LOM 2026: every IRVE obligation for French businesses
The Loi d'Orientation des Mobilités (Mobility Orientation Act) imposes on French businesses a strict and progressive timeline for installing EV charging stations. Fines of up to €75,000 per car park, DREAL inspections active since July 2026: here is what you need to know to bring your site into compliance.
What is the LOM law and who is affected?
The Loi d'Orientation des Mobilités (LOM), adopted in December 2019, is the founding text of French policy on EV charging infrastructure. It imposes progressive obligations on owners and operators of private car parks attached to commercial (tertiary) and residential buildings to install IRVE charging points.
Affected by the LOM are:
- Office car parks with more than 10 spaces, new or existing
- Shopping centres and their outdoor or covered car parks
- Hotels and tourist establishments with a private car park
- Co-ownership properties with a shared car park (the reinforced "right to plug in" obligation)
- Industrial companies whose car park is used by employees
- Local authorities for their public car parks
Main triggering criterion: any car park with more than 10 spaces associated with a commercial (tertiary) or residential building. The building's floor area has no longer been the primary criterion since the 2021 implementing decrees.
The 2024–2030 LOM obligations timeline
| Date | Obligation | Who is affected? |
|---|---|---|
| 01/01/2025 | Mandatory pre-equipment (ducts, conduits, switchboard) | Any existing commercial (tertiary) car park >10 spaces |
| 01/01/2026 | Extension to new collective residential car parks | Co-ownership properties, company-provided housing |
| 01/07/2026 | Active DREAL inspections + financial penalties | Fines of up to €75,000/non-compliant car park |
| 01/01/2027 | 20% of spaces equipped with active charging stations (car parks >200 spaces) | Operational charging stations, not just pre-wiring |
| 01/01/2030 | National target: 400,000 charging stations at professional sites | End of transitional period — maximum penalties |
Since 1 July 2026, DREAL inspections (Regional Directorate for the Environment) have been in effect. A notice of non-compliance can be issued on a simple report — including by a third party (employee, neighbour, competitor). The formal notice allows 6 months to achieve compliance before the fine.
The penalties in force since July 2026
The LOM penalty framework is structured in three progressive phases:
Phase 1: Administrative formal notice (2024–2025)
The DREALs issue a formal notice to comply with a 6-month deadline. No immediate financial penalty, but registration in the non-compliance register.
Phase 2: Active fines (since July 2026)
In the absence of remediation after the formal notice: an administrative fine of up to €75,000 per non-compliant car park. This fine is renewable annually as long as the non-compliance persists. Publication in ADEME's public register.
Phase 3: Blocking of permits (from 2027)
Non-compliant sites may be refused the renewal of certain planning and operating permits (ERP, ICPE). A major operational risk for office building managers.
LOM and the Décret Tertiaire: the dual obligation for buildings >1,000 m²
Businesses whose buildings exceed 1,000 m² of commercial (tertiary) floor area are subject simultaneously to two complementary obligations:
- The LOM requires car parks to be equipped with charging stations
- The Décret Tertiaire requires the building's energy consumption to be reduced by −40% by 2030
The apparent contradiction (installing charging stations increases consumption) is resolved by Spark Pilot, which makes it possible to isolate IRVE consumption from the Décret Tertiaire calculation thanks to MID-certified sub-meters. The platform directly generates exports compatible with the national OPERAT platform.
The APER law: photovoltaic carports and charging stations, an opportunity for synergy
The Loi d'Accélération des Énergies Renouvelables (APER, Renewable Energy Acceleration Act) requires the installation of solar panels on outdoor car parks with more than 80 spaces:
- Before the end of 2026: car parks with more than 400 spaces
- Before the end of 2028: car parks with 80 to 400 spaces
If your car park falls within this scope, it is strongly recommended to combine APER and LOM in a single project. Sharing trenches and electrical connections can reduce the total project cost by 25 to 35% compared to two separate projects. Sparklin coordinates the technical and administrative files in this type of integrated project.
How to finance LOM compliance?
Several schemes can cover up to 40% of the cost of an IRVE project:
- CEE (Energy Savings Certificates): redeemable with energy suppliers. Sparklin is listed on the CEE certificates applicable to IRVE.
- Reduced VAT of 5.5%: applicable to installation works in car parks of residential buildings and company-provided housing.
- Regional subsidies: many Regions and Metropolitan Areas have their own schemes. Sparklin handles monitoring and the preparation of applications.
- Accelerated tax deduction: Spark Plus charging stations are eligible for accelerated depreciation over 12 months in accounting terms.
How Sparklin supports you towards LOM compliance
For each client, Sparklin carries out a free LOM compliance study including:
- Audit of the existing electrical installation and calculation of the power available for charging
- Mapping of your obligations according to the area and type of car park
- Simulation of power distribution based on your real consumption profile
- Pre-application for funding (CEE + regional subsidies) with an estimate of the amounts available
- Phased deployment plan with a compliance timeline
A Sparklin expert analyses your situation within 48 hours and provides you with a compliance report including a costed action plan.
Free LOM compliance audit →