request of the French government to study the creation of an irradiation department to support the CEA”.
• (3) Available energy is equal to the theoretical maximum energy less generation losses due to technical reasons inherent to power plants, such as planned outages, unplanned outages due to damage or for safety reasons, and regulatory testing.

The start-up of a reactor is a long and complex process that brings equipment into operation for the first time. This explains the unplanned outages experienced by the new reactor, including:

• an outage from 15 February 2025 to 19 April 2025 to carry out work on several pieces of equipment, particularly the turbine;
• an outage from 19 June to 15 October 2025 in order to carry out work on the three protection valves in the primary circuit.

Equipment manufacturing and quality – the reactor vessel

In the first half of 2017 the ASNR examined higher-than-expected carbon content levels in the bottom of the reactor vessel and the vessel head, following documentation submitted by Framatome under EDF’s supervision. Based on the opinion of a group of ASNR-appointed experts, the ASNR concluded that the mechanical properties of the vessel head and vessel bottom were adequate for their uses, including in the event of an accident⁽¹⁾. On 9 October 2018, the ASNR authorised commissioning of the bottom of the vessel subject to functional checks, and commissioning of the vessel head for a limited lifespan until the end of 2024.

In December 2022, Framatome submitted a request to postpone the date for replacement of the vessel head until the end of the first operating cycle.

In response to this request, and following the public consultation held from 11 to 31 March 2023, the ASNR published a resolution on 16 May 2023 authorising use of the current reactor vessel head until “the reactor shutdown during which the first complete requalification test of the primary circuit takes place”.

The new vessel head has now been manufactured in Framatome’s factories. The existing one will be replaced during the first full inspection.

Lessons learned from Taishan

EDF has taken into account the lessons learned from the start-up and operation of EPRs currently in service internationally.

Before the first nuclear reaction at the Flamanville 3 EPR in September 2024, measures were taken to replace 64 heat-treated peripheral fuel assemblies at the Taishan 1 EPR in order to guard against the risk of fuel rod leaks observed during its second operating cycle. These fuel leaks were caused by:

• the failure of devices (springs) in certain fuel assembly retention grids located on the periphery of the reactor core, as these springs did not undergo rapid, sufficient irradiation due to the extended power ramp-up time;
• wear and tear on the fuel cladding (the metal casing containing the uranium pellets) due to friction with the broken springs.

Following the longer than expected ramp-up period for the Flamanville 3 EPR, adopting a prudent, conservative approach, an additional measure was implemented during the first full inspection, involving the introduction of non-irradiated fuel assemblies into the Flamanville 3 reactor core before the start of its second operating cycle.

These preventive measures have been shared with the ASNR.

Cost to completion

For details on the investments made for the Flamanville 3 EPR, see section 6.1 “Consolidated financial statements at 31 December 2025”, note 9.3 “Property, plant and equipment used in generation and other tangible assets by the Group”.

Repairs of stress corrosion detected on the auxiliary circuits of a number of nuclear reactors

During scheduled controls included in the 10-year inspection of the Civaux 1 reactor in late 2021, stress corrosion was identified on parts of the auxiliary circuit piping in the reactor’s main primary circuit. EDF immediately carried out inspections and expert appraisals of the four series of reactors making up the French nuclear fleet (900MW, 1,300MW-P4, 1,300MW-P’4 and N4).

The examinations performed in 2022 led to an initial characterisation of the stress corrosion sensitivity of the fleet’s 56 reactors: 40 reactors were identified as having little or no sensitivity to stress corrosion (the 32 reactors in the 900MW series and the 8 reactors in the 1,300MW-P4 series), and 16 reactors were identified as sensitive or highly sensitive to stress corrosion (the 12 reactors in the 1,300MW-P’4 series and the 4 reactors in the N4 series). The industrial programme for the preventive replacement of sections of piping in stress corrosion-sensitive reactors ended in the first quarter of 2024.

The reactor inspection programme continued in 2025 with a volume of checks similar to 2024. The inspections were carried out during scheduled maintenance outages and no additional or dedicated outages were conducted. As a result the auxiliary lines inspection programme was completed by the end of 2025 as initially scheduled, supplemented by controls on other lines (pressuriser expansion lines, main primary circuit, small-diameter lines).

EDF has finalised its monitoring and maintenance strategy and submitted it to the ASNR, which is expected to state its position in 2026.

Two processes for desensitising lines to stress corrosion (remote levelling of internal wall welds and compression of welds) were qualified and implemented at several reactors in 2025.

The stress corrosion management project was closed at the end of 2025 and stress corrosion monitoring will transition to permanent mode in routine equipment maintenance programmes from 2026, through implementation of the monitoring and maintenance strategy.

The risk associated with the stress corrosion issue is described in section 2.2.1 “Operational performance risks” risk 1B “Risk of non-achievement of objectives for operation and/or lifespan extensions of nuclear power plants (France and United Kingdom)”.

Action against Counterfeit, Fraudulent and Suspect Items (CFSI)

EDF continues to pay particular attention to quality control in the manufacturing and assembly of parts for nuclear plants in operation or under construction. The detection of any signs of fraud or suspicious practices systematically leads to investigations and the implementation of actions to protect EDF’s interests.

Given the current increase in practices that could relate to CFSI, EDF has launched an action plan primarily designed to strengthen its prevention and detection capabilities and engage the entire nuclear sector in the fight against CFSI. Details of this plan, which defines targeted and graduated actions, were presented in a letter from EDF to the ASN dated 19 March 2024, and it has been considered appropriate by the ASNR.

In 2025, implementation of these reinforcement actions continued at both the fleet in operation and the power plants under construction.

At the fleet in operation, documentation checks and inspections of components potentially suspected of being CFSI did not reveal any particular anomalies in the equipment concerned.

• (1) ASN Opinion 2017-AV-0298 of 10 October 2017.

1.4.1.1.2.2   Nuclear safety, environment, radiation protection

The risks related to nuclear safety, the environment and radiation protection are described in section 2.2.2 “Specific nuclear operation risks”, risk 2C “Nuclear safety risks at plants in operation resulting in nuclear civil liability”.

Constant nuclear safety

As a nuclear operator, EDF takes responsibility for nuclear safety. In a rapidly changing context (competitive market, environmental challenges, European interconnection, etc.), EDF reaffirms the absolute priority of protecting human health and the environment, notably by preventing accidents and limiting their nuclear safety consequences. Implementation of the French nuclear power programme has led EDF to put in place a safety policy that:

• takes into account, right from the design stage, the risks and issues that might arise during power plant operation (risks relating to the operation itself, and to internal or external attacks);
• is founded on application of strict rules of operation, and a cautious and inquiring attitude in its technical teams, developed through establishment of a true safety culture;
• draws on the experience accumulated from operating a standardised fleet;
• integrates and promotes a continuous improvement approach, notably embodied in a constant concern to reduce the number of automatic reactor shutdowns;
• benefits from nuclear engineering and R&D internal to the Group, in order to anticipate any failings, maintain facilities in good working order, upgrade equipment continuously, reassess safety margins, monitor technological advances, and implement new, more efficient techniques and project management for facilities undergoing decommissioning;
• invests significantly in skill development: every nuclear generation site is equipped with a simulator used for training and practice for all types of situation.

The control system

Nuclear safety is subject to numerous controls, both internal and external. For each nuclear power plant⁽¹⁾, EDF carries out Overall Excellence Assessments jointly with WANO⁽²⁾ peer reviews every four years. These take place over a three-week period and involve some 40 inspectors.

The General Inspector for Nuclear Safety and Radiation Protection is appointed and reports directly to the Chairman and CEO of EDF. He or she holds discussions with employees in the nuclear sector. Every year, an opinion on the overall safety of France’s nuclear fleet is issued based on the inspections carried out, and initiatives for improvement are proposed to the Company’s management. The Inspector’s annual report is made public.

The steps taken by EDF have reduced the average annual number of automatic reactor shutdowns, which has been divided by four in some twenty years. In 2025, there were 23 across the entire fleet, including one at the Flamanville 3 reactor.

• At national level, nuclear safety in France is controlled by the ASNR by means of:

• > scheduled or unannounced inspections carried out by the ASNR: around 450 per year across all EDF’s nuclear facilities,
• > regular 10-year inspections to verify the facility’s compliance with the rules applicable to it. These inspections are also conducted to update assessments of risks or issues associated with the facility for protected interests (public safety, health and sanitation, and the protection of nature and the environment). They consider the condition of the facilities, the experience gained during their operation, new developments in know-how, including knowledge on climate change and its effects, and the rules applicable to similar facilities.

At the end of the 10-year inspection, the operator sends the ASN a report on the conclusions, stating its position regarding the compliance of its facility, and the changes made to correct any points of non-compliance identified or improve the safety of the facility. The ASNR shares its analysis of this report with the minister responsible for nuclear safety, and states its position as regards continued operation of the reactor for another 10 years following the inspection. It may also set additional requirements for the operator⁽³⁾. The 10-year inspection is an essential step for continuing power plant operation.

• (1) They involve the Nuclear Electricity Generation Centres (CNPEs).
• (2) World Association of Nuclear operators.
• (3) See the Regulatory framework panel, “The Nuclear Safety Authority, now the Nuclear Safety and Radiation Protection Authority (ASNR)”, in section 1.4.1.1.2.1 “EDF’s nuclear fleet in France and its operation”.

• At international level, inspections take place regularly. They are a channel for sharing experience accumulated worldwide:

• > inspections by the IAEA’s⁽¹⁾ Operational Safety Analysis Review Team (OSART) are carried out at the request of the French State (once per year). Their purpose is to make recommendations and spread good practices. In 2025, an OSART inspection was carried out at Chinon,
• > international peer reviews conducted by the WANO⁽²⁾ are organised at the request of EDF. They involve a safety performance assessment with regard to international best practices. In 2025, four peer reviews were carried out.

Warning system

In the event of an accident, a crisis response procedure is in place to limit the environmental and human impacts and make sure the facility is safe. This procedure is founded on two closely coordinated plans, designed to cover the local and national level respectively:

• the internal emergency plan for each nuclear site, developed by EDF;
• the special intervention plan, prepared by French prefectures in collaboration with the French government and EDF.

For greater effectiveness, these plans take account of risks both external (flooding, etc.) and internal (fire, etc.). The adequacy of the system for warning, informing and protecting people is regularly assessed through accident simulation exercises. Each year, approximately 100 exercises are organised for the entire French nuclear fleet, i.e. around one every three days. Around ten of these are nationwide exercises overseen by the ASNR, which involve EDF and the public authorities, including the prefectures.

EDF has been enriching its crisis management procedure since the earliest analyses following the Fukushima accident of March 2011. It has set up a national unit capable of providing rapid material and human assistance to any site experiencing a serious issue. Simulation exercises for this nuclear rapid response unit, called the FARN, have been conducted from the regional bases at Civaux, Paluel, Dampierre and Bugey. The unit can be deployed to a reactor at any site in difficulty.

Significant safety events

The operational safety of nuclear facilities is taken into consideration right from their design phase. It is regularly monitored, with a staff mobilisation policy and major investment plans.

Any shortcoming classified as particularly important according to the detailed criteria defined by the ASNR is referred to as a “significant event”. The detection of significant events by nuclear operators plays a key role in the prevention of incidents and accidents. The regulations require all nuclear operators to declare significant events to the ASNR, to protect the interests listed in Article L. 593-1 of the French Environment Code.

The significance of the event is determined by the power plant’s management based on an analysis carried out by the plant’s teams and the site’s independent safety department.

The declaration process for significant safety events (SSE) is part of the ongoing drive to improve nuclear safety and transparency. One of its main aims is to enable analysis of these events, so as to facilitate the subsequent assessment of an incident or the risk of an incident, and improve prevention practices in an establishment and/or a sector of activity.

All significant events must be declared to the ASNR by the nuclear operators or transporters within a maximum period of 48 working hours. Declarations include a proposed classification on the INES⁽³⁾ scale (which comprises seven levels from 1 to 7, depending on the events’ significance; events with no nuclear safety significance are classified INES level 0). The ASNR retains final authority for the classification of events. The ASNR refers to the INES scale to select events that are sufficiently serious to warrant a public statement.

Since the introduction of a scale of this kind in France in 1987, no event at INES level 3 (serious incident – very low external radioactive emission and exposure of the public, representing a fraction of regulatory limits) or above has occurred in the French nuclear fleet. In 2025, EDF declared 742  significant safety events (SSEs) in France, excluding Flamanville 3, compared to 755 SSEs in 2024. No SSE of INES level 2 or above was declared (as in 2024).

The Group’s nuclear safety policy is an integral part of the training given to employees of EDF and its service providers. After initial training lasting several months – up to 24 months for key positions (safety engineer, operator, etc.) – each employee must undergo mandatory retraining every year, two years or three years, depending on the functions and fields of activity.

Detailed nuclear safety results for 2025 are published in the annual report drawn up by the General Inspector for Nuclear Safety and Radiation Protection and are available online⁽⁴⁾.

Environmental protection

EDF’s environmental approach was initiated in 2002 at a number of sites. It was then extended to all nuclear generation units. It is based on an ISO  14001-certified environmental management system (EMS). See section 3.2.1 “Environmental management system”. For a description of the processing of radioactive waste from the back-end of the fuel cycle and decommissioning, see section 1.4.1.1.2.3 “The challenges of nuclear operations”.

Radiation protection

Thanks to mobilisation of the various stakeholders, EDF is continuing the drive for improvement of radiation protection and dosimetry (through training and exercises for employees and management, stricter monitoring of plant cleanliness, upgrading the equipment available to operators, optimised installation of lead screens, standardisation of working methods and equipment on the nuclear sites, reinforced supervision, etc.).

As a result, for the past decade the average annual collective dose is 0.69 man-Sieverts (manSv)⁽⁵⁾ per reactor, down by 1% from the previous decade, whereas the average volume of hours worked has increased by 23%. In 2025, the average collective dose was 0.68 manSv per reactor. The average annual individual dose (EDF employees and industrial partners) remained below 1 millisievert (mSv) in 2025 (0.81mSv), well below the regulatory limit of 20mSv for the whole body over a rolling 12-month period.

EDF is proactively pursuing its ALARA (As Low as Reasonably Achievable) policy to manage collective dose levels. It continues to reduce exposure to radiation through multi-year plant clean-up programmes, and by testing new technologies aimed at reducing the radioactive source term.

• (1) International Atomic Energy Agency.
• (2) World Association of Nuclear operators.
• (3) International Nuclear Event Scale.
• (4) 2025 report: igsnr.com/wp-content/uploads/2026/02/Rapport-IGSNR-2025.pdf
• (5) Sum of the doses absorbed by the whole body due to exposure to radiation from radioactivity for all activities and all persons involved.

1.4.1.1.2.3   The challenges of nuclear operations

A – Stages and challenges of the nuclear fuel cycle

The risks associated with the nuclear fuel cycle are described in chapter 2, risk 2B “Risks related to control of the fuel cycle”.

The nuclear fuel cycle encompasses all industrial operations in and outside France which contribute to supplying fuel to generate energy in a reactor, then to unloading and processing the fuel.

EDF coordinates all the operations in the cycle, which consists of three stages:

• the front end of the cycle, comprising the purchase by EDF of concentrates derived from uranium ore, which are then made into more sophisticated products through fluorination (or conversion), enrichment, and fuel assembly fabrication by industrial fuel cycle operators with which EDF has multi-year service contracts;
• the core of the cycle, when the fuel is used in the reactor: reception, loading, operation, and unloading. The fuel stays four to five years in the reactor. These operations are carried out by EDF;
• the back end of the cycle, for the reactor fleet in France, comprising interim pool storage, reprocessing of spent fuel, conditioning of radioactive waste and recycling of reusable materials, and interim storage of conditioned waste prior to long-term storage.

In most cases EDF is the owner of, and responsible for, the fuel and materials it uses in the various stages of the cycle.

Front end of the cycle

To ensure continuity and security of supply for its reactors in France and the United Kingdom, EDF retains overall control of all operations at every stage of the cycle, through a portfolio of contracts and by building up stocks at the various stages of the front end of the cycle (natural uranium, fluorinated enriched or unenriched uranium, and warehousing of new fuel assemblies). Orano is an important supplier in this stage of the cycle.

Natural uranium procurement

EDF’s uranium supplies are guaranteed by long-term contracts for periods of up to 20 years, following a policy of diversification in terms of sources and suppliers. The indexation formulas in these supply contracts are partly fixed (baseline prices that may be inflation-adjusted) and partly variable (based on market price indexes). They generally stipulate floor and ceiling prices that moderate the effects of market price fluctuations on supply costs. Where necessary, the Group implements a strategy to hedge its foreign exchange risk and the US inflation risk.

EDF takes care to implement best practices in mineral extraction. Since 2011, EDF has carried out regular mine audits based on a method developed with the WNA⁽¹⁾. See section 3.3.3.4.3 “Responsibility in the fuel supply chain”.

Fluorination (or conversion)

EDF’s needs are covered by Orano in France, and other producers internationally such as Cameco in Canada and Converdyn in the United States.

Enriching natural uranium in uranium-235

EDF covers its enrichment service requirements through contracts with major global enrichment companies: Orano (France), Urenco (United Kingdom, Germany, Netherlands, United States), based on contracts with mostly fixed prices.

Enriched reprocessed uranium

Since the 1990s, reprocessing has made it possible to recycle uranium from spent fuel processing (95% of the spent fuel mass) for reuse in the reactors. This reprocessing resumed in 2018 and currently concerns four 900MW reactors. Subject to the completion of technical modifications and obtaining the necessary authorisations, some 1,300MW reactors will receive reprocessed uranium-based fuel assemblies by 2027.

Fuel assembly fabrication

EDF sources its fuel assemblies either internally, through its subsidiary Framatome, or externally from Westinghouse.

Fuel supply for the two EDF reactors at Hinkley Point C (United Kingdom)

In September 2016, EDF, Orano and Framatome signed agreements for the supply of uranium, conversion and enrichment services, and fuel assembly fabrication, for the Hinkley Point C reactors’ fuel supply.

Back end of the cycle

The risks associated with the back end of the cycle are described in section 2.2.2 “Specific nuclear operation risks”, risk 2A “Risks related to control of radioactive waste processing, decommissioning of nuclear facilities, and secure coverage of the related obligations” and risk 2B “Risks related to control of the fuel cycle”.

In accordance with its powers under Article L. 594-4 of the French Environment Code, in early 2024 the Directorate General for Energy and Climate (DGEC) and the French Treasury commissioned an external audit of the valuation of EDF’s spent fuel management costs at 31 December 2023. The audit began in the second quarter of 2024 and was completed on 28 May 2025 with no significant impact on EDF’s approach to calculating its obligation as reflected in the amount of the provision for spent fuel management at 31 December 2023. To date, the DGEC, which commissioned this audit, has not yet issued a follow-up letter.

Processing of spent fuel from EDF’s nuclear power plants

EDF’s current strategy, in agreement with the French State, is to process spent fuel and wherever possible recycle substances: plutonium in the form of MOX fuel, and reprocessed uranium (see “Front end of the cycle” above).

Some 1,100 tonnes of spent fuel are processed every year. The volume is determined by the amount of recyclable plutonium in the reactors that are authorised to load MOX fuel.

The spent fuel journey

EDF and Orano: a close partnership

Relations between EDF and Orano concern the shipment, processing, and recycling of spent fuel. The two companies have entered into a series of agreements:

• in December 2008: a framework agreement covering the period 2008-2040;
• in October 2024: an implementation contract covering the period 2024-2026, and the related supply contracts for MOX assemblies.

Spent fuel storage capacities

On 26 February 2024 the Nuclear Policy Council (CPN), chaired by the French President, confirmed France’s policy for the back end of the nuclear fuel cycle, involving continuation of the processing and recycling of spent fuel with a view to closing the cycle. These policy orientations are in line with the French President’s speech given in Belfort on 10 February 2022 concerning the continued operation of the current fleet and the construction of new reactors.

• (1) World Nuclear Association.

EDF and Orano have proposed an industrial plan for the future nuclear fuel cycle facilities at the Orano site in La Hague, notably including a new spent fuel processing plant and a new MOX fuel fabrication plant. Orano will be the project manager of the plan, which also comprises a project for new storage capacities that will later be connected to the future processing facilities. This plan was presented to the ASNR on 24 September 2024 and the DGEC, in its letter of 10 March 2025, did not issue any objections. In addition, the CPN specified on 17 March 2025 that the plan “will principally be financed by EDF”. The industrial plan, developed under the leadership of Orano, is the “Aval du Futur” programme. At its meeting of 12 March 2026, the Nuclear Policy Council took note of the progress made on this programme, which aims to upgrade the back-end fuel cycle facilities at La Hague in order to meet the needs of the existing nuclear fleet, and subsequently the EPR2 reactors. It also highlighted the preliminary agreement reached between Orano and EDF, which will secure the programme’s development until the final investment decisions are taken.

Moreover, the prospect of keeping the current nuclear fleet in operation beyond 50 years if the safety conditions are fulfilled, as stated in the President’s speech given in Belfort, has deferred the horizon of the saturation risk for the spent fuel storage facilities operated by Orano in La Hague to 2040, or possibly later.

The projected commissioning date of these new storage capacities is compatible with the needs identified for the purpose of continuing the operation of the nuclear fleet.

Finally, implementation of the plan to densify the storage pools at Orano’s current facilities in La Hague is continuing, marked by immersion of the first densified baskets in mid-2025. This plan is an effective countermeasure to the risk of saturation in the event of a malfunction in the fuel cycle facilities.

As another supplementary solution, Orano is also studying the possibility of dry temporary storage for spent fuel. Specific financial provisions have been set aside for the dry storage and densification scenarios.

Storage of conditioned final radioactive waste

Radioactive waste is classified into different categories depending on its nature, its level of radioactivity and the lifespan of its radionuclide components: high-level waste (HLW), intermediate-level waste (ILW), low-level waste (LLW) and very low-level waste (VLLW). It is called long-lived (LL) when it remains active for more than 31 years.

High-level waste and long-lived intermediate-level waste

After spent fuel processing, vitrification of high-level waste (HLW) is possible; this is a very high-quality conditioning process resulting in a small volume. The volume of waste is calculated on the basis of a reference inventory corresponding to the former plants’ operation and 50 years of operation for the current PWR fleet (including Flamanville 3). The total volume of all the HLW conditioned in this way is around 9,300m³ (electricity consumption by one million people over one year generates around 3m³ of HLW).

Long-lived intermediate-level waste (ILW-LL) includes:

• structures from assemblies (radioactive waste flasks and end-pieces, pieces of fuel cladding, etc.) separated during spent fuel processing. They are currently compacted and conditioned in stainless steel containers;
• waste resulting from certain operating, maintenance and dismantling activities.

The total volume of ILW-LL is about 37,000m^3. This includes waste generated during the operation and decommissioning of permanently shut-down installations, including UNGG (natural uranium graphite gas) reactors, and waste from the PWR fleet currently in operation (including Flamanville 3). The calculation is based on a 50-year operating lifespan for PWR plants.

This waste generates less heat than HLW and can thus be placed in storage sooner.

The Cigéo project for an industrial geological storage centre

Overview

The Cigéo project is France’s deep geological storage facility project for ILW-LL and HLW generated by all French nuclear facilities until they are decommissioned, including waste from spent fuel processing. This project is led by ANDRA. The centre is to be located in the east of France at the border between the Meuse and Haute-Marne départements.

After 15 years of research, evaluation and a public debate, the principle of deep geological storage was adopted by Law 2006-739 of 28 June 2006 (amended) on the sustainable management of radioactive materials and waste, as a safe long-term solution to manage this type of waste without shifting the burden onto future generations. Cigéo will consist of surface facilities to receive and prepare waste packages, and to excavate and build the necessary underground structures. The waste will be stored in installations some 500 metres underground, in an impermeable layer of argillaceous rock able to contain radioactivity over very long periods (several hundred thousand years). Cigéo is designed to operate for at least 100  years while having the flexibility to be adaptable for future generations.

Pending its storage in deep-level geological layers, HLW and ILW-LL from the reprocessing of spent fuel at the Orano plant in La Hague is stored on site in dedicated specific facilities.

Key stages of the project

On 11 January 2018, the ASN considered that the Cigéo project had reached satisfactory overall technological maturity at the safety options file stage. A detailed design review was organised by a group of independent experts at the request of the Directorate General for Energy and Climate (DGEC). In late 2020, this group issued a generally favourable opinion on the file presented by ANDRA.

The public inquiry regarding the Cigéo project’s public utility was held between 15 September and 23 October 2021. It resulted in a favourable opinion from the inquiry commissioners (along with five recommendations to the project manager), made public on 20 December 2021. The findings of the commission noted that the public enquiry had “attracted a large number of contributions from the public, most of them with extensive supportive arguments” and that Cigéo was “opportune, relevant, and robust”.

Prior to the enquiry, a second appraisal of Cigéo’s Socioeconomic assessment by France’s General Secretariat for Investment (SGPI) had resulted in a favourable opinion “both for the overall project and its transport component”. It stressed that “the Cigéo project has strong prudential and insurance value to cope with environmental and health risks”.

In an opinion issued on 13 January 2021, the French Environmental Authority emphasised the educational nature of the environmental assessment. It made a series of recommendations, which ANDRA took into account in the public inquiry.

Decree 2022-993 of 7 July 2022 declared Cigéo to be in the public interest and adjusted the Pays barrois (Meuse) area land use master plan, the Haute-Saulx (Meuse) local inter-municipality urban planning document, and the Gondrecourt-le-Château (Meuse) local urban planning document for compatibility. Decree 2022-992 of 7 July 2022 also included the Cigéo project among the operations of national interest specified in Article R. 102-3 of the French Urban Planning Code.

The application for an authorisation to create the Cigéo centre was submitted on 17 January 2023.

On 22 June 2023 the ASN declared the application admissible, and on 27 June 2024 France’s Environmental Authority also issued an opinion on the application to create the centre. This meant that technical examination of the application could begin. This involved three meetings of the ASN’s Advisory Committee of Experts: the first took place in April 2024, the second in December 2024, and the third in June 2025. In an opinion issued on 25 November 2025, the ASNR considered that ANDRA had acquired sufficient knowledge regarding the basic data used for the safety assessment and that the safety demonstration for the operational and post-closure phases, based on that knowledge, was satisfactory at the stage of application for an authorisation to create a new facility. This demonstration will have to be expanded in preparation for commissioning, which will be limited to the pilot industrial phase. The ASNR considers that the file, supplemented by ANDRA in accordance with the commitments it made during the investigation, could give rise to a public inquiry.

ANDRA’s schedule underlying the costing defined in 2016 includes an initial industrial pilot phase and anticipated delivery of the first waste between 2035 and 2040. This date will be updated in the reference schedule supporting the new cost order.

Treatment of bituminous waste

As part of its review of Cigéo’s safety options file, the ASNR requested that alternative options to storing bituminous waste in its current state at Cigéo be investigated. In September 2018, a group of experts was appointed by the DGEC to draw up a report on current bituminous waste management practices. In September 2019, this group concluded that the various management options (storage or neutralisation) were feasible in principle. However, it stressed the importance of continuing the studies already under way to identify the most appropriate option. A four-party research programme involving producers and ANDRA is still exploring this question.

Cigéo tax status

Regarding the tax status of Cigéo, Article 127 of France’s Finance Law for 2021 modified the tax regime for basic nuclear facilities (INB) set out in Article 43 of France’s Finance Law for 2000. It introduced a change in the calculation method for the tax on storage of high-level waste and long-lived intermediate-level waste. Subsequently, Article 18 of the Finance Law for 2025 codified the provisions relating to the INB tax that will be payable by Cigéo. However, the application measures for these principles and their potential impact on the level of taxation on the installation have yet to be clarified.

Costing of Cigéo

Cigéo’s current reference costing is specified in the order of 15 January 2016.

In May 2025, ANDRA submitted a report on the Cigéo cost update to the Directorate-General for Energy and Climate (DGEC), the ASNR and the relevant parliamentary committees. Stakeholders, including waste producers, issued an opinion on this report which will lead the State to set the new “target cost” for Cigéo in the first half of 2026. EDF has nonetheless updated the Cigéo provision in the 2024 financial statements to take account of information that is sufficiently certain and was not included in the 2016 cost calculation.

The ICEDA radioactive waste conditioning and interim storage facility

ICEDA, located at the Bugey site, is the facility dedicated to the conditioning and interim storage of long-lived intermediate-level waste (ILW-LL) from operations (excluding ILW-LL from spent fuel processing) and reactor dismantling. The facility was commissioned in 2020 and conditioned its first waste in 2021.

Since 2021, all the radioactive waste from decommissioning operations at Chooz A and operating activities at Fessenheim and Cruas has been conditioned at the ICEDA facility.

In 2024, the ASN approved a modification to the radiological characteristics of waste that could be received for conditioning at the ICEDA facility. On 24 February 2025, the ASNR granted conditioning authorisation incorporating the new scope, allowing ICEDA to condition 100% of the waste for which the facility was designed.

After the two reactors at the Fessenheim plant were shut down permanently, EDF filed an application to modify the ICEDA’s authorisation decree in order to allow the facility to condition waste resulting from the decommissioning of Fessenheim. The amended decree was published on 28 February 2025.

Long-lived low-level waste

Long-lived low-level waste (LLW-LL) comes from the dismantling of UNGG reactors (graphite bricks that made up the core of these reactors and their fuel assemblies). In July 2015, ANDRA submitted a report on the feasibility of a storage facility located in the Soulaines region (Aube) in France to the ASN for review. Work on this proposal is ongoing as part of the National Plan for Managing Radioactive Matter and Waste (PNGMDR), to identify the waste that could be stored in the facility.

In accordance with ASN opinion 2020-AV-0357 of 6 August 2020 and the  fifth PNGMDR⁽¹⁾, in March 2024 ANDRA submitted a file presenting the  technical and safety options selected for LLW-LL storage at the  Vendeuvre-Soulaines site. This file is currently being examined by the ASNR.

In addition, the studies conducted by EDF to characterise the radiological inventory of this waste in more detail have demonstrated significant gains, suggesting that it should be possible to store the graphite from the first decommissioned reactor (Chinon A2) in the existing Aube surface level storage centre, with no need to wait until a specific storage centre is commissioned.

The scenario currently modelled in the financial provisions for Chinon A2 graphite extracted from the reactor up to 2045 is therefore storage at the Aube centre, assuming construction of a temporary storage facility at Chinon and final storage in a specific LLW-LL centre.

For other reactors, the financial provisions cover direct storage of graphite waste in an LLW-LL repository.

Short-lived low-level and intermediate-level waste and very-low-level waste

Short-lived low-level and intermediate-level waste (LILW-SL) and very low-level waste (VLLW) comes from:

• the operation of nuclear facilities: gloves, filters, resins, etc.;
• the decommissioning of these facilities: concrete, scrap metal, insulation, pipes, etc.

This type of waste is stored near surface at the Soulaines and Morvilliers facilities run by ANDRA in the Aube département. To reduce volumes, some waste undergoes preliminary melting or incineration at the Centraco plant owned by Cyclife France.

Following the public debate on the PNGMDR carried out in 2019, in line with the joint decision by the Ministry for the Ecological Transition and the ASN (the authorities in charge of the PNGMDR), legislation allowing the reuse of very low-level metallic waste in France was published on 14 February 2022. This regulatory change made it possible to implement an industrial recycling and sale solution for this waste metal. This is the purpose of the EDF-developed Technocentre project, concerning a dedicated facility for recycling and sale of very low-radioactivity metals, to be located on the Fessenheim site.

EDF referred the Technocentre project to the National Public Debate Commission (CNDP) in early 2024. The public debate, organised by the CNDP and led by EDF, took place from 10 October 2024 to 7 February 2025 and after it ended EDF decided to go ahead with the project.

Creation and development of the Cyclife group: a subsidiary dedicated to decommissioning and radioactive waste management

EDF created the holding company Cyclife in 2016 following the acquisition of the English and Swedish assets of the waste processing company Studsvik. The objective of the Cyclife group, formed by merging Cyclife UK, Cyclife Sweden and Cyclife France (formerly a SOCODEI subsidiary), is to consolidate development of the Group’s internal and external waste processing and decommissioning activities, with two aims:

• to take advantage of opportunities on the decommissioning market in Europe and Japan, capitalising on the know-how and assets developed for decommissioning work in France;
• to control critical operations and key technologies and optimise them over the long run, to provide a secure foundation for the EDF group’s future decommissioning operations.

• (1) Decree 2022-1547 and the implementation order published in France’s Journal officiel of 10 December 2022.

In 2018, Cyclife SAS acquired an 84.6% stake in Cyclife Digital Solutions, which specialises in systems and digital simulation for decommissioning and waste management. This subsidiary is now wholly-owned.

In 2019, the subsidiaries Cyclife Engineering and Graphitech⁽¹⁾ were formed to develop solutions for dismantling light-water reactors and designing waste processing facilities (Cyclife Engineering), and for dismantling graphite reactors (Graphitech).

Cyclife Germany was set up in December 2021 to provide a direct presence in one of the largest markets in Europe, in order to strengthen Cyclife’s positioning in waste processing and facilitate its development in decommissioning activities.

On 22 December 2021, Cyclife SAS signed a contract to acquire the engineering company Aquila Nuclear Ltd. in the United Kingdom.

This new acquisition strengthened Cyclife’s position in the United Kingdom’s nuclear engineering sector and complemented the introduction of a decommissioning business unit at the subsidiary Cyclife UK, which was already active in this market.

In February 2022, EDF set up a new nuclear waste management subsidiary owned in equal shares by Cyclife SAS and Veolia Nuclear Solutions, named Waste2Glass. Its purpose is to develop new nuclear waste processing channels using vitrification based on the Veolia group’s Geomelt and MVS processes, and conduct technical and economic feasibility studies for identified nuclear waste streams.

On 31 March 2022, the Cyclife group pursued its expansion by acquiring the French company Quadrica, a specialist in the development of digital tools. In January 2024, Cyclife Digital Solutions and Quadrica merged, to gain in visibility and continue development of digital solutions.

On 1 January 2024, Cyclife Japan was created to strengthen the Group’s Japanese footprint. Initial partnerships have already underpinned work on the relevance of the solutions offered by Cyclife to the needs of Japanese nuclear operators.

In June 2024, Cyclife GmbH acquired 100% of the shares in BalckeDürr Nuklear Service, which has since been renamed Cyclife GmbH. This company specialises in decommissioning and clean-up operations and waste sorting/conditioning/release services, with projects notably in Germany and Sweden.

On 1 July 2025, the acquisition of 51% of DNUC and Effectiv Consulting (EC) was completed via the subsidiary Cyclife Engineering. DNUC and EC specialise in on-site work and dismantling operations.

The Cyclife Technocentre subsidiary was created in November 2025 to build and operate the new VLL metal recycling facility in Fessenheim.

On 1 January 2026, the subsidiaries Cyclife UK and Cyclife Aquila Nuclear merged into Cyclife UK to improve their visibility, strengthen their market presence and optimise cross-functional activities.

The Cyclife Group is therefore continuing its growth (over 1,400 employees at the end of 2025). With operations in five countries (France, Germany, the United Kingdom, Sweden and Japan), Cyclife is able to provide a fully integrated decommissioning/waste management offering.

R&D

EDF conducts both its own R&D activities and R&D with a network of partners (nuclear operators, industrial operators, very small, small and medium-sized businesses, institutional and academic players). This work focuses on radioactive waste management and decommissioning. As a recognised major player in these areas, EDF is actively participating in four different European projects, aiming to:

• improve the performance of waste management and decommissioning projects;
• develop its expertise;
• contribute to the development and implementation of international best practices.

Coverage of future expenses for spent fuel management and long-term radioactive waste management

Every year, EDF sets aside financial provisions for the back end of the nuclear fuel cycle in France and for radioactive waste management⁽²⁾.

B – The challenges of preparing for the future of the nuclear fleet in France

The French Environment Code does not specify any maximum operating lifespan for nuclear installations, but it requires an inspection every 10  years to assess their compliance with applicable regulations, and an updated assessment of their risks and issues for protected interests. These assessments consider the condition of the installations, the experience gained during their operation, new developments in know-how, including knowledge on climate change and its effects, and the rules applicable to similar facilities.

EDF’s industrial strategy is to continue operation of the fleet significantly beyond 40 years, in optimum conditions as regards safety and efficiency, given the significant investment made during the fourth 10-year inspections, the post-Fukushima improvements, and French energy needs. The French President announced during a speech on 10 February 2022 in Belfort that he wanted “to extend the lifespan of all reactors that can be extended” and that “no nuclear reactor in operation will be closed in the future (…), except for safety reasons”. He also stated that he had asked EDF to “study the conditions necessary for extending the lifespan beyond 50 years”, paving the way for continuing operation of France’s nuclear reactors beyond a 50-year lifespan.

EDF’s industrial ambition as it prepares for the future of the nuclear fleet refers to three time horizons: up to 50 years, 50 to 60 years and beyond 60 years

Up to 50 years

EDF is carrying out the fourth 10-year inspections of its 900MW and 1,300MW series, with large-scale modifications to the installations and major safety improvements, in order to demonstrate that these reactors are fit to operate for a further 10 years. For the 1,450MW series, procedures for the 30-year milestone have the same improvement objectives as the 40-year milestone for the other two series.

900MWe series

During the first half of 2016, all the technical, economic and governance conditions were fulfilled for extending the operating lifespan of the 900MWe series power plants in the French nuclear fleet in line with the Group’s industrial strategy. On 28 July 2016, EDF’s Board of Directors therefore approved the extension of the operating lifespan of 900MWe series power plants in France (excluding Fessenheim) from 40 to 50 years from 1 January 2016 onwards, without prejudice to the ASNR’s position on the measures suggested by EDF for each of the nuclear units in question.

On 23 February 2021, the ASNR issued a resolution on the conditions for continued operation of EDF’s 900MW reactors beyond their fourth 10-year inspection in view of the conclusions of the generic phase, and set out related requirements. The ASNR “considered that the measures planned by EDF, combined with the ASN’s requirements, open up the prospect of continued operation of the 900MW reactors for a further ten years following their fourth 10-year inspection”. These generic measures will be supplemented by measures specific to each reactor, once the report of the conclusions of each reactor’s inspection has been submitted to the Ministry in charge of nuclear safety and the ASNR.

On 10 August 2023, the ASNR stated its position on the continued operation of Tricastin 1 beyond 40 years (until its fifth 10-year inspection, scheduled for 2029), in view of the conclusions of its fourth 10-year inspection.

• (1) Jointly owned by EDF and Veolia.
• (2) See section 6.1 “Consolidated financial statements at 31 December 2025”, note 14 “Provisions related to nuclear generation and dedicated assets”.

In addition, following a request from EDF to extend the deadlines for some of the requirements defined in the resolution of 23 February 2021 mentioned earlier, the ASNR issued a new resolution on 19 December 2023 amending certain requirements.

The modifications being rolled out in the first phase of works during the fourth 10-year inspections are continuing, thanks to the lessons learned from the first such inspections (by the end of 2025, the fourth 10-year inspections had been completed for 25 reactors). The modifications in the second phase of work were successfully completed on the Tricastin 1 first-of-a-kind reactor during its partial inspection in 2023, rolled out in 2025 to four additional reactors (Bugey 2, Tricastin 2, Dampierre 1, Bugey 4) and completed in early 2026 at another reactor (Gravelines 1). The results of these fourth 10-year inspections are satisfactory. They demonstrate that there is a strong capability for industrialising operations, and that the involvement of industrial partners has contributed to the success of this project.

1,300MWe series

Examination with the ASNR of the generic phase of the fourth 10-year inspections of the 1,300MWe series began in 2021 and is continuing.

On 1 July 2025, the ASNR stated its position on the conditions for continued operation of EDF’s 1,300MW reactors beyond their fourth 10-year inspection in view of the conclusions of the generic phase, and set out related requirements. These generic measures will be supplemented by measures specific to each reactor, once the report of the conclusions of each reactor’s inspection has been submitted to the Ministry in charge of nuclear safety and the ASNR.

In January 2026, EDF began the first fourth 10-year inspection of the 1,300MWe series, on the first of its kind, Paluel’s reactor 1.

On 28 July 2021, the Board of Directors approved extension of the depreciation period of the 1,300MWe power plants from 40 to 50 years in the consolidated financial statements. This accounting estimate is not an indication of the ASNR’s future position concerning continuing plant operation, which will be stated for each reactor after their 10-year inspections, as specified by law.

1,450MWe series

Examination with the ASN of procedures for the third 10-year inspections of the 1,450MW series has begun, and the first of these inspections is planned for 2029. The accounting depreciation period for the 1,450MW series currently remains at 40 years, but its future extension remains an industrial objective for the Group.

50-60 years

On 13 June 2023, the ASN issued an opinion on the prospects for continuing operation of EDF’s nuclear reactors until they reach 60 years.

Studies for the fifth 10-year inspections of the 900MWe series were launched at the end of 2022, with the first of these inspections planned for 2029. These studies include the major issue of adaptation to climate change and an in-depth compliance review of plants and the potential impacts of ageing.

Following the public consultation launched at the end of October 2024, the ASNR stated a position on 10 December 2024 on the general guidelines adopted by EDF for these fifth 10-year inspections, which it considers relevant and consistent with the current state of knowledge. The fifth 10-year inspections should make it possible to consolidate the significant safety improvements made to the reactors during their fourth 10-year inspections, and increase the consideration given to the effects of climate change.

At the end of its ongoing examination, the ASNR will issue a position in 2028 on the continued operation of the 900MWe reactors for a further 10 years, based on the conclusions of the generic phase of the fifth 10-year inspections.

Beyond 60 years

A “long-term” review of the fleet’s continued operation beyond 60 years was initiated in 2023. It is included in the timetable set by the ASNR, which will state its position in late 2026 after expert assessment and examination phases in 2025 and 2026 respectively.

The work focuses on the issues of ageing, as well as covering the identification of scientific and methodological R&D and development needs. It is also informed by intensive international discussions with other nuclear operators, and with leading centres of expertise.

Investment in the existing nuclear fleet in France: the Grand Carénage industrial refurbishment programme

On 22 January 2015, EDF’s Board of Directors approved the principle of the Grand Carénage programme to renovate major equipment, enhance reactor safety and, conditions permitting, continue their operation beyond 40 years. It incorporates the additional safety improvements identified after the Fukushima accident.

The Grand Carénage programme is being implemented progressively in compliance with:

• the objectives of the Law on the Energy Transition for Green Growth;
• France’s multi-year energy programmes (PPEs);
• the ASNR’s opinions and recommendations;
• specific procedures needed for reactors to remain in operation for more than 40 years.

On 31 March 2022, EDF’s Board of Directors formally recorded the completion of the Grand Carénage programme’s first phase on 31 December 2021, and approved the principle of its continuation, with a new roadmap for 2022-2028 incorporating information gained from current ASNR examinations, notably concerning the fourth 10-year inspections of 900MW and 1,300MW plants, and the start of the Studies phase for the fifth 10-year inspections of 900MW plants.

Cost of the programme

Investments for the period 2022 to 2028, phase 2 of the Grand Carénage programme, were re-estimated at the end of 2025 at €36.3  billion, in current euros, or €32.6  billion in 2021 euros. In 2025, total investments amounted to €5.0  billion. These amounts include the cost of stress corrosion-related work, estimated at €1.3  billion in current euros (€1.2 billion in 2021 euros) over the period 2022-2025.

Industrial work will continue beyond 2028, and investment expenditure will remain high beyond that date.

C – Challenges relating to power plant dismantling

In its capacity as an operator, EDF takes full regulatory, financial, and technical responsibility for the decommissioning of its power plants and the other nuclear installations it operates⁽¹⁾. EDF therefore manages the entire life cycle of its nuclear generation facilities.

• (1) The Tricastin Operational Hot Unit (BCOT), the Saint-Laurent silos, the ICEDA waste storage facility, etc.

To date, 11 reactors using four different technologies have been permanently shut down:

• three pressurised water reactors (PWRs): one at the Chooz site (Chooz A) and two at Fessenheim;
• the heavy water reactor (HWR) at Brennilis;
• the Superphenix fast neutron reactor (FNR) at the Creys-Malville site;
• the six Natural Uranium Graphite Gas (UNGG) reactors at Bugey, Saint-Laurent and Chinon.

These sites remain the property of EDF, and they will remain under its responsibility and monitoring. Given its role as responsible operator, EDF will act as the project owner for the decommissioning.

EDF estimates that it will take approximately fifteen years to dismantle a PWR reactor, with no schedule margin.

The decommissioning of EDF’s legacy nine first-generation reactors in final shutdown will produce approximately 1.5  million  tonnes of primary waste. 80% of this waste is non-radioactive, and the remaining 20% is intermediate-level waste (ILW) or very low-level waste (VLLW). None of it is high-level waste.

The decommissioning of the two reactors at Fessenheim will produce 380,000 tonnes of waste, 95% of it non-radioactive.

The existing reprocessing facilities for short-lived VLLW and LLW have been supplemented by the ICEDA facility for the conditioning and storage of long-lived intermediate-level waste (ILW-LL) from operation and decommissioning⁽¹⁾.

The system for handling decommissioning waste has yet to be completed with the new LLW-LL storage facility (see the paragraph on “Long-lived low-level waste (LLW-LL)” in section 1.4.1.1.2.3 “The challenges of nuclear operations”, paragaph “A  -  Stages and challenges of the nuclear fuel cycle”). For the dismantling of UNGG reactors, there are plans to build an interim storage facility for the LLW-LL graphite sleeves⁽²⁾ from the Saint-Laurent silos until a permanent disposal site becomes available (the first removal of graphite from the Chinon A2 reactor is scheduled for 2045).

Chooz A

Chooz A is a pressurised water reactor that used a technology similar to the 57 reactors currently in operation. It was commissioned in 1967 and operated until 1991. The reactor location, in a rocky cavern in a hillside, means that access conditions, entry and exit of materials, and effluent management are more difficult than for the rest of the existing PWR fleet.

The work begun in 2017 to complete the underwater dismantling of the Chooz A reactor vessel and its internal components experienced difficulties until 2022. The Covid pandemic had a serious impact on the work: in particular, filtration was suspended during the 2020 lockdown, resulting in the formation of organic matter and thus high turbidity in the water. In addition, given the frequent unavailability of the crane needed to lift the reactor vessel and remove it from its concrete shaft, it was decided to completely renovate this crane to address obsolescence issues and qualify it to handle the mass of the reactor vessel.

The project made significant progress in 2023 and 2024:

• emptying the pool after segmentation of vessel internals;
• segmentation of the primary system pipework prior to lifting out the vessel;
• renovation of the reactor cavern crane.

In 2025, the work reached a new major milestone when the reactor vessel was lifted out (extraction from the concrete shaft in which it was installed) and transferred to the transit stand. Pre-segmentation operations are currently under way, notably leak–proofing the bottom of the pool using a polymer seal and the start of cutting of the insulation.

To ensure that the decommissioning scenario respects the provisions of the Chooz A decommissioning decree, particularly the timetable for the intermediate stage (“stage 1”: electromechanical dismantling and clean-up of structures), an application to amend the decree under Article R. 593-48 of the French Environment Code was officially submitted in December 2025. Completion of reactor vessel dismantling is currently expected in 2027.

A partnership agreement between EDF and the French national research agency CNRS was signed on 7 September 2022 for a project to reuse the caverns for research on neutrinos once the installations have been decommissioned. This will put the facility’s unusual configuration to good use.

Fessenheim

Reactors 1 and 2 at the Fessenheim power plant were permanently shut down on 22 February 2020 and 30 June 2020 respectively. These  shutdowns were followed by the start of decommissioning operations (draining of circuits, removal of boron, removal of fuel) and preparations for dismantling (sealing off and removal of certain equipment and support functions, decontamination of primary circuits, etc.).

On 1 September 2023, responsibility for the Fessenheim site was transferred from EDF’s Nuclear Generation Division (DPN) to the Decommissioning Projects and Waste Department (DP2D).

All the spent fuel was removed from the site and sent to La Hague in the space of just over two years, a very good performance. As a result, 99.9% of the site’s radioactivity has been removed and the first industrial transfer of radioactive operating waste to the ICEDA facility has taken place. A  large-scale primary circuit decontamination operation (Full System Decontamination: FSD) was carried out on both reactors. It was completed in June 2023.

The treatment of the upper parts of the used steam generators (resulting from replacement during the operation of reactors 1 & 2) was carried out in Sweden. The first three lower parts were transported to Sweden in October 2025, after obtaining multilateral agreement from the safety authorities of the countries crossed in transit. Transport of the last three lower parts is scheduled for mid-2026.

The electromechanical dismantling of part of the turbine hall, with a view to converting it into a radioactive waste decoupling and transit facility, has been completed and the conversion work is under way.

• (1) See section 1.4.1.1.2.3 “The challenges of nuclear operations”, paragraph on “The ICEDA radioactive waste conditioning and interim storage facility”.
• (2) These graphite sleeves come from the operation of France’s legacy UNGG (natural uranium graphite gas) reactors. They are hollow cylindrical graphite structures that surrounded the fuel rods.

Major steps were taken towards obtaining the decree ordering decommissioning operations, which will mark the start of the decommissioning phase: the decommissioning application for Fessenheim was filed with the Minister for the Ecological Transition and the ASN in December 2020, the ASN Advisory Committee held a meeting on 22 June 2023, a public inquiry took place (from 25 March to 30 April 2024) and subsequently the Inquiry Committee and the Prefecture issued favourable opinions.

Under the current schedule, the decommissioning decree for the Fessenheim installations is expected to be published in the first quarter of 2026 and to take effect in the second quarter of 2026, following approval by the ASNR of the general operating rules applicable to decommissioning.

The trajectory of the preparatory work for decommissioning is in line with the provisional schedule. It was 96% complete by the end of 2025, making it possible to reach the initial state of decommissioning required by the decree in the first half of 2026: adaptation or renovation of dismantling support functions (electricity, ventilation-heating, handling), new facilities and tools in preparation for dismantling, updating of operating documentation in accordance with the new framework resulting from the decree.

Brennilis

The decommissioning work included in the scope of the decree authorising partial dismantling has been completed and the site is now preparing for the next stage, which will concern the reactor vessel. The work involved in this new stage is being carried out under the terms of the “full dismantling” decree, published on 26 September 2023, which came into effect in June 2024 following the ASN’s approval of the new general operating rules.

In 2025, asbestos removal work was completed on one of the two loading faces of the reactor block, from which the extraction operations for the vessel’s fuel channels will be carried out, due to begin in 2027. In addition, assembly of the site buildings (metal structures, workshops and waste conditioning areas) for the dismantling of the vessel’s peripheral circuits has been completed. The first cuts in the concrete wall to create the openings in the reactor block for access to the peripheral circuits were made in December 2025. Segmentation of these circuits is scheduled to begin in 2026.

Creys-Malville

After removal of the reactor vessel containment plugs, installation of the “SCOT” rotating confinement structure and commissioning of the automated workshop, segmentation of the reactor vessel internals began in 2024.

By the end of 2025, the neutron shield support (the first part of the vessel internals) had been completely segmented and conditioned in waste packages, and the second part, the diagrid, had been extracted and was in the process of segmentation. The diagrid, a metal component that supported the fuel elements, was the last large-scale component that could be removed from inside the vessel for dismantling in an adjacent workshop. The segmentation operation has been slowed down by a delay in restoration of the evacuation line for the R73 waste containers suitable for transporting this type of waste. Meanwhile, work inside the reactor building is continuing: the internals segmentation machine has been inserted into the vessel, the testing phase prior to segmentation of the vessel’s fixed internal structures has begun, dismantling of the small rotating plug has been completed and dismantling work has started on the reactor pit and the safety containment vessel.

In the peripheral buildings, dismantling work in the steam generator buildings began in 2025 and will continue until 2030.

UNGG reactors

The industrial dismantling strategy for the UNGG reactors was reviewed in depth in late 2015, notably leading to a switch from underwater to in-air dismantling, which involves:

• an essentially remote-controlled dismantling process;
• qualification of tools and the remote operation platform on the Industrial Demonstrator located near Chinon;
• dismantling of the initial “first-of-a-kind” reactor (Chinon A2), and putting the five other reactors into a safe storage configuration in order to benefit from experience on the first reactor decommissioning before the wider roll-out.

Under this strategy, dismantling operations for the reactor caissons should be completed between 2063 and 2093, depending on the reactors.

Updating the industrial decommissioning scenario for first-generation power plants, particularly UNGG plants, led to a €590 million increase in the related financial provision at 31 December 2015.

In a cover letter accompanying the resolutions of 17 March 2020 supporting the technical options chosen, the ASN took the view that EDF should aim to shorten the schedule for completing this work “in view of the legal obligation for the dismantling of each reactor to take place in as short a time as possible”. EDF confirmed that it was conducting regular schedule reviews based on the results from the industrial demonstrator and the first reactor. So far, no new information has arisen to enable optimisation of the schedule.

Construction work on the Industrial Demonstrator was completed in late 2021. The first tests, carried out in September 2022, concerned the development of tools for recovery of graphite bricks from reactors, and the progressive design of the robotic arms required to dismantle UNGG reactors is moving forward. The manufacture of the mechanical part of the first remote operation arm was completed in 2025, on schedule. All that remains is to mount the hydraulic part on the arm and carry out the overall tests.

The test programme is progressing as planned and a report is presented annually to the ASNR.

Following the inspection on “the management of complex projects” which ended in November 2020, EDF’s responses and commitments were sent to the ASN in May 2022.

Regarding the regulatory aspect of these procedures, the application for a dismantling authorisation for the silos at the Saint-Laurent site was submitted to the ASN in electronic format on 30 September 2022. The dismantling applications for Chinon A2 and A1 and the applications for substantial changes to the decommissioning decrees for Chinon A3, Saint-Laurent A, and Bugey 1 were filed on 15 December 2022, in line with the ASN resolutions of March 2020. EDF submitted updated versions of all these applications in February 2024 in response to the requests made by the Nuclear Safety and Radiation Protection Mission (MSNR) as part of the admissibility analysis. The ASN and the IRSN began their examination of the applications on 25 November 2024 in preparation for a meeting of an Advisory Committee of Experts that was held in March 2026. In 2025, three decommissioning matters were examined in parallel:

• a technical assessment by the ASNR/DES branch;
• a review of the dismantling schedule by the ASNR/DRC, mainly through a three-day inspection in Lyon and on site, resulting in a follow-up letter and a positive assessment from the ASNR. “Thus, at the end of this inspection, the inspectors have a high level of confidence in EDF’s ability to develop “derisking” tests in the Industrial demonstrator, to dismantle the first UNGG reactor and the reactors planned in the future”;
• an assessment of the environmental (chemical and radiological) condition of soil and groundwater by an ad hoc Working Group led by the decommissioning advisory committee.

The draft ASNR/DES report was sent to EDF in mid-November 2025.

These assessments and reviews are general and cross-functional, although specific requests can be made, notably for the Chinon A2 “first-of-a-kind” reactor.

Meanwhile, decommissioning operations around the reactor caissons are continuing at all three sites.

At the Bugey 1 site, the electrical buildings have been demolished, bringing the total decommissioned surface to 27% of the target for the safe storage configuration (which requires decommissioning of all surfaces other than the reactor building and premises needed for dismantling the reactor building). Asbestos was removed from the turbine hall in 2023 by extracting several hundred asbestos-containing tubes integrated into the engineering equipment. On 29 September 2025, the effluent storage station was commissioned for industrial operation.

At Chinon A2, the ferrules (sections of the primary circuit) of all four heat exchanger buildings were evacuated to Cyclife-France for melting. An inspection programme to establish a detailed characterisation of the installation is under way, with a particular focus in 2025 on scanning the reactor ceiling to enable accurate modelling.

Decommissioning of the Chinon A3 heat exchangers has been completed: 5,200  tonnes of metal circuits have been dismantled after 12  years of work.

At the Saint-Laurent A2 reactor, decommissioning of non-caisson components resumed in the second quarter of 2024 after reinforcing control of lead risks. Thanks to fast-paced industrial operations, the milestone of completing dismantling of the circuits located under the reactor vessel was achieved in early December 2024. Electro-mechanical dismantling work is continuing, notably in the pool buildings that used to house the fuel storage pools.

Decommissioning costs and assets held to cover long-term nuclear commitments

Since the beginning of operations at its power plants, EDF has established financial provisions to cover dismantling, engineering, monitoring and maintenance of its facilities, and site security⁽¹⁾. The aim of decommissioning operations is to restore the sites to their original condition and makes the land reusable for industrial purposes.

Article L. 594-2 of the French Environment Code and its implementing regulations define the provisions that are unrelated to the operating cycle and must therefore be covered by dedicated assets⁽²⁾. Accordingly, dedicated assets have been gradually built up since 1999⁽³⁾.

An external audit commissioned by the Directorate General of the Treasury and the Directorate General for Energy and Climate (DGEC) concerning “dismantling expenses for existing permanently shut-down facilities and the management of radioactive waste from these facilities” took place from December 2020 to May 2021, pursuant to the letter of instruction received on 5 June 2020 from the DGEC. This audit covered non-PWR legacy installations that have been shut down permanently, i.e. Superphénix, Brennilis, and the six UNGG reactors. The final audit report was remitted to the audited party on 9 July 2021. The DGEC’s follow-up letter was issued on 22 November 2021 and the audit report was posted on the Ministry for the Ecological Transition website.

This report highlighted “an organisation with a structural focus on execution of dismantling projects”, an “annual costing and review process [that] is robust, and provides good traceability for the assumptions used and the original data”, and “a long-term industrial approach to overcome the few remaining technological challenges”. Finally, the report confirmed that “the provisions are consistent with the basic scenarios of the projects and cover the full range of expenses of the audited scope” and concluded they “are adequately sized” due to testing of the size of EDF’s expenses and provisions.

Beyond the well-controlled processes and organisations, two minor points with low materiality were reported (and corrected when the estimates were revised at the 2021 year-end). Areas for improvement were identified relating to project planning, project maturity assessment and the risks and uncertainties quantification process. They did not call into question the conservative estimates of the associated decommissioning and waste management costs. The audit report also noted EDF’s use of a set of best practices that are rarely implemented in decommissioning projects.

The written response to this follow-up letter was sent on 21 February 2022, resulting in introduction of an action plan to address the areas for improvement mentioned above. All of the actions were completed by the end of 2024.

1.4.1.1.3   “New Nuclear” projects

For the risks associated with these projects, see section 2.2.1 “Operational performance risks”, risk 1A “Risks related to management of large, complex industrial projects, including EPRs”.

1.4.1.1.3.1   Preparation of a programme to build new EPR2 nuclear reactors in France

Thanks to the work done by EDF and Framatome on the New Model EPR project, the technical configuration was developed in late 2017 for an “EPR2” model which could ultimately expand the offering of the French nuclear industry both in France and for the export market. The EPR2 is an optimised version of the EPR, an industrial successor to the EPR that integrates experience gained from EPR projects and power plants currently in operation.

In May 2021 EDF submitted a comprehensive dossier on a renewal programme for nuclear installations in France to the French State (“Proposal by EDF and the nuclear industry for a new reactor programme in France”). The basic principles of this dossier are the implementation of a programme to build three pairs of EPR2 reactors successively at Penly, Gravelines and near Bugey, and the continuation of feasibility studies for the construction and operation by EDF of eight additional EPR2 reactors at other nuclear sites.

On 17 March 2025, the Nuclear Policy Council examined the main principles of the proposed financing and regulatory framework and announced plans for a subsidised State loan covering at least half of the construction costs, a contract for difference cover nuclear power output, and risk sharing between EDF and the State. These measures were the subject of a preliminary agreement between the State and EDF on the above basis; they await approval by the European Commission as compatible with the State aid rules defined in the Treaty on the Functioning of the European Union (TFEU), with a view to EDF making a final investment decision (FID) in late 2026. The French government filed the official notification in November 2025, and on 31 March 2026 the European Commission adopted the decision to begin the formal review procedure⁽⁴⁾.

On 18 December 2025⁽⁵⁾, EDF presented to its Board of Directors the forecast estimate for the programme to build six EPR2 reactors at the Penly, Gravelines and Bugey sites. This estimate amounts to €72.8  billion₂₀₂₀ and was audited in the first quarter of 2026 by the Interministerial Nuclear New Build Delegation (DINN). At its meeting of 12 March 2026, the Nuclear Policy Council took note of the findings of this audit and asked EDF to implement the recommendations made by the end of 2026, and to report on them as part of the follow-up process overseen by the DINN. It also confirmed the key principles and parameters of the financing and regulatory framework for the EPR2 programme.

Pending the FID in 2026, the Board of Directors authorised EDF to continue development of the programme, with a budget of €2.7 billion for 2026. The target date for commissioning of the first EPR2 at Penly is 2038, to be followed by the other reactors at intervals of 12 to 18 months.

• (1) See section 6.1 “Consolidated financial statements at 31 December 2025”, note 14 “Provisions related to nuclear generation and dedicated assets”.
• (2) See section 6.1 “Consolidated financial statements at 31 December 2025”, note 14.1.3 “Coverage of EDF’s long-term nuclear obligations”.
• (3) See section 6.1 “Consolidated financial statements at 31 December 2025”, note 14.1.2.2 “Strategic allocation and composition of dedicated assets”.
• (4) See the European Commission’s press release of 31 March 2026.
• (5) See EDF’s press release of 18 December 2025 “EDF shares its forecasted cost estimate of the EPR2 programme for €72.8bn”.

Governance

Pursuant to the recommendations made by Jean-Martin Folz in 2019⁽¹⁾ and the French Court of Auditors in its summer 2020 report on EPRs, EDF has decided to strengthen the design & build governance for EPR2 reactors. EDF has therefore set up a new organisation that separates the Project Owner function from the Project Manager function. This organisation was strengthened in 2024 as part of the reorganisation of EDF’s nuclear activities described in section 1.4.1.1.1 “Nuclear organisation and governance”. This work is continuing, with reinforced positioning for the project owner and inclusion of Edvance and the Supply Chain team in project management.

The project owner, among other duties, bears all of the following key responsibilities:

• controlling the safety, quality, time and cost dimensions of the new nuclear projects (the EPR2 and SMR programmes);
• ensuring that the programmes’ long-term profitability is secure;
• overseeing programmes during both the development and execution phases;
• ensuring that the programmes achieve a good operational performance over the long term;
• ensuring that administrative authorisations are obtained, managing land use, integrating the project into the local area, and overseeing major construction projects.

The project manager is responsible for designing the EPR2 reactors and if the FID is made, will ensure that they are built in compliance with the safety, quality, cost, schedule and security objectives set by the project owner.

Progress report and outlook

The general conceptual design studies begun in 2018 were finalised by the end of 2021. This stage was preceded by the submission of the preliminary safety report to the ASN in February 2021, and completion of the ASN’s examination of the safety options file (as stated in letters of April and September 2021).

A new sequence then began in January 2022, focusing on three priorities:

• continuation of engineering studies; a technical maturity review was organised in 2023 covering the main buildings of the nuclear island. This review gave EDF feedback on the project from a committee of independent experts, in order to secure the next steps in EPR2 development and construction. A second review held in mid-2024 validated completion of the “detailed design” milestone for the nuclear buildings. In 2025, studies continued, including a decision to increase the size of one of the buildings to facilitate fuel handling and the installation of equipment. Design maturity reviews will continue in the first half of 2026, to prepare for the FID;
• close relations with key partners, to learn from studies by suppliers and give them the necessary visibility to invest in skills and industrial facilities; the main civil engineering contract for Penly was signed in October 2023;
• worksite preparation, particularly procedures for administrative and regulatory authorisations:

• >Penly: on 11 February 2022 EDF referred the proposal to build two EPR2 reactors at Penly to the National Public Debate Commission (CNDP). The public debate was held between late October 2022 and late February 2023, in parallel with a public consultation on energy organised by the State. On 28 June 2023, EDF’s Board of Directors decided to continue preparations for the EPR2 programme and the Penly project, following which applications were submitted for an authorisation to create a facility and an environmental authorisation. In June 2024, an environmental authorisation decree was issued authorising EDF to carry out preparatory work. This authorisation was the subject of a non-suspensive appeal before the Council of State, which was rejected on 22 December 2025. The Penly project was officially recognised as a project of common interest by a Council of State decree of 25 January 2025,

• >the preparatory work that began in 2024 intensified in 2025, with a particular focus on reinforcing the existing sea wall, cliff reprofiling, setting up temporary accommodation and car parks, extending the offshore platform, evacuating past archaeological excavations, and constructing the site access station and car park at the site entrance,

• >Gravelines: on 22 November 2023 EDF referred the proposal to build two EPR2 reactors at Gravelines to the CNDP. At its plenary session on 10 January 2024, the CNDP decided to organise the Gravelines public debate, which began on 17 September 2024 and ended on 17 January 2025. On 20 May 2025, EDF’s Board of Directors decided to continue developing the project to build two EPR2 units at Gravelines. This project entered a key phase when its Grand Chantier (major project) status was officialised on 18 June 2025, and it was recognised as a project of common interest by a Council of State decree of 17 July 2025. An application was made to have the planning documents adjusted for compatibility, giving rise to a preliminary consultation in the summer of 2025. In September 2025 EDF began ongoing consultation with the aim of continuing information sharing and dialogue about the project with the public in the long term. In late October, EDF filed an application for environmental authorisation for site preparation work,

• >Bugey: the public debate for the Bugey site began on 28 January and ended on 15 May 2025. On 30 September 2025, EDF announced that it had decided to continue the project (while making certain changes based on the information collected), and to file the applications for the necessary administrative authorisations for construction. Application for recognition as a project of common interest was made in late November 2025.

1.4.1.1.3.2   Small Modular Reactors (SMRs)

The EDF group is continuing its strategy of developing a Generation III Small Modular Reactor (SMR) jointly with its subsidiary NUWARD, to  support the energy transition and meet industrial operators’ needs in  Europe and internationally in the 2030s. The basic design phase of NUWARD continued in the first half of 2024, with deeper consideration of the project’s design and market positioning. The lessons learned led to a change in strategy, and development is continuing with a new approach based exclusively on proven technological building blocks.

This approach will build on the technical, industrial and commercial knowledge accumulated by NUWARD, and the Group’s own experience in nuclear power and PWR technology. NUWARD is aiming for a simple, highly modular design that can be delivered in 5 years.

In 2025, the project continued with the conceptual design phase focusing on a 1,150MWth multi-energy platform, capable of delivering up to 400MWe or up to 320MWe and 290MWth in co-generation mode, achieving an overall efficiency of 53%. The conceptual design phase is scheduled to end in mid-2026. Meanwhile, NUWARD has pursued a co-development strategy aimed at attracting equity from industrial players, customers and financial investors and continuing to benefit from State support.

NUWARD aims to develop its first series of power plants through its customers, as a Nuclear IPCEI⁽²⁾ under a cross-border partnership with France, Italy and Poland.

• (1) In a report submitted to the French Minister for the Economy and Finance and the Chairman & Chief Executive Officer of EDF in October 2019.
• (2) Important Project of Common European Interest.

1.4.1.1.3.3   International developments

United Kingdom

In the United Kingdom, EDF Energy is a participant in the project to build two nuclear reactors at Hinkley Point, together with China General Nuclear Power Corporation (CGN). The project company Nuclear New Build (NNB) is the project owner.

The Industrial Projects & Partnerships Division supports:

• overall management of the project, and ensures that lessons learnt are shared across projects (to  benefit HPC and  future projects);
• monitoring of manufacturing (via the Supply Chain Division);
• construction, and preparation for the commissioning phase (via the Construction & Testing Division).

The subsidiaries EDVANCE and EPR-Engineering, with the support of the Engineering Division, carry out design studies and contract monitoring.

Framatome supplies the components and the instrumentation and control system, and the turbine is supplied by Arabelle Solutions.

EDF is a participant in the Sizewell C project to build two EPR reactors, owing a 12.5% stake alongside the UK government (44.9%), La Caisse (20%), Centrica (15%) and Amber Infrastructure (7.6%) (see section 1.4.5.1.2.5 “The New Nuclear Industry”).

EDF also owns a 33.5% stake in Bradwell B, in partnership with CGN (see section 1.4.5.1.2.5 “The New Nuclear Industry”).

India

In March 2018, EDF and the Indian national electricity company Nuclear Power Corp of India Ltd. (NPCIL) signed the “Industrial Way Forward Agreement” (IWFA), a non-binding industrial cooperation agreement for the construction of six EPR reactors in India at the Jaitapur site. This agreement sets out the industrial plan, the partners’ roles and responsibilities, and the next steps in the project. It states that the EDF group and its partners will supply all the studies and equipment for the nuclear island, the conventional island, the auxiliary systems, and the heat sinks and galleries. EDF does not plan to invest in this project. The client, NPCIL, will be the general project manager, constructor and integrator in the execution phase.

In accordance with the schedule laid down in the IWFA, EDF and its partners submitted a comprehensive conditional non-binding proposal to NPCIL in late 2018, followed by a binding technical and commercial proposal in April 2021. Since then, EDF, with the support of the French government, has continued its discussions with Indian stakeholders within the framework of a Special Task Force led by the two countries’ governments. In the long term, the goal is to be able to converge with NPCIL on technical and commercial matters, with a view to signing a binding Pre-Engineering Contract.

Netherlands

The Netherlands made a major shift in its energy policy in 2021. Having initially planned to close the country’s only nuclear power plant in Borssele in 2033, the government decided to revive nuclear power to meet two imperatives: reducing CO₂ emissions by phasing out fossil fuels, and ensuring a secure electricity supply, in line with European and national climate targets.

The process of selecting a partner to build a plant with two high-power units was also initiated. In response, EDF carried out a paid Technical Feasibility Study for the construction of two EPR reactors at the Borssele site, and is currently participating in the competitive dialogue led by the Dutch government and NEO NL, the entity it has created to take charge of the project’s development. The next step in this process will lead EDF and its competitors to define the outline of a fair and robust call for tenders together with NEO NL. Announcement of the selected partner is currently scheduled for late 2027/early 2028.

Poland

Poland’s energy transition plans are the most ambitious in Europe, as coal still accounted for 54% of its electricity mix and 65% of its heat mix in 2024. This transition is mainly based on the development of offshore wind farms and a nuclear programme that is the largest in Europe after the French programme, with a target of 6 to 9GW of nuclear capacity in service by 2045. In July 2025, the Polish government invited four countries (Canada - Atkins Realis, South Korea - KHNP, France - EDF, and the United States - Westinghouse) to participate in competitive dialogue for the contract to build the country’s second nuclear power plant, in central Poland.

Other key prospects

EDF is aiming to develop a fleet of high-power reactors in Europe, as several countries have decided to launch or relaunch new nuclear programmes on the continent. EDF is in discussions with Finland, Sweden, Slovenia and other countries to carry out preliminary studies to derisk projects prior to the submission of formal offers.

In Canada, EDF provides support for local operators (Ontario Power Generation and Bruce Power) in their respective development processes for large-scale projects in Ontario.

1.4.1.1.3.4   Digital transformation of nuclear engineering

The Nuclear Engineering and Project Transformation Programme aims to deeply and sustainably transform nuclear engineering in order to improve its industrial control and competitiveness.

Its main objectives are to:

• standardise and simplify engineering processes and methods by integrating system engineering principles, and digitise them for the move towards digital engineering and efficient data-centric practices;
• standardise products based on proven solutions, base international offerings on the standard products and replicate them across projects;
• reconfigure relations with the supply chain by streamlining the supplier panel, making suppliers accountable, and developing the extended enterprise model of operation;
• integrate the information system around PLM (Product Lifecycle Management) solutions, and ensure its interoperability with the information systems of external stakeholders (customers, suppliers, authorities, etc.) to establish a truly digital ecosystem;
• capitalise more effectively on knowledge and know-how and develop internal skills, while optimising the use of outsourcing.

1.4.1.1.4   Activities related to nuclear generation: Framatome

Framatome⁽¹⁾ is a leading international player in nuclear energy, owned by EDF (80.5%) and Mitsubishi Heavy Industries (19.5%).

The company is highly-reputed for its innovative solutions and high added-value technologies for the worldwide nuclear fleet. With its recognised expertise, sound references and more than 24,000 employees, Framatome designs, manufactures, installs and maintains components and fuels, as well as instrumentation and control systems for nuclear power plants. In 2025, Framatome hired over 2,600 employees to maintain and increase its skills and ensure its growth.

Framatome has a significant industrial presence in France, Germany and the United States.

• (1) Framatome, Framatome Healthcare, Framatome Defense, and Framatome Space are registered brands and trademarks of Framatome and its subsidiaries in the USA and other countries.

Framatome’s German subsidiary is headquartered in Erlangen (Bavaria). With over 2,500 employees, it is the company’s second-largest engineering site. Its main business is maintaining, prolonging and upgrading nuclear plants (especially Instrumentation & Control systems) all over the world. This site also contributes to EPR reactor construction projects in France and the United Kingdom, having already participated in the construction of EPR reactors in Finland and China. Framatome’s subsidiary Advanced Nuclear Fuels GmbH (ANF) produces fuel assemblies for PWRs (pressurised water reactors) and BWRs (boiling water reactors).

Framatome’s U.S. subsidiary is headquartered in Lynchburg (Virginia). With over 2,300 employees, its main business is maintaining and modernising North American nuclear power plants (United States and Canada) currently in operation, to supply them with the necessary fuel, provide support for the potential construction of new plants, and restart nuclear power plants that had been permanently shut down. Framatome also owns 50% of IsoGen Corp., a joint venture with Kinectrics Inc., which produces medical isotopes at nuclear reactors operated by Bruce Power in Canada.

Framatome also has industrial or commercial operations in more than 20 countries, including South Africa, Argentina, Belgium, Brazil, Bulgaria, Canada, China, South Korea, Spain, Finland, Hungary, Japan, Kazakhstan, the Czech Republic, Romania, the United Kingdom, Slovakia, Switzerland and Sweden.

Framatome’s strategy focuses on its core business of manufacturing, supplying and commissioning nuclear steam supply systems, providing maintenance services, and supplying reactor fuel. It aims to offer safe, competitive solutions, industrialise them and execute projects in accordance with the quality/cost/deadline criteria set with customers.

The company has a customer base that includes some of the world’s leading energy companies, and it works on more than 380 nuclear reactors worldwide. Framatome’s experience with reactors of all types of technology means it can meet specific customer requirements all over the world.

1.4.1.1.4.1   Framatome’s activities

With over 65 years of experience in the design and construction of nuclear power plants, Framatome can draw on recognised expertise, provided by highly-qualified engineers and operators.

Engineering

Framatome’s experts are specialists in the design of the principal components of nuclear steam supply systems, metallurgy, mechanics, neutronics, scientific calculation work, fluid mechanics and risk and safety analysis. Framatome’s engineering services include the core of the power plant, known as the nuclear island, and the main components of the primary circuit. These notably include steam generators, pumps, the pressuriser and the nuclear reactor vessel.

Framatome’s specialists and technicians mainly work on major nuclear new build projects such as EPRs, and development of SMRs and Generation IV reactors.

Equipment manufacturing

More than 100 power plants in 11 countries are fitted with Framatome components. The Framatome plants in Le Creusot, Saint-Marcel, Jeumont and Montbard in France produce key nuclear steam supply system equipment for electricity companies all over the world, to equip new-build power plants or to replace items at power plants in operation. The company manufactures advanced-technology heavy equipment (reactor vessels, steam generators, etc.) and mobile components (reactor coolant pump units and control rod drive mechanisms).

In 2025, Framatome continued to ramp up production at its Saint-Marcel plant which specialises in heavy components. The plant supplies key forged components for new build projects, notably the EPR reactors at Hinkley Point C in the United Kingdom, and has started production of components for the EPR2 programme in France and the Sizewell C EPR in the United Kingdom. It also supplies parts for replacement components in reactors currently in operation.

The acquisitions of Jeumont Electric and Vanatome in 2024, then Velan France (now Valserve) and Segault in 2025, together with the acquisition of a stake in Selectarc, ensure stability in Framatome’s supply chain and have strengthened its industrial capacity and performance in the nuclear and defence sectors.

Instrumentation and control (I&C) systems

Framatome designs, manufactures and installs reliable nuclear instrumentation and control systems for plants in operation and new builds. Its analogue and digital solutions include safety I&C systems, operational I&C systems, nuclear instrumentation, lifecycle solutions, global I&C engineering expertise simulators, human-machine interface design and human factors engineering. Framatome has installed over 300 complete I&C systems on reactors of all types worldwide.

Fuel

Framatome designs, develops and manufactures fuel assemblies for pressurised water reactors, boiling water reactors and research reactors. The company’s know-how spans the entire process: from design of the fuel assembly, to production of zirconium and its alloys – zirconium being vitally important for fuel production – on to fuel fabrication and related services, right through to operations on nuclear power plants.

The company performs all relevant calculations for improving fuel management and performance, in compliance with the highest safety standards. Nearly 260,000 Framatome fuel assemblies have been loaded into more than 200 reactors in operation around the world.

Commissioning and operation licensing of nuclear power plants

Framatome has gained substantial international experience from working with nuclear safety authorities on all types of reactors that exist around the world. The company can thus support operators in dealings with their respective safety authority, and in the application of existing regulations in the relevant country.

In France, Framatome has developed expertise in application of the ministerial order concerning nuclear pressure equipment.

The company also provides its international customers with technical centres where numerous tests are carried out each year to qualify their equipment. It assists customers preparing qualification studies and the related documentation.

Maintaining, modernising and extending the operating lifespan of existing nuclear power plants

Framatome offers innovative solutions and services to maintain and modernise existing nuclear power plants and extend their lifespan while preserving their safety, performance and availability. Framatome has over 65 years’ international experience and puts it to use for all types of technologies and the maintenance of more than 300 reactors worldwide. Its teams have expertise and knowledge of the requirements concerning maintenance, component replacement, inspections and checks, refuelling operations, and optimised management of reactor outages for maintenance. The company’s activities principally cover the management of equipment and spare parts, I&C modernisation, and chemistry and radiochemistry services.

Management of major projects

Framatome’s involvement in new-build nuclear reactor projects spans design, procurement and supply, and commissioning. The company’s teams draw on its expertise in the management of complex projects to meet customer requirements in compliance with the most stringent international safety standards. In the case of new-build projects, the company proposes solutions for nuclear islands.

As the equipment designer, Framatome participates in the maintenance of the four EPR reactors in service around the world: China (Taishan 1 & 2), Finland (Olkiluoto 3) and France (Flamanville 3).

Framatome is participating alongside EDF in the construction of EPR projects in France (the EPR2 programme) and the United Kingdom (Hinkley Point C 1 & 2 and Sizewell C 1 & 2).

In 2017, EDF and Framatome created Edvance, a joint engineering subsidiary for new nuclear build projects in France and worldwide.

1.4.1.1.4.2   Key achievements by Framatome in 2025

Project execution was well controlled, in accordance with the company’s contractual commitments, and the actions to optimise structural costs continued. Production output by the plants was in line with the commitments made to customers, despite pressures on the supply chain.

Several primary component replacement operations were carried out: in France for EDF (replacement of steam generators in Unit 2 of the Flamanville nuclear power plant, which will continue until the second quarter of 2026), and in Canada for Bruce Power (Bruce Power Unit 3).

Framatome continued to grow its installed base in the North American market in an environment that remained active and highly competitive. Deliveries of equipment for the Angra 3 project in Brazil were suspended, given the payment difficulties of the customer Electrobras.

The instrumentation and control business continued to grow, driven in France, the UK, Europe and the United States by new build projects, renovation projects, and dynamic service activities.

In 2025, Framatome decided to group all of its commercial cybersecurity activities within its I&C business in order to pool its expertise and establish a unified cybersecurity strategy, against a backdrop of growing cybersecurity needs among players in the nuclear and critical industries.

The subsidiaries Allentis (network monitoring and detection), Cyberwatch (vulnerability management) and Foxguard (industrial cybersecurity integrator and supplier of customised IT systems) now belong to the Framatome Cybersecurity Business Line, which is part of the I&C Business Unit.

Major project management and component manufacturing activities continued at a steady pace:

In France

• For the Flamanville 3 EPR, after connection to the grid on 21 December 2024, the project reached several major milestones in 2025: the end of the DEM33 testing phase (zero power testing and gradual ramp-up to 60% power) in November 2025, and the final DEM34 testing phase (ramp-up to 100% power and verification of the behaviour of the core and primary systems), which has been under way since December, with 100% power reached on 14 December 2025.
• For the EPR2 programme, Framatome started manufacturing the U1 EPR2 Primary Motor Pump Unit (GMPP) in September 2025. Production of large components also continued at the Le Creusot, Saint Marcel and Jeumont plants.

In the United Kingdom

• For the HPC EPR, after production of the reactor vessel was completed in July 2025, the hydraulic tests of the steam generators of the second reactor at Hinkley Point C were finalised in September 2025. The reactor vessel and two steam generators for the second reactor were delivered to the HPC project, and the remaining two steam generators were also completed.
• For the Sizewell C EPR, after the Financial Investment Decision (FID) in July 2025, officially launching construction, the Financial Close (signature of operational and financial agreements) was reached in November 2025. Production of large components began at the Le Creusot, Saint Marcel and Jeumont plants.

In 2025, Framatome’s fuel business concluded contracts in Hungary and the Czech Republic to supply fuel to VVER-type power plants and renewed agreements for the supply of MOX fuel to EDF’s power plants. It is also benefiting from the dynamism of the American market.

Investments were launched as part of an industrial programme to ramp up production, in conjunction with the EPR2 programme in France and with the intent of strengthening sovereignty. These investments concern the manufacturing and assembly of primary and auxiliary equipment components. They also concern the fuel supply chain, which is modernising and consolidating its growth and production capability for new operations.

Several external growth transactions were completed in 2025. Framatome acquired Velan SAS and Segault, two companies specialising in high-performance valves for the nuclear, defence and energy sectors. Velan SAS changed its name to Valserve. These acquisitions are part of the strategy to grow and strengthen the supply chain, and follow the acquisition of Vanatome in 2024, thus enabling the creation of Framatome’s Valves Business Line. Framatome also completed the acquisition of the remaining stake in Reaktortest, a Slovakia-based non-destructive testing (NDT) company, and acquired a 40% stake in Selectarc. The partnership with Selectarc aims to ensure a long-term supply of strategic filler metals, which are essential to the manufacturing process for components of the primary circuit of French nuclear reactors.

More generally, Framatome is part of the EDF group’s operational excellence initiative aiming to enhance operational performance and optimise lead times. The objective of this initiative is to ensure stability in the supply chain, control and optimise the manufacturing lead times of Framatome and its key suppliers, and maintain skills. Framatome’s plants are thus rolling out plans to ensure that manufacturing and construction are compliant from the outset. All stakeholders are engaged, with the aim of standardising activities.

Framatome also continued to develop its brands (Framatome Healthcare, Framatome Defense and Framatome Space).

As part of the development of activities related to its Framatome Healthcare brand, Framatome’s proprietary isotope production technology is used for the commercial production of lutetium-177 in a CANDU reactor operated by Bruce Power in Canada. In 2025, Framatome and SN Nuclearelectrica SA signed an agreement confirming a similar medical isotope production project at the Cernavoda power plant in Romania. Furthermore, Framatome and the Belgian company Ion Beam Applications announced in early 2025 that they intended to set up a network of facilities in Europe and the United States for the production of Astatine-211, a radioisotope used for alpha radionuclide therapy. Finally, an agreement for a prototype irradiation project was signed with EDF in November 2025, for the production of Cobalt-60 in one of the reactors of EDF’s fleet.

Under the Framatome Defense brand, launched in October 2020, Framatome serves the needs of France’s defence programmes and related sovereignty issues through its industrial establishments located throughout the country. Framatome Defense’s main contributions are to future nuclear programmes such as the Barracuda-type nuclear attack submarine programme, third-generation ballistic missile submarines (SNLE 3G), the future new-generation aircraft carrier (PA-NG) and projects for the benefit of the CEA’s Military applications division, particularly concerning nuclear propulsion. All of Framatome’s Business Units are involved, and 2025 saw the implementation of industrial capacity investment plans financed by the French Ministry of Defence, the commissioning of the Defence Business Line at the Jeumont site, and the production and delivery of equipment, components, studies and services from several industrial sites for its defence customers.

Under the Framatome Space brand, launched in October 2023, Framatome provides nuclear skills and tools to the space industry to help it achieve its next exploration objectives. The year 2024 was marked by the first ALUMNI study for the European Space Agency (ESA), conducted in cooperation with Ariane Group and the CEA. This study paves the way for future developments in both radioisotope and fission reactor technologies. In 2025, Framatome established strategic partnerships in Italy with Enea to conduct a feasibility study for the development of TRISO fuel for a surface reactor, and in the United Kingdom with Perpetual Atomics to provide support for the development of radioisotope space systems. This second partnership led to the signature of the first ‘prime contractor’ contract for the ESA in September 2025. Framatome is positioning itself as a specialist for future developments.

At the WNE (World Nuclear Exhibition), the major global event for the civil nuclear industry, the Waste Eraser project – concerning the treatment of ion exchange resins⁽¹⁾ – won an innovation award.

1.4.1.1.4.3   Basic Nuclear Installations (INB)

Framatome operates an INB which makes nuclear fuels located at its Romans-sur-Isère site, identified by the French authorities as INB 63-U.

2025 nuclear safety results⁽²⁾

As in 2024, there were no major safety or radiation protection events at the sites for which Framatome is a nuclear operator, i.e. the Romans-sur-Isère, Richland and Lingen fuel production sites. In 2025, Framatome declared 13 significant safety events (SSE) of level 0 on the international INES scale, and 1 SSE of level 1.

Detailed nuclear safety results for 2025 are published in the annual report drawn up by the General Inspector for Nuclear Safety and the report on the Romans-sur-Isère site published in application of the French Law on Transparency and Nuclear Safety⁽³⁾.

Dedicated assets

Dedicated assets have been established to cover long-term nuclear commitments. See section 6.1 “Consolidated financial statements at 31 December 2025”, note 16.1 “Other provisions for decommissioning”.

1.4.1.1.5   Arabelle Solutions

On 31 May 2024, EDF acquired the nuclear activities of GE Vernova relating to the conventional island of nuclear power plants, with the exception of service activities in the Americas. These activities are managed by Arabelle Solutions, a wholly-owned subsidiary of EDF.

Arabelle Solutions’ activities mainly relate to the conventional island of nuclear power plants:

• New nuclear activity: design, manufacture and installation of core equipment for the conventional island (including the Arabelle turbine and the Gigatop alternator) for new nuclear power plants, notably suitable for EPR and EPR2 technology reactors, and Small Modular Reactors (SMR);
• Services activity: maintenance and upgrades of this equipment for existing nuclear power plants. Arabelle Solutions also supplies turbines for naval activities, notably for British nuclear submarines.

Arabelle Solutions employs approximately 3,600 people in 16 countries, mainly in France (2,350 employees, or approximately 65% of the workforce), India (approximately 500 employees) and the United Kingdom (approximately 350 employees).

The principal industrial assets operated by Arabelle Solutions are the following, located in those three countries:

• the Belfort site in France, where Arabelle turbines and very high-power alternators (over 1,000MW) are manufactured;
• the Sanand plant in India, specialising in low-power turbines (for SMRs) and medium-power turbines (notably for Indian nuclear facilities);
• two repair workshops: one in La Courneuve in France for turbines and pumps, and the other in Rugb in the United Kingdom, which handles repairs of alternators and medium-power turbines, and also manufactures the turbines currently used in British nuclear submarines;
• an industrial facility located in Ludres in France, specialising in obsolescence management and the production and repair of electronic boards for nuclear power plants.

Arabelle Solutions currently has industrial or commercial operations in some twenty countries around the world.

Arabelle Solutions has a customer base that includes some of the world’s leading energy companies. Its technology is present in one-third of all the nuclear plants installed in the world, and it carries out maintenance operations on more than 100 nuclear units each year.

Arabelle Solutions is involved alongside EDF in the construction, commissioning and maintenance of the conventional islands of Flamanville 3 and Hinkley Point C, as well as in the preparations for EPR new builds in France (the EPR2 programme) and the United Kingdom (Sizewell C).

Arabelle Solutions has done business in China for over 27 years, providing construction services (engineering and equipment) and maintenance services for turbines and/or alternators. These services have been used at more than 30 units in China, with multiple reactor types (M310, CPR1000, EPR, AP1000, etc.). Arabelle Solutions operates in China through a joint venture, named Arabelle (Wuhan) Engineering Technology Co., Ltd., with the Central Southern China Electric Power Design Institute (CSEPDI, 20% minority shareholder).

• (1) Ion exchange resins, used in nuclear power plants to treat waste water, are difficult to solidify for final storage. By liquefying the resins, the Waste Eraser reduces the volume of waste and therefore the costs associated with final storage, while ensuring safe long-term storage.
• (2) Framatome’s objective is to detect, report and address as adequately as possible all points of non-compliance and anomalies arising in the course of its activities. This indicator aims to further strengthen the sharing of experience, and to broaden the analyses of and the importance assigned to weak signals. The INES level 0 events declared are safety deviations, considered as “weak signals” that must be given due consideration in a continuous improvement approach, for better control of risk prevention in the performance of activities. In order to promote reporting of “weak signals” and the sharing of experience, Framatome detects and records every deviation, which is then analysed by the independent safety function to determine the level of declaration to the Safety Authority.
• (3) Available from the website www.framatome.com

Arabelle Solutions has also done business in India for many years. It has supplied the great majority of the turbines for India’s nuclear power plants and is working with its partner BHEL on production of the turbines for the new Gorakhpur and Kaiga nuclear power plants. It also has a factory in Sanand.

Arabelle Solutions is also participating in projects for the construction of the Akkuyu nuclear power plants in Turkey and the El Dabaa plant in Egypt, and the extension of the Paks power plant in Hungary (see section 2.2.1 “Operational performance risks”, risk 1A “Risks related to management of large, complex industrial projects, including EPRs”).

The main projects completed by Arabelle Solutions in 2025 include several critical component repairs on the existing French fleet for EDF, and in South Africa for Eskom (the Steam Generator Retrofit contract concerning unit 1 of the Koeberg power plant). New structural agreements were concluded with EDF, notably for increasing the capacity of CP1-model reactors with EDF (11 low-pressure shaft lines) and the renewal of a long-term Nuclear Controls agreement. Arabelle Solutions is beginning to see growth on the Services market in a global environment that remains highly competitive, and has signed new agreements, notably in Romania (Cernavoda lifespan extension), Sweden (multi-year maintenance contract with Uniper), China (Service Cooperation Agreement with Dongfang) and the United Arab Emirates (Barakah). Nevertheless, equipment deliveries to international customers proceeded without incident.

In new nuclear projects, significant contracts were signed for the supply of equipment (with or without installation), mainly for projects in Poland (AP1000), the United Kingdom (Sizewell C/EPR), the United States (SMR project developed by Terrapower) and France (EPR2 with an extended scope including heat exchangers, pumps, valves, engine room pipes, and the PANG new-generation aircraft carrier project with Naval Group). Significant project milestones were achieved regarding Flamanville 3 in France, Hinkley Point C in the United Kingdom, EPR2, Akkuyu in Turkey, El Dabaa in Egypt, and Darlington in Canada.

1.4.1.2   Thermal generation in mainland France

Thermal power generation facilities are an important component of the electricity mix to keep a real-time balance between generation and consumption. They respond to fluctuations in electricity consumption and renewable energy generation (solar and wind power in particular). They help to ensure an adequate level of voltage and frequency on the grid. This role is set to increase with the massive influx of intermittent generation facilities into the French and European electricity grids.

1.4.1.2.1   EDF’s thermal generation fleet in mainland France

At 31 December 2025, the thermal fleet operated by EDF was diversified both in terms of fuel and capacity:

Generation in 2025

Electricity generation by EDF’s thermal power plants in mainland France represented 0.75% of its total electricity output in 2025. At the end of 2025, the thermal generation fleet in operation had a total installed capacity of 4,945MW.

Thermal generation (net energy output) in 2025 totalled 3.14TWh, with a higher level of operation than in 2024 (2.65TWh). In 2025, coal-fired plants supplied 0.2TWh, CCGT plants 2.57TWh, and combustion turbine plants 0.36TWh.

The challenge for these thermal generation facilities, which are used to variable extents throughout the year, is maintaining maximum reliability and availability. The fleet’s adaptability to a sustained level of operation has been demonstrated. Particularly high demands were made of combustion turbine plants, which provided a very good response rate when called into operation.

1.4.1.2.2   Challenges relating to thermal generation

A thermal fleet in transition

Between 2013 and 2015, EDF permanently shut down 10 coal-fired generation units, and on 1 April 2021, it permanently shut down the Le Havre power plant. In May 2025, EDF announced that it is going to permanently shut down the last two generation units of the Cordemais thermal power plant on 31 March 2027.

An action plan to limit the environmental footprint of other thermal generation facilities in mainland France

The Group launched a cross-functional strategic project for decarbonised thermal energy in 2021, which identified the various measures and techniques available to decarbonise its current fossil-fired generation plants or construct new low-carbon thermal plants.

Roadmaps were defined and are currently being implemented to examine all the opportunities for decarbonising existing generation plants, and to manage solutions for developing new decarbonised thermal capacity in case the electricity system needs it.

Tests of operation fuelled by bioliquid (Hydrotreated Vegetable Oils, compliant with the RED II directive) were therefore conducted on two combustion turbines in July 2023 (Brennilis) and June 2024 (Vaires-sur-Marne).

The results of these tests were positive in both their technical and environmental aspects, confirming the relevance of this decarbonisation solution. Also, following the RED certification awarded at the end of the feasibility assessment process during the June 2024 test at Vaires, the electricity generated using sustainable fuel is officially recognised as renewable.

Emissions by the thermal fleet

In 2025, EDF’s thermal fleet in mainland France emitted 1.5 million tonnes of CO₂ (1.3 million tonnes in 2024). The CO₂ content per kWh generated in 2025 was 469g/kWh net (compared to 477g/kWh net in 2024). This decrease was mainly due to higher power output by the CCGT fleet, notably reflecting the return to the network and EDF’s thermal generation mix of the Bouchain CCGT plant, which had been offline since April 2024. As a result, the share of the four CCGT plants was greater than in 2024, contributing 65% of the thermal fleet’s CO₂ emissions; 20% were contributed by the CETAC operation centre’s combustion turbines (a  slight increase compared with 2024, given the heavy use of oil-fired combustion turbines) and 15% by Cordemais. CCGT plants contributed 81% of thermal power generation in 2025 (compared to 79% in 2024), resulting in a lower relative contribution from the coal-fired plants in 2025 at nearly 6% of thermal power generation (compared to nearly 7.5% in 2024). In 2010, the CO₂ content per kWh generated was more than 900gCO₂/kWh net.

In 2025, EDF’s thermal power plants in mainland France emitted 225 tonnes of SO₂ (294 tonnes in 2024), 1,293 tonnes of NO_x (974 tonnes in 2024) and 7  tonnes of dust (6  tonnes in 2024). Per kWh generated, compared to 2010, pollutant emissions were reduced by a factor of more than 30 for NO_x, more than 165 for SO₂, and 500 for dust. These drastic reductions have been made possible by:

• closing down the oldest thermal power plants;
• renovating and installing state-of-the-art flue-gas treatment equipment at the most recent coal-fired plants;
• using low-sulphur fuel;
• commissioning combined-cycle gas turbines;
• the preferential use of gas at the Montereau combustion turbines since 1 January 2025.

An efficient thermal generation fleet thanks to natural gas combined cycles turbines

EDF has commissioned the following facilities:

• France’s first combined cycle gas turbine (CCGT) at Blénod in 2011;
• two CCGTs at Martigues in 2012 and 2013;
• a new-generation CCGT at Bouchain in 2016, in partnership with General Electric.

This modernisation of the thermal generation fleet has reduced atmospheric emissions of CO₂, nitrogen oxides and sulphur oxides.

The Martigues CCGT facilities result from repowering of former oil-fired units, reusing some of their equipment such as the steam turbine, the condenser and the water treatment facilities. The installed capacity of the Martigues site is 930MW. Its efficiency is over 50%, significantly higher than the efficiency of coal-fired thermal units.

The Bouchain CCGT plant has innovative features in terms of capacity (it can reach 600MW in under 30 minutes) and efficiency (over 60%). It also demonstrates good environmental performance. Its CO₂ emissions are around 360g/kWh, close to just a third of the emissions by the nearby old coal-fired plant shut down in 2015.

Improvement of CCGT plant performance through hybridisation

Ever on the lookout for flexibility and innovative solutions for electricity grid security, EDF has launched its project to hybridise the Blénod CCGT plant with a BESS (Battery Energy Storage System), a 15MW battery capable of storing and releasing electricity according to network needs, while operating in synergy with the CCGT.

This demonstrator is a first in France and involved more than 70 experts from several Group entities. The innovation is based on the principle of hybridisation: the battery is integrated into the Blénod combined cycle gas turbines, creating a patented technical synergy. The battery can operate on its own or as a complement to the CCGT, providing increased flexibility. It can be activated in a few seconds, without additional CO₂ emissions, which makes it possible to take advantage of the full power of the CCGT: the responsiveness of the BESS (Battery Energy Storage System) improves the responsiveness to the CCGT, which then takes over.

Decommissioning of permanently shut-down thermal fleet units

EDF has planned all the decommissioning operations for units that have been permanently shut down or are scheduled for permanent shutdown. Financial provisions have been set aside to cover decommissioning costs for all the units currently in operation and the site remediation works⁽¹⁾.

In 2025, EDF continued the decommissioning work on sites that are no longer in operation.

EDF is careful to preserve the potential of its sites, through reasonable allocation of spaces and local monitoring of relevant urban planning regulations to secure its own needs. By applying this differentiated management of spaces and ground, EDF’s land is gradually being released from land use rules (freeing up new land resources, with potential for biodiversity and land de-artificialisation) while taking account of the Group’s needs and assisting local authorities as they develop new types of activity.

• (1) See section 6.1 “Consolidated financial statements at 31 December 2025”, note 16.1 “Other provisions for decommissioning”.

1.4.1.3    Renewable energy generation and storage

The EDF group is a major player in renewable energies in Europe, and the largest supplier of hydropower in the European Union.

Hydropower is the principal renewable energy produced by the Group. The Group is also a leading actor in the development of competitive industrial channels, primarily for wind and solar power.

Renewable energies account for over a quarter of the Group’s total installed capacity.

The EDF group’s commitments for expanding renewable energies are also presented in section 3.2.2.1.2.1.2 “Low-carbon generation” - “Roadmap for increasing the Group’s decarbonised generation”.

The Group’s net installed capacity in renewable energies at end-2025⁽¹⁾

• (1) Proportionally to the Group’s percentage ownership.
• (2) Including the Middle East.

1.4.1.3.1    Hydropower generation in France

1.4.1.3.1.1    EDF’s hydropower generation fleet

Hydropower is the largest source of renewable electricity, and the second source of electricity generation in France after nuclear power. It is an important sector for the electricity system due to its flexibility and its contribution in terms of network balance and supply security.

EDF’s hydropower fleet comprised 424 power plants at the end of 2025, with an average age of 80 years⁽¹⁾.

In mainland France, hydropower plants are mainly located in mountainous areas in the Pyrenees, the Alps, the Massif Central and the Jura, and along the Rhine. Their combined installed capacity amounts to around 20.12GW⁽²⁾ (23.3% of EDF’s total installed capacity) and the observed potential average annual output is nearly forty terawatt hours.

The various hydropower facilities are designed to optimise the use of water resources in the valleys under a multi-use water management approach. Given the size and variety of its facilities, EDF has installations able to respond to all types of desired uses, in base load and peak load. They provide optimisation levers due to their flexibility of use.

• (1) The average generation potential over 60 years is restated based on observed climate change.
• (2) Gravity-based generation potential only, not including pumped-storage energy.

• (1) Sliding 1-year arithmetic mean for a constant fleet, recalculated in 2021; no new facilities commissioned or declassified in 2025.
• (2) Excluding French overseas départements and regions, and Corsica.

1.4.1.3.1.2    Performance of the hydropower generation fleet

In 2025, EDF spent more than €630  million (external purchases and capitalised labour) on hydropower fleet development and maintenance, to ensure optimised, safe operation.

A highly-automated and remotely-monitored fleet

Approximately 77% of the installed hydropower capacity (i.e. over 20,115MW) is remotely controlled from telecontrol centres, under centralised management for each valley. These centres can adjust the operating programme at any time to meet electricity system requirements or respond to economic opportunities on the electricity market.

To improve the reliability of its power plants, EDF monitors physical parameters of the machinery (temperature, vibration, etc.) from its regional operations centres. Any anomaly can thus be speedily detected, and incidents can be avoided through enhanced knowledge of the condition and operating behaviour of equipment.

Two of these regional operations centres now function as 24/7 support and service centres, providing remote support to the operator in order to limit mobilisation of on-call personnel and provide technical support to the employees mobilised when necessary.

Technical performance of the fleet and hydraulicity conditions in 2025

Hydropower output can vary significantly from year to year due to weather-related fluctuations in water resources. The year 2025 was characterised by a slight water deficit and good generation performance. EDF’s hydropower fleet delivered 10.23% of EDF’s total power output in France.

Anticipating future needs driven by the rise of intermittent renewable energy (solar and wind power), the emphasis is on increasing hydropower plant flexibility and fine-tuning power plant management.

1.4.1.3.1.3    Hydropower safety

EDF performs regular monitoring and maintenance of dams, contributing to hydropower safety. Hydropower safety consists of all the measures taken during the design and subsequent operation of hydropower facilities, to protect people and property against water-related hazards arising from the presence or operation of structures.

Hydropower safety is a major, permanent concern for EDF and involves three main activities:

• control of operational risks, i.e. risks caused by changes in water levels or water flow downstream of the facilities;
• management of the facilities during periods of exceptionally high water levels, to keep the installations and surrounding communities safe;
• measures to prevent the major risk of dam or reservoir failure, through regular monitoring and maintenance of facilities under the supervision of public authorities. In France⁽¹⁾, 259 class A and B hydropower structures undergo hazard assessment studies every ten and fifteen years respectively. These studies consolidate an overview of the facilities and associated countermeasures, forming part of a risk mitigation procedure⁽²⁾. The 67 largest dams are covered by a special administrative procedure (the Special Intervention Plan).

See also section 2.2.1 “Operational performance risks”, risk 1F “Hydropower safety risks”.

In 2025, work was carried out to prevent the risk of boulders falling on the Gnioure (Ariège) and Coiselet (Ain) dams. This required the reservoir level to be lowered as a preventive measure.

1.4.1.3.1.4    Challenges relating to hydropower generation

Hydropower is a key component of the energy transition, due to both its low-carbon output and its flexibility and storage capability, which far outperforms other energy storage solutions. Hydropower also plays a major role in the regional management of water resources.

Concession renewals

• (1) Mainland France and overseas départements and regions, including wholly-owned subsidiaries.
• (2) For further details, see the annual report of the Inspector for Hydropower Safety, available from EDF’s website.

The agreement proposed by the French government (see the “regulatory framework” panel above) must now be transposed into French legislation, to give a new impetus to hydropower expansion and launch new large-scale projects. The proposed law 2334 “to revive investment in the hydropower sector in order to contribute to the energy transition” was tabled by two French members of parliament on 13 January 2026. It was adopted at first reading by the National Assembly on 5 February 2026, and will be examined by the Senate on 13 April 2026.

EDF has identified a project portfolio with the potential to add 2GW of capacity by 2035, notably the construction of the new Montézic pumped-storage hydropower plant (PSHP), and 2GW beyond that horizon, i.e. a potential 20% increase in its installed hydropower capacity.

Rather than waiting, EDF has been seeking ways to improve its hydropower generation fleet for several years:

• it has increased turbine flow rates or machine efficiency (overpower) for unamended concessions, where necessary replacing the machines and equipment concerned (turbo-alternator units, transformers, etc.) to accommodate these power gains; examples include:

• >the renovation of the Grand-Maison Pelton units, which began in 2012 and was completed in 2025, resulting in a gain of 13MW on each of the four turbines thanks to replacement of the wheels and injectors with a new design, and replacement of the transformers and alternators,

• >the modernisation of the Laval-de-Cère 2 hydropower plant, the most powerful in the Lot département, which will increase its generation capacity from 90MW to 100MW thanks to replacement of the two existing Francis turbines with two new, more efficient turbines featuring a revised design (yielding an efficiency gain of around 5%). This project is being carried out over three years and will be completed in 2027;

• it has made improvements in compliance with Article L. 511-1-6 of the French Energy Code for concessions that have undergone non-substantial amendments. Since 2022, seven applications for capacity increases have been submitted. The Montahut (Hérault) project, which will be completed in 2026, is increasing the plant’s capacity from 90MW to 96MW or nearly 7%, by replacing the two Pelton wheels with more powerful and better-designed models, modifying the injectors for greater efficiency, and changing the two alternators.

EDF is also involved in an 18MW pump turbine project in Saut-Mortier (Jura) to improve generation flexibility in the Ain valley. Initial work is already under way.

See also section 2.2.3 “Market regulation, political and legal risks”, risk 3B “Risks related to changes in the legislative and regulatory framework for hydropower concessions”.

Local integration in the hydropower valleys

EDF wants to contribute to sustainable, shared development in the areas around hydropower generation facilities, which are generally rural and mountainous, and sometimes isolated. EDF’s relations with local areas are founded on its behaviour as a responsible operator and long-term industrial actor in the valleys.

EDF’s dealings with hydropower zones principally concern two levers:

• employment, by trying to maximise local economic impact. EDF Hydro⁽¹⁾ makes 82% of all its purchases in its hydropower zones, thus benefiting the local industrial fabric by doing business with over 5,945 local companies. The employment footprint of EDF’s hydropower operations in mainland France is estimated at 4,917 indirect jobs⁽²⁾. EDF has also worked together with economic and institutional players in the valleys for over ten years through the “EDF Une rivière, un territoire” (EDF One River, One Region) programme, which has backed nearly 780 jobs by making equity loans to over 90 local businesses;
• ongoing dialogue with economic, political, and non-profit actors in the areas concerned, particularly water users and environmental stakeholders:

• >for balanced management of resources. The summer of 2025 was marked by two heatwaves and a significant rainfall deficit in the south, particularly in the Pyrenees, which affected the low-water support measures implemented by EDF: flow support on the river Garonne, carried out in close collaboration with the Établissement Public Garonne, accounted for up to 40% of the flow in Toulouse, and the Matemale agreement organising EDF’s support measures for the river Aude was activated by the French State at the same time as restrictions on water use. Support measures for the Garonne ended in September, but resumed in October,

• >for voluntary dialogue and consultation. EDF conducts numerous regional dialogue processes and consultations. For example, as part of the Vouglans – Saut-Mortier project in the Jura (to install a pump turbine on the left bank of the Saut-Mortier reservoir in the immediate vicinity of the existing hydropower plant, with commissioning scheduled for 2031), EDF organised an extensive voluntary targeted consultation process that lasted from the launch of studies in 2020 until April 2023 and led to several changes being made to the project to strike the best balance between energy, environmental and water use issues. This initiative was acknowledged during the public inquiry, held from May to June 2023. The construction phase of the project began in the summer of 2024, and dialogue and consultation are continuing.

Managing access to water

The maximum capacity⁽³⁾ of the dams operated by EDF in France is nearly 7 billion m³ of water. As well as being a hydropower producer, EDF is also a contributor to the sustainable local management of water resources.

EDF sustains the flows of many rivers in summer, to the benefit of aquatic ecosystems and other water uses: drinking water, irrigation, river-based sports and leisure activities.

• (1) EDF Hydro is the division of EDF SA that is in charge of operating hydropower facilities under concessions or permits in mainland France, and the associated engineering activities.
• (2) Using generally accepted academic definitions, based on the amount of purchases made in the French economy in 2025 and indirect employment content per million euros (economic data source: INSEE).
• (3) This is not the same as the active storage capacity that can actually be released given the characteristics of the facilities (such as the height of water intake structures), which is necessarily less.

Water resources are managed in consultation with the various stakeholders; in some cases, this involves agreements (overseen by the State as concession grantor) with local authorities, anglers, farmers, and the managers of tourist destinations and industrial sites. EDF is thus very much a stakeholder in local water management governance. The company has an innovative “Basin coordinator delegates” scheme ensuring that all EDF’s functions have representation in France’s water management authorities such as Basin Committees and water authority boards, on behalf of the French Electricity Union (UFE).

Action for climate change adaptation

For EDF’s hydropower activities, climate disruption could potentially have an impact on:

• plant safety and associated investments;
• the longevity of certain structures and equipment;
• variations in hydropower generation potential and its contribution to energy mix flexibility;
• the production and economic performance of assets;
• water uses and therefore management of multiple uses;
• water quality and ecosystems upstream and downstream of hydropower facilities and in reservoirs.

As a result, the three main challenges identified concern:

• 1. preserving the safety of facilities and people;
• 2. maintaining high-level economic and environmental performance;
• 3. continuing to make EDF’s essential contribution to management of multiple water uses in mainland France.

EDF’s climate change adaptation strategy for its hydropower operations in mainland France, developed as part of the ARCHE programme for adaptation and climate resilience of hydropower at EDF, was validated by the EDF group at the end of 2023. The Climate Change Adaptation Plan for hydropower was finalised and disseminated in January 2025.

The ARCHE programme action plan sets out four main areas and is broken down into about fifty actions, including for example:

• adapting EDF’s knowledge: scenarios of future changes in hydroclimatic parameters and other uses, improved weather forecasting, digital twins of watershed areas:

• >in 2025, the 2022 study on the impact of climate change on thermally sensitive dams (mainly arch dams) was improved by adding modelling of the reservoir’s water temperature profile;

• adapting EDF’s assets: plant monitoring, assessment of extreme hazards and vulnerability, making modifications to structures:

• >in 2025, a vulnerability assessment (not covering safety issues) was launched for generation assets, including evaluation of resilience measures and return-to-normal procedures. A preliminary assessment of all the hydropower fleet’s facilities and equipment was conducted;

• adapting EDF’s operations: business continuity, the business model (water management, storage, flexibility), development, environmental performance:

• >in 2025, development of a Major Climate Event Plan was launched, with three major climate events identified as priorities. This plan will be finalised at the end of 2026 after incorporating feedback from the planned 2026 national crisis exercise on the same subject);

• adapting EDF’s positioning/role: by developing communication, particularly scientific communication, on the role of hydropower, its development potential, and its contribution to the resilience of the regions. Examples of action undertaken in 2025 include:

• >a call for faster development of PSHPs was signed by EDF Hydro at the International Forum on Pumped Storage Hydropower, September 2025, Paris,

• >review and amendment of the ‘How-to Guide on Hydropower Climate Change Resilience’ published in September 2025 by the Hydropower Sustainability Alliance (an NGO bringing together public and private players in the sector),

• >presidency of ETIP Hydropower (European Technology and Innovation Platform for innovation cooperation in the field of hydropower) and contributing to the “Hydropower and Climate Change (adaptation and mitigation)” working group,

• >publications, notably via the learned society Société Hydrotechnique de France, about the carbon footprint and the advantages of PSHPs for the energy transition.

1.4.1.3.2    EDF power solutions

In February 2025, the activities of EDF Renewables, EDF’s International Division and EDF’s International Legal Division were merged to form EDF power solutions. The new entity has nearly 8,000 employees⁽¹⁾.

As a responsible and innovative industrial player, EDF power solutions develops, builds and operates renewable and low-carbon energy plants and flexibility and electricity transmission solutions. Using all its expertise, EDF power solutions works alongside its customers, providing them with tailor-made services to contribute to the decarbonisation and performance of electricity systems. In all the regions where it does business, the entity’s teams show daily dedication to accelerating the energy transition.

This new organisation aims to capitalise on technical, commercial and geographical synergies for a more efficient rollout of the Group’s low-carbon energy activities (excluding nuclear power and French hydropower, but including hydropower outside France) and flexibility solutions, in line with the goals of the Ambitions 2035 corporate plan and market developments. It also aims to clarify the organisation structure for external stakeholders, facilitate coordination and management of key relationships, and present a critical mass to partners.

EDF power solutions rolls out solutions that are central to the four pillars of Ambitions 2035: hydropower, onshore and offshore wind power, solar power, electricity storage, thermal power, networks and decarbonisation solutions (BtoB, BtoC, BtoG). In France, these solutions are limited to wind, solar and battery power.

EDF power solutions is also present in around twenty countries, including Belgium through Luminus (see section 1.4.5.3 “Belgium”). Its business outside France is divided into five geographic areas: North America, Latin America, Africa, Europe, Middle East and Central Asia, and Asia-Pacific (see section 1.4.5.4.1 “EDF power solutions’ international operations”).

With operations spanning the entire value chain from project origination to operation and maintenance via development, engineering, and asset construction and asset, EDF power solutions had installed capacity of 33GW gross and 20GW net at 31 December 2025. Excluding Luminus, this capacity is 30GW gross and 18GW net (the net capacity reflects EDF power solutions’ percentage shareholding).

The majority of EDF power solutions’ assets are deconsolidated. EDF power solutions develops, builds and operates its assets with co-investor partners.

Total net generation in 2025 amounted to 47TWh (43TWh excluding Luminus).

• (1) Number of employees in consolidated operations, including Luminus employees.

1.4.1.3.2.1    EDF power solutions’ installed capacity by energy type and country

Installed capacity by energy type and geographic area (excluding Luminus)

• (1) Capacities at 31/12/2024 are the sum of the capacities of EDF Renewables and EDF’s International Division. The scope is identical to 2025.
• (2) Gross capacity: total capacity of the facilities in which EDF power solutions is a shareholder.
• (3) Net capacity: capacity corresponding to EDF power solutions’ percentage shareholding.
• (4) The Europe, Middle East and Central Asia area does not include France or Luminus.

1.4.1.3.2.2    EDF power solutions’ activities in France

In France, EDF power solutions develops, builds and operates onshore and offshore wind projects, as well as solar and battery projects. At 31  December 2025, EDF power solutions had a total 4,031MW gross installed/operating capacity: 1,843MW of onshore wind power, 1,002MW of offshore wind power and 1,186MWp of solar power. A further 1,363MW of gross capacity (all technologies combined) is currently under construction. Net power output in 2025 amounted to 5.8TWh in France.

Onshore operations in France

During 2025, EDF power solutions installed and commissioned a range of onshore wind and solar assets in France, including the Châteaudun solar power plant (Eure-et-Loir), the Baignes wind farm (Charente) and the repowered Kergrist wind farm (Morbihan).

In the market for flexibility and battery network services, EDF power solutions is continuing its efforts to implement hybrid or stand-alone projects, notably with the upcoming commissioning of the Catalan Energy Storage battery.

Offshore operations in France

EDF power solutions has strong expertise in offshore wind power in France. In 2022, EDF power solutions and its partners commissioned France’s first offshore wind farm off the coast of Saint-Nazaire, with a capacity of 480MW. In 2024, EDF power solutions commissioned the 500MW Fécamp offshore wind farm off the coast of Normandy, and finally 2025 saw the full commissioning and inauguration of France’s very first floating offshore wind farm, Provence Grand Large (25MW). EDF power solutions now has a gross installed offshore wind power capacity of 1,000MW in France. Another significant milestone was reached in February 2025, when the Nord Prefecture received environmental authorisation for the construction and operation of the Dunkirk offshore wind farm, a key step for the successful continuation of the project’s development. Lastly, the construction of the Calvados offshore wind farm continues, and the first twelve boreholes for its foundations were begun and completed in 2025. EDF power solutions is also continuing development of the EMMN (Éolienne en mer de Manche Normandie) fixed wind farm and the EMGL (Éoliennes Méditerranée Grand Large) floating wind farm with a capacity of approximately 1,000MW and 250MW respectively, projects that were won in 2023 and 2024 following offshore wind tenders No. 4 and No. 6. BW Ideol acquired a 15% stake in the EMGL project in December 2025; it remains jointly controlled by EDF power solutions and Maple Power SAS, with each partner holding a 42.5% stake.

The EDF group’s R&D activities are mainly carried out by EDF’s Research and Development Department. These activities are in line with the Group’s raison d’être and the strategic orientations of the Ambitions 2035 corporate plan.

EDF’s R&D is both integrated and cross-disciplinary, to foster synergies and method transfers between the different divisions. It is competent for all the Group’s fields of activity, with subject-, function- and project-specific skills, and integrative skills for large-scale systems. It has 1,880 employees in France, plus 155 PhD students and 107 work-study trainees of 48 different nationalities. Worldwide, it also has 274 employees on local contracts and 14 expatriates. It is organised on a multi-site basis, with several sites in France and other countries, mainly Germany, the United Kingdom, Italy, the United States, China and Singapore. EDF R&D’s main centre is at Palaiseau on the Paris-Saclay Marcel Boiteux science campus.

The main mission of the EDF group’s R&D is to provide day-to-day support to the Group’s businesses and subsidiaries by contributing its high-level expertise and its high-performance experimentation and simulation capabilities. It also helps to build the Group’s future, by anticipating the major changes and challenges to come.

Its research areas are structured around five strategic axes, the first four of which are those of the Ambitions 2035 corporate plan:

• supporting customers for electrification and reducing their carbon footprint;
• being able to generate more low-carbon electricity (nuclear, hydro and depending on demand, renewable energies);
• developing the networks to meet the challenges of the energy transition;
• developing flexibility solutions to meet the needs of the electricity system;
• accelerating the digital transformation.

In 2025, the EDF group’s total R&D budget was €806 million, comprising the EDF R&D budget of €550 million and the R&D carried out separately by certain subsidiaries, mainly Framatome, Enedis, EDF Energy and Arabelle Solutions. In France, EDF’s entire R&D operating budget is dedicated to decarbonisation and the transition of energy systems.

EDF R&D’s work serves all the Group’s functions. It explores technological solutions that can improve their performance, and prepare for the Group’s future in the longer term. It contributes to making EDF a world-leading industrial group in low-carbon electricity systems.

Network research for Enedis is carried out under a service agreement which contains obligations guaranteeing the protection of commercially sensitive information and compliance with the principle of the distributor’s management independence. Enedis also runs its own R&D programme, independently of EDF.

1.5.1.1   Supporting customers for electrification and reducing their carbon footprint

The goal of achieving carbon neutrality by 2050, and the 2022 energy crisis caused by the Ukrainian conflict, have led EDF to step up work to electrify customers’ uses and make the best possible use of sources of flexibility.

EDF’s R&D supports the entities in charge of residential customers, business customers, industrial customers and local authorities, helping them to:

• decarbonise and electrify industrial, residential, tertiary and agricultural uses;
• decarbonise and electrify the mobility and transport sector;
• promote the implementation of electricity-intensive uses.

1.5.1.2   Being able to generate more low-carbon electricity (nuclear, hydro and depending on demand, renewable energies)

In centralised generation (nuclear, hydro and other renewable energies -onshore/offshore wind, solar, etc.), EDF’s R&D is developing tools and methods to:

• improve the safety of generation plants
• optimise their operating lifespan, including extensions beyond 60 years for nuclear reactors;
• optimise the construction times of nuclear new builds;
• raise their performance in terms of output and environmental impact.

1.5.1.2.1   Consolidating and sustaining nuclear generation with a very low-carbon footprint

EDF

EDF’s R&D is working to protect EDF’s industrial assets through actions in line with its policy to improve the safety of facilities. The aim is to enhance performance and extend their operating lifespan beyond 60 years. For new nuclear projects, the aim is also to secure design options, optimise construction times, and evaluate fourth-generation reactors.

To support these programmes, R&D is developing digital simulation tools and experimental test resources. It also designs tools able to handle the new challenges posed by digital data mass growth, IT security and new information and communication technologies.

R&D is continuing to develop digital initiatives, prioritising close partnership-based collaboration with the other stakeholders in the nuclear industry.

In addition, EDF’s R&D is developing high added-value codes for nuclear, mechanical, hydraulic and thermo-hydraulic calculation.

Framatome

Framatome’s R&D aims to develop expert knowledge of the most advanced technologies, in order to attain the highest standards of safety and performance for its activities as a designer and supplier of nuclear steam supply systems, nuclear equipment and services, and fuels.

This R&D activity is primarily carried out by Framatome’s own development teams and technical centres, in partnership with EDF’s R&D. International partnerships have also been set up.

1.5.1.2.2   Supporting the development of low-carbon renewable energies, energy storage and low-carbon hydrogen

One major avenue of research for EDF’s R&D is support for the rise of low-carbon renewable energies in France and internationally. For renewable energies, energy storage and low-carbon hydrogen and its derivatives, the goal of this research is to:

• identify technological breakthroughs that offer a significant competitive advantage; and
• help the most promising technologies emerge industrially, working in partnership with academics, industry and start-ups.

EDF is studying a wide range of low-carbon renewable energies, low-carbon hydrogen technologies and storage solutions: hydropower, solar power, onshore and offshore wind power, biomass, electrochemical batteries, renewable heat, and more.

For offshore wind power, its R&D division is developing specific tools to model the hydrodynamic and mechanical dimensions of fixed and floating offshore wind turbines.

EDF’s R&D is also working to develop tools and methods to enhance operational performance and optimise the cost of projects concerning renewable energy generation systems, energy storage, and systems for hydrogen production by electrolysis using EDF group low-carbon electricity.

1.5.1.2.3   Environmental performance of EDF’s infrastructures

Climate change, the marked decline in biodiversity and the Earth’s limited resources are making a low-carbon energy mix absolutely necessary. EDF’s R&D work is designed to:

• contribute to determining how changes to the regulatory environment should be implemented;
• prove that EDF’s generation facilities are on a par with the best available techniques (BAT) at an economically acceptable cost, and to leverage these BAT in new projects;
• identify and control EDF’s impacts on the aquatic and terrestrial environments;
• be able to anticipate and adapt to the impacts of climate change: for example, forecasting changes in the availability and quality of local water resources, and assessing the robustness of power plant heat sinks in view of these changes;
• contribute to leveraging EDF’s positive actions with stakeholders, including in regions and local areas.

1.5.1.3   Developing the networks to meet the challenges of the energy transition

The energy transition to a decarbonised economy in Europe hinges on large-scale integration of intermittent, distributed low-carbon renewable energies, especially in the distribution network. This integration requires smart grids to be developed, so as to have the capacity to manage a more decentralised electricity system with a much higher number of stakeholders. The major challenges are technical, economic and regulatory in nature, with new challenges to be tackled such as:

• developing transmission and interconnection networks at European level, and reinforcing European wholesale market coupling in order to optimise electricity exchanges;
• managing the intermittency of generation sources using low-carbon renewable energies, and pushing back the boundaries relating to local energy flow management and electricity grid stability that limit integration of renewables into electricity systems, especially in isolated areas;
• integrating new uses of electricity by optimising the generation mix and grid requirements, and exploring flexibility levers and the way they are structured;
• optimising distributed energy systems (demand-side management, distributed generation and storage, etc.) and safely integrating them into larger-scale energy systems;
• adapting the control of electricity systems in order to cope with the lower system inertia resulting from increasing use of power electronics to connect uses and new generation sources.

These challenges require research on the transmission and distribution grid equipment, generation and energy storage installations and their communication functions and protocols, management equipment and practices, and also the economy of electric uses and services and related markets.

1.5.1.4   Developing flexibility solutions to meet the needs of the electricity system

The rise of intermittent renewable energies (wind and solar power) and new uses of electricity (electric vehicles, heat pumps, hydrogen, etc.) in electricity systems is changing the management of the balance between generation and consumption in those systems. Since generation and consumption must be balanced at all times, both supply-side and demand-side upward and downward flexibility levers are needed to cope with variations in injections and withdrawals, whether they are predictable or uncertain.

In this context, the R&D work is aiming to:

• develop models for forecasting renewable energy supply and demand at different time horizons and at different levels of the electricity system;
• anticipate the future flexibility needs of electricity systems, by developing low-carbon electricity system modelling that includes detailed representation of the technical constraints on generation, consumption and networks, plus the impact of weather and climate hazards on electricity system management;
• develop flexibility levers at existing generation facilities, energy storage solutions and appropriate management systems;
• develop flexibility in uses (e.g. smart charging), notably defining the algorithm required to manage this flexibility;
• develop tools for forecasting the supply-demand balance and optimising market flexibilities as closely to real time as possible, to provide support for the entities in charge of optimisation and trading;
• identify business models for deriving income from flexibility, and develop relevant pricing.

1.5.1.5   Accelerating the digital transformation

The digital transformation impacts the entire electricity system, and is a key driver of the electricity and climate transitions described above. Information technology research focuses on:

• anticipating and managing potential disruptions caused by fast-growing technologies such as artificial intelligence (AI), quantum computing, the Internet of Things (IoT), mobile networks including 5G and satellites, industrial system cybersecurity, robotics, etc.;
• maintaining and developing scientific computing resources and high-performance algorithms for use in studies conducted by EDF’s R&D and the engineering departments.

1.5.1.6   EDF’s scientific R&D partnerships and international research

To conduct its research and development programmes, EDF’s R&D forms a large number of scientific partnerships both in France and internationally. The goals of these partnerships are to give EDF access to the highest international levels in disciplines that are central to the EDF group’s key challenges, to supplement its in-house skills, and to direct academic research towards R&D that is relevant for the EDF group. These partnerships take various forms:

France

EDF’s R&D has entered into framework agreements with major public research organisations in France. The main academic partners are the French Alternative Energies and Atomic Energy Commission (CEA), the French national research agency (CNRS), and national research organisations such as INRAE, IFP Énergies Nouvelles, BRGM, INRIA, CSTB and INERIS.

The R&D team also has around twenty joint laboratories and teams that have existed for several years with academic partners and technical or industrial centres, such as HYNES (studying water and the environment) with INRAE, and MELUSINE (dedicated to membrane technology applications for the reuse of process water and chemicals).

Partnership framework agreements have also been signed with various industrial and/or academic entities.

Several partnerships are part of the Paris-Saclay science campus ecosystem, for example:

• the SEISM Scientific Interest Group on earthquakes (GIS SEISM), whose members are the higher education institutions CentraleSupélec and ENS Paris-Saclay, the CNRS, France’s national geological research agency BRGM and EDF;
• the Institute of Mechanical Science and Industrial Applications IMSIA, a joint research unit consisting of the National School of Advanced Engineering ENSTA, the CNRS, the CEA, and EDF.

EDF’s R&D is also a member of the Energy Transition Institutes which were set up as part of France’s “Investments for the Future” programme. These institutes include the Ile-de-France Photovoltaic Institute (IPVF); France Énergies Marines, which focuses on marine energies and offshore wind power, Efficacity, which conducts research into energy efficiency; and the Supergrid Institute, which specialises in the electricity networks of the future.

Finally, EDF is a founding member of several European associations with EU recognition, such as Nugenia (the Nuclear generation II & III alliance), the SNETP (Sustainable nuclear energy technology platform) for nuclear power, and EASE (the European association for storage of energy) for energy storage. Its R&D team is actively involved in the European Industrial Alliance on SMRs, where R&D experts are contributing their expertise as members of several of the alliance’s technical working groups, particularly the Industrial Applications, Technology and R&D&I, Skills, Public Engagement, and NuclearSafety and Safeguard groups.

Germany

In the early 2000s, EDF set up EIFER, a European Economic Interest Group in Germany, together with the Karlsruhe Institute of Technology (KIT). EIFER is the leading centre for hydrogen research. EIFER’s teams are also fully engaged with themes relating to local distributed energy systems, biomass, regional energy data processing, and digital mapping systems (GIS), as well as analysing developments in the German electricity system and energy market.

United Kingdom

The EDF R&D UK Centre consolidates the Group’s positions in the British research ecosystem. It works with the University of Manchester, Imperial College, the National Nuclear Laboratory (NNI) and the University of Bristol on research concerning nuclear power and renewable energies.

EDF R&D UK provides direct support for development of EDF’s business in:

• existing nuclear plants (extension of the lifespan of AGRs (Advanced gas-cooled reactors)), and plant decommissioning following announcement of the planned shutdown of several reactors;
• new projects such as Hinkley Point C;
• generation IV reactors.

The centre is also fully mobilised in research concerning digital clients and offshore wind power projects.

Italy

In Italy, Edison’s Research, Development & Technological Innovation (RD&TI) Division provides support for strategy in the medium and long term, and for the development of new Edison services and offerings in the shorter term. The teams and R&D laboratories are mainly located in innovation units in the two Italian Polytechnic Universities of Milan and Turin, thus nurturing cooperation and embedding Edison RD&TI in Italy’s innovation and research world. The topics covered include electric mobility and interactions between electric vehicles, buildings and the grid, industrial robotics, and industrial decarbonisation.

Asia

The R&D centre based in Beijing is a valuable asset for contributing to large-scale Chinese demonstrators developed by partners (such as CGN, CNNC, and State Grid Corporation of China for smart grids and nuclear facilities. It also benefits from China’s highly advanced ecosystem of innovative construction methods (digital technologies, additive manufacturing⁽¹⁾, etc.). This centre actively supports EDF China’s commercial activities for local multi-energy systems combining electricity, biomass, hydrogen and heating and cooling networks.

The Singapore-based Asia-Pacific R&D centre focuses more specifically on the energy transition and industrial decarbonisation in South-East Asia, in order to open up business opportunities for EDF in this region of the world. This centre is benefiting from an EDF multi-energy platform for a project with the renowned Nanyang Technological University (NTU). It is also working with academic partners and local industry in a range of projects:

• feasibility studies for electricity interconnections in South-East Asia and changes in Singapore’s electricity mix;
• real-time low-carbon energy certification;
• assessment of regional opportunities for centralised or distributed energy storage;
• industrial decarbonisation (e.g. of the mining sector in Australia).

United States

For the past twelve years, the Group has had an R&D centre in Silicon Valley. This centre supports EDF’s business development in the United States and contributes to innovation in the Group. Its work covers several areas including:

• direct support in US market analyses for the group’s subsidiary EDF power solutions North America;
• market design to inform the choice of development projects by the Group’s business units in the United States;
• analysis of the dynamics of the US nuclear sector;
• assessment of new business models for the Group in the United States.

This section presents the business control and risk management systems applicable to the Group for 2025. These systems, developed and implemented with due respect for the management independence of network infrastructure operators, are in line with the framework defined by the corpus of Group policies.

They also comply with the general principles set out in the French Financial Market Authority’s (AMF’s) risk management and internal control system reference framework of 2 July 2010. They are based on developments in the main international reference frameworks, particularly COSO 2013.

Framework and objectives

The EDF group organises its business and risk control through some 40 Group policies, signed by the Executive Committee. This corpus defines the long-term, cross-functional requirements to be implemented in all of the Group’s controlled entities and subsidiaries. Regular updates are made to adapt requirements to changes in regulations and strategic policy orientations. They are fully in line with the Group’s raison d’être.

Organisation

The organisation structure of EDF’s Executive Management is described in section  4.3.1 “Members of the Executive Committee”. Each Executive Committee member is responsible for implementing all actions necessary for controlling the risks within their scope.

Scope

Within the scope of control (which excludes subsidiaries that are regulated infrastructure operators), the control objectives and principles are applied by the entities and subsidiaries themselves, which also ensure that they are implemented in their own controlled entities and subsidiaries.

For the regulated infrastructure operators and other significant affiliates, EDF representatives in their governance bodies make sure that a business and risk control system is put in place, and that there is regular reporting on risk mapping, internal control and audit activities (audit programme and main results). They may also conduct periodic audits of the respective entities to check the effectiveness and appropriateness of each of these systems. The applicable principles are adapted in the case of the regulated infrastructure operators, to ensure compliance with their management independence obligations.

The Group operates in a fast-changing environment that entails numerous risks of various kinds: political, geopolitical, regulatory, strategic or operational. Some are exogenous, while others are endogenous and inherent to the Group’s businesses. Their consequences may affect the Group’s operating results and financial position, and its ability to finance its strategy or development. They may also affect its internal or external stakeholders, its environment, or its reputation.

The Group presents below the specific risks to which it considers itself exposed, and the principal actions to control them without overriding the management independence of network infrastructure operators. No description is provided for non-specific risks, but they are also given due consideration.

Risks are divided into five categories described in sections 2.2.1 to 2.2.5:

• section  2.2.1 “Operational performance risks” describes the risks related to the Group’s operations in its various industrial projects and activities. In particular, this section describes the Group’s risk relating to current and/or future EPR projects, which is a major risk;
• section  2.2.2 “Specific nuclear operation risks” supplements section 2.2.1 for activities specifically related to the Group’s nuclear operations;
• section 2.2.3 “Market regulation, political and legal risks” describes the risks related to changes in public policy and regulations in the countries and territories where the Group operates, as well as the legal risks to which the Group is exposed;
• section 2.2.4 “Financial and market risks” describes the risks arising from exposure to the energy markets in which the Group operates, as well as risks related to changes in the financial markets and the reliability of the related information;
• section 2.2.5 “Group transformation and strategic risks” describes the risks related to the Group’s ability to adapt, particularly in terms of strategy and skills, in response to the needs for transformation brought about by climate change, new competition, and technological and societal changes.

All the risks identified in this document have been selected because they are significant in terms of the scale of their estimated impact for the Group. They are also ranked based on a qualitative assessment of their criticality that simultaneously considers the significance of the potential impact for the Group, the probability of occurrence and the level of control. The criticality assessments take account of the existing tried-and-tested control actions (but not new or future actions). This ranking produces a three-level scale of criticality for all risks: high, intermediate or moderate. The risk categories themselves are not ranked.

As a general rule, the scope of exposure is France, Belgium, Italy, the United Kingdom and all countries where the Group is present. When the scope of exposure is smaller, this is specified in the table and in the risk description.

Exposure to risk may vary depending on the period considered. The potential impact of these risks may produce effects at very different time horizons, from the very short term (less than a year), to the medium term (a few years) or even the very long term (several decades or more) depending on the nature of the industrial activity.

Control measures have been put in place to manage risks. Some of these measures such as internal control and the capital commitment approval process apply to all risks (see section 2.1 “Risk management and business control”); others are specific to each risk.

Link with the double materiality analysis. The goal here is to explain the link between the “risks” identified in this section, and the “impacts, risks and opportunities” (IRO) identified in the sustainability statement (see section 3.1.3 “Strategy, material impacts, risks and opportunities and CSR policy”).

Some of the risks in this section concern CSR issues (environmental, social and governance (ESG) matters). Under the Group’s risk mapping methodology referred to in the previous section, these may have:

• internal consequences (in which case they correspond to “risks” in the Sustainability statement);
• or external consequences (in which case they correspond to potential negative “impacts” in the Sustainability statement).

The analyses are consistent with each other: in short, the IROs (risks or negative impacts in the Sustainability statement) provide details of the CSR issues described in this section.

Table of risks – numbers, names and criticality

The following table summarises the correspondence between the risks in this chapter and the IROs in chapter 3 “Sustainability Statement and Vigilance Plan”.

The criticality assessment takes account of the existing control actions.

Criticality:    high    intermediate   moderate

• (1) This column indicates the European Sustainability Reporting Standards (ESRS) for which at least one IRO has been identified that corresponds to the risk.

1A – Risks related to management of large, complex industrial projects, including EPRs

CRITICALITY:  

a)   Context

As part of its business, the Group carries out projects (as project owner and/or project manager) that are highly complex, particularly the EPR projects at Flamanville 3 in France (in the start-up testing phase - see section  1.4.1.1.2.1 “EDF’s nuclear fleet in France and its operation” - “Flamanville 3”) and Hinkley Point C (HPC) in the United Kingdom (currently under construction - see section 1.4.5.1.2.5 “The New Nuclear Industry” - “Hinkley Point C (HPC)”), but also future projects such as the EPR2 projects in France (see section 1.4.1.1.3.1 “Preparation of a programme to build new EPR2 nuclear reactors in France”). These projects represent a major risk for the Group in terms of the potential financial impact on its balance sheet and the implications for its development strategy. They require significant investments and lengthy regulatory approval and review procedures.

The Group’s other large-scale projects currently under way are:

• major projects concerning the existing nuclear fleet (the Grand Carénage industrial refurbishment programme (see section  2.2.1 “Operational performance risks”, risk 1B “Risk of non-achievement of objectives for operation and/or lifespan extensions of nuclear power plants (France and the United Kingdom)”) and decommissioning projects (see section  2.2.2 “Specific nuclear operation risks”, risk 2A “Risks related to control of radioactive waste processing and decommissioning of nuclear facilities, and secure coverage of the related obligations”);
• offshore renewable energy projects (offshore wind power);
• international hydropower projects.

b)   Main risks

Cross-cutting risks concerning major projects

These projects face many technical, operational, economic, regulatory, political and environmental risks which could delay them, increase their cost, or even bring them to a halt.

Risks of technical or operational non-performance

The technical and operational risks associated with large, complex industrial projects expose the Group to major uncertainties in the execution and operation of these projects, with a potentially significant impact on the Group’s business, earnings, asset values, financial position, reputation, organisation and outlook.

In addition to or as a result of these uncertainties, the Group may also find itself in breach of its contractual obligations.

Risks related to financing and the regulatory framework

New reactor construction projects, particularly in France and the United Kingdom, require considerable investments, an appropriate market organisation and acceptable financing and revenue conditions.

Securing the necessary funding may be delayed or compromised by the economic and institutional environment, or the state of progress on projects.

External risks – political and geopolitical risks, administrative procedure risks

All these projects are large-scale and of long duration. They involve many industrial partners and require administrative authorisations, licences or permits which may be subject to disputes, withdrawals or delays in issuance.

These risks are exacerbated by a resurgence of geopolitical tensions and even conflicts in the countries where the Group has projects and operations. Following the establishment of the new US administration in January  2025, they may also manifest through potential international sanctions and tax measures (see section 2.2.1 “Operational performance risks”, risk 1E “Risks related to operational continuity of supply chains and contractual relations”).

Risks related to CSR issues

A very large number of stakeholders are involved in the Group’s major projects, which may, for example, need to be combined with regional development projects, or experience difficulties with acceptance by local populations. In addition, all major projects are exposed to the challenge of respecting the Group’s commitments to workers’ rights throughout the value chain.

Risks specific to the principal projects

Risks related to the Flamanville 3 EPR (France)

The Flamanville 3 reactor reached 100% nominal power on 14 December 2025 (see section  1.4.1.1.2 “Nuclear power generation in France”  - “Flamanville  3 EPR”). The test programme is continuing, to trial the equipment at full power and verify that it is working properly. On 26 September 2026, the Flamanville 3 reactor will be stopped for its first full inspection and a regulatory maintenance shutdown that will involve nearly 20,000 maintenance activities. This operation is an integral part of the commissioning process. It will bring the EPR to the level of robustness required for the coming decades.

Risks related to the Hinkley Point C EPR (United Kingdom)

Control of design and close monitoring of manufacturing and the major milestones for construction of Hinkley Point C (HPC) will determine the profitability of the project, and the financing of any future projects in the United Kingdom.

The main risks until the completion of the project concern:

• the ability to secure the skills and resources required for construction and commissioning;
• the ability to deliver and install qualified equipment in accordance with the start-up test schedule;
• the organisational arrangements necessary to achieve the required electro-mechanical assembly rates;
• the possibility of industrial action and work stoppages in response to changes and increases in the on-site workforce;
• the ability to resolve quality issues so that equipment and electro-mechanical assemblies can be delivered on time;
• management of the technical configuration and documentation so as to respect the commissioning schedule;
• the ability to effectively manage supply chain issues caused by the geopolitical and macroeconomic climate;
• resilience and the ability to respond to growing and ever-evolving cybersecurity threats and related events.

To support the control actions for these risks, the Group is:

• reinforcing the teams with experienced people;
• strengthening the consortium of companies handling the electro-mechanical assemblies;
• reorganising the site geographically, to facilitate access for equipment;
• making greater use of prefabrication.

Moreover, as the financing requirements for the HPC project exceeded the shareholders’ initial contractual commitments (committed equity), the shareholders were asked to provide additional equity (voluntary equity). The Group is currently the only contributor of voluntary equity, and is actively seeking funding solutions until HPC is commissioned.

The profitability and financing of the HPC project are sensitive to:

• delays in construction or difficulties in the commercial commissioning of the HPC EPR units, which could entail additional costs, bearing in mind that an overrun beyond 31  October 2036 could entail the loss of the revenue protection granted to these structures under the Contract for Difference (CfD) (see section 1.4.5.1.2.5 “The Nuclear New Industry”);
• inflation and changes in electricity market prices beyond the term of the CfD;
• the exchange rate between the pound sterling and the Euro.

CGN’s non-contribution of voluntary equity could entail a need for alternative debt or equity financing that could affect EDF’s profitability (dilution risk).

Risks related to fleet upgrading in France (EPR2)

In France, failure to obtain, or a delay in obtaining, financing and the authorisations required to continue development of the EPR2 reactor could have an impact on the Group’s financial position. Any delay in the launch of the project could lead to interruptions in engineering activities, and difficulties in maintaining skills and mobilising the supply chain, which would be detrimental to the industrial control and overall performance of the programme.

The major challenge is to create the right conditions for the decision to launch the programme, and to define the legal and financial framework necessary for its implementation.

To achieve this objective, several actions have been undertaken:

• consolidation of the cost and schedule estimates, based on a sufficiently mature design;
• strengthening the industrial strategy in a partnership approach with our main suppliers;
• notification to the European Commission of the programme’s structuring arrangements, in accordance with State aid regulations;
• obtaining administrative authorisations within a timescale compatible with the programme schedule.

Once the project is launched, EDF’s financial trajectory and the profitability of the project for EDF will be exposed to risks pertaining to cost control and construction scheduling.

Risks related to the Sizewell C EPRs (United Kingdom)

The Group’s risk as a non-controlling shareholder of Sizewell C is limited to its financing commitment, which is capped at £1.1 billion. As supplier of the design, the steam supply system and the turbine, the Group bears the risks incumbent on it in application of the contractual clauses, which also define the limits of those risks.

This project will help to sustain skills, capitalise on past experience and generate scale effects for the benefit of the EPR2 programme in France.

c)   Control actions

New organisation of nuclear activities

The two major changes in the Group’s organisation for nuclear operations (see section 1.4.1.1.1 “Nuclear organisation and governance”) are:

• reinforcement of project leadership for new nuclear projects, positioned at the level of the Executive Committee in a division that reports directly to the Chairman and Chief Executive Officer. This division is in charge of strategic management of new nuclear programmes and accountable for achievement of results on safety, quality, costs and project deadlines;
• reinforcement of new nuclear project management and the Supply Chain Division, equipping the new nuclear project manager to successfully execute the EPR2 programme. The project manager oversees and carries out the construction of major nuclear projects in compliance with the framework and objectives in terms of safety, security, quality, schedules and costs, until they are handed over to the operating teams.

Actions to strengthen competitiveness

The EDF group is committed to improving the competitiveness of Nuclear New Build projects, particularly by means of:

• efficiency gains in engineering and data use;
• equipment standardisation and prefabrication;
• a competitiveness plan with the main suppliers.

The vigilance plan and CSR issues

In accordance with EDF’s vigilance plan, project management takes into consideration every project’s potential impacts on human rights, the environment, health and safety throughout the value chain, and the CSR issues of dialogue and consultation with stakeholders, ethics and responsible land management (see chapter  3 “Sustainability Statement and Vigilance Plan”).

1B – Risk of non-achievement of objectives for operation and/or lifespan extensions of nuclear power plants (France and United Kingdom)

CRITICALITY:  

a)   Context

The fleet of nuclear reactors that the Group currently operates in France is highly standardised (see section 1.4.1.1.2.1 “EDF’s nuclear fleet in France and its operation”). The Group aims to continue operating its nuclear fleet in France significantly beyond 50 years and to achieve this, it has drawn up a major industrial refurbishment programme (the Grand Carénage programme).

In the United Kingdom, the fleet consists of advanced gas-cooled reactors (AGR) and the Sizewell B pressurised water reactor (PWR):

• for the fleet of advanced gas-cooled reactors, the objective is to continue the operation of Heysham 1 and Hartlepool until 2028 and Heysham 2 and Torness until 2030;
• for the pressurised water reactor (Sizewell  B), the objective is to continue its operation for a further 20  years after the 40  years currently planned (see section 1.4.5.1.2.2 “Nuclear production”).

b)   Main risks

The occurrence of any of the risks described below could result in significant additional costs, a decrease in electricity generation, a decline in revenues and a negative impact on the Group’s financial position and the valuation of its nuclear assets.

Nuclear fleet in France

• The standardisation of the nuclear fleet entails the risk of a malfunction common to several reactors (see section  1.4.1.1.2 “Nuclear power generation in France”).
• The Group could have to make repairs or significant, costly modifications to all or some of its nuclear fleet. Events may occur that affect the operation of the fleet or its output, which could lead to a temporary shutdown or closure of all or part of the fleet.
• At each reactor, during the 10-year inspections, EDF carries out studies and makes changes to improve the level of safety and demonstrate the reactor’s ability to operate for a further 10 years. After receiving a report on the inspection’s findings for each reactor, the ASNR states its position on the measures taken by the operator and may issue additional requirements.
• Delays in preparation and drafting of the authorisations required to initiate operations may be a source of uncertainty. Delays in the manufacture and delivery to site of new equipment, or performance of on-site work when a large number of industrial operations are taking place at the same time, may also be sources of uncertainty.
• Risks of anomalies in components, equipment or parts of equipment delivered by EDF’s contractors and suppliers (see section 7.1.5 “Litigation”) could require justification or correction of the anomalies and potentially extend shutdowns in the nuclear fleet. EDF has set up a plan to prevent and combat counterfeiting, falsification and fraud in the plants manufacturing equipment for nuclear power plants.
• The high nuclear modulation situation present since 2024 could entail additional maintenance costs.

Nuclear fleet in the United Kingdom

• Given the nuclear safety rules applicable in the United Kingdom and AGR reactor technology, when the time comes EDF Energy may not obtain the necessary authorisations from the Office for Nuclear Regulation (ONR) to operate its existing nuclear reactors until the end-of-operation date currently planned (for AGRs) or under consideration (for the Sizewell B PWR), or may obtain such authorisations under conditions entailing significant expenditure or investment for the Group.

Other nuclear facilities

• The Group is also financially exposed to risks associated with nuclear reactors where EDF is not the operator but a shareholder (Belgium, China). The Group may need to contribute, in proportion to its investment, to costly repairs or modifications to these reactors, or to events that may have an impact on their operating lifespan, output or availability. The Group is also exposed in terms of the value of its assets.

Other risks

• Any serious nuclear incident not involving the Group but with extensive consequences worldwide could lead the safety authorities to issue new reactor upgrade requirements applicable to reactors owned by the Group and in which it has investments.

c)   Control actions

The action plans are led by the operational nuclear fleet engineering and operating teams.

In France, in particular, these plans are part of the START 2025 project, the Grand Carénage industrial refurbishment programme (see section 1.4.1.1.2.1 “EDF’s nuclear fleet in France and its operation”), and the new organisation of nuclear activities (see section  1.4.1.1.1 “Nuclear organisation and governance”). Key features of these plans are:

• the periodic safety review, carried out during the 10-year inspections, which reinforces the level of safety in view of international best practices, the condition of the facilities, the experience gained from their operation, and developments in knowledge and the rules applicable to similar facilities;
• a regularly updated control and repair strategy for all its reactors, on which the ASNR states its position.

In the United Kingdom, risk control is based on:

• ongoing interactions with the regulator on safety cases relating to the operating lifespan of facilities, assessment by the regulator and licensing requirements;
• Sizewell B’s long-term operating programme, with a technical and business case to support the decision on the investment programme required for extending the operating lifespan;
• reviews, where necessary, of the AGR plants’ operating lifespan and preparations for defuelling in the event of early closure;
• strategies for preventive monitoring and maintenance of facilities so as to respond early to problems that could lead to loss of generation.

1C – Risk of attacks against assets, including cyberattacks

CRITICALITY:  

a)   Context

The Group is exposed to risks of failure by or damage to its tangible and intangible assets, including its information system. In particular, these risks may arise from malicious acts, including cybercrime.

b)   Main risks

Attacks against assets

The Group’s assets consist of its workforce and its tangible and intangible assets. The main risks for its assets are:

• malicious acts of any kind, or a crisis situation (conflicts, terrorist attacks, etc.) in areas where the Group operates, with negative consequences for the Group’s operational activity, financial, legal or asset position, or reputation;
• more stringent laws and regulations relating to the protection of sensitive sites and critical infrastructures.

Attacks against the cybersecurity of information systems

This risk concerns disruption or interruption of a business process, deterioration, unavailability, loss or disclosure of information following a major cyberattack or malicious action, or as a result of carelessness, human error, or espionage.

This risk is increasing for the following reasons:

• the current geopolitical context;
• the rising number and professionalisation of threats;
• acceleration of the digital transformation of business processes;
• the larger attack surface in our information systems, due to operation as an extended enterprise, growing dependence on external solutions (Cloud technologies, SaaS, etc.), adoption of new technologies (AI, IOT, etc.), and the obsolescence of certain components of our IS.

c)   Control actions

Attacks against assets

The vital importance of the Group’s power generation and the extent of the potential negative material consequences have led to the gradual implementation of a system covering the entire security chain, from detection to protective intervention, including diagnosis, deterrence and prevention.

This system is made up of:

• an Asset Security against Malicious Acts policy;
• an appropriate organisation at all levels of the Group;
• procedures for the protection of people, real estate assets and intangible assets, instructions and tools.

In 2025, the main asset protection actions were:

• preparing for implementation of the EU’s NIS 2 (Network & Information Security 2) Directive, in liaison with the French National Agency for Information Systems Security (Agence nationale de la sécurité des systèmes d’information - ANSSI), and the Critical Entities Resilience (CER) Directive, in liaison with EDF’s supervisory authority, and finalisation of compliance with France’s “PCMNIT” regulations (for protection and control of nuclear materials, their facilities and their transport);
• management and coordination of the asset security community by the Security Management Steering Committee, composed of Executive Committee-level asset security managers;
• acculturation actions, notably via completion of the “Cyber Protection Pass” e-learning and presentations by the Group Information Systems Division to raise the business lines’ awareness of asset protection;
• subscription to a new security assistance contract to meet the EDF group’s legal obligations to protect its employees abroad (on short-term assignments and expatriation);
• updating the Security and Economic Intelligence Division’s Business Continuity Plan and applying it in a Group crisis exercise.

Attacks against the cybersecurity of information systems

The system for these attacks consists mainly of:

• an Information Systems Security policy;
• an appropriate organisation at all levels of the Group, including creation of the Cyber Centre of Excellence;
• an IT and Telecommunications Resources Charter applicable to all users of EDF SA’s information systems (employees or partners), which is incorporated into the Company’s internal rules;
• a Group instruction on personal data protection which explains the requirements of the GDPR as part of the Group’s Ethics and Compliance policy.

The main actions identified for 2025-2026 relate to:

• implementation of the recommendations defined following the 2023 internal assessment: stronger management, standardisation, development of operational cyber activities, greater integration of industrial information systems into the Group’s cybersecurity, increased awareness of cybersecurity and information protection;
• improvement and industrialisation of response capabilities in case of a successful attack: adapting crisis management and reinforcing forward planning, notably for post-incident reconstruction;
• grouping together the central functions’ skills and cyber expertise from 1  January 2025, to provide comprehensive, homogeneous control of processes and support for the Group, while maintaining a network of local contacts;
• recognition by the ANSSI of the Group’s cyber surveillance skills (through the PDIS qualification as a Security Incident Detection Service Providers).

1D – Risks to safety or health at work (employees and contractors)

CRITICALITY:  

a)   Context

Employees are a concern of the highest importance for the Group and its contractors. Due to the industrial nature and diversity of its activities, compliance with health and safety rules and consideration of risks likely to harm people working on the Group’s sites is a priority.

b)   Main risks

The risk of work-related accidents or illnesses cannot be ruled out for the Group’s areas of activity, including across the entire value chain.

c)   Control actions

• Implementation of the necessary steps to ensure compliance with health and safety laws and regulations in the various countries in which the Group operates.
• Group-wide actions:

• >definition and promotion of life-saving rules and the BEST (Bâtir ensemble l’excellence en santé sécurité au travail) framework for workplace health and safety,

• >for health and safety management: organisation of an annual “Safety break” for group discussions in each team, with the aim of improving and strengthening safety action plans where they work.

• Actions at the level of each Group entity: action plans aimed at continuously improving occupational safety and health.

1E – Risks related to operational continuity of supply chains and contractual relations

CRITICALITY:  

a)   Context

Access to materials, products and services critical to the Group may be threatened by small markets, changes in the industrial offering, greater competition from new uses, regulations (export barriers and controls) and/or geopolitical tensions.

b)   Main risks

The Group is exposed to:

• risks related to the performance and operational durability of supply chains and contractual relations with its suppliers;
• the risk of reduced capability, unavailability and price volatility (supply disruption or pressures);
• a logistics risk relating to the materials, equipment or services that it purchases for the needs of its businesses;
• the resulting risks concerning deadlines and product quality.

These difficulties could limit the Group’s ability to achieve its operating and development objectives, and that could have a significantly negative effect on the Group’s financial performance and competitive position.

Access to critical materials, products and services for the Group

For certain raw materials, scarcity or conditions of access may become critical for the Group due to geological, geopolitical, industrial or regulatory restrictions, or for reasons related to competition, particularly in an energy transition context.

Certain crises (public health crises, conflicts) may also exacerbate or generate difficulties regarding access to certain products, materials or services required for the Group’s operations, and may make execution of certain services particularly complex, or even delay their completion.

Geopolitical risk factors are on the rise and could increase the risks of industrial or IT dependence throughout the value chain.

Supplier panels

In certain fields, the Group currently depends on a limited number of industrial players that possess specific skills and the required experience. This creates a risk of exposure for the Group in the event of default by one or more of these suppliers or by service providers with specific skills.

Contractual relations and partnerships

Relations with partners working on projects with EDF may also be a source of difficulties. Global trade tensions could have an impact on the management of some of the Group’s activities and projects.

These risks may be exacerbated by conflicts between nations or blocs of nations.

c)   Control actions

Access to critical materials, products and services for the Group

Granular management is implemented for materials, products and services critical to the Group, their sources and possible alternatives. Control of the conditions under which raw or semi-worked materials are extracted, processed, packaged or made available for purposes of the Group may involve stricter rules concerning knowledge of regulatory requirements and the duty of vigilance.

Supplier panels

The Group has a Supplier policy to guarantee project performance, secure supplies and limit the risks related to supplier failures and quality crises.

The Group implements actions, particularly for the improvement of supplier selection and qualification processes by taking account of workers’ rights and human rights (see section 3.3.3 “ESRS S2 - Workers in the value chain”).

The Group has set up a “Supplier Policy platform” to coordinate the actions of the internal entities involved in supplier relations.

The control actions supporting continuation of the supplier panel include:

• tight control of procurement categories, with a capability-based approach to suppliers and close monitoring of strategic suppliers;
• support initiatives taken with suppliers, to assist them in improving their operational performance;
• the France Nucléaire 2 Fund (FFN2), set up to respond to financing and support needs of companies in the nuclear sector (small, medium and intermediate-sized businesses with significant nuclear know-how).

Contractual relations and partnerships

The Contract Management function carries out enhanced management of contracts with suppliers, applying vigilance actions at every stage to make sure that operations, deadlines and associated costs are well controlled.

In response to the laws and regulations adopted by certain countries, including the United States and China, and to ensure compliance with their legislation and decisions, the EDF group has introduced appropriate arrangements and taken precautionary measures, particularly for the organisation of its nuclear projects, especially in the United Kingdom.

Lastly, building strong partnership relations with our major suppliers is essential to guarantee secure supplies and create shared value. This approach promotes trust, innovation and good long-term performances. By taking a long-term view, we strengthen our competitiveness and resilience to market changes. This partnership approach is set out in the EDF group’s Supplier policy.

1F – Hydropower safety risks

CRITICALITY:  

Hydropower safety comprises all the measures taken in plant design and operation to protect people and property against the risks and hazards associated with the presence or operation of hydropower facilities.

The Group’s hydropower facilities present specific risks with potentially very serious consequences: dam failure, overflow during floods, operating manoeuvres.

Hydropower safety is the major, constant concern of the producer. It involves three main activities:

• measures to prevent the major risk of failure of a hydropower structure, through monitoring and maintenance of facilities under the supervision of the public authorities: in France, mainly the Regional Environment, Land Use and Housing Authorities (Directions régionales de l’environnement, de l’aménagement et du logement - DREAL);
• management of the structures during periods of exceptionally high water levels, to keep the facilities and surrounding communities safe;
• control of operational risks: varying water levels in reservoirs, and water flows downstream of the structures.

EDF watches over and regularly maintains its dams, notably through continuous monitoring. Real-time readings and analyses of multiple data at each site (settlement, pressure and leakage measurements, combined with visual inspection of the structures and verification of mechanical parts, etc.) give EDF regular assessments of the condition of the dams it operates. In Grenoble and Toulouse, EDF teams analyse the largest or least accessible dams remotely and in real time, thanks to a series of sensors.

For each of the “large dams”, pursuant to French regulations, a hazard assessment study comprising a complete examination is conducted every 10 or 15 years respectively for class A and class B dams. This study requires an exhaustive examination of the condition of the structures, involving draining, or inspection of the submerged parts using underwater equipment. These operations are carried out under the strict supervision of the public authorities (the Hydraulic Structures Control and Safety Department of each DREAL).

At the organisational level, the Inspector General for Hydropower Safety prepares an annual report for the Chairman and CEO of EDF, to whom he or she reports directly, as well as reporting to the actors involved in hydropower safety (see section  1.4.1.3.1.3 “Hydropower safety”). This report is drawn up after analyses, inspections and assessments by the Inspector for Hydropower Safety, and its purpose is to provide an opinion on the level of hydropower safety in the Group’s installations, identifying areas for reflection and progress to improve and consolidate safety. The report is made available on the Group’s website.

1G – Blackout risk

CRITICALITY:  

The French electricity system could be faced with a blackout – a widespread grid incident of significant scale – which could involve the Group even if the triggering event or events occurred on infrastructure not operated by EDF and/or were attributable to a third party.

Blackouts may be caused by a combination of rapidly-occurring phenomena:

• sudden, simultaneous failure of several generation assets or a sudden large-scale drop in consumption;
• cascading failures in the transmission network, neighbouring networks, or interconnections.

The initiating event is usually a major breakdown of equipment that is essential for power transmission (or more rarely, generation) occurring in specific, aggravating circumstances that trigger automatic protective devices, leading to rapid deactivation of a significant portion of the electricity system’s network and/or generation equipment.

The blackout of 28  April 2025 on the Iberian peninsula illustrates the increasing complexity of maintaining stability in the grid, with the reduction of inertia in the electricity system and the increase in intermittent energy output.

Poor voltage management at certain points in the grid can trigger cascading disconnection of generation units and cause a widespread incident. Detailed analyses of the Iberian event show that the risk of a large-scale network incident is increasing, potentially affecting all European countries. The overcapacity situation in France and Europe could be a factor that increases this risk.

Unforeseeable power cuts of this kind could:

• create major disruption in all or part of the country, lasting several hours or even several days depending on the scale of the incident;
• have a negative impact on the Group’s reputation with its customers and stakeholders;
• have an impact on the Group’s financial position.

Management and prevention of this risk is the core of French transmission grid operator RTE’s mission, as the entity responsible for controlling the French electricity system 24 hours a day, and balancing electricity supply and demand in France, particularly in real time. This responsibility covers the management of frequency and voltage control on the transmission network across the entire territory of mainland France, for which RTE enters into contracts with producers. The resources implemented by RTE are part of the framework defined by France’s public authorities. They comply with the policies common to European transmission system operators (TSOs), established within the European Network of Transmission System Operators for Electricity (ENTSO-E). RTE also establishes with producers and contractualises the conditions for restoring the grid in the event of a blackout.

EDF SA’s contribution to control of this risk lies in its commitment to:

• ensure that operation by its generation facilities is scheduled to match the needs of its customer portfolio as closely as possible (end consumers plus sales minus wholesale purchases), as required by its balance responsible entity contract;
• ensure that the performance of its power plants and automated mechanisms complies with regulatory standards and obligations (design capacity of equipment);
• respond to RTE’s calls for tenders for the provision of reserves and fulfil its relevant contractual obligations with RTE;
• respect the contractual obligations made to RTE in all contracts relating to system services and network balance, thereby contributing to the maintenance of frequency and voltage;
• enter into contracts with RTE to enable coordinated planning of generation unit shutdowns and work on the networks.

1H – Risk of insufficient supply to meet demand (EDF scope)

CRITICALITY:  

Lower power output by the nuclear fleet, combined with a lack of wind and/or high demand for electricity, may create a risk of insufficient supply in view of demand in the EDF scope.

This risk for the winter of 2025-2026 is much lower than for the three previous winters, due in particular to the very good forecast winter availability of EDF’s nuclear power plants, and persistently sluggish consumption since the 2022 crisis.

However, given the temperature sensitivity of consumption by some of EDF’s customers, a risk of imbalance during a period of very cold weather could arise, combined with a low-wind situation affecting wind power generation and the liquidity of short-term markets. This risk can only be predicted a few days ahead, based on weather forecasts.

In the event of a supply/demand imbalance:

• EDF may have to buy very large volumes of energy on the wholesale markets at very high prices;
• if there is insufficient liquidity on the markets, the financial risks are greater because they depend on the imbalance settlement payments due under the balance responsible entity’s contract, which can be much higher than market prices;
• consequences for the corporate image are possible, if the situation leads RTE to load shedding in the event that the imbalance is attributable to EDF.

The occurrence of an imbalance between supply and demand could result in high unforeseen costs for the Group, and have a significant impact on its financial performance. It could also cause serious reputational damage if such an event were to lead to service interruptions affecting customers, compromising stakeholder confidence and the Group’s position as a reliable energy supplier.

The main action to control this risk, given EDF’s vulnerability to the risk of a seasonal supply/demand imbalance, is to achieve good winter availability in EDF’s generation fleet and to manage resources (notably water resources) in a way that preserves them for winter use. This notably requires good control of the duration of nuclear reactor outages, particularly at the start of winter, and minimisation of unplanned outages.

In 2024, nuclear generation recovered to 361.7TWh. In 2025, it reached 373TWh, up by 3.1% (+11.3TWh) compared to 2024, confirming the continued improvement observed.

1I – Industrial safety risks and impact on environmental assets, including biodiversity

CRITICALITY:  

The Group operates or has operated facilities which, in the course of their operation or decommissioning, may be the cause of chronic or incidental events, or of industrial accidents that can give rise to environmental impacts (damage to biodiversity, risks of air, soil or water pollution) or health risks.

All of the Group’s facilities and projects are concerned by the issues of controlling potential pollution or damage to biodiversity. The main themes relate to water withdrawal, liquid discharges (pollution, temperatures), and gaseous discharges (dust, SOx, NOx) in view of climate change, protection of biodiversity, and control of waste production. This is particularly the case in France, where EDF is a user of significant land and natural resources. The challenge is especially important given that regulatory changes are introducing more stringent requirements for protecting biodiversity, controlling pollution, and more generally managing all the impacts on environmental assets.

The Group operates around 40  “Seveso classified” facilities (upper and lower tier) under the European Directive for the prevention and management of major industrial risks. They are essentially storage or warehousing facilities for fuel oil, gas or chemicals.

See also chapter 3 “Sustainability Statement and Vigilance Plan”.

• An industrial safety failure at any of the Group’s industrial facilities may have a negative impact on the operational activity, the financial or legal position with regard to the duty of vigilance, the Group’s environmental assets or its reputation. Such a failure could call into question the Group’s ability to respond to its CSR issues.
• Accidents at neighbouring industrial facilities that belong to other operators and are not under the Group’s control could have an impact on the Group’s facilities.
• The Group could be held liable if the measures taken for industrial safety, protection of the environment, and control of these risks do not prove to be fully effective.
• In the event of a major incident, the Group could find itself unable in the long term to maintain a level of civil liability and damage insurance cover at least equal to current levels.

The risks specific to nuclear and hydropower facilities are further discussed in sections  2.2.1 “Operational performance risks” and 2.2.2 “Specific nuclear operation risks”.

• Risk control studies are carried out at each industrial site:

• >they consider compliance with regulations, actions to control potential health or environmental impacts, and continuous improvement actions for prevention and protection concerning soil, water, air and the potential effects on human health. If necessary, they include measures to avoid, mitigate and offset impacts,

• >these risk control studies are reviewed and updated within the regulatory deadlines applicable to each category of facility or when significant changes are made to facilities or their operating methods. Facility safety monitoring and control measures are implemented internally, and by the decentralised State services during inspections;

• Risk studies and control actions take account of past experiences. For example, the additional post-Lubrizol orders relating to the storage of flammable liquids and toxic materials are implemented in the Group’s facilities that are subject to the regulations for installations classified for environmental protection (IPCEs);
• EDF’s industrial and natural risks network ensures that the new requirements are monitored, appropriated and applied at industrial sites;
• The Group mobilises significant resources for biodiversity (see section 3.2 “Environmental information”).

With its “Ambitions 2035” company project, which extends its raison d’être, the EDF group intends to contribute to building the electricity system of tomorrow. Achieving this goal requires a systemic approach involving climate, natural and just transition issues. The Group’s CSR architecture embodies this approach and helps to anchor the meta-mission of decarbonisation without overlooking our dependence on natural resources and the ability of stakeholders to make the transitions.

OUR CSR COMMITMENTS

Our raison d’être:

To build a net zero energy future with electricity and innovative solutions and services,
to help save the planet and drive wellbeing and economic development.

As part of our “Ambitions 2035” strategic plan, EDF has set out 3 main objectives and 12 CSR commitments.

The sustainability statement corresponds to sections 3.1 to 3.5.

Non-financial performance is a component of the Group’s integrated performance.

The Group has endeavoured to apply the normative requirements set by the ESRS⁽¹⁾, as applicable at the date of preparation of the sustainability statement. 2025 is the second year of application of the directive, on an identical scope. According to the Omnibus Directive, the application of the revised and simplified ESRS standards is foreseen for 2026, but this timetable remains subject to change.

In some cases, difficulties in accessing comprehensive data have forced the Group to use certain information on a case-by-case basis:

• partial scopes (see section 3.1.1.1 “Scope”) applied to some data. These partial scopes will be gradually extended to cover the entire Group scope;
• estimates (see sections 3.1.1.3.1 “Assessments concerning the value chain” and 3.1.1.3.2. “Sources of estimation and outcome uncertainty”) that may be refined as the quality of available data improves.

The sustainability information was prepared in accordance with the legal and regulatory requirements resulting from the transposition of the European Directive on the disclosure of information on corporate sustainability (Corporate Sustainability Reporting Directive or “CSRD”, EU No. 2022/2464 transposed in France by Order No. 2023-1142 of 6 December 2023 and Decree No. 2023-1394 of 30 December 2023). The information relating to the taxonomy was established in accordance with Regulation 2020/852 of 18 June 2020 (known as the “Taxonomy Regulation”) and Regulation (EU) 2021/2139 adopted on 4 June 2021. These regulations were supplemented in July 2021 by Regulation (EU) 2021/2178 on the content and presentation of information to be communicated, simplified in January 2026 by the publication of Commission Delegated Regulation (EU) 2026/73. In March 2022, complementary delegated acts (Regulations (EU) 2023/2485 and 2023/2486) were adopted to cover certain activities in the nuclear and gas sectors.

3.1.1.1   Scope

Principles

For environmental, social and societal indicators, the scope covered by the sustainability statement is based on the Group’s scope of financial consolidation (see section 6.1 “Consolidated financial statements at 31 December 2025”, note 3 “Scope of consolidation”). This scope includes EDF SA, as well as the controlled subsidiaries (full consolidation), in accordance with international accounting standards (IAS-IFRS). The Group concluded that its reporting scope within the meaning of the ESRS corresponds to its scope of financial consolidation plus, for the indicators prescribed by the ESRS, certain assets under operational control, notably at Dalkia. The entities acquired during the financial year are included, where applicable, in the financial scope of consolidation in the year of acquisition if their acquisition was completed at least six months before the accounting closing date.

The indicators of the sustainability statement relating to the value chain (Scope 3 greenhouse gases only) include equity-accounted investments and non-controlled interests up to the share held by the EDF group.

It should be noted that all the Group’s activities fall within the Energy sector. This sector is defined, according to Delegated Regulation (EU) 2023/2772 of 31 July 2023 and the NACE classification, as a sector with a high climate impact (electricity generation and distribution sector).

Applicable scope

The sustainability statement covers all the Group’s activities, its consolidated subsidiaries and its geographic locations. It includes information concerning the upstream and downstream value chain that was identified as material during the identification of impacts, risks and opportunities during the double materiality analysis.

There is no intentional omission of any information related to the Group’s intellectual property, know-how or results of innovations. Moreover, the Group does not make any use of the exemption from publishing information related to imminent developments or matters under negotiation, in accordance with Articles 19 bis (3) and 29 bis (3) of Directive 2013/34/EU.

The table below lists the indicators concerned by a partial collection scope for 2025. Half of these indicators are specific indicators that the Group is working to implement. All indicators are collected from a broad scope that includes at least the main contributors to each indicator. From 2024 to 2025, the collection of indicators was expanded. The indicators “Number and rate of recordable work-related accidents” and “Preservation and restoration of natural areas” are now consolidated at Group level. The scope of the indicators “Local purchasing rate”, “Supplier CSR audits/assessments”, “Solidarity performance” and “Percentage of employees in high-risk positions trained in corruption prevention” was expanded as explained in the table below. Lastly, the indicator “Number and surface area of sensitive sites in terms of biodiversity”, which was not collected in 2024, was collected in 2025. In accordance with the revised ESRS, the Group will organise itself to collect this data across the Group as part of the process initiated in 2024, which will continue to progress in the coming years.

As the totals in the tables, presented in the sustainability statement, are based on unrounded amounts, there may be differences between these amounts and the sum of the rounded amounts of the items which they comprise.

• (1) ESRS, European Sustainability Reporting Standards.

• * EDF specific indicator.
• ** Subsidiary EDF Production Électrique Insulaire (EDF PEI).

3.1.1.2   Time horizons

The time horizons used by the Group are those defined in the ESRS 1 standard. The short-term time horizon corresponds to the reference period of the financial statements, the medium-term horizon extends from the end of the short-term reference period up to five years, and the long-term horizon corresponds to the impacts, targets or expected actions over a period longer than five years. Moreover, targets are often set for 2035 in line with the Group’s strategic project.

For the specific case of climate risk analysis, the EDF group uses scenarios with a horizon of up to 2100 (see section 3.2.2.3 “Business model resilience to climate change: use of climate scenarios”).

3.1.1.3   Estimates and sources of uncertainty associated with the estimates and results

3.1.1.3.1   Assessments concerning the value chain

The assessment of the impacts and risks of the stakeholders of the EDF group’s value chain, for all subjects, and on the Group’s upstream and downstream activities, was carried out based on internal expertise. This analysis focused mainly on the Group’s tier-one suppliers and customers. This assessment will be completed in the coming years on the basis of the sustainability reports that will be produced by the players in the Group’s value chains.

Regarding the data from the value chain, for this second year, the assessments only concern the greenhouse gas (GHG) footprint (Scope 3). These estimates are inherent to the methodologies for estimating Scope 3 emissions, which are often based on standard emission factors, to the lack of consensus on certain accounting practices, and to regular regulatory changes. Furthermore, a certain degree of uncertainty may be attached to activity data, and emission factors, which convert activity data into CO₂ emissions, are themselves subject to variations depending on the sources and contexts of application. In this context, the Group has made its best efforts to comply with the best market practices and methodologies. For other data that may be relevant to collect in the future depending on materiality, this will be based mainly on data disclosed in the sustainability reports of the Group’s suppliers and customers.

3.1.1.3.2   Sources of estimation and outcome uncertainty

The sustainability-related information may be subject to inherent uncertainty due to incomplete scientific or economic knowledge and to the quality of the internal and external data used (e.g. data calculated for the value chain). In addition, certain information such as forward-looking data, missing data (in particular relating to the last days of the year), and the quantification of certain information in terms of sustainability, in particular environmental, are subject to estimates and judgements based on the Group’s experience and internationally recognised sustainability benchmarks as well as on the best available information to date. For example, for certain environmental data on certain specific industrial facilities, direct measurements are not possible and have required the development of calculation models based on a certain number of measured data.

These estimates are sensitive to methodological choices and to the assumptions used. The nature and scope of the estimates used or the limitations on the scope of collection made on a case-by-case basis on certain data are explained in each relevant section of this report, entitled “Details on the indicators”, with regards to the 2025 data communicated. This is the case, for example, for indicators relating to water withdrawal and consumption (see section 3.2.4.2.5 “Indicators related to water withdrawal and consumption”).

3.1.1.4   Changes in preparation or presentation of sustainability-related information

The sustainability statement, which introduces metrics aligned with European sustainability standards, did not change significantly in 2025, pending the revised standards in line with the Omnibus Directive.

In the event that changes in methodology or corrections of material errors have resulted in restatements of information from the previous year, the nature of the adjustments made and their impact on the amended information are specified in relation to the indicators concerned in the different sections of the sustainability statement (this is the case in sections 3.2.2 “ESRS E1 – Climate change”, and 3.2.6 “ESRS E5 - Resource use and circular economy”).

Two new targets were added to the sustainability statement: one on the withdrawal of freshwater for industrial use and another on anti-corruption training for exposed persons. The target on the restoration of natural sites was extended both in terms of period and scope.

3.1.1.5   Information from other legislative acts or information frameworks

For more information, see section 3.5.1.2. “Table of all data points arising from other EU legislation”.

For the sake of consistency and to avoid any duplication of information, this report is based on specific references to relevant sections of the Universal Registration Document (URD). This approach makes it possible to centralise information while facilitating its accessibility for stakeholders. The use of these references also meets the requirements of the CSRD in terms of transparency, connectivity and traceability of information.

The environment is at the heart of the EDF group’s commitments. An environmental management system (EMS) is in place to ensure that the Group’s various activities have the lowest possible environmental impact. The Group obtained its very first ISO 14001 certification in 2002.

The EMS, backed by EDF’s governance bodies, ensures the implementation of the environmental commitments in the Group’s CSR policy (see sections 3.1.2 “Governance” and 3.1.3.6 “Corporate Social Responsibility”, and chapter 4 “Corporate governance”).

In line with the CSR policy’s requirements, each Group entity has established its own environmental management approach, tailored to its specific challenges. While respecting the management independence of network operators, each entity defines its own organisational structure, roles, and responsibilities to fulfil its environmental commitments and effectively manage associated risks. To this end, adequate human and financial resources are allocated.

The EMS operates through Group, entity and function processes, to give stakeholders formal assurance that:

• environmental risks are under control and the EDF group complies with regulations and its commitments: each entity draws up and implements an environmental programme or action plan that takes account of the relevant Group commitments, its own significant environmental aspects and its regulatory obligations, and does so by considering its risks and opportunities;
• the efficiency of its organisations is improving in line with the challenges: each entity being responsible for them;
• its internal control, as well as internal and external audits of its EMS, interfaces with the Group’s EMS;
• mandatory sustainability reporting is performed concerning the environmental activities of the entities: each entity collects and communicates the required environmental information to the Impact Department.

The Impact Department is responsible for the overall coordination of the Group’s EMS as well as for managing interfaces between EDF and its subsidiaries. This includes the operational coordination of environmental management, which is carried out with the active involvement of all entities whose activities have a significant environmental impact at the Group level.

In accordance with the international standard ISO 14001 (2015 version), the Group’s EMS is certified by an external body, the AFNOR. All industrial sites are covered by an EMS, and more than 80% of them are certified.

The latest certification audit campaign, conducted by AFNOR over the period from the beginning of April 2024 to the end of May 2025, confirms that the certified EMS of entities and subsidiaries implemented are effective, relevant and mature, and make it possible to improve performance in all areas of the environment. The environmental commitments integrated into the CSR policy (see section 3.1 “General information”) are broken down into structuring, relevant and ambitious policies (water, carbon, circular economy, biodiversity). The environment is considered to be highly integrated, notably in the support functions and in the regions. The drive for improvement is strong and far-reaching. These audits identified three new cases of non-compliances, those from the previous campaign having been resolved. Progress is mainly expected in the monitoring of indicators in action plans or the use of internal audit reports.

• * Environment managing boards or equivalent.

Personal well-being and solidarity development are key issues of the Group’s raison d’être. This concerns both its employees and its stakeholders. The four main CSR commitments identified in this respect are the safety and health of all individuals, ethics and human rights, the promotion of equality, diversity and inclusion, and the fight for the prevention of energy poverty and for social innovation.

In 2021, the EDF group published a set of guidelines⁽¹⁾ listing the Group’s commitments and the fundamental requirements for its business relationships in terms of human rights and fundamental freedoms, environmental protection, protection of personal safety and health and business ethics. These EDF group human rights commitments were approved and signed by the Chairman and Chief Executive Officer.

The commitments apply to the activities of EDF SA and all the companies it controls, for all Group employees, with the exception of RTE and Enedis.

The notion of “business relationship” includes suppliers and subcontractors with whom an established commercial relationship is maintained, as well as project partners.

In compliance with contractual obligations, failure to meet these requirements, when repeated and not corrected after observations are made, may result in the termination of relations.

3.3.1.1   Human rights commitments

3.3.1.1.1   Compliance with international standards

The EDF group does not tolerate any infringement of human rights and fundamental freedoms, either in its activities or in those of its business relationships when their activities are related to this relationship⁽²⁾.

International Standards

In accordance with the United Nations Guiding Principles on business and human rights (UNGPs), the EDF group undertakes to respect, at the very least, international standards for the protection and defence of human rights and fundamental freedoms, and in particular the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, and the fundamental conventions of the International Labour Organization (ILO). Since January 2025, the Group has been a member of the TISFD (Taskforce on Inequality and Social-related Financial Disclosures) alliance, whose objective is to foster the emergence of economic practices that promote fairer societies. This alliance brings together around a hundred organisations from various sectors.

Conflicting standards

If the laws of a country where it operates conflict with these international standards, the EDF group endeavours to find a solution to render it compliant with both the spirit of the international standards and national laws.

Vigilance approach

To ensure that human rights and fundamental freedoms are respected in its operations, the EDF group has implemented a vigilance approach to identify, assess and prevent any potential infringement of human rights or fundamental freedoms. This vigilance approach has been designed to comply with the French Duty of Vigilance Law and is based on the recommendations of the UN Guiding Principles on business and human rights.

Vulnerable persons

The EDF group pays special attention to the impact of its operations on individuals recognised as vulnerable⁽³⁾ under international human rights law and investigates, in complete transparency, impartiality and good faith, any alleged infringements of human rights or fundamental freedoms connected to the operations of the Group’s entities, providers and subcontractors.

Proven cases of injury

If an infringement of human rights or fundamental freedoms is proven in the operations of the Group’s entities, the EDF group has agreed to engage in dialogue with the victims and/or their representatives to address the situation, pursuant to the OECD Principles for Multinational Enterprises with which the EDF group complies.

Practical sheets to better understand the Group’s human rights commitments

Eight thematic fact sheets break down and contextualise each human rights commitment published in the document “Human rights and fundamental freedoms, safety and health, environment, and business ethics: the EDF group’s commitments and requirements”. These sheets, available in five languages (French, English, Spanish, Italian and simplified Chinese), explain the Group’s commitments, international reference frameworks, definitions relating to these commitments, the main risk factors, the main risk control actions and the available tools, where applicable. They are available on the Group’s intranet and cover the following topics:

• fair and favourable working conditions;
• security forces;
• the fight against harassment and violence at work;
• non-discrimination;
• freedom of association;
• Indigenous populations;
• child labour;
• forced labour.

3.3.1.1.2   The rights of Group employees and workers in the value chain

The Group’s CSR policy also covers the Group’s commitments in terms of the rights of employees and workers in the value chain. These commitments are reflected notably through the items described below.

For further details on the CSR policy, see section 3.1.3.6 “Corporate social responsibility policy” and for governance, in section 3.1.2 “Governance”.

The EDF group is committed to respecting the internationally recognised human rights below, which represent the salient issues identified in risk mapping in view of its activities, and asks its business relationships to respect them.

The rights of employees

The EDF group is committed to respecting human rights and fundamental freedoms by complying, at a minimum, with the provisions of the International Labour Organization (ILO) standards (see section 3.3.1.1.1 “Compliance with international standards”).

• (1) www.edf.fr/sites/groupe/files/2023-02/edfgroup_rse_referentiel-ddv-2021_en.pdf
• (2) www.edf.fr/en/the-edf-group/taking-action-as-a-responsible-company/corporate-social-responsibility/well-being-and-solidarity/human-rights
• (3) Vulnerable individuals, groups and communities are those who face a particular risk of being exposed to discrimination and violations of their human rights. People who are disadvantaged, marginalised or excluded from society are often particularly vulnerable. International law grants them special protection, through specific treaties.

Combating discrimination

In terms of the prevention of discrimination, the EDF group guarantees equal treatment for its employees and is against any form of distinction, exclusion or preference, whether based on presumed race, skin colour, gender, age, religion, political beliefs, national origin, social origin, disability, family status, sexual orientation or gender identity. In the countries where it operates and for its own operations, the EDF group actively promotes equality in the workplace and equal treatment for equal work for the women and men working for the Group and strives to achieve balanced work teams at all levels of the Company. Diversity is encouraged at all staffing levels and employees must be protected from all forms of discrimination or retaliation.

Combating harassment, sexism and violence

The EDF group does not tolerate any form of harassment or violence, whether within or outside the workplace, relating to the working relationships established in the workplace. The Group is committed to preventing and protecting its employees and interns from all forms of harassment, sexism and violence in the workplace.

Refusal of all forced labour

The EDF group is against all types of forced labour, as defined in the ILO fundamental conventions as well as any form of human trafficking. In particular, for the projects and operations implemented by the Group, it ensures that all employees have given their free, informed consent for the performance of all their duties. In particular, the EDF group ensures that its intermediaries and recruitment agencies do not use any practices that could result in forced labour. The Group is committed to protecting the free movement of workers and, notably, will not confiscate the travel documents, identity papers or any other personal belongings of workers in any circumstances whatsoever.

No child labour

The EDF group is against all types of child labour, as defined in the ILO fundamental conventions. The Group commits to not employ anyone under the age of 15 (subject to the exceptions set out in ILO Convention 138) or anyone under the age of 18 for work considered dangerous as provided for in the ILO convention.

Freedom of association, right to collective bargaining and trade union rights

The EDF group upholds an individual’s right to freedom of association and the right to collective bargaining as defined by the ILO. The Group recognises that all employees are free to form and/or join the workers’ organisation of their choice and will not interfere with that right.

In accordance with the EDF group’s Global Agreement on Social and Environmental Responsibility, the EDF group undertakes to respect and protect the autonomy and independence of trade unions, in compliance with the laws and regulations in force. It aims to guarantee the effective exercise of trade union rights and recognises the representative trade union organisations in the Company as contact people and partners. The EDF group respects strict neutrality as to whether or not its employees choose to belong to a trade union, and if so, which trade union they wish to be represented by. Employees are not discriminated against because of their union membership and/or activities. Notably, the EDF group sets aside a number of hours dedicated to the performance of trade union functions and mandates, as well as a supervised career path for employees holding representative and/or trade union positions. The EDF group prohibits any harassment, intimidation, sanction or discrimination against an employee because of their trade union activities, and does not discourage employees from joining organisations of their choice. The Group respects the right to collective bargaining and the role of workers’ organisations in the collective bargaining process.

Work time

The EDF group complies with ILO standards as well as all applicable laws and regulations on working hours in all countries where it operates.

Compensation, working conditions, and employee benefits

The EDF group strives to comply with the ILO standards on pay, working conditions and employee benefits. The Group is committed to paying a decent wage, covering the basic needs of its employees and their families, and to providing adequate social security cover for all its employees. When employee accommodation is provided by the Company, the EDF group ensures that decent housing or accommodation is provided in compliance with the ILO standards.

In 2025, all Group employees received a decent wage, in accordance with the applicable benchmarks.

Respect of safety and health for all

To tackle the industrial and commercial challenges it faces, the Group must remain a socially responsible and committed employer and customer and a benchmark in terms of safety and health.

The EDF group makes safety and health for all its No. 1 priority, whether for our employees, interns, subcontractors or in terms of environmental health, of the development of air quality, of the reduction of noise, visual or light pollution, of commercial offerings related to comfort, and of well-being. The Group’s entities comply with the highest standards defined in the nuclear safety policy, the hydropower safety standards and the Group’s Prevention and Health & Safety Policy. Lastly, each new project is analysed from the point of view of the safety and health of the people involved, and with regard to its impact on the environment and the health of local residents⁽¹⁾.

The Group’s Prevention and Health & Safety Policy was updated in November 2025 and is based on a commitment jointly signed by the Chairman and Chief Executive Officer and all the members of the Executive Committee. This Group policy applies to all the companies controlled by the EDF group, in all the countries in which EDF operates, and to everyone. It concerns its employees, its interns and its subcontractors.

The policy’s priorities are, first and foremost, to eradicate fatal and serious accidents, reduce the overall number of accidents and combat absenteeism, and improve the physical and psychological health of employees at work. The policy aims to anchor throughout the Group the foundation formed by the Group’s life-saving rules and the BEST safety and health management reference framework.

EDF’s Executive Committee reviews safety and health figures and monitors action plans regularly. A Group Strategic Safety and Health Committee oversees the implementation of the policy.

EDF is committed to improving the physical and psychological health of its employees and subcontractors, placing the absolute priority on protecting them and eradicating fatal and serious accidents.

In line with the steps taken at the Group to eradicate serious and fatal accidents, our policy aims to develop a collective safety requirement supported by both Group and subcontractor employees. It reinforces the progress made in collaboration with our service providers by promoting joint actions in the field, such as joint visits and the signing of charters.

3.3.1.1.3   The rights of affected communities

The EDF group is committed to protecting the rights of the local communities affected by its operations and arranging, systematically and worldwide, transparent, debated discussions and consultations for each new project relating to a facility drawing on a budget of more than €60  million and having a significant impact on the territories or the environment.

• (1) See in notably the BEST requirements guide for the EDF group for Safety and Health Management, and its self-assessment tool.

The Group recognises the role of human rights and environmental defenders from all walks of life, both among its suppliers and in civil society. It is committed to protecting the exercise of their rights and ensures that it identifies the risks to human rights and environmental activists caused by its business operations and allows them to speak freely about its operations.

The EDF group identifies, for each project, the potential impact on the health, living conditions and environment of local communities, with reference to the performance standards of the International Finance Corporation (World Bank Group) and proposes suitable measures.

Indigenous populations

The EDF group is committed to respecting the specific characteristics and rights of indigenous peoples as defined in the UN Declaration on the Rights of Indigenous Peoples (UNDRIP) and ILO Convention 169, which provides, in particular, that “indigenous peoples shall not be forcibly removed from their lands or territories. No relocation shall take place without the free, prior and informed consent of the indigenous peoples concerned and after agreement on just and fair compensation”.

The EDF group is aware of the unique issues facing indigenous peoples and is committed to following the best international standards in this area and, more specifically, the UNDRIP (United Nations Declaration on the Rights of Indigenous Peoples), ILO Convention 169 and World Bank standards. In particular, the EDF group recognises the criteria for characterising indigenous peoples included in these standards, including historical and geographic “pre-existence”, “cultural distinctiveness”, “self-identification”, and “non-dominance”. The EDF group upholds the individual and collective rights of indigenous peoples and communities, including their right to self-determination, their right to land, territories and resources, and their right to FPIC (Free Prior and Informed Consent) in its projects and activities, as defined by ILO Convention 169.

Whenever its operations threaten or affect the livelihood of a community, the Group implements compensation and/or restoration measures for their livelihood matching or exceeding the level prior to its operations.

The EDF group is committed to respecting and protecting or safeguarding, in agreement with the populations concerned, any expressions of their culture, religion or heritage present on the land used for its operations.

In terms of the use of security forces, the Group is committed to protecting the safety of its employees and sites in strict compliance with human rights, including those of local communities, and only authorises the use of force for preventive or defensive purposes in a manner proportionate to the nature and severity of the threat.

3.3.1.1.4   The rights of consumers and end-users

EDF’s vigilance plan follows the United Nations Guiding Principles on business and human rights (UNGP), the Organization for Economic Cooperation and Development (OECD) Guidelines, the fundamental conventions of the International Labour Organization (ILO) and the UN Universal Declaration of Human Rights.

This vigilance plan and other specific human rights documents were taken into account to identify material impacts, risks and opportunities in relation to consumers and end-users. For more information on these IROs as well as actions to remedy the impacts on human rights (see section 3.3.5 “ESRS S4 - Consumers and end-users”).

Since 2022, a person specialising in business and human rights has been a member of the EDF group’s Stakeholder Council in order to better integrate this expertise within said body (see section 3.1.3.2 “Interests and points of view of stakeholders”).

3.3.1.2   The EDF group’s whistleblowing system

3.3.1.2.1   Scope

The Group’s ethics, compliance and duty of vigilance whistleblowing procedure applies to all EDF group entities.

In order to make report-handling more secure and to strengthen the confidentiality and security of personal data, in 2018, the Executive Committee decided to set up a single whistleblowing system for all wrongdoing reported under the Sapin II Law and the Duty of Vigilance Law, as well as wrongdoing reported by employees and external employees, and third-party direct witnesses, alleging harassment and discrimination. This Group system benefits all Group entities, except for the subsidiaries in the regulated sector, Enedis and RTE, which have their own whistleblowing system to uphold their managerial independence.

Whistleblowers may choose to use the Group whistleblowing system or the other channels available to them (manager, human resources, employee representatives, local ethics and compliance officers, mediators, etc.).

The referee body for the EDF group procedure for collecting and processing reports of wrongdoing, appointed by the Executive Committee, is the Group Ethics and Compliance Department (DECG)⁽¹⁾.

Information on the whistleblowing system is available at:

• the EDF website⁽²⁾, which is therefore accessible to everyone (external employees, suppliers and subcontractors and third parties (customers, residents, etc.). The website notably reminds users that the Group’s whistleblowing procedure guarantees protection against any retaliation or discriminatory measures for any whistleblower who meets the conditions set out in the legislation in force. These points are also included in the “Whistleblower Support Guide” and in the EDF Code of Conduct.
• the intranet, with a video on the Group whistleblowing system, the Whistleblowing Support Guide, and the link to the Group platform;
• sites where a sign is also displayed (“How to alert?”) which specifies which employees can report, the facts that may be reported, the respect for confidentiality and the protection of the whistleblower, as well as the procedures for triggering the whistleblowing system (two QR codes provide direct access to the support guide and the outsourced platform).

In addition, each entity’s Ethics and Compliance Manager (EDF Departments and subsidiaries) is in charge of communicating the whistleblowing procedure to employees (relaying information through their own community or during awareness-raising campaigns, notably during the “Ethics & Compliance All Actors” week). With regard to suppliers and subcontractors, the whistleblowing system is included in the CSR Charter between EDF and its suppliers, which is a component of the contract.

3.3.1.2.2   Accessibility of the system

The Group whistleblowing system, managed from an independent server that is not connected to EDF’s IS, can be accessed at any time via the EDF group website. The interface is available in several languages (French, English, Italian, Spanish, German, Portuguese, Dutch and Mandarin) in France and abroad, and the whistleblower can report wrongdoing in the language of their choosing.

• (1) Decree of 4 October 2022: the body is tasked with gathering the wrongdoing report and with processing it in compliance with the procedure. This referee is appointed by the Company.
• (2) www.edf.fr/en/the-edf-group/taking-action-as-a-responsible-company/ethics-and-compliance-programme/whistleblowing-system

Locally, it is possible to carry out an alert in writing to the Ethics and Compliance Manager or line manager, human resources and any other authorised functions in the entity’s local implementation note. For certain large international projects, a local whistleblowing system is set up.

3.3.1.2.3   Reporting wrongdoing

The EDF group whistleblowing procedure to report facts constituting:

• a violation or an attempt to conceal a violation of the law or a regulation falling under the EDF group’s scope of responsibility;
• a violation or an attempt to conceal a violation of an international commitment ratified by France, of a European Union law, or of the Code of Conduct, falling under the EDF group’s scope of responsibility;
• a threat or damage to the general interest falling under the EDF group’s scope of responsibility;
• a risk or serious infringement of human rights and fundamental freedoms, the safety and health of individuals or the environment, falling under the EDF group’s scope of responsibility and its business relations.

3.3.1.2.4   Analysis of the admissibility of reports

Once the report has been submitted, whistleblowers receive confirmation within seven days from the delivery of such report. Whistleblowers can submit reports anonymously in countries where this is authorised. These anonymous reports are admissible as long as the factual elements are sufficiently detailed and precise to demonstrate the reality of the facts reported.

Each whistleblowing report is examined for admissibility by the DECG whistleblowing committee in order to determine, before investigating the actions reported, whether it meets the criteria defined in section 3.3.1.2.3 “Reporting wrongdoing”, and whether the appropriate protective measures can be identified.

During the admissibility phase, the recipient of the alert can discuss with the whistleblower and rely on experts (Group Ethics and Compliance Department, Legal Department, Ethics and Compliance Officers, Duty of Vigilance Managers) to obtain the additional information necessary for the finalisation of the admissibility analysis.

3.3.1.2.5   Processing of admissible reports

Upon confirmation of the whistleblowing report’s admissibility, the investigating officer appointed signs a specific confidentiality undertaking and has a maximum of three months within which to communicate to the whistleblower the information on the measures envisaged or taken in order to remedy the wrongdoing reported, and on the reasons for those measures.

The investigation of reported facts (verification of the facts, interviews of the persons concerned, search for evidence, etc.) is carried out with the support of business experts, the ethics and compliance officers of the entities or subsidiaries, the support departments (the Ethics and Compliance Department (DECG) the Human Resources Department, the Security and Economic Intelligence Department (DSIE), the Legal Department, the Audit Department, etc.) or, when necessary, external consultants. These experts are bound by the same strict confidentiality obligations (with the prior signature of a confidentiality undertaking).

Upon completion of the investigation into the matter, if the facts reported are found to be true, an action plan is implemented. The whistleblowing report will be closed only upon complete fulfilment of that action plan.

3.3.1.2.6   Protection of whistle-blowers: mechanisms in place to identify, report and investigate non-compliance/unlawful behaviour

The EDF group’s whistleblowing procedure was revised in 2023 to take account of the Waserman Law of 21 March 2022, transposing into French law the European directive on the protection of whistleblowers, and its implementing decree of 4 October 2022. After being validated by the competent authorities, the revised whistleblowing procedure will come into force on 1 June 2023.

This whistleblowing procedure ensures protection against any retaliatory measures or discriminatory measures for any author of an alert. The Group Ethics and Compliance Department is responsible for steering and monitoring the implementation of this procedure, and also keeps archived data to ensure the protection of the whistleblower (see section 3.3.1.2 “The EDF group’s whistleblowing system”).

3.3.1.2.7   2025 results

Whistleblowing results are consolidated and included in the annual ethics and compliance report submitted to the Executive Committee and presented to the EDF Board of Directors’ Corporate Responsibility Committee. The DECG consolidated all admissible alerts made in 2025 at the EDF group, and Enedis (via the Group system or any other channel).

In 2025, 735 admissible alerts were recorded (including 160 in the Group whistleblowing system). More alerts were received from subsidiaries compared to 2024, demonstrating an increased awareness of the system throughout the Group. 468 alerts related to incidents located in France and 267 internationally. 180 related to EDF and 555 to the Group’s subsidiaries. Among them, 46% of the cases reported relate to harassment/discrimination. In 2025, 65% of the alerts processed were sufficiently detailed to give rise to corrective actions or disciplinary sanctions (20 dismissals pronounced for proven harassment). 20% of alerts for which the facts were not proven nevertheless gave rise to actions to improve processes.

For these 2025 results, the following should be noted:

• alerts admissible in the Group system: 58% in 2025;
• 2025 results of investigations following alerts: 42% of investigations were non-proven, 40% proven and 18% partially proven;
• safety and health alerts were included in the “Human rights” category;
• the whistleblower’s relationship with the Group (all channels combined): 81% employees, 9% third-parties, 9% external employees, 1% occasional employees.

Measures taken following alerts (all channels combined): 59% corrective, 15% disciplinary and corrective, 23% disciplinary, 3 legal cases, 2 legal and corrective cases, and 3 legal, corrective and disciplinary cases.

3.3.1.2.8   Focus on serious human rights incidents for the Company’s workforce

Incidents of discrimination and harassment

As explained in section 3.3.1.2.7 “2025 results”, alerts for acts of harassment/discrimination are monitored in a separate category by the alert system. Certain acts of harassment/discrimination, whether or not reported by the whistleblowing system, may result in fines, penalties and compensation for damages.

These incidents of harassment/discrimination had financial consequences for EDF. More specifically, the amount of compensation paid by EDF in 2025, pursuant to a final court ruling, for the aforementioned offences amounted to €235,500 for discrimination, including harassment. Convictions for discrimination and psychological harassment relate to age discrimination in the context of compulsory retirement imposed pursuant to Article 4 of the SNIEG on “long-term sick” employees who have become unfit for any work, and to a dispute over career progression linked to discrimination on the grounds of gender or disability. In addition, two convictions refer to trade union discrimination.

Fines, sanctions and/or compensation actually paid by a Group entity are taken into account. Provisions and convictions for which an appeal with suspensive effect is pending are therefore excluded.

Serious human rights incidents

It collects the number of serious human rights incidents and complaints affecting the Group’s workforce during the reporting period, as well as the total amount of fines, sanctions and compensation for damages resulting from these incidents/complaints.

According to the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, the following are included as violations of human rights in the context of labour law:

• discrimination in the workplace based on gender, race or ethnic origin, nationality, religion or belief, disability, age, sexual orientation, or other relevant forms of discrimination;
• harassment as a specific form of discrimination;
• forced or compulsory labour;
• human trafficking;
• child labour exploitation;
• failure to maintain a safe and healthy working environment;
• failure to respect the right of workers to form or join trade unions and representative organisations of their own choosing.

Only the violations listed above should be taken into account. This excludes violations related to local regulations that are more restrictive than international law. The 2012 UN Interpretative Guide to Guiding Principle 14 states that “the severity of the impacts will be based on their magnitude, extent and whether or not they are irremediable.” This means that both the severity of the impact (its magnitude) and the number of individuals who are or will be affected (its extent) are taken into account. The “irremediable” aspect is the third important factor, used here to signify any limit on the ability to restore those concerned to a situation at least identical, or similar, to their situation before the negative impact.

As regards the enforceable ILO conventions, as well as the Group’s requirements and commitments in relation to possible impacts, EDF has established a set of guidelines entitled “Human rights and fundamental freedoms, safety and health, environment, and business ethics”, which is available on the EDF website⁽¹⁾.

No serious human rights incidents were recorded in 2025. Fines, sanctions and/or compensation actually paid by a Group entity are taken into account. Provisions and convictions for which an appeal with suspensive effect is pending are therefore excluded. Referrals from OECD National Contact Points (NCPs) are also taken into account.

Several business conduct issues concern the EDF group:

• systems put in place to ensure ethical business practices;
• relations with suppliers: the quality of the relationship between EDF and its suppliers is at the heart of the success of the Group’s activities;
• crisis management and safety: if an exceptional incident happens, the crisis management measures can be costly, and may be above the costs of repairing the induced damages and the earnings losses due to the disruption in the Group’s supply of goods and services;
• lobbying: the assessment of the EDF group’s lobbying involves an annual review process that may trigger follow-up actions.

During the double materiality analysis carried out in 2023/2024, and after a review in 2025 that did not lead to any changes, the following IROs were identified as material:

• (1) Sub-theme defined by EDF.

Public policies, supplier relationships, and ethical issues can have consequences for the Group. Group strategies that are not aligned with public policies can create risks, whereas aligned policies can, conversely, create new opportunities. Whistleblowers, supplier relations, and compliance with the Code of Conduct are also important issues and can have financial and reputational consequences if poorly managed. A  cyberattack could also have major financial and operational consequences. On the other hand, a good-quality relationship with loyal suppliers can lead to operational gains, and the company can contribute to improving CSR issues within its ecosystem.

The identification of risks, opportunities and dependencies related to the conduct of business was carried out based on internal and external sources, such as the Group’s risk mapping and SASB sector reports. The Group also identified its business dependencies by conducting a dependency analysis of its value chains.

No significant current financial impact has been assessed for material risks and opportunities.

3.5.1.1   List of disclosure requirements met