Changes to the Rules for Participation in French Shareholders' General Meetings

Shareholders must plan their securities transactions further in advance in order to participate in the General Meeting or vote, as securities must be registered in their accounts at least 5 days before the date of the General Meeting (instead of two days currently).

The new rules (record date on D-5, enhanced dematerialization, e-convocations by default) have been effective since February 16, 2026, except for the obligation to be able to communicate electronically with registered shareholders (Article 3), which applies to General Meetings convened on or after July 1, 2026.

Required actions

• Shareholders must anticipate their securities transactions earlier in order to participate in the General Meeting or vote, as the registration of securities in an account must now be effective at least 5 days before the date of the General Meeting (instead of 2 today).

• Shareholders should prioritise online consultation.

• If chosen by the issuer, electronic notice becomes the default, without prior shareholder consent.

• Shareholders must keep their email address up to date with their SGSS contacts or those of the issuing company.

• Those wishing to receive documents in paper format must submit a request 90 days before the notice of meeting by registered postal mail with acknowledgement of receipt, sent to the issuer.

• For shareholders registered in nominative form, a return to paper notice will be permitted only for 2 years starting February 16, 2026.

What is new?

Decree No. 2026‑94 of February 13, 2026 on the modernization of communication methods with shareholders of certain commercial companies, recently published in the French Official Journal, introduces new rules for holding shareholders’ General Meetings.

1. Record Date: Change from D‑2 to D‑5

The date on which shareholders must be registered in order to participate in the General Meeting is now 5 business days before the meeting.

• Record date remains at the start of the day

• Votaccess votes: D‑1 at 15h CET (unchanged)

• Paper voting forms: D‑3 (unchanged)

The registration date (D‑5) is aligned with the date by which the authors of a resolution added to the agenda must prove their status as shareholders.

2. Digitalisation of documents

• The notice brochure will no longer be attached to paper mailings if it is available online on the issuer’s website.

• Regulatory documents available on the issuer’s website will no longer be sent by post.

3. Default electronic notice

When the issuer chooses this option, electronic notice then becomes the default method, without requiring the shareholder’s prior consent.

Shareholders wishing to continue receiving a paper notice must submit a request 90 days before the publication of the notice of meeting, by registered postal mail with acknowledgement of receipt, sent to the issuer.

Transitional period: For a period of two years, shareholders whose securities are held in registered form ("les actionnaires au nominatif") may request that notices and communications continue to be delivered by post.

4. Proxies and powers of attorney

The retention period by intermediaries is reduced from 3 years to 2 years (from the date of the General Meeting).

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Source: Décret n° 2026-94 du 13 février 2026 relatif à la modernisation des modalités de communication avec leurs actionnaires de certaines sociétés commerciales - Légifrance

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