Find all the latest
HR news here

Strengthening employer obligations during heat waves

Decree No. 2025-482 of 27 May 2025 and the Order of 27 May 2025 have strengthened and clarified employer obligations in the event of heat waves, with effect from 1 July 2025.

The legal framework governing heat waves prior to 1 July 2025

Employers were already required to protect workers from risks associated with high temperatures, in particular due to their general obligation to protect employees’ health and safety under Articles L. 4121-1 et seq. of the French Labour Code, and certain pre-existing provisions in the same Code.

However, the increasing frequency and intensity of heat waves linked to climate change have led to the introduction of a specific and reinforced regulatory framework in the Labour Code on this topic.

Creation of a dedicated section on climate-related risk prevention in the Labour Code

The Decree of 27 May 2025 amends Article R. 4223-13 of the French Labour Code, which until now only required employers to heat workplaces during cold periods.

The article now provides that “indoor workplaces must be maintained, in all seasons, at a temperature appropriate to the activity of the workers and to the environment in which they operate. Where a temperature control device is used, it must not emit any hazardous fumes.

For outdoor worksites, Article R. 4225-1 specifies that they must be organised in such a way that workers “are protected from the effects of weather conditions.”

Furthermore, Article R. 4225-2 of the French Labour Code provides that: “The employer shall provide workers with drinking and fresh water to enable them to hydrate and cool down.”

To define periods of “intense heat”, the Labour Code now refers to the Météo-France heatwave alert system, with the yellow alert level being considered as the first level of intense heat within the meaning of the Code (see new Article R. 4463-1 of the French Labour Code and the Order of 27 May 2025).

Changes in the assessment of occupational risks

Employers must now assess the risks associated with workers’ exposure to intense heat, whether indoors or outdoors (Articles R. 4463-1 et seq. of the Labour Code).

If the assessment identifies a risk to workers’ health or safety, the employer must define prevention measures or actions. The employer must also establish reporting procedures for any signs of physiological distress, discomfort or emergency situations, as well as procedures for providing assistance, particularly for remote or isolated workers.

Factors such as employees’ health condition and age must be taken into account to assess vulnerability to intense heat and adapt preventive measures, in coordination with occupational health services.

During periods of intense heat, employers must in particular provide a sufficient quantity of drinking fresh water. They must also ensure that water intended for consumption is kept cool throughout the working day, near workstations, especially on outdoor worksites.

Note: When running water cannot be provided (e.g. worksites not connected to the water supply), the quantity of water provided must be at least three litres per day per worker.

As a result, employers must update the DUERP – single occupational risk assessment document (and the PAPRIPACT – annual programme for the prevention of occupational risks and improvement of working conditions in companies with more than 50 employees).

Specific provisions for the construction sector

The Order of 27 May 2025 establishes that orange and red alert periods (heatwave alerts) constitute, under Article D. 5424-7-1 of the French Labour Code, weather conditions giving entitlement to compensation for work stoppages due to weather conditions in construction and public works companies.

Note: Two Orders of 23 May 2025 also provide that for 2024 and 2025, the reimbursement amount paid to employers for heatwave periods is equal to 50% of the amount provided for other weather-related stoppages under the scheme, although CIBTP France may decide to increase this rate.

Direction RH at your side

These new obligations require employers to exercise increased vigilance when organising work during periods of intense heat. They involve updating prevention tools (DUERP, PAPRIPACT), adapting workstations and implementing practical measures to ensure worker health and safety.

Direction RH supports companies in this process by providing expertise in risk assessment, regulatory compliance and the implementation of tailored prevention and awareness measures.

en_GB