France: Release of the Multi-Year Energy Plan 3 – France finally sets a course for its energy policy through 2035, albeit with some shortcomings

Nevertheless, PPE 3 raises major questions—both in terms of substance and of how it was developed—about the credibility of the chosen target pathways, the robustness of its instruments, and the stability of the proposed legal framework.

I. PPE 3: Development, targets and instruments

PPE 3 is marked both by a lengthy and unstable legislative process (a) and by the setting of guidelines intended to steer France’s energy-policy decisions over the next decade (b).

a. The development of PPE 3

PPE 3 is the result of a lengthy and turbulent legislative process, shaped by successive consultations, postponed decisions and sometimes contradictory announcements. As one of the cornerstones of France’s energy and climate strategy (SFEC), it was adopted against a backdrop of ongoing government instability, more than a year later than the previous schedule, which ends in late 2024.

Preparation of PPE 3, which began at the end of 2023 with an initial public consultation, continued through several consultation phases in 2024 and 2025, against the backdrop of an expected alignment with European targets, notably those stemming from the “Fit for 55” package. The significant changes between the various drafts—particularly the downward revision of the targets for photovoltaics—heightened uncertainty among stakeholders, as did the contradictory announcements in summer 2025². Adopted by decree on February 12, 2026 and published in the Official Journal on February 13, PPE 3 was eagerly awaited by the renewable energy sector to re-establish a clearer and more stable planning framework in a regulatory environment that remains uncertain.

b. The main priorities

With PPE 3, the French government aims to set an energy-policy course for the next ten years by linking three core targets: energy sovereignty, CO₂ neutrality and competitive energy prices. PPE 3 therefore serves as the reference framework for government action in the energy sector through 2035, while also fitting into the course toward CO₂ neutrality set through 2050.

The first priority of PPE 3 is a sharp increase in electricity generation from CO₂-free sources, which is expected to reach between 650 and 693 TWh by 2035, compared with 544 TWh in 2025. This increase is intended to support the massive electrification of end uses, identified as a key lever for phasing out fossil fuels. Accordingly, PPE 3 provides for a very substantial reduction in fossil energy consumption, from around 900 TWh in 2023 to nearly 330 TWh in 2035.

To achieve these targets, PPE 3 relies on a diversified energy mix that combines a decisive revival of nuclear power with further expansion of renewable energy. In the nuclear sector, this marks a break with the previous PPE: to ensure controllable and sovereign energy generation over the long term, it provides for extending the operating life of the existing fleet, optimizing its output, and building new EPR2 reactors³.

In parallel, the targets for renewable electricity are being adjusted to reflect actual consumption, while still pursuing ambitious targets—particularly for photovoltaics and onshore and offshore wind power, with the latter intended to play a central role in France’s industrial strategy.

PPE 3 is not limited to the electricity sector: it also covers the development of non-electric low-carbon energies such as biomethane, decarbonized hydrogen, biofuels, and renewable heating and cooling, to provide solutions for uses that are difficult to electrify. This holistic approach is complemented by a particular focus on the flexibility and resilience of the power grid, as well as on controlling costs for public finances, notably through greater use of competitive support mechanisms.

Finally, PPE 3 stands out for its stated aim of giving industries greater visibility by maximizing the economic and industrial impacts of energy-policy decisions. The first-time introduction of a “review clause” in 2027 also plays a role, intended to allow the course to be adjusted to the actual evolution of the country’s energy demand.

II. Key substantive and procedural weaknesses of PPE 3

The weaknesses of PPE 3 lie both in the inherent limits of its targets and instruments (a) and in the conditions under which it was drafted, marked by delays and procedural objections (b).

a. Converging fundamental criticisms pointing to weak planning

While the publication of PPE 3 has ended a period of ongoing regulatory uncertainty, several substantive weaknesses quickly emerge in its content—highlighted by both institutional bodies and economic stakeholders. The criticism is aimed less at the stated targets than at the reality of the proposed pathways, the legal certainty of the instruments used to achieve them, and the ability of the chosen framework to ensure long-term stability.

In its opinion of January 31, 2025, the High Council for Climate Change therefore highlighted several points requiring particular attention, notably the pace of the phase-out of fossil fuels, the coherence of policy for decarbonized mobility, the resilience of the energy system to climate change, the social accessibility of the energy transition, the safeguarding of low-carbon investments, and the governance of France’s energy and climate strategy.

These issues are particularly tangible in the solar sector. The downward revision of installation volumes means they are widely seen as insufficient in light of existing industrial capacity and the climate targets being pursued. Against a backdrop of a weakening market and with many projects already underway or in development, this course reinforces the sense of a growing gap between planning and economic reality, with visible consequences for employment and the stability of the industrial fabric. More broadly, the sector points to insufficient medium- and long-term predictability, which is hardly compatible with investment cycles that span several years.

These sector-specific difficulties point to a broader criticism linked to the very nature of the PPE itself, which remains primarily an indicative planning instrument. The PPE creates neither a means obligation nor a results obligation for the state, which limits its operational reach. As Institut Montaigne notes⁴, this feature leads to persistent uncertainty about the effectiveness of the announced actions, its long-term financing, and the stability of support mechanisms.

This uncertainty is further compounded by ongoing administrative constraints, a lack of budget transparency and, more recently, tensions around certain contractual commitments by the state. Finally, the long-term predictability of PPE 3 itself appears limited, caught between announcements of reports that could lead to adjustments and the introduction of a “review clause” from 2027, giving the impression of an evolving plan that is highly dependent on future political and budgetary decisions.

A development process weakened by delays and now contested

Beyond the key decisions taken, PPE 3 has drawn consistent criticism regarding its development process, characterized by an especially long and bumpy timeline. The period between setting the modelling assumptions (2020–2021), defining the targets (2022), completing the public and citizen consultations, and publishing the decree in February 2026 has created a significant gap between the initial assumptions and current energy balances.

While these shifts can partly be explained by exogenous shocks—geopolitical crises, supply constraints, nuclear plant outages or cost increases—the structural conditions have changed fundamentally, undermining the robustness of the technical “finalization” of the plan. This criticism is aimed less at the principle of setting a course than at the drafting method chosen, and calls for better alignment between the political timeline, economic modelling and the operational credibility of future development pathways.

These procedural weaknesses are now playing out in court, as several actions for abuse of power have been filed with the Council of State against the decree of February 12, 2026. In addition to objections based on manifest errors of assessment, procedural defects or challenges to the financing mechanisms, some actions criticize the legal instrument chosen to adopt PPE 3.

In fact, Article L. 100-1 A of the Energy Code provides that the targets and priorities of national energy policy must be set by a law that had to be adopted before July 1, 2023, while the PPE, which under Article L. 141-1 is set by decree, is intended to specify the targets defined in that law. However, since no prior legislative text exists, adopting PPE 3 solely through regulatory power fuels current objections and contributes to undermining the procedural legitimacy of the energy planning framework, without prejudging the outcome of the ongoing proceedings.

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Sources and notes:

1 Decree No. 2026-76 of February 12, 2026 on multiannual energy planning, published in the Official Journal of the French Republic on February 13, 2026 (JORF No. 0037, Text No. 11), issued pursuant to Article L. 141-1 of the Energy Code.
2 In a press release dated August 1, 2025, the government announced the publication of an “energy roadmap” for the next ten years, presented as an interim PPE 3 and differing in substance and form from the draft decree submitted for consultation in spring 2025. This new direction, whose legal scope was not specified and which was intended pending the so-called “Gremillet” law, notably provided for a postponement of the targets for electricity generation from renewable energy (photovoltaics and wind power) in favor of strengthening nuclear targets, as consumption dynamics were assessed as weaker than expected.
3 EPR2 is a standardized evolution of the EPR nuclear reactor, intended to enable series production and better cost and schedule control, while ensuring CO2-free and dispatchable electricity generation.
4 Third Multiannual Energy Plan (PPE3): How to tackle planned obsolescence | Institut Montaigne