France Sapin II — Anti-Corruption Law (Loi n° 2016-1691)

French anti-corruption law requiring large companies to implement compliance and due diligence programmes.

12

Rules extracted

112

Obligations decomposed

9.3x

Avg obligations per rule

🇫🇷 France

Jurisdiction

About this regulation

Loi Sapin II is France's principal anti-corruption law, enacted on 9 December 2016. It establishes mandatory compliance programs for companies and public entities exceeding 500 employees and EUR 100 million in revenue. Article 17 sets out eight required pillars: code of conduct, internal whistleblowing, risk mapping, third-party due diligence, accounting controls, training, disciplinary measures, and monitoring/evaluation. The law creates the Agence Française Anticorruption (AFA) with powers to audit and sanction non-compliance. It also introduces the CJIP (convention judiciaire d'intérêt public), a deferred prosecution agreement mechanism for corruption, influence peddling and laundering the proceeds of tax fraud.

What AuditDSS covers

Source

1

Regulation

Extracted

12

Rules

Decomposed

112

Obligations

9.3x

Decomposition ratio

Each rule is decomposed into an average of 9.3 atomic obligations — the smallest testable units that can be independently violated.

Fully extracted & scored

All 112 obligations have been decomposed, titled, risk-scored, and embedded for semantic matching.

Risk scoring

Every obligation in Sapin II is scored across independent risk dimensions:

W

Obligation Weight

How critical within the regulatory framework

L

Violation Likelihood

How often breached in practice

E

Enforcement Evidence

Regulator enforcement history and penalties

C

Cascade Dependency

How many obligations depend on this one

Regulatory details

Full title
France Sapin II — Anti-Corruption Law (Loi n° 2016-1691)
Regulatory body
Agence Française Anticorruption
Jurisdiction
🇫🇷 France
Document type
statute
Effective date
June 1, 2017
Issuing authority
French Parliament
Official source
View source document ↗

Who this applies to

companies with 500+ employees and EUR 100M+ revenuepublic establishmentsstate-owned enterprisesFrench subsidiaries of foreign groups meeting thresholds

Key requirements

  • code of conduct (Pillar 1)
  • internal whistleblowing (Pillar 2)
  • risk mapping (Pillar 3)
  • third-party due diligence (Pillar 4)
  • accounting controls (Pillar 5)
  • training (Pillar 6)
  • disciplinary measures (Pillar 7)
  • monitoring and evaluation (Pillar 8)
  • AFA audit compliance
  • CJIP (deferred prosecution)

Frequently asked questions about Sapin II

What is Sapin II?

Loi Sapin II is France's principal anti-corruption law, enacted on 9 December 2016. It establishes mandatory compliance programs for companies and public entities exceeding 500 employees and EUR 100 million in revenue. Article 17 sets out eight required pillars: code of conduct, internal whistleblowing, risk mapping, third-party due diligence, accounting controls, training, disciplinary measures, and monitoring/evaluation. The law creates the Agence Française Anticorruption (AFA) with powers to audit and sanction non-compliance. It also introduces the CJIP (convention judiciaire d'intérêt public), a deferred prosecution agreement mechanism for corruption, influence peddling and laundering the proceeds of tax fraud.

Who does Sapin II apply to?

Sapin II applies to companies with 500+ employees and EUR 100M+ revenue, public establishments, state-owned enterprises, French subsidiaries of foreign groups meeting thresholds.

How many obligations does Sapin II contain?

AuditDSS has decomposed Sapin II into 112 atomic obligations from 12 rules. Each obligation is independently testable and risk-scored.

What are the key requirements of Sapin II?

The key requirements include: code of conduct (Pillar 1), internal whistleblowing (Pillar 2), risk mapping (Pillar 3), third-party due diligence (Pillar 4), accounting controls (Pillar 5), training (Pillar 6), disciplinary measures (Pillar 7), monitoring and evaluation (Pillar 8), AFA audit compliance, CJIP (deferred prosecution).

How can I assess my Sapin II compliance?

Upload your compliance policy to AuditDSS. The platform maps your document against all 112 Sapin II obligations using deterministic AI scoring — not checklists or LLM summaries. You get a risk-scored gap analysis showing exactly which obligations are covered, partially covered, or missing.

Which jurisdiction enforces Sapin II?

Sapin II is enforced in France by Agence Française Anticorruption.

When did Sapin II come into effect?

Sapin II became effective on June 1, 2017.

What industry does Sapin II apply to?

Sapin II is primarily relevant to the Medical Devices & Diagnostics industry. AuditDSS covers 64 regulations in this industry sector.

Build a Sapin II compliance pack

Don't have a compliance policy yet? AuditDSS generates a complete compliance pack for Sapin II — alone or combined with other regulations your business needs. Every clause is mapped to specific obligations.

Policy

High-level commitments and governance framework covering Sapin II requirements.

Procedures

Step-by-step operational procedures to implement each policy commitment.

Forms & checklists

Ready-to-use forms, registers, and checklists for day-to-day compliance operations.

Multi-regulation

Combine Sapin II with other regulations into a single unified compliance pack for your business.

Already have a policy? Assess it against Sapin II

1

Upload your document

Upload your compliance policy, program manual, or operational document. AuditDSS accepts any text-based document.

2

AI maps against 112 obligations

Your document is scored against every obligation in Sapin II. Each claim is mapped to the obligation tree and evaluated for coverage.

3

Risk-scored gap report

Receive every gap ranked by risk priority with remediation guidance, enforcement evidence, and cascade impact analysis.

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Assess your Sapin II compliance

Upload your document and get a risk-scored gap analysis against 112 Sapin II obligations in under 5 minutes.