Commission Decision (EU) 2025/1771 of 8 September 2025 on fees due to the European Union Agency for the Cooperation of Energy Regulators for its tasks under Regulation (EU) No 1227/2011 of the European Parliament and of the Council and repealing Commission Decision (EU) 2020/2152

January 13, 2026
Official Journalof the European Union ENL series
2025/1771 11.9.2025
(1) Open and fair competition in the internal electricity and gas markets and ensuring a level playing field for market participants requires integrity and transparency of wholesale energy markets. Regulation (EU) No 1227/2011 of the European Parliament and of the Council(2)establishes a comprehensive framework to achieve this objective.
(2) Regulation (EU) No 1227/2011 tasked the European Union Agency for the Cooperation of Energy Regulators (the ‘Agency’) with monitoring wholesale energy markets in order to ensure, in close cooperation with the national regulatory authorities and other national authorities, their effective oversight. Article 32 of Regulation (EU) 2019/942 introduced fees to improve the Agency’s funding and cover costs related to its functions under Regulation (EU) No 1227/2011.
(3) Article 32 of Regulation (EU) 2019/942 sets out the scope and the basic principles of the fee scheme and tasked the Commission with setting the fees and the way in which they are to be paid, which has been done by the Commission with the adoption of Decision (EU) 2020/2152(3). Increased funding available to the Agency has enabled the Agency to improve the quality of the services provided by the Agency to entities reporting data and to market participants in general.
(4) Commission Delegated Regulation (EU) 2019/715(4)establishes the framework financial regulation for the bodies which are set up by the Union under the Treaty on the Functioning of the European Union and the Treaty establishing the European Atomic Energy Community and which have legal personality and receive contributions charged to the Union budget. The Agency is such a body and, as required by Delegated Regulation (EU) 2019/715, adopted its own financial rules, the Financial Regulation of the Agency(5), which are in line with those pursuant to Delegated Regulation (EU) 2019/715.
(5) The Agency’s programming document, established in accordance with Article 20 of Regulation (EU) 2019/942 and Article 32 of the Financial Regulation of the Agency, contains annual and multi-annual programming and in this context sets out in detail the Agency’s tasks and the resources deployed for those tasks. The programming document is therefore the appropriate tool to identify those costs which are eligible to be covered by fees pursuant to Article 32 of Regulation (EU) 2019/942.
(6) In accordance with Article 20 of Regulation (EU) 2019/942, the Commission provides an opinion on the Agency’s draft programming document, including the Agency’s proposals as regards which costs are considered as eligible for funding by fees.
(7) According to recital 37 of Regulation (EU) 2019/942, the Agency should be mainly financed from the general budget of the Union. Therefore, the fee income should not exceed the contribution to the Agency from the Union budget.
(8) In order to provide transparency that fees are only used to cover eligible costs and that the Agency remains to be mainly financed by the general budget of the Union, the Consolidated Annual Activity Report, established in accordance with Article 48 of the Financial Regulation of the Agency, should provide information about the different sources of revenue received and the use of this revenue.
(9) In light of the evolving energy markets and the energy crisis, Regulation (EU) No 1227/2011 was amended in May 2024 by Regulations (EU) 2024/1106(6)and (EU) 2024/1789(7)of the European Parliament and of the Council, which introduced a number of changes to the reporting framework of data related to wholesale energy products. For example, now also details of transactions related to the storage of electricity, hydrogen or natural gas as well as transactions related to balancing markets need to be reported to the Agency. Also changes in the market, for example more high-frequency trading, as well as inflation result in increased costs incurred by the Agency. Furthermore, Regulation (EU) 2024/1106 provided the Agency with the new task of exercising the supervision and investigatory powers pursuant to Articles 13 to 13c and Article 16 of Regulation (EU) No 1227/2011.
(10) In addition, Regulation (EU) No 1227/2011, as amended, provides that market participants should report the data set out in Articles 7c and 8 of that Regulation only through Registered Reporting Mechanisms (‘RRMs’) and disclose information and submit inside information reports only through Inside Information Platforms (‘IIPs’). RRMs and IIPs are to be authorised by the Agency according to certain requirements set out in Regulation (EU) No 1227/2011, as amended, and as further detailed by the Commission by means of a delegated regulation according to Articles 4a(8) and 9a(6) of the same Regulation. The Agency shall monitor the compliance of RRMs and IIPs with the requirements according to which they have been authorised and, where it finds them non-compliant, it shall withdraw their authorisations.
(11) Regulation (EU) 2019/942 has also been amended in order to reflect the changes introduced in Regulation (EU) No 1227/2011. In particular, pursuant to the amended Article 32 of Regulation (EU) 2019/942, fees due to the Agency should cover the Agency’s tasks for collecting, handling, processing and analysing of information reported by market participants, or by persons or entities reporting on their behalf, pursuant to Article 8 of Regulation (EU) No 1227/2011 and for disclosing inside information pursuant to Articles 4 and 4a of that Regulation. Revenues from those fees may also cover the costs of the Agency for exercising the supervision and investigatory powers pursuant to Articles 13 to 13c and Article 16 of Regulation (EU) No 1227/2011. The amount to be covered by fees set by the Agency can be lower than the total eligible costs.
(12) In addition, in accordance with Article 32 of Regulation (EU) 2019/942, the fees should be proportionate to the costs of the relevant services as provided in a cost-effective way and be sufficient to cover those costs and they should be set at such a level as to ensure they are non-discriminatory and avoid placing an undue financial or administrative burden on market participants or entities acting on their behalf.
(13) Therefore, Decision (EU) 2020/2152 should be repealed in order to take into account the modifications introduced by Regulation (EU) 2024/1106 and Regulation (EU) 2024/1789.
(14) Decision (EU) 2020/2152 placed the obligation to pay the fees on RRMs, through which, at the time, the majority of market participants reported data records. RRMs are currently registered by the Agency on the basis of Article 11 of Commission Implementing Regulation (EU) No 1348/2014(8). The Agency also registers IIPs, through which market participants disclose inside information. The definition of RRMs and relevant references thereof should reflect that, while in the future RRMs will need to be authorised by the Agency pursuant to Article 9a of Regulation (EU) No 1227/2011, the fee-paying requirement continues to apply to the RRMs already registered with the Agency even if they are not authorised yet. IIPs have so far not been covered by Decision (EU) 2020/2152. However, given that, according to the legislative amendments mentioned above, fees should be due to the Agency by IIPs, this Decision also applies to IIPs and more specifically once they are authorised pursuant to Article 4a of Regulation (EU) No 1227/2011.
(15) This Decision also includes an updated definition of transaction record, with a reference to Regulation (EU) No 1227/2011 to ensure that such definition is not affected by any possible changes to Implementing Regulation (EU) No 1348/2014. The definition is fundamental for the identification of data clusters and hence for the calculation of fees and should hence be sufficiently detailed. For the identification of data clusters, a market participant is considered to be a beneficiary of the transaction or, if such information is not available, a counterparty of the transaction.
(16) Article 8(1) of Regulation (EU) No 1227/2011, as amended, introduces an obligation on market participants to report to the Agency providing information about their exposures. That new reporting requirement should be covered by and reflected in this Decision.
(17) The main cost drivers of the relevant services, and hence of the Agency’s eligible costs, are the number of RRMs and IIPs, the number of market participants they report for and the amount and the characteristics of the data they report. In order to reflect those cost drivers, the fee each RRM needs to pay should be a combination of a flat amount, the flat enrolment fee component, and a variable amount, the transaction records-based fee component. The latter depends on the number of market participants for which the RRM is reporting data as well as the amount and the characteristics of the reported data.
(18) The changes introduced by Regulation (EU) 2024/1106 and Regulation (EU) 2024/1789 result in a considerable increase in the Agency’s costs which will need to be covered by fees. Therefore, both the flat enrolment fee component and the revenues generated from the transaction records-based fee component should be increased in this Decision. At the same time fees should not place an undue financial burden on RRMs and thereby indirectly on market participants. Therefore, the increase in revenues generated from the transaction records-based fee component should be achieved in a proportionate way which avoids a large increase of revenue stemming from smaller market participants reporting a low number of transactions records but also avoids that revenues stemming from market participants reporting a high volume of transaction records increase excessively.
(19) The flat amount should reflect the Agency’s costs for processing applications for authorisation or registration of RRMs as well as for ensuring continued compliance of already authorised or registered RRMs with the requirements set out in Regulation (EU) No 1227/2011. In the future, such requirements shall be further detailed out by the Commission by means of a delegated regulation according to Articles 4a(8) and 9a(6) of the same Regulation. Since those costs are incurred by the Agency regardless of whether RRMs report transaction records or fundamental data, the flat amount should be paid by all RRMs.
(20) Pursuant to Article 4a of Regulation (EU) No 1227/2011 and once the relevant delegated act supplementing that Article is adopted, the Agency is to be in charge of authorising and supervising IIPs, equivalent to the supervision of RRMs. Therefore, IIPs should pay a fix fee equivalent to the flat enrolment fee component RRMs have to pay.
(21) Fundamental data like information related to the capacity and use of facilities for production, storage, consumption or transmission of electricity and natural gas or related to the capacity and use of LNG facilities, is only collected by the Agency to complement the collected transaction records. Fundamental data should therefore not be included in the calculation of the variable fee component. Since the status of a RRM as such is a significant cost driver for the Agency, RRMs reporting fundamental data should nevertheless pay the flat fee component.
(22) In order to avoid setting an undue financial burden on RRMs, the variable amount of the transaction record-based fee component should reflect the amount of reported transaction records, which is linked to the volume of trading and hence the potential revenues of a RRM. The variable component should take account of the fact that many RRMs report data for a multitude of market participants that are often active on several organised market places and are using different trading channels.
(23) In order to effectively uncover market abuses, the Agency does not only collect data on trades and other contracts, but also a considerable amount of data on orders to trade placed on organised market places like energy exchanges. Therefore, also orders to trade should be covered by the fee scheme in order to ensure cost proportionality. For the same reasons, lifecycle information should be covered by the fee scheme as well.
(24) Trading of wholesale energy products at organised market places is characterised by a higher level of standardisation than the trading of such products outside organised market places. Moreover, reported transaction records stemming from organised market places include orders to trade. Market developments in the trading of standard contracts like algorithmic and high frequency trading are gaining in importance resulting in an increasing number of orders to trade being reported from organised market places per standard supply contract compared to supply contracts concluded outside organised market places. Transaction records on wholesale energy products stemming from organised market places should therefore be weighted differently than those stemming from outside organised market places when calculating the variable fee component.
(25) Pursuant to Article 8(1) of Regulation (EU) No 1227/2011 and once the relevant implementing act supplementing that Article is adopted, RRMs will report market participants’ exposure to the Agency for each individual market participant. Therefore, a dedicated fee component should be introduced setting a fix amount for each such report, irrespective of its content or length
(26) Pursuant to Article 71 of the Financial Regulation of the Agency, an agency is only to provide services after the corresponding fee has been paid in its entirety. Since the fees are calculated on the basis of the amount of transaction records reported and inside information reports submitted in the previous year, the amounts receivable can only be established, and invoices be sent out, at the beginning of each year. RRMs and IIPs should nevertheless be able to continuously report data and submit inside information reports to the Agency, hence also prior to them having paid the invoice for the respective year. RRMs which cease to be authorised or registered by the Agency, should not be entitled to any reimbursement of fees paid or waiving of fees due. Equally, IIPs which cease to be authorised by the Agency, should not be entitled to any reimbursement of fees paid or waiving of fees due.
(27) In case a positive or negative correction amount to balance differences between the transaction records- based fee component paid in the previous year and the transaction records-based fee component that would have been paid according to the actual reporting in that year applies, the calculation of the correction amount should be based on the transaction record-based fee component a RRM actually paid in the previous year, and not on the initially calculated amount, since the actually paid amount differs from the initially calculated amount in case a reduction factor applies.
(28) As the Agency incurs additional costs to be covered by fees already in 2025, it should be able to levy a surcharge amounting to the difference between the revenues from fees as budgeted in the Agency’s Programming Document for 2025-2027 and the sum of the amounts already invoiced in 2025. The surcharge should be calculated in a straightforward way in order for RRMs to easily identify how the different market participants, on whose behalf they are reporting data, impact the invoiced surcharge. Therefore, the surcharge should depend on the number of market participants a RRM is reporting transaction records for. In case a market participant reports data via more than one RRM, this market participant would nevertheless be taken into account for each RRM when calculating the surcharge. Since the surcharge may have an impact on the charges paid by a market participants to a RRM, market participants which ceased to be market participants earlier in 2025 should not be taken into account when calculating the surcharge.
(29) To ensure that the Agency receives sufficient revenues from fees to cover its eligible costs, the Agency should have the option to add a surcharge to the invoices sent out in January 2026. That surcharge should be based on the number of market participants a RRM reports transaction records for. Since the possible surcharge in 2026 is calculated at the same time as the other fee components, the calculation can be based on the number of market participants identified for a RRM when calculating the transaction records-based fee component. For purposes of legal certainty and to provide assurance to RRMs that this option is not used to unduly increase the Agency’s eligible costs, the total revenues the Agency can receive including this surcharge should be capped to the estimated revenues from fees as presented in the Agency’s Programming Document for 2025-2027 or to the revenues from fees as budgeted in the Agency’s Programming Document for 2026-2028, whichever of the two values is lower.
(30) The calculation of the transaction record-based fee component is considerably different from 2026 onwards compared to the calculation of that component in previous years. In 2026 this could lead to exaggerated values for the correction amount when calculated in order to balance differences between the transaction records-based fee component paid in 2025 and the transaction records-based fee component that would have been paid according to the actual reporting in 2025. In 2026, the Agency should therefore calculate the correction amount by subtracting the transaction records-based fee component paid in 2025 not from the transaction record-based fee component calculated, but from a predetermined value calculated according to the fees’ subcomponents per data cluster applicable prior to the adoption of this Decision.
(31) Exposure reports are reported ex-post, hence in the year in which the exposure reporting obligation becomes applicable (‘the reference year’) the Agency will receive less exposure reports than in the following years. Therefore, the number of exposure reports reported by a RRM in the reference year needs to be adapted to be a proper basis for calculating the exposure report-based fee component in the year following the reference year. No exposure report-based fee component will be calculated in the reference year.
(32) In order to avoid that this Decision would need to be amended purely because fee revenues are insufficient to cover eligible costs due to inflation, fees should be automatically adjusted to inflation should fee revenues fall below eligible costs. Further, to allow RRMs and IIPs to prepare for the changes to the different fee components, the adjustment should only have effect in the subsequent year and should be announced by the Agency sufficiently in advance.
(33) The Agency should send invoices to RRMs and IIPs. Since the fees are entirely determined by this Decision, which is the basis for the Agency establishing the amounts receivable, in accordance with Article 71 of the Financial Regulation of the Agency, the invoices should be debit notes.
(34) The invoices sent to RRMs should include information about how the fee was calculated to make it transparent to the RRM how the different market participants it is reporting data for contribute to the invoiced fee. To avoid an undue financial burden for RRMs, it should be possible that large invoices are paid in instalments in agreement with the Agency. At the same time, the Agency needs to have regular and plannable revenues from fees in order to be able to cover its costs and to plan its spending accordingly. The increase in fee revenues could mean that a considerable share of those revenues would only be available to the Agency later in the year if the deadline of 30 September was to be maintained for all invoices. Therefore, the deadline of 30 September should only apply to the highest invoices, whereas lower invoices should be paid no later than 30 June.
(35) Deciding to which extent electricity or gas transmission system operators who are RRMs can recover costs incurred by having to pay the fees due to the Agency from network users via network tariffs is part of the duties and powers of Member States’ regulatory authorities pursuant to Article 59(1) of Directive (EU) 2019/944 of the European Parliament and of the Council(9)and Article 78(1) of Directive (EU) 2024/1788 of the European Parliament and of the Council(10).
(36) Article 32 of Regulation (EU) 2019/942 requires the Commission to regularly examine the level of the fees. This should be done together with the evaluations of the Agency’s performance pursuant to Article 45 of Regulation (EU) 2019/942. Such a requirement does not prevent the Commission from revising the fee scheme independently of those evaluations.
(37) In accordance with Article 32 of Regulation (EU) 2019/942, a public consultation took place and the Agency’s Administrative Board and Board of Regulators were consulted,
(1) ‘registered reporting mechanism’ means an entity authorised by the Agency in accordance with Article 9a of Regulation (EU) No 1227/2011 or registered by the Agency in accordance with Article 11 of Implementing Regulation (EU) No 1348/2014 for the purpose of reporting transaction records or fundamental data;
(2) ‘transaction record’ means an individual data set containing details of a trade, order to trade, irrespective of whether it is matched or unmatched, or bilateral trade related to wholesale energy products, including any lifecycle event of those trades, orders to trades or bilateral trades, which is reported to the Agency, excluding data relating to system-generated orders;
(3) ‘exposure report’ means an individual submission by a RRM on behalf of a market participant to the Agency in accordance with Article 8 of Regulation (EU) No 1227/2011 containing information on the basis of which the Agency calculates that market participant’s exposures;
(4) ‘market participant’ means an entity registered with the national regulatory authority in the Member State in accordance with Article 9 of Regulation (EU) No 1227/2011.
(a) collecting, handling, processing and analysing of information reported by RRMs;
(b) collecting, handling, processing and analysing of information reported by IIPs;
(c) exercising the supervision and investigation powers pursuant to Articles 13 to 13c and Article 16 of Regulation (EU) No 1227/2011.
(a) not exceed the eligible costs pursuant to paragraph 1;
(b) be lower than the Union contribution to the Agency according to the Union budget for the respective year.
(a) a flat enrolment fee component of EUR 15 000;
(b) where applicable, an exposure report-based fee component calculated pursuant to paragraph 2;
(c) where applicable, a positive or negative correction amount to balance differences between the exposure report-based fee component paid in the previous year and the exposure report-based fee component that would have been paid according to the actual reporting in that year;
(d) a transaction records-based fee component calculated pursuant to Article 7, unless a RRM is solely reporting fundamental data;
(e) where applicable, a positive or negative correction amount to balance differences between the transaction records- based fee component paid in the previous year and the transaction records-based fee component that would have been paid according to the actual reporting in that year.
(a) The Agency identifies the data clusters of the respective RRM. One data cluster shall consist of one of the following:(i)all transaction records reporting wholesale energy products pursuant to Articles 7c and 8 of Regulation (EU) No 1227/2011 reported to the Agency on a continuous or periodic basis stemming from a specific market participant using a specific organised market place;(ii)all transaction records reporting wholesale energy products pursuant to Articles 7c and 8 of Regulation (EU) No 1227/2011 reported to the Agency on a continuous or periodic basis stemming from a specific market participant without using an organised market place; (i) all transaction records reporting wholesale energy products pursuant to Articles 7c and 8 of Regulation (EU) No 1227/2011 reported to the Agency on a continuous or periodic basis stemming from a specific market participant using a specific organised market place; (ii) all transaction records reporting wholesale energy products pursuant to Articles 7c and 8 of Regulation (EU) No 1227/2011 reported to the Agency on a continuous or periodic basis stemming from a specific market participant without using an organised market place;
(i) all transaction records reporting wholesale energy products pursuant to Articles 7c and 8 of Regulation (EU) No 1227/2011 reported to the Agency on a continuous or periodic basis stemming from a specific market participant using a specific organised market place;
(ii) all transaction records reporting wholesale energy products pursuant to Articles 7c and 8 of Regulation (EU) No 1227/2011 reported to the Agency on a continuous or periodic basis stemming from a specific market participant without using an organised market place;
(i) all transaction records reporting wholesale energy products pursuant to Articles 7c and 8 of Regulation (EU) No 1227/2011 reported to the Agency on a continuous or periodic basis stemming from a specific market participant using a specific organised market place;
(ii) all transaction records reporting wholesale energy products pursuant to Articles 7c and 8 of Regulation (EU) No 1227/2011 reported to the Agency on a continuous or periodic basis stemming from a specific market participant without using an organised market place;
(b) for each of the data clusters referred to in point (a) the Agency identifies the fee subcomponent pursuant to paragraph 2 or paragraph 3;
(c) the transaction records-based fee component is the sum of the subcomponents identified pursuant to point (b).
Transaction records per data cluster Fee subcomponent in EUR
1 to 100 250
101 to 1 000 500
1 001 to 10 000 1 000
10 001 to 100 000 2 000
100 001 to up to 1 million 4 000
More than 1 million to up to 10 million 8 000
More than 10 million to up to 100 million 16 000
More than 100 million to up to 1 billion 32 000
More than 1 billion to up to 2 billion 64 000
More than 2 billion 96 000
Transaction records per data cluster Fee subcomponent in EUR
1 to 10 250
11 to 100 500
101 to 1 000 1 000
1 001 to 10 000 2 000
10 001 to 100 000 4 000
100 001 to up to 1 million 8 000
More than 1 million to up to 10 million 16 000
More than 10 million 32 000
(a) identifying for each RRM the number of market participants registered in accordance with Article 9 of Regulation (EU) No 1227/2011 on 30 June 2025 for which the RRM reported transaction records in the period from 1 January to 30 June 2025;
(b) summing up the numbers of market participants identified by all RRMs pursuant to point (a);
(c) dividing the number identified pursuant to point (a) by the sum pursuant to point (b) and multiplying the result with EUR 7,6 million.
(a) transaction records reporting wholesale energy products pursuant to point (a) of Article 3(1) of Implementing Regulation (EU) No 1348/2014 stemming from a specific market participant using a specific organised market place;
(b) and all transaction records reporting wholesale energy products pursuant to point (b) of Article 3(1) of Implementing Regulation (EU) No 1348/2014 stemming from a specific market participant
Transaction records per data cluster Fee subcomponent in EUR
1 to 1 000 250
1 001 to 10 000 500
10 001 to 100 000 1 000
100 001 to 1 million 2 000
More than 1 million to up to 10 million 4 000
More than 10 million to up to 100 million 8 000
More than 100 million 16 000
Transaction records per data cluster Fee subcomponent in EUR
1 to 100 250
101 to 1 000 500
1 001 to 10 000 1 000
10 001 to 100 000 2 000
100 001 to 1 million 4 000
More than 1 million to up to 10 million 8 000
More than 10 million 16 000
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EU) 2019/942 of the European Parliament and of the Council of 5 June 2019 establishing a European Union Agency for the Cooperation of Energy Regulators (1), and in particular Article 32 thereof,
Whereas:
(1) Open and fair competition in the internal electricity and gas markets and ensuring a level playing field for market participants requires integrity and transparency of wholesale energy markets. Regulation (EU) No 1227/2011 of the European Parliament and of the Council (2) establishes a comprehensive framework to achieve this objective.
(2) Regulation (EU) No 1227/2011 tasked the European Union Agency for the Cooperation of Energy Regulators (the ‘Agency’) with monitoring wholesale energy markets in order to ensure, in close cooperation with the national regulatory authorities and other national authorities, their effective oversight. Article 32 of Regulation (EU) 2019/942 introduced fees to improve the Agency’s funding and cover costs related to its functions under Regulation (EU) No 1227/2011.
(3) Article 32 of Regulation (EU) 2019/942 sets out the scope and the basic principles of the fee scheme and tasked the Commission with setting the fees and the way in which they are to be paid, which has been done by the Commission with the adoption of Decision (EU) 2020/2152 (3). Increased funding available to the Agency has enabled the Agency to improve the quality of the services provided by the Agency to entities reporting data and to market participants in general.
(4) Commission Delegated Regulation (EU) 2019/715 (4) establishes the framework financial regulation for the bodies which are set up by the Union under the Treaty on the Functioning of the European Union and the Treaty establishing the European Atomic Energy Community and which have legal personality and receive contributions charged to the Union budget. The Agency is such a body and, as required by Delegated Regulation (EU) 2019/715, adopted its own financial rules, the Financial Regulation of the Agency (5), which are in line with those pursuant to Delegated Regulation (EU) 2019/715.
(5) The Agency’s programming document, established in accordance with Article 20 of Regulation (EU) 2019/942 and Article 32 of the Financial Regulation of the Agency, contains annual and multi-annual programming and in this context sets out in detail the Agency’s tasks and the resources deployed for those tasks. The programming document is therefore the appropriate tool to identify those costs which are eligible to be covered by fees pursuant to Article 32 of Regulation (EU) 2019/942.
(6) In accordance with Article 20 of Regulation (EU) 2019/942, the Commission provides an opinion on the Agency’s draft programming document, including the Agency’s proposals as regards which costs are considered as eligible for funding by fees.
(7) According to recital 37 of Regulation (EU) 2019/942, the Agency should be mainly financed from the general budget of the Union. Therefore, the fee income should not exceed the contribution to the Agency from the Union budget.
(8) In order to provide transparency that fees are only used to cover eligible costs and that the Agency remains to be mainly financed by the general budget of the Union, the Consolidated Annual Activity Report, established in accordance with Article 48 of the Financial Regulation of the Agency, should provide information about the different sources of revenue received and the use of this revenue.
(9) In light of the evolving energy markets and the energy crisis, Regulation (EU) No 1227/2011 was amended in May 2024 by Regulations (EU) 2024/1106 (6) and (EU) 2024/1789 (7) of the European Parliament and of the Council, which introduced a number of changes to the reporting framework of data related to wholesale energy products. For example, now also details of transactions related to the storage of electricity, hydrogen or natural gas as well as transactions related to balancing markets need to be reported to the Agency. Also changes in the market, for example more high-frequency trading, as well as inflation result in increased costs incurred by the Agency. Furthermore, Regulation (EU) 2024/1106 provided the Agency with the new task of exercising the supervision and investigatory powers pursuant to Articles 13 to 13c and Article 16 of Regulation (EU) No 1227/2011.
(10) In addition, Regulation (EU) No 1227/2011, as amended, provides that market participants should report the data set out in Articles 7c and 8 of that Regulation only through Registered Reporting Mechanisms (‘RRMs’) and disclose information and submit inside information reports only through Inside Information Platforms (‘IIPs’). RRMs and IIPs are to be authorised by the Agency according to certain requirements set out in Regulation (EU) No 1227/2011, as amended, and as further detailed by the Commission by means of a delegated regulation according to Articles 4a(8) and 9a(6) of the same Regulation. The Agency shall monitor the compliance of RRMs and IIPs with the requirements according to which they have been authorised and, where it finds them non-compliant, it shall withdraw their authorisations.
(11) Regulation (EU) 2019/942 has also been amended in order to reflect the changes introduced in Regulation (EU) No 1227/2011. In particular, pursuant to the amended Article 32 of Regulation (EU) 2019/942, fees due to the Agency should cover the Agency’s tasks for collecting, handling, processing and analysing of information reported by market participants, or by persons or entities reporting on their behalf, pursuant to Article 8 of Regulation (EU) No 1227/2011 and for disclosing inside information pursuant to Articles 4 and 4a of that Regulation. Revenues from those fees may also cover the costs of the Agency for exercising the supervision and investigatory powers pursuant to Articles 13 to 13c and Article 16 of Regulation (EU) No 1227/2011. The amount to be covered by fees set by the Agency can be lower than the total eligible costs.
(12) In addition, in accordance with Article 32 of Regulation (EU) 2019/942, the fees should be proportionate to the costs of the relevant services as provided in a cost-effective way and be sufficient to cover those costs and they should be set at such a level as to ensure they are non-discriminatory and avoid placing an undue financial or administrative burden on market participants or entities acting on their behalf.
(13) Therefore, Decision (EU) 2020/2152 should be repealed in order to take into account the modifications introduced by Regulation (EU) 2024/1106 and Regulation (EU) 2024/1789.
(14) Decision (EU) 2020/2152 placed the obligation to pay the fees on RRMs, through which, at the time, the majority of market participants reported data records. RRMs are currently registered by the Agency on the basis of Article 11 of Commission Implementing Regulation (EU) No 1348/2014 (8). The Agency also registers IIPs, through which market participants disclose inside information. The definition of RRMs and relevant references thereof should reflect that, while in the future RRMs will need to be authorised by the Agency pursuant to Article 9a of Regulation (EU) No 1227/2011, the fee-paying requirement continues to apply to the RRMs already registered with the Agency even if they are not authorised yet. IIPs have so far not been covered by Decision (EU) 2020/2152. However, given that, according to the legislative amendments mentioned above, fees should be due to the Agency by IIPs, this Decision also applies to IIPs and more specifically once they are authorised pursuant to Article 4a of Regulation (EU) No 1227/2011.
(15) This Decision also includes an updated definition of transaction record, with a reference to Regulation (EU) No 1227/2011 to ensure that such definition is not affected by any possible changes to Implementing Regulation (EU) No 1348/2014. The definition is fundamental for the identification of data clusters and hence for the calculation of fees and should hence be sufficiently detailed. For the identification of data clusters, a market participant is considered to be a beneficiary of the transaction or, if such information is not available, a counterparty of the transaction.
(16) Article 8(1) of Regulation (EU) No 1227/2011, as amended, introduces an obligation on market participants to report to the Agency providing information about their exposures. That new reporting requirement should be covered by and reflected in this Decision.
(17) The main cost drivers of the relevant services, and hence of the Agency’s eligible costs, are the number of RRMs and IIPs, the number of market participants they report for and the amount and the characteristics of the data they report. In order to reflect those cost drivers, the fee each RRM needs to pay should be a combination of a flat amount, the flat enrolment fee component, and a variable amount, the transaction records-based fee component. The latter depends on the number of market participants for which the RRM is reporting data as well as the amount and the characteristics of the reported data.
(18) The changes introduced by Regulation (EU) 2024/1106 and Regulation (EU) 2024/1789 result in a considerable increase in the Agency’s costs which will need to be covered by fees. Therefore, both the flat enrolment fee component and the revenues generated from the transaction records-based fee component should be increased in this Decision. At the same time fees should not place an undue financial burden on RRMs and thereby indirectly on market participants. Therefore, the increase in revenues generated from the transaction records-based fee component should be achieved in a proportionate way which avoids a large increase of revenue stemming from smaller market participants reporting a low number of transactions records but also avoids that revenues stemming from market participants reporting a high volume of transaction records increase excessively.
(19) The flat amount should reflect the Agency’s costs for processing applications for authorisation or registration of RRMs as well as for ensuring continued compliance of already authorised or registered RRMs with the requirements set out in Regulation (EU) No 1227/2011. In the future, such requirements shall be further detailed out by the Commission by means of a delegated regulation according to Articles 4a(8) and 9a(6) of the same Regulation. Since those costs are incurred by the Agency regardless of whether RRMs report transaction records or fundamental data, the flat amount should be paid by all RRMs.
(20) Pursuant to Article 4a of Regulation (EU) No 1227/2011 and once the relevant delegated act supplementing that Article is adopted, the Agency is to be in charge of authorising and supervising IIPs, equivalent to the supervision of RRMs. Therefore, IIPs should pay a fix fee equivalent to the flat enrolment fee component RRMs have to pay.
(21) Fundamental data like information related to the capacity and use of facilities for production, storage, consumption or transmission of electricity and natural gas or related to the capacity and use of LNG facilities, is only collected by the Agency to complement the collected transaction records. Fundamental data should therefore not be included in the calculation of the variable fee component. Since the status of a RRM as such is a significant cost driver for the Agency, RRMs reporting fundamental data should nevertheless pay the flat fee component.
(22) In order to avoid setting an undue financial burden on RRMs, the variable amount of the transaction record-based fee component should reflect the amount of reported transaction records, which is linked to the volume of trading and hence the potential revenues of a RRM. The variable component should take account of the fact that many RRMs report data for a multitude of market participants that are often active on several organised market places and are using different trading channels.
(23) In order to effectively uncover market abuses, the Agency does not only collect data on trades and other contracts, but also a considerable amount of data on orders to trade placed on organised market places like energy exchanges. Therefore, also orders to trade should be covered by the fee scheme in order to ensure cost proportionality. For the same reasons, lifecycle information should be covered by the fee scheme as well.
(24) Trading of wholesale energy products at organised market places is characterised by a higher level of standardisation than the trading of such products outside organised market places. Moreover, reported transaction records stemming from organised market places include orders to trade. Market developments in the trading of standard contracts like algorithmic and high frequency trading are gaining in importance resulting in an increasing number of orders to trade being reported from organised market places per standard supply contract compared to supply contracts concluded outside organised market places. Transaction records on wholesale energy products stemming from organised market places should therefore be weighted differently than those stemming from outside organised market places when calculating the variable fee component.
(25) Pursuant to Article 8(1) of Regulation (EU) No 1227/2011 and once the relevant implementing act supplementing that Article is adopted, RRMs will report market participants’ exposure to the Agency for each individual market participant. Therefore, a dedicated fee component should be introduced setting a fix amount for each such report, irrespective of its content or length
(26) Pursuant to Article 71 of the Financial Regulation of the Agency, an agency is only to provide services after the corresponding fee has been paid in its entirety. Since the fees are calculated on the basis of the amount of transaction records reported and inside information reports submitted in the previous year, the amounts receivable can only be established, and invoices be sent out, at the beginning of each year. RRMs and IIPs should nevertheless be able to continuously report data and submit inside information reports to the Agency, hence also prior to them having paid the invoice for the respective year. RRMs which cease to be authorised or registered by the Agency, should not be entitled to any reimbursement of fees paid or waiving of fees due. Equally, IIPs which cease to be authorised by the Agency, should not be entitled to any reimbursement of fees paid or waiving of fees due.
(27) In case a positive or negative correction amount to balance differences between the transaction records- based fee component paid in the previous year and the transaction records-based fee component that would have been paid according to the actual reporting in that year applies, the calculation of the correction amount should be based on the transaction record-based fee component a RRM actually paid in the previous year, and not on the initially calculated amount, since the actually paid amount differs from the initially calculated amount in case a reduction factor applies.
(28) As the Agency incurs additional costs to be covered by fees already in 2025, it should be able to levy a surcharge amounting to the difference between the revenues from fees as budgeted in the Agency’s Programming Document for 2025-2027 and the sum of the amounts already invoiced in 2025. The surcharge should be calculated in a straightforward way in order for RRMs to easily identify how the different market participants, on whose behalf they are reporting data, impact the invoiced surcharge. Therefore, the surcharge should depend on the number of market participants a RRM is reporting transaction records for. In case a market participant reports data via more than one RRM, this market participant would nevertheless be taken into account for each RRM when calculating the surcharge. Since the surcharge may have an impact on the charges paid by a market participants to a RRM, market participants which ceased to be market participants earlier in 2025 should not be taken into account when calculating the surcharge.
(29) To ensure that the Agency receives sufficient revenues from fees to cover its eligible costs, the Agency should have the option to add a surcharge to the invoices sent out in January 2026. That surcharge should be based on the number of market participants a RRM reports transaction records for. Since the possible surcharge in 2026 is calculated at the same time as the other fee components, the calculation can be based on the number of market participants identified for a RRM when calculating the transaction records-based fee component. For purposes of legal certainty and to provide assurance to RRMs that this option is not used to unduly increase the Agency’s eligible costs, the total revenues the Agency can receive including this surcharge should be capped to the estimated revenues from fees as presented in the Agency’s Programming Document for 2025-2027 or to the revenues from fees as budgeted in the Agency’s Programming Document for 2026-2028, whichever of the two values is lower.
(30) The calculation of the transaction record-based fee component is considerably different from 2026 onwards compared to the calculation of that component in previous years. In 2026 this could lead to exaggerated values for the correction amount when calculated in order to balance differences between the transaction records-based fee component paid in 2025 and the transaction records-based fee component that would have been paid according to the actual reporting in 2025. In 2026, the Agency should therefore calculate the correction amount by subtracting the transaction records-based fee component paid in 2025 not from the transaction record-based fee component calculated, but from a predetermined value calculated according to the fees’ subcomponents per data cluster applicable prior to the adoption of this Decision.
(31) Exposure reports are reported ex-post, hence in the year in which the exposure reporting obligation becomes applicable (‘the reference year’) the Agency will receive less exposure reports than in the following years. Therefore, the number of exposure reports reported by a RRM in the reference year needs to be adapted to be a proper basis for calculating the exposure report-based fee component in the year following the reference year. No exposure report-based fee component will be calculated in the reference year.
(32) In order to avoid that this Decision would need to be amended purely because fee revenues are insufficient to cover eligible costs due to inflation, fees should be automatically adjusted to inflation should fee revenues fall below eligible costs. Further, to allow RRMs and IIPs to prepare for the changes to the different fee components, the adjustment should only have effect in the subsequent year and should be announced by the Agency sufficiently in advance.
(33) The Agency should send invoices to RRMs and IIPs. Since the fees are entirely determined by this Decision, which is the basis for the Agency establishing the amounts receivable, in accordance with Article 71 of the Financial Regulation of the Agency, the invoices should be debit notes.
(34) The invoices sent to RRMs should include information about how the fee was calculated to make it transparent to the RRM how the different market participants it is reporting data for contribute to the invoiced fee. To avoid an undue financial burden for RRMs, it should be possible that large invoices are paid in instalments in agreement with the Agency. At the same time, the Agency needs to have regular and plannable revenues from fees in order to be able to cover its costs and to plan its spending accordingly. The increase in fee revenues could mean that a considerable share of those revenues would only be available to the Agency later in the year if the deadline of 30 September was to be maintained for all invoices. Therefore, the deadline of 30 September should only apply to the highest invoices, whereas lower invoices should be paid no later than 30 June.
(35) Deciding to which extent electricity or gas transmission system operators who are RRMs can recover costs incurred by having to pay the fees due to the Agency from network users via network tariffs is part of the duties and powers of Member States’ regulatory authorities pursuant to Article 59(1) of Directive (EU) 2019/944 of the European Parliament and of the Council (9) and Article 78(1) of Directive (EU) 2024/1788 of the European Parliament and of the Council (10).
(36) Article 32 of Regulation (EU) 2019/942 requires the Commission to regularly examine the level of the fees. This should be done together with the evaluations of the Agency’s performance pursuant to Article 45 of Regulation (EU) 2019/942. Such a requirement does not prevent the Commission from revising the fee scheme independently of those evaluations.
(37) In accordance with Article 32 of Regulation (EU) 2019/942, a public consultation took place and the Agency’s Administrative Board and Board of Regulators were consulted,
HAS ADOPTED THIS DECISION:

Subject matter

This Decision sets the fees and the way in which they are to be paid to the European Union Agency for the Cooperation of Energy Regulators, hereinafter the ‘Agency’, pursuant to Article 32 of Regulation (EU) 2019/942.

Definitions

For the purposes of this Decision, the definitions of ‘inside information platform’ as laid down in Article 2(17) and ‘organised market place’ as laid down in Article 2(20) of Regulation (EU) No 1227/2011 and the definition of ‘fundamental data’ as laid down in Article 2(1) of Implementing Regulation (EU) No 1348/2014 shall apply.
In addition, the following definitions shall apply:

(1) ‘registered reporting mechanism’ means an entity authorised by the Agency in accordance with Article 9a of Regulation (EU) No 1227/2011 or registered by the Agency in accordance with Article 11 of Implementing Regulation (EU) No 1348/2014 for the purpose of reporting transaction records or fundamental data;
(2) ‘transaction record’ means an individual data set containing details of a trade, order to trade, irrespective of whether it is matched or unmatched, or bilateral trade related to wholesale energy products, including any lifecycle event of those trades, orders to trades or bilateral trades, which is reported to the Agency, excluding data relating to system-generated orders;
(3) ‘exposure report’ means an individual submission by a RRM on behalf of a market participant to the Agency in accordance with Article 8 of Regulation (EU) No 1227/2011 containing information on the basis of which the Agency calculates that market participant’s exposures;
(4) ‘market participant’ means an entity registered with the national regulatory authority in the Member State in accordance with Article 9 of Regulation (EU) No 1227/2011.

Costs covered by the fees

(1) The programming document, including the budget, adopted by the Administrative Board of the Agency by 31 December of each year pursuant to Article 20 of Regulation (EU) 2019/942, hereinafter the ‘programming document’, shall identify those costs which are eligible for funding by fees in the following year and provide an estimate of the eligible costs planned to be funded by fees for additional two years thereafter. Eligible costs are costs, including overhead, incurred by the Agency by:
(a) collecting, handling, processing and analysing of information reported by RRMs;
(b) collecting, handling, processing and analysing of information reported by IIPs;
(c) exercising the supervision and investigation powers pursuant to Articles 13 to 13c and Article 16 of Regulation (EU) No 1227/2011.

(2) The programming document shall set the amount to be covered by fees in the following year. That amount shall:
(a) not exceed the eligible costs pursuant to paragraph 1;
(b) be lower than the Union contribution to the Agency according to the Union budget for the respective year.
(3) The Agency shall provide detailed information on the amount of fees collected and the costs covered by the fees in the previous year in the Consolidated Annual Activity Report pursuant to Article 48 of the Financial Regulation of the Agency. The Agency shall make the respective sections of this report public.

Obligation to pay fees: RRMs

(1) Each RRM shall pay a yearly fee calculated pursuant to Article 6. All fees shall be paid in EUR.
(2) At the latest by 31 January of each year, the Agency shall send each RRM an invoice for the annual fee to be paid within a deadline of four weeks. The invoice shall provide detailed information on how this fee was calculated. The Agency and a RRM may mutually agree that invoices exceeding EUR 250 000 are paid in instalments. The deadline for payment of the last instalment in case of invoices exceeding EUR 250 000 and up to EUR 1 000 000 shall not be later than 30 June and the deadline for payment of the last instalment in case of invoices exceeding EUR 1 000 000 shall not be later than 30 September.
(3) In case an entity applies to become a RRM, the Agency shall send the entity an invoice amounting to 50 % of the flat enrolment fee component pursuant to point (a) of Article 6(1) and only accept the application once the invoice is paid. Where the Agency rejects the application because the entity does not comply with the requirements pursuant to the delegated act adopted in accordance with Article 9a(6) of Regulation (EU) No 1227/2011 or pursuant to Article 11 of Implementing Regulation (EU) No 1348/2014, the entity is not entitled to a reimbursement of the paid fee. After registration or authorisation of an entity as RRM, the Agency shall send the entity an invoice over the remaining fee consisting of 50 % of the flat enrolment fee component pursuant to point (a) of Article 6(1) and, unless the RRM declares that it will solely report fundamental data, the transaction records-based component pursuant to Article 7(4).
(4) RRMs which cease to be authorised or registered by the Agency shall not be entitled to any reimbursement of paid fees or to the waiving of any fees due.

Obligation to pay fees: IIPs

(1) Each IIP shall pay a yearly fee of EUR 15 000.

(2) In case the sum of the individual fees calculated for each RRM pursuant to Article 6 and of the individual fees each IIP will have to pay pursuant to paragraph 1 would exceed the amount to be covered by fees pursuant to Article 3(2), the yearly fee that each IIP will have to pay is decreased by multiplying it with a reduction factor calculated as follows:
(3) At the latest by 31 January of each year, the Agency shall send each IIP an invoice for the annual fee to be paid within a deadline of four weeks.
(4) In case an entity applies to become an IIP, the Agency shall send the entity an invoice amounting to 50 % of the fee pursuant to paragraph 1 and only accept the application once the invoice is paid. Where the Agency rejects the application because the entity does not comply with the requirements pursuant the delegated act adopted in accordance with Article 4a(8) of Regulation (EU) No 1227/2011, the entity is not entitled to a reimbursement of the paid fee. After authorisation of an entity as IIP, the Agency shall send the entity an invoice over the remaining fee pursuant to paragraph 1.

(5) IIPs which cease to be authorised by the Agency shall not be entitled to any reimbursement of paid fees or to the waiving of any fees due.

Calculation of the individual annual fees for RRMs

(1) The annual fee that a RRM has to pay shall be the sum of the following components:
(a) a flat enrolment fee component of EUR 15 000;
(b) where applicable, an exposure report-based fee component calculated pursuant to paragraph 2;
(c) where applicable, a positive or negative correction amount to balance differences between the exposure report-based fee component paid in the previous year and the exposure report-based fee component that would have been paid according to the actual reporting in that year;
(d) a transaction records-based fee component calculated pursuant to Article 7, unless a RRM is solely reporting fundamental data;
(e) where applicable, a positive or negative correction amount to balance differences between the transaction records- based fee component paid in the previous year and the transaction records-based fee component that would have been paid according to the actual reporting in that year.
(2) The exposure report-based fee component referred to in point (b) of paragraph 1 is calculated by summing up all exposure reports received from a RRM in the previous year and multiplying this sum by EUR 250.

(3) The correction amount referred to in point (c) of paragraph 1 is calculated by subtracting the exposure report-based fee component paid in the previous year from the exposure report-based fee component calculated in the current year.
(4) A negative correction amount referred to in point (c) of paragraph 1 shall not be higher than the exposure report-based fee component calculated for the current year.
(5) The correction amount referred to in point (e) of paragraph 1 is calculated by subtracting the transaction records- based fee component paid in the previous year from the transaction records-based fee component calculated in the current year.
(6) In case of a new RRM which was registered or authorised in the previous year, the correction amount pursuant to point (e) of paragraph 1 is calculated by subtracting the amount pursuant to Article 7(4) from the transaction records-based fee component calculated in the current year pursuant to Article 7(5) after dividing the latter by 365 and multiplying it with the number of calendar days between the registration date and the end of the previous year.
(7) A negative correction amount referred to in point (e) of paragraph 1 shall not be higher than the transaction records-based fee component calculated for the current year.
(8) In case the sum of the individual fees calculated for each RRM pursuant to paragraphs 1 to 7 above and of the individual fees each IIP will have to pay pursuant to Article 5(1) would exceed the amount to be covered by fees pursuant to Article 3(2), the individual fee that each RRM will have to pay is decreased by multiplying it with a reduction factor calculated as follows:

Calculation of the transaction records-based fee component

(1) The transaction records-based fee component is calculated on the basis of the transaction records reported in the previous year by each RRM as follows:
(a) The Agency identifies the data clusters of the respective RRM. One data cluster shall consist of one of the following:
(i) all transaction records reporting wholesale energy products pursuant to Articles 7c and 8 of Regulation (EU) No 1227/2011 reported to the Agency on a continuous or periodic basis stemming from a specific market participant using a specific organised market place;
(ii) all transaction records reporting wholesale energy products pursuant to Articles 7c and 8 of Regulation (EU) No 1227/2011 reported to the Agency on a continuous or periodic basis stemming from a specific market participant without using an organised market place;
(b) for each of the data clusters referred to in point (a) the Agency identifies the fee subcomponent pursuant to paragraph 2 or paragraph 3;
(c) the transaction records-based fee component is the sum of the subcomponents identified pursuant to point (b).
(2) The fee subcomponents per data cluster for transaction records pursuant to subitem (i) of point (a) of paragraph 1 are as follows:
Transaction records per data cluster
Fee subcomponent in EUR
1 to 100
250
101 to 1 000
500
1 001 to 10 000
1 000
10 001 to 100 000
2 000
100 001 to up to 1 million
4 000
More than 1 million to up to 10 million
8 000
More than 10 million to up to 100 million
16 000
More than 100 million to up to 1 billion
32 000
More than 1 billion to up to 2 billion
64 000
More than 2 billion
96 000
(3) The fee subcomponents per data cluster for transaction records pursuant to subitem (ii) of point (a) of paragraph 1 are as follows:
Transaction records per data cluster
Fee subcomponent in EUR
1 to 10
250
11 to 100
500
101 to 1 000
1 000
1 001 to 10 000
2 000
10 001 to 100 000
4 000
100 001 to up to 1 million
8 000
More than 1 million to up to 10 million
16 000
More than 10 million
32 000
(4) In case of a new RRM the transaction records-based component in the year of registration is EUR 100 for each calendar day from the day of authorisation or registration until the end of the year. The RRM and the Agency may mutually agree on a different amount in order to better reflect the expected reporting by the RRM.
(5) In case of a new RRM which was authorised or registered in the previous year, the number of transaction records for each data cluster is adjusted prior to identifying the respective fee subcomponents as follows:

Inflation adjustment

(1) In case the sum of the individual fees calculated for each RRM pursuant to Article 6 (1) to (7) and of the fees invoiced to IIPs pursuant to Article 5(1) is lower than the eligible costs identified pursuant to Article 3(1), the amounts laid down in Article 5(1), Article 6(1) point (a), Article 6(2), Article 7(2), Article 7(3) and Article 7(4) are increased by the inflation rate of the Union with effect in the subsequent year.
(2) The inflation rate of the Union to be used is the rate of change for the last 12 months of the ‘Eurostat HICP (All items) — European Union all countries’ published in May prior to the year when the increase will have effect.
(3) The Agency shall publish the increased amounts referred to in paragraph 1 at the latest by 30 June of the year prior to the year when the increase will have effect.

Enforcement

(1) The invoices sent by the Agency pursuant to Articles 4(2), 4(3), 5(3) or 5(4) shall constitute debit notes pursuant to Article 71 of the Financial Regulation of the Agency.
(2) The Agency shall take all appropriate legal steps to ensure full payment of the invoices issued by applying the relevant rules, including those on default interest and on recovery, of the Financial Regulation of the Agency.
(3) In case a RRM is overdue with paying the fee for at least one month, the Agency may decide to disable the RRM’s ability to report data to the Agency until the fee is paid in full.

Transitional rules in 2025

(1) Within two weeks from entry into force of this Decision, the Agency shall send each RRM an invoice for a surcharge to be paid within four weeks.
(2) This surcharge to be paid by each RRM is calculated by:
(a) identifying for each RRM the number of market participants registered in accordance with Article 9 of Regulation (EU) No 1227/2011 on 30 June 2025 for which the RRM reported transaction records in the period from 1 January to 30 June 2025;
(b) summing up the numbers of market participants identified by all RRMs pursuant to point (a);
(c) dividing the number identified pursuant to point (a) by the sum pursuant to point (b) and multiplying the result with EUR 7,6 million.

Transitional rules in 2026

(1) In case in 2026 the sum of the individual fees calculated for each RRM pursuant to Article 6 (1) to (7) and of the fees to be invoiced to IIPs pursuant to Article 5(1) is lower than the amount budgeted as revenues from fees in 2026 as laid down in the Programming Document of the Agency for 2026-2028, the invoices sent out pursuant to Article 4(2) shall include a surcharge.
(2) The sum of those surcharges shall amount to the difference between either the amount budgeted as revenues from fees in 2026 as laid down in the Programming Document of the Agency for 2026-2028 or EUR 23,5 million, whichever of the two values is lower, and the sum of the individual fees calculated for each RRM pursuant to Article 6 (1) to (7) together with the sum of the fees invoiced to IIPs pursuant to Article 5(1).
(3) The surcharge to be included in the invoice to be paid by a RRM is calculated by dividing the number of data clusters referred to in Article 7(1), point (a) identified for this RRM when calculating the individual annual fee in January 2026 by the sum of the number of data clusters identified for all RRMs in January 2026 and multiplying the result with the difference referred to in paragraph 2.

(4) By way of derogation from Article 6(5), in 2026 the correction amount referred to in point (e) of Article 6(1) is calculated by subtracting the transaction records-based fee component paid in 2025 from the value which would have been the result of calculating the transaction records-based fee component in 2026 using the values in the Annex.
(5) Article 6(1), point (b), Article 6(1), point (c), Article 6(2) and Article 6(3) shall not apply to the fees levied in 2026.

Other transitional rules

(1) By way of derogation from Article 6(2), once the exposure reporting obligation becomes applicable (‘the reference year’), the year following the reference year the exposure report-based fee component referred to in Article 6(1), point (b), is calculated by summing up all exposure reports received from a RRM in the reference year, dividing this sum by the number of exposure reports due in the reference year and multiplying the result by EUR 1 000.

(2) Article 6(1), point (c) and Article 6(3) shall not apply to the fees levied in the year following the reference year.

Evaluation

The Commission shall evaluate the implementation of this Decision five years after its entry into force and every five years thereafter.

Repeal

Decision (EU) 2020/2152 is repealed.

Entry into force and application

This Decision shall enter into force on the third day following that of its publication in the Official Journal of the European Union.

The fee subcomponents per data cluster for:

(a) transaction records reporting wholesale energy products pursuant to point (a) of Article 3(1) of Implementing Regulation (EU) No 1348/2014 stemming from a specific market participant using a specific organised market place;

(b) and all transaction records reporting wholesale energy products pursuant to point (b) of Article 3(1) of Implementing Regulation (EU) No 1348/2014 stemming from a specific market participant

are as follows:

Transaction records per data cluster
Fee subcomponent in EUR
1 to 1 000
250
1 001 to 10 000
500
10 001 to 100 000
1 000
100 001 to 1 million
2 000
More than 1 million to up to 10 million
4 000
More than 10 million to up to 100 million
8 000
More than 100 million
16 000

The fee subcomponents per data cluster for all transaction records reporting wholesale energy products pursuant to point (a) of Article 3(1) of Implementing Regulation (EU) No 1348/2014 stemming from a specific market participant without using an organised market place are as follows:

Transaction records per data cluster
Fee subcomponent in EUR
1 to 100
250
101 to 1 000
500
1 001 to 10 000
1 000
10 001 to 100 000
2 000
100 001 to 1 million
4 000
More than 1 million to up to 10 million
8 000
More than 10 million
16 000

Political and Security Committee Decision (CFSP) 2025/1770 of 27 August 2025 on the appointment of the EU Operation Commander for the European Union military operation in the Mediterranean (EUNAVFOR MED IRINI) and repealing Decision (CFSP) 2024/1848 (EUNAVFOR MED IRINI/3/2025)

January 13, 2026
Official Journalof the European Union ENL series
2025/1770 8.9.2025
(1) On 31 March 2020, the Council adopted Decision (CFSP) 2020/472, which established and launched a European Union military operation in the Mediterranean (EUNAVFOR MED IRINI).
(2) Pursuant to Decision (CFSP) 2020/472, the Council authorised the Political and Security Committee (PSC) to take decisions on the appointment of the EU Operation Commander for EUNAVFOR MED IRINI (‘EU Operation Commander’).
(3) On 26 June 2024, the PSC adopted Decision (CFSP) 2024/1848(2), appointing Rear Admiral Valentino RINALDI as EU Operation Commander from 19 July 2024.
(4) On 3 June 2025, the Italian military authorities proposed that Rear Admiral Marco CASAPIERI succeed Rear Admiral Valentino RINALDI as EU Operation Commander from 12 September 2025.
(5) On 17 June 2025, the EU Military Committee supported the proposed appointment made by the Italian military authorities.
(6) A decision on the appointment of Rear Admiral Marco CASAPIERI as EU Operation Commander should be taken.
(7) Decision (CFSP) 2024/1848 should be repealed,
THE POLITICAL AND SECURITY COMMITTEE,
Having regard to the Treaty on European Union, and in particular Article 38 thereof,
Having regard to Council Decision (CFSP) 2020/472 of 31 March 2020 on a European Union military operation in the Mediterranean (EUNAVFOR MED IRINI) (1), in particular Article 8(2) thereof,
Whereas:
(1) On 31 March 2020, the Council adopted Decision (CFSP) 2020/472, which established and launched a European Union military operation in the Mediterranean (EUNAVFOR MED IRINI).
(2) Pursuant to Decision (CFSP) 2020/472, the Council authorised the Political and Security Committee (PSC) to take decisions on the appointment of the EU Operation Commander for EUNAVFOR MED IRINI (‘EU Operation Commander’).
(3) On 26 June 2024, the PSC adopted Decision (CFSP) 2024/1848 (2), appointing Rear Admiral Valentino RINALDI as EU Operation Commander from 19 July 2024.
(4) On 3 June 2025, the Italian military authorities proposed that Rear Admiral Marco CASAPIERI succeed Rear Admiral Valentino RINALDI as EU Operation Commander from 12 September 2025.
(5) On 17 June 2025, the EU Military Committee supported the proposed appointment made by the Italian military authorities.
(6) A decision on the appointment of Rear Admiral Marco CASAPIERI as EU Operation Commander should be taken.
(7) Decision (CFSP) 2024/1848 should be repealed,
HAS ADOPTED THIS DECISION:
Rear Admiral Marco CASAPIERI is hereby appointed as EU Operation Commander for the European Union military operation in the Mediterranean (EUNAVFOR MED IRINI) from 12 September 2025.
Decision (CFSP) 2024/1848 is hereby repealed.
This Decision shall enter into force on 12 September 2025.

Commission Implementing Decision (EU) 2025/1769 of 27 August 2025 amending Implementing Decision (EU) 2019/450 as regards the publication of references of European Assessment Documents for battery-powered hold-open systems with optional radio system and spherical and cylindrical bearings with special sliding material made of a modified polyamide-polyethylene blend and other construction products

January 13, 2026
Official Journalof the European Union ENL series
2025/1769 3.9.2025
(1) In accordance with Article 19 of Regulation (EU) No 305/2011, following requests by manufacturers for European Technical Assessments, the organisation of Technical Assessment Bodies has adopted 21 European Assessment Documents.
(2) The European Assessment Documents that have been adopted by the organisation of Technical Assessment Bodies relate to the following references for construction products:—battery-powered hold-open systems with optional radio system;—spherical and cylindrical bearings with special sliding material made of a modified polyamide-polyethylene blend;—reduced thermal bridge wall brackets as part of the subframe of ventilated wall cladding systems or other façade systems;—kits for non-load-bearing mineral board external wall systems (superseding technical specification ‘EAD 090120-00-0404’);—variant: kits for external wall claddings with multilayer composite rigid cladding elements – extension of scope;—lightweight composite panels with expanded polymer or aluminium honeycomb core;—natural binder made from ‘Scaglia Rossa’ marl for construction mixtures;—hexagonal woven mesh gabions, mattresses and sack gabions (superseding technical specification ‘EAD 200019-00-0102’);—welded gabion kits for use in building foundations;—kits for anti-falling debris ceiling protection composed of welded steel wire mesh and washers;—self-supporting multi-layer waterproofing and insulating system for pitched roofs;—flashings for daylight devices;—polymeric additives for hydraulically bound layers in road construction;—processed bottom ashes from municipal solid waste incinerators as aggregates for unbound materials for use in road construction;—non-metallic expansive mixture based on calcium oxide for concrete;—cathodic corrosion protection systems made of thermally sprayed zinc anodes combined with polymeric coatings;—power-actuated fastenings in concrete for redundant non-structural applications (superseding technical specification ‘EAD 330083-03-0601’);—variant: seismic performance for the connection of interior non-load-bearing drywall partition walls metal stud to concrete using multiple power actuated fasteners;—mounting channels (superseding technical specification ‘EAD 330667-00-0602’);—variant: building kits based on massive panels with metal frame structure – extension of scope;—attic stair kits. — battery-powered hold-open systems with optional radio system; — spherical and cylindrical bearings with special sliding material made of a modified polyamide-polyethylene blend; — reduced thermal bridge wall brackets as part of the subframe of ventilated wall cladding systems or other façade systems; — kits for non-load-bearing mineral board external wall systems (superseding technical specification ‘EAD 090120-00-0404’); — variant: kits for external wall claddings with multilayer composite rigid cladding elements – extension of scope; — lightweight composite panels with expanded polymer or aluminium honeycomb core; — natural binder made from ‘Scaglia Rossa’ marl for construction mixtures; — hexagonal woven mesh gabions, mattresses and sack gabions (superseding technical specification ‘EAD 200019-00-0102’); — welded gabion kits for use in building foundations; — kits for anti-falling debris ceiling protection composed of welded steel wire mesh and washers; — self-supporting multi-layer waterproofing and insulating system for pitched roofs; — flashings for daylight devices; — polymeric additives for hydraulically bound layers in road construction; — processed bottom ashes from municipal solid waste incinerators as aggregates for unbound materials for use in road construction; — non-metallic expansive mixture based on calcium oxide for concrete; — cathodic corrosion protection systems made of thermally sprayed zinc anodes combined with polymeric coatings; — power-actuated fastenings in concrete for redundant non-structural applications (superseding technical specification ‘EAD 330083-03-0601’); — variant: seismic performance for the connection of interior non-load-bearing drywall partition walls metal stud to concrete using multiple power actuated fasteners; — mounting channels (superseding technical specification ‘EAD 330667-00-0602’); — variant: building kits based on massive panels with metal frame structure – extension of scope; — attic stair kits.
— battery-powered hold-open systems with optional radio system;
— spherical and cylindrical bearings with special sliding material made of a modified polyamide-polyethylene blend;
— reduced thermal bridge wall brackets as part of the subframe of ventilated wall cladding systems or other façade systems;
— kits for non-load-bearing mineral board external wall systems (superseding technical specification ‘EAD 090120-00-0404’);
— variant: kits for external wall claddings with multilayer composite rigid cladding elements – extension of scope;
— lightweight composite panels with expanded polymer or aluminium honeycomb core;
— natural binder made from ‘Scaglia Rossa’ marl for construction mixtures;
— hexagonal woven mesh gabions, mattresses and sack gabions (superseding technical specification ‘EAD 200019-00-0102’);
— welded gabion kits for use in building foundations;
— kits for anti-falling debris ceiling protection composed of welded steel wire mesh and washers;
— self-supporting multi-layer waterproofing and insulating system for pitched roofs;
— flashings for daylight devices;
— polymeric additives for hydraulically bound layers in road construction;
— processed bottom ashes from municipal solid waste incinerators as aggregates for unbound materials for use in road construction;
— non-metallic expansive mixture based on calcium oxide for concrete;
— cathodic corrosion protection systems made of thermally sprayed zinc anodes combined with polymeric coatings;
— power-actuated fastenings in concrete for redundant non-structural applications (superseding technical specification ‘EAD 330083-03-0601’);
— variant: seismic performance for the connection of interior non-load-bearing drywall partition walls metal stud to concrete using multiple power actuated fasteners;
— mounting channels (superseding technical specification ‘EAD 330667-00-0602’);
— variant: building kits based on massive panels with metal frame structure – extension of scope;
— attic stair kits.
— battery-powered hold-open systems with optional radio system;
— spherical and cylindrical bearings with special sliding material made of a modified polyamide-polyethylene blend;
— reduced thermal bridge wall brackets as part of the subframe of ventilated wall cladding systems or other façade systems;
— kits for non-load-bearing mineral board external wall systems (superseding technical specification ‘EAD 090120-00-0404’);
— variant: kits for external wall claddings with multilayer composite rigid cladding elements – extension of scope;
— lightweight composite panels with expanded polymer or aluminium honeycomb core;
— natural binder made from ‘Scaglia Rossa’ marl for construction mixtures;
— hexagonal woven mesh gabions, mattresses and sack gabions (superseding technical specification ‘EAD 200019-00-0102’);
— welded gabion kits for use in building foundations;
— kits for anti-falling debris ceiling protection composed of welded steel wire mesh and washers;
— self-supporting multi-layer waterproofing and insulating system for pitched roofs;
— flashings for daylight devices;
— polymeric additives for hydraulically bound layers in road construction;
— processed bottom ashes from municipal solid waste incinerators as aggregates for unbound materials for use in road construction;
— non-metallic expansive mixture based on calcium oxide for concrete;
— cathodic corrosion protection systems made of thermally sprayed zinc anodes combined with polymeric coatings;
— power-actuated fastenings in concrete for redundant non-structural applications (superseding technical specification ‘EAD 330083-03-0601’);
— variant: seismic performance for the connection of interior non-load-bearing drywall partition walls metal stud to concrete using multiple power actuated fasteners;
— mounting channels (superseding technical specification ‘EAD 330667-00-0602’);
— variant: building kits based on massive panels with metal frame structure – extension of scope;
— attic stair kits.
(3) The European Assessment Documents that have been adopted by the organisation of Technical Assessment Bodies satisfy the demands to be met in relation to the basic requirements for construction works set out in Annex I to Regulation (EU) No 305/2011. It is therefore appropriate to publish the references to those European Assessment Documents in theOfficial Journal of the European Union.
(4) The list of references to European Assessment Documents for construction products is published pursuant to Commission Implementing Decision (EU) 2019/450(2). For reasons of clarity, references to new European Assessment Documents should be added to that list.
(5) Implementing Decision (EU) 2019/450 should therefore be amended accordingly.
(6) In order to enable the use of the European Assessment Documents as early as possible, so that the manufacturers already holding a European Technical Assessment can place their product on the market, this Decision should enter into force on the day of its publication,
‘020094-00-1107 Battery-powered hold-open systems with optional radio system’
‘050078-00-0301 Spherical and cylindrical bearings with special sliding material made of a modified polyamide-polyethylene blend’
‘090018-00-0404 Reduced thermal bridge wall brackets as part of the subframe of ventilated wall cladding systems or other façade systems’
‘090120-01-0404 Kits for non-load-bearing mineral board external wall systems (superseding technical specification ‘EAD 090120-00-0404’)’
‘090125-00-0404-v01 Variant: Kits for external wall claddings with multilayer composite rigid cladding elements – Extension of scope’
‘090262-00-0404 Lightweight composite panels with expanded polymer or aluminium honeycomb core’
‘150059-00-0301 Natural binder made from “Scaglia Rossa” marl for construction mixtures’
‘200019-01-0102 Hexagonal woven mesh gabions, mattresses and sack gabions (superseding technical specification ‘EAD 200019-00-0102’)’
‘200171-00-0103 Welded gabion kits for use in building foundations’
‘210161-00-0501 Kits for anti-falling debris ceiling protection composed of welded steel wire mesh and washers’
‘220119-00-0402 Self-supporting multi-layer waterproofing and insulating system for pitched roofs’
‘220163-00-0401 Flashings for daylight devices’
‘230172-00-0102 Polymeric additives for hydraulically bound layers in road construction’
‘240002-00-0108 Processed bottom ashes from municipal solid waste incinerators as aggregates for unbound materials for use in road construction’
‘260055-00-0301 Non-metallic expansive mixture based on calcium oxide for concrete’
‘260100-00-0301 Cathodic corrosion protection systems made of thermally sprayed zinc anodes combined with polymeric coatings’
‘330083-04-0601 Power-actuated fastenings in concrete for redundant non-structural applications (superseding technical specification ‘EAD 330083-03-0601’)’
‘330083-04-0601-v01 Variant: Seismic performance for the connection of interior non-load-bearing drywall partition walls metal stud to concrete using multiple power actuated fasteners’
‘330667-01-0602 Mounting channels (superseding technical specification ‘EAD 330667-00-0602’)’
‘340452-00-0204-v01 Variant: Building kits based on massive panels with metal frame structure – Extension of scope’
‘340556-00-0506 Attic stair kits’.
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EU) No 305/2011 of the European Parliament and of the Council of 9 March 2011 laying down harmonised conditions for the marketing of construction products and repealing Council Directive 89/106/EEC (1), and in particular Article 22 thereof,
Whereas:
(1) In accordance with Article 19 of Regulation (EU) No 305/2011, following requests by manufacturers for European Technical Assessments, the organisation of Technical Assessment Bodies has adopted 21 European Assessment Documents.
(2) The European Assessment Documents that have been adopted by the organisation of Technical Assessment Bodies relate to the following references for construction products:
—
battery-powered hold-open systems with optional radio system;
—
spherical and cylindrical bearings with special sliding material made of a modified polyamide-polyethylene blend;
—
reduced thermal bridge wall brackets as part of the subframe of ventilated wall cladding systems or other façade systems;
—
kits for non-load-bearing mineral board external wall systems (superseding technical specification ‘EAD 090120-00-0404’);
—
variant: kits for external wall claddings with multilayer composite rigid cladding elements – extension of scope;
—
lightweight composite panels with expanded polymer or aluminium honeycomb core;
—
natural binder made from ‘Scaglia Rossa’ marl for construction mixtures;
—
hexagonal woven mesh gabions, mattresses and sack gabions (superseding technical specification ‘EAD 200019-00-0102’);
—
welded gabion kits for use in building foundations;
—
kits for anti-falling debris ceiling protection composed of welded steel wire mesh and washers;
—
self-supporting multi-layer waterproofing and insulating system for pitched roofs;
—
flashings for daylight devices;
—
polymeric additives for hydraulically bound layers in road construction;
—
processed bottom ashes from municipal solid waste incinerators as aggregates for unbound materials for use in road construction;
—
non-metallic expansive mixture based on calcium oxide for concrete;
—
cathodic corrosion protection systems made of thermally sprayed zinc anodes combined with polymeric coatings;
—
power-actuated fastenings in concrete for redundant non-structural applications (superseding technical specification ‘EAD 330083-03-0601’);
—
variant: seismic performance for the connection of interior non-load-bearing drywall partition walls metal stud to concrete using multiple power actuated fasteners;
—
mounting channels (superseding technical specification ‘EAD 330667-00-0602’);
—
variant: building kits based on massive panels with metal frame structure – extension of scope;
—
attic stair kits.
(3) The European Assessment Documents that have been adopted by the organisation of Technical Assessment Bodies satisfy the demands to be met in relation to the basic requirements for construction works set out in Annex I to Regulation (EU) No 305/2011. It is therefore appropriate to publish the references to those European Assessment Documents in the Official Journal of the European Union.
(4) The list of references to European Assessment Documents for construction products is published pursuant to Commission Implementing Decision (EU) 2019/450 (2). For reasons of clarity, references to new European Assessment Documents should be added to that list.
(5) Implementing Decision (EU) 2019/450 should therefore be amended accordingly.
(6) In order to enable the use of the European Assessment Documents as early as possible, so that the manufacturers already holding a European Technical Assessment can place their product on the market, this Decision should enter into force on the day of its publication,
HAS ADOPTED THIS DECISION:
The Annex to Implementing Decision (EU) 2019/450 is amended in accordance with the Annex to this Decision.
This Decision shall enter into force on the day of its publication in the Official Journal of the European Union.

In the Annex to Implementing Decision (EU) 2019/450, the following rows are inserted in sequential order following the order of the reference numbers:

‘020094-00-1107
Battery-powered hold-open systems with optional radio system’
‘050078-00-0301
Spherical and cylindrical bearings with special sliding material made of a modified polyamide-polyethylene blend’
‘090018-00-0404
Reduced thermal bridge wall brackets as part of the subframe of ventilated wall cladding systems or other façade systems’
‘090120-01-0404
Kits for non-load-bearing mineral board external wall systems (superseding technical specification ‘EAD 090120-00-0404’)’
‘090125-00-0404-v01
Variant: Kits for external wall claddings with multilayer composite rigid cladding elements – Extension of scope’
‘090262-00-0404
Lightweight composite panels with expanded polymer or aluminium honeycomb core’
‘150059-00-0301
Natural binder made from “Scaglia Rossa” marl for construction mixtures’
‘200019-01-0102
Hexagonal woven mesh gabions, mattresses and sack gabions (superseding technical specification ‘EAD 200019-00-0102’)’
‘200171-00-0103
Welded gabion kits for use in building foundations’
‘210161-00-0501
Kits for anti-falling debris ceiling protection composed of welded steel wire mesh and washers’
‘220119-00-0402
Self-supporting multi-layer waterproofing and insulating system for pitched roofs’
‘220163-00-0401
Flashings for daylight devices’
‘230172-00-0102
Polymeric additives for hydraulically bound layers in road construction’
‘240002-00-0108
Processed bottom ashes from municipal solid waste incinerators as aggregates for unbound materials for use in road construction’
‘260055-00-0301
Non-metallic expansive mixture based on calcium oxide for concrete’
‘260100-00-0301
Cathodic corrosion protection systems made of thermally sprayed zinc anodes combined with polymeric coatings’
‘330083-04-0601
Power-actuated fastenings in concrete for redundant non-structural applications (superseding technical specification ‘EAD 330083-03-0601’)’
‘330083-04-0601-v01
Variant: Seismic performance for the connection of interior non-load-bearing drywall partition walls metal stud to concrete using multiple power actuated fasteners’
‘330667-01-0602
Mounting channels (superseding technical specification ‘EAD 330667-00-0602’)’
‘340452-00-0204-v01
Variant: Building kits based on massive panels with metal frame structure – Extension of scope’
‘340556-00-0506
Attic stair kits’.

Commission Implementing Decision (EU) 2025/1767 of 27 August 2025 concerning certain emergency measures relating to sheep pox and goat pox in Romania and repealing Implementing Decision (EU) 2025/1406 (notified under document C(2025) 5932)

January 13, 2026
Official Journalof the European Union ENL series
2025/1767 29.8.2025
(1) Sheep pox and goat pox is an infectious viral disease affecting caprine and ovine animals and can have a severe impact on the concerned animal population and the profitability of farming causing disturbance to movements of consignments of those animals and products thereof within the Union and exports to third countries.
(2) In the event of an outbreak of sheep pox and goat pox in caprine or ovine animals, there is a serious risk of the spread of that disease to other establishments of caprine or ovine animals.
(3) Commission Delegated Regulation (EU) 2020/687(2)supplements the rules for the control of the listed diseases referred to in Article 9(1), points (a), (b) and (c), of Regulation (EU) 2016/429, and defined as category A, B and C diseases in Commission Implementing Regulation (EU) 2018/1882(3). In particular, Articles 21 and 22 of Delegated Regulation (EU) 2020/687 provide for the establishment of a restricted zone in the event of an outbreak of a category A disease, including sheep pox and goat pox, and for certain measures to be applied therein. In addition, Article 21(1) of that Delegated Regulation provides that the restricted zone is to comprise a protection zone, a surveillance zone, and, if necessary, further restricted zone around or adjacent to the protection and surveillance zones.
(4) Commission Implementing Decision (EU) 2025/1406(4)was adopted following outbreaks of sheep pox and goat pox in Romania, and it lays down emergency measures to be taken by that Member State. More particularly, Implementing Decision (EU) 2025/1406 provides that the protection, surveillance, and further restricted zones to be established by Romania, in accordance with Article 21 of Delegated Regulation (EU) 2020/687, are to comprise at least the areas listed in the Annex to that Implementing Decision.
(5) Since the adoption of Implementing Decision (EU) 2025/1406, Romania has notified the Commission of fifteen additional outbreaks of sheep pox and goat pox in establishments where ovine and caprine animals were kept, located in the counties of Teleorman and Olt, within the already established restricted zones listed in the Annex to that Implementing Decision.
(6) In the current epidemiological situation, there is a high risk for the further spread of sheep pox and goat pox, in particular due to the fact that, according to the information provided by Romania, outbreaks occurred after the previous restricted zones had been lifted, suggesting that the disease persists and continues to circulate.
(7) Therefore, a new restricted zone, comprising a protection and a surveillance zone in Romania, as the one set out in the Annex to Implementing Decision (EU) 2025/1406 should be established and adjusted, both spatially and temporally, in order to prevent the further spread of sheep pox and goat pox in the territory of Romania and to the rest of the Union.
(8) In addition, in order to minimise the risk of the further spread of the disease, it is also necessary to prolong the duration of the new protection and surveillance zones beyond the minimum requirements of Commission Delegated Regulation (EU) 2020/687.
(9) The size of the protection and surveillance zones, and the duration of the measures to be applied therein, is based on the criteria set out in Article 64(1) of Regulation (EU) 2016/429, as well as on the rules laid down in Delegated Regulation (EU) 2020/687. The criteria applied for the choice of the size of the protection and surveillance zones, as well as of the duration of the measures to be applied therein, consider not only the epidemiological situation as regards sheep pox and goat pox in the areas affected by that disease, but also of the overall epidemiological situation of sheep pox and goat pox in the entire territory of Romania, and of the level of risk for the further spread of the disease. For the determination of the duration of the measures, the international standards of the Terrestrial Animal Health Code of the World Organisation for Animal Health(5)have also been taken into account.
(10) Implementing Decision (EU) 2025/1406 should, therefore, be repealed and replaced by this Decision.
(11) Given the urgency of the epidemiological situation in the Union as regards the spread of sheep pox and goat pox, and the need to prevent that disease from spreading from the affected establishments in Romania to other parts of that Member State or to other Member States, Romania should adopt the measures provided for in this Decision immediately.
(12) The measures provided for in this Decision are in accordance with the opinion of the Standing Committee on Plants, Animals, Food and Feed,
(a) a restricted zone, which comprises protection and surveillance zones is established immediately by the competent authority of that Member State in accordance with Article 21 of Delegated Regulation (EU) 2020/687, and under the conditions laid down in that Article;
(b) the protection and surveillance zones referred to in point (a) comprise at least the areas listed in the Annex to this Decision;
(c) the measures required to be applied in the protection and surveillance zones, are applied at least until the dates listed in the Annex to this Decision.
Region and ADIS reference number of the outbreak Areas established as protection and surveillance zones, part of the restricted zone in Romania referred to in Article 1 Date until applicable
Teleorman countyRO-CAPRIPOX-2025-00014RO-CAPRIPOX-2025-00015RO-CAPRIPOX-2025-00016RO-CAPRIPOX-2025-00017RO-CAPRIPOX-2025-00018RO-CAPRIPOX-2025-00019RO-CAPRIPOX-2025-00020RO-CAPRIPOX-2025-00021 Protection zone:Those parts of Teleorman, Olt and Argeș counties, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 44.281899, Long. 24.870992 (2025/14), Lat. 44.27906, Long. 24.873868 (2025/15), Lat. 44.302455, Long. 24.96162 (2025/16), Lat. 44.255644, Long. 24.879311 (2025/17), Lat. 44.282747, Long. 24.936885 (2025/18), Lat. 44.281473, Long. 24.897365 (2025/19), Lat. 44.260135, Long. 24.883573 (2025/20), Lat. 44.295664, Long. 25.004148 (2025/21). 3.9.2025
Surveillance zone:Those parts of Teleorman, Olt and Argeș counties, contained within a circle of a radius of 20 kilometres, centred on UTM 30, ETRS89 coordinates 44.281899, Long. 24.870992 (2025/14), Lat. 44.27906, Long. 24.873868 (2025/15), Lat. 44.302455, Long. 24.96162 (2025/16), Lat. 44.255644, Long. 24.879311 (2025/17), Lat. 44.282747, Long. 24.936885 (2025/18), Lat. 44.281473, Long. 24.897365 (2025/19), Lat. 44.260135, Long. 24.883573 (2025/20), Lat. 44.295664, Long. 25.004148 (2025/21), excluding the areas contained in the protection zone. 18.9.2025
Surveillance zone:Those parts of Teleorman, Olt and Argeș counties, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates 44.281899, Long. 24.870992 (2025/14), Lat. 44.27906, Long. 24.873868 (2025/15), Lat. 44.302455, Long. 24.96162 (2025/16), Lat. 44.255644, Long. 24.879311 (2025/17), Lat. 44.282747, Long. 24.936885 (2025/18), Lat. 44.281473, Long. 24.897365 (2025/19), Lat. 44.260135, Long. 24.883573 (2025/20), Lat. 44.295664, Long. 25.004148 (2025/21). 4.9.2025 – 18.9.2025
Olt countyRO-CAPRIPOX-2025-00007RO-CAPRIPOX-2025-00008RO-CAPRIPOX-2025-00009RO-CAPRIPOX-2025-00010RO-CAPRIPOX-2025-00011RO-CAPRIPOX-2025-00012RO-CAPRIPOX-2025-00013 Protection zone:Those parts of Teleorman, Olt and Argeș counties, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 44.33564, Long. 24.77224 (2025/7), Lat. 44.323172, Long. 24.78142 (2025/8), Lat. 44.380891, Long. 24.815991 (2025/9), Lat. 44.312664, Long. 24.748821 (2025/10), Lat. 44.365143, Long. 24.777882 (2025/11), Lat. 44.329438, Long. 24.775184 (2025/12), Lat. 44.362673, Long. 24.774821 (2025/13). 3.9.2025
Surveillance zone:Those parts of Teleorman, Olt and Argeș counties, contained within a circle of a radius of 20 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 44.33564, Long. 24.77224 (2025/7), Lat. 44.323172, Long. 24.78142 (2025/8), Lat. 44.380891, Long. 24.815991 (2025/9), Lat. 44.312664, Long. 24.748821 (2025/10), Lat. 44.365143, Long. 24.777882 (2025/11), Lat. 44.329438, Long. 24.775184 (2025/12), Lat. 44.362673, Long. 24.774821 (2025/13), excluding the areas contained in the protection zone. 18.9.2025
Surveillance zone:Those parts of Teleorman, Olt and Argeș counties, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 44.33564, Long. 24.77224 (2025/7), Lat. 44.323172, Long. 24.78142 (2025/8), Lat. 44.380891, Long. 24.815991 (2025/9), Lat. 44.312664, Long. 24.748821 (2025/10), Lat. 44.365143, Long. 24.777882 (2025/11), Lat. 44.329438, Long. 24.775184 (2025/12), Lat. 44.362673, Long. 24.774821 (2025/13). 4.9.2025 – 18.9.2025
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EU) 2016/429 of the European Parliament and of the Council of 9 March 2016 on transmissible animal diseases and amending and repealing certain acts in the area of animal health (‘Animal Health Law’) (1), and in particular Article 259(1) thereof,
Whereas:
(1) Sheep pox and goat pox is an infectious viral disease affecting caprine and ovine animals and can have a severe impact on the concerned animal population and the profitability of farming causing disturbance to movements of consignments of those animals and products thereof within the Union and exports to third countries.
(2) In the event of an outbreak of sheep pox and goat pox in caprine or ovine animals, there is a serious risk of the spread of that disease to other establishments of caprine or ovine animals.
(3) Commission Delegated Regulation (EU) 2020/687 (2) supplements the rules for the control of the listed diseases referred to in Article 9(1), points (a), (b) and (c), of Regulation (EU) 2016/429, and defined as category A, B and C diseases in Commission Implementing Regulation (EU) 2018/1882 (3). In particular, Articles 21 and 22 of Delegated Regulation (EU) 2020/687 provide for the establishment of a restricted zone in the event of an outbreak of a category A disease, including sheep pox and goat pox, and for certain measures to be applied therein. In addition, Article 21(1) of that Delegated Regulation provides that the restricted zone is to comprise a protection zone, a surveillance zone, and, if necessary, further restricted zone around or adjacent to the protection and surveillance zones.
(4) Commission Implementing Decision (EU) 2025/1406 (4) was adopted following outbreaks of sheep pox and goat pox in Romania, and it lays down emergency measures to be taken by that Member State. More particularly, Implementing Decision (EU) 2025/1406 provides that the protection, surveillance, and further restricted zones to be established by Romania, in accordance with Article 21 of Delegated Regulation (EU) 2020/687, are to comprise at least the areas listed in the Annex to that Implementing Decision.
(5) Since the adoption of Implementing Decision (EU) 2025/1406, Romania has notified the Commission of fifteen additional outbreaks of sheep pox and goat pox in establishments where ovine and caprine animals were kept, located in the counties of Teleorman and Olt, within the already established restricted zones listed in the Annex to that Implementing Decision.
(6) In the current epidemiological situation, there is a high risk for the further spread of sheep pox and goat pox, in particular due to the fact that, according to the information provided by Romania, outbreaks occurred after the previous restricted zones had been lifted, suggesting that the disease persists and continues to circulate.
(7) Therefore, a new restricted zone, comprising a protection and a surveillance zone in Romania, as the one set out in the Annex to Implementing Decision (EU) 2025/1406 should be established and adjusted, both spatially and temporally, in order to prevent the further spread of sheep pox and goat pox in the territory of Romania and to the rest of the Union.
(8) In addition, in order to minimise the risk of the further spread of the disease, it is also necessary to prolong the duration of the new protection and surveillance zones beyond the minimum requirements of Commission Delegated Regulation (EU) 2020/687.
(9) The size of the protection and surveillance zones, and the duration of the measures to be applied therein, is based on the criteria set out in Article 64(1) of Regulation (EU) 2016/429, as well as on the rules laid down in Delegated Regulation (EU) 2020/687. The criteria applied for the choice of the size of the protection and surveillance zones, as well as of the duration of the measures to be applied therein, consider not only the epidemiological situation as regards sheep pox and goat pox in the areas affected by that disease, but also of the overall epidemiological situation of sheep pox and goat pox in the entire territory of Romania, and of the level of risk for the further spread of the disease. For the determination of the duration of the measures, the international standards of the Terrestrial Animal Health Code of the World Organisation for Animal Health (5) have also been taken into account.
(10) Implementing Decision (EU) 2025/1406 should, therefore, be repealed and replaced by this Decision.
(11) Given the urgency of the epidemiological situation in the Union as regards the spread of sheep pox and goat pox, and the need to prevent that disease from spreading from the affected establishments in Romania to other parts of that Member State or to other Member States, Romania should adopt the measures provided for in this Decision immediately.
(12) The measures provided for in this Decision are in accordance with the opinion of the Standing Committee on Plants, Animals, Food and Feed,
HAS ADOPTED THIS DECISION:
Romania shall ensure that:

(a) a restricted zone, which comprises protection and surveillance zones is established immediately by the competent authority of that Member State in accordance with Article 21 of Delegated Regulation (EU) 2020/687, and under the conditions laid down in that Article;
(b) the protection and surveillance zones referred to in point (a) comprise at least the areas listed in the Annex to this Decision;
(c) the measures required to be applied in the protection and surveillance zones, are applied at least until the dates listed in the Annex to this Decision.

Implementing Decision (EU) 2025/1406 is repealed.
This Decision is addressed to Romania.

Protection and surveillance zones established around the confirmed outbreak

Region and ADIS reference number of the outbreak
Areas established as protection and surveillance zones, part of the restricted zone in Romania referred to in Article 1
Date until applicable
Teleorman county
RO-CAPRIPOX-2025-00014
RO-CAPRIPOX-2025-00015
RO-CAPRIPOX-2025-00016
RO-CAPRIPOX-2025-00017
RO-CAPRIPOX-2025-00018
RO-CAPRIPOX-2025-00019
RO-CAPRIPOX-2025-00020
RO-CAPRIPOX-2025-00021
Protection zone:
Those parts of Teleorman, Olt and Argeș counties, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 44.281899, Long. 24.870992 (2025/14), Lat. 44.27906, Long. 24.873868 (2025/15), Lat. 44.302455, Long. 24.96162 (2025/16), Lat. 44.255644, Long. 24.879311 (2025/17), Lat. 44.282747, Long. 24.936885 (2025/18), Lat. 44.281473, Long. 24.897365 (2025/19), Lat. 44.260135, Long. 24.883573 (2025/20), Lat. 44.295664, Long. 25.004148 (2025/21).
3.9.2025
Surveillance zone:
Those parts of Teleorman, Olt and Argeș counties, contained within a circle of a radius of 20 kilometres, centred on UTM 30, ETRS89 coordinates 44.281899, Long. 24.870992 (2025/14), Lat. 44.27906, Long. 24.873868 (2025/15), Lat. 44.302455, Long. 24.96162 (2025/16), Lat. 44.255644, Long. 24.879311 (2025/17), Lat. 44.282747, Long. 24.936885 (2025/18), Lat. 44.281473, Long. 24.897365 (2025/19), Lat. 44.260135, Long. 24.883573 (2025/20), Lat. 44.295664, Long. 25.004148 (2025/21), excluding the areas contained in the protection zone.
18.9.2025
Surveillance zone:
Those parts of Teleorman, Olt and Argeș counties, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates 44.281899, Long. 24.870992 (2025/14), Lat. 44.27906, Long. 24.873868 (2025/15), Lat. 44.302455, Long. 24.96162 (2025/16), Lat. 44.255644, Long. 24.879311 (2025/17), Lat. 44.282747, Long. 24.936885 (2025/18), Lat. 44.281473, Long. 24.897365 (2025/19), Lat. 44.260135, Long. 24.883573 (2025/20), Lat. 44.295664, Long. 25.004148 (2025/21).
4.9.2025 – 18.9.2025
Olt county
RO-CAPRIPOX-2025-00007
RO-CAPRIPOX-2025-00008
RO-CAPRIPOX-2025-00009
RO-CAPRIPOX-2025-00010
RO-CAPRIPOX-2025-00011
RO-CAPRIPOX-2025-00012
RO-CAPRIPOX-2025-00013
Protection zone:
Those parts of Teleorman, Olt and Argeș counties, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 44.33564, Long. 24.77224 (2025/7), Lat. 44.323172, Long. 24.78142 (2025/8), Lat. 44.380891, Long. 24.815991 (2025/9), Lat. 44.312664, Long. 24.748821 (2025/10), Lat. 44.365143, Long. 24.777882 (2025/11), Lat. 44.329438, Long. 24.775184 (2025/12), Lat. 44.362673, Long. 24.774821 (2025/13).
3.9.2025
Surveillance zone:
Those parts of Teleorman, Olt and Argeș counties, contained within a circle of a radius of 20 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 44.33564, Long. 24.77224 (2025/7), Lat. 44.323172, Long. 24.78142 (2025/8), Lat. 44.380891, Long. 24.815991 (2025/9), Lat. 44.312664, Long. 24.748821 (2025/10), Lat. 44.365143, Long. 24.777882 (2025/11), Lat. 44.329438, Long. 24.775184 (2025/12), Lat. 44.362673, Long. 24.774821 (2025/13), excluding the areas contained in the protection zone.
18.9.2025
Surveillance zone:
Those parts of Teleorman, Olt and Argeș counties, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 44.33564, Long. 24.77224 (2025/7), Lat. 44.323172, Long. 24.78142 (2025/8), Lat. 44.380891, Long. 24.815991 (2025/9), Lat. 44.312664, Long. 24.748821 (2025/10), Lat. 44.365143, Long. 24.777882 (2025/11), Lat. 44.329438, Long. 24.775184 (2025/12), Lat. 44.362673, Long. 24.774821 (2025/13).
4.9.2025 – 18.9.2025

Commission Decision (EU) 2025/1765 of 11 April 2025 on the measure State aid SA.53630 (2020/C) – (ex 2019/FC) – Belgium Alleged aid granted to Ladbrokes in relation to virtual betting (notified under document C(2025) 2174)

January 13, 2026
Official Journalof the European Union ENL series
2025/1765 3.9.2025
(1) By letter of 1 March 2019, the Commission services received a complaint lodged by the undertakings Rocoluc NV and European Amusement Company NV (hereafter respectively referred to as ‘Rocoluc’ and ‘EAC’) Belgian sister companies active in the gaming and betting sectors, and on 23 February 2024 another complaint by their sister company V.D.B. Faculty NV (‘The Faculty’), also active in the gaming sector with a class II licence (all three sister companies also referred to as ‘the complainants’).
(2) The complainants allege grant of State aid by the Belgian authorities through anad hoc‘authorisation’ to the Belgian company Ladbrokes (registered as Derby S.A.) to operate virtual betting in Belgium which would have been granted to it without appropriate remuneration (hereafter the ‘contested measure’). Ladbrokes, a class IV licence holder, is the (international) brand name under which Derby S.A. a Belgian company specializing in gaming and betting activities and a subsidiary of the multinational betting and gaming company Entain Holdings PLC operates (hereafter for the purposes of this decision all together are referred to as ‘Ladbrokes’).
(3) By letter of 2 September 2020, the Commission informed the Belgian authorities that it had decided to initiate the procedure laid down in Article 108(2) of the Treaty on the Functioning of the European Union in respect of the contested measure (hereinafter the ‘Opening Decision’)(1).
(4) The Commission decision to initiate the procedure was published in the Official Journal of the European Union. The Commission called on interested parties to submit their comments.
(5) The Belgian authorities submitted comments on the Opening Decision on 9 October 2020. Rocoluc and EAC submitted comments on the Opening Decision on 18 November 2020. The Commission received comments on the Opening Decision from Ladbrokes on 18 December 2020. The Belgian authorities provided their observations on the third parties’ comments on 10 February 2021.
(6) On 26 May 2021, following the annulment without preservation of the effects (with effectsex tuncas to the date of adoption) of the Royal Decree on ‘games of chance on virtual sporting events in fixed class IV gaming establishments’ dated 4 May 2018 (hereafter the ‘2018 Royal Decree’)(2), the complainants requested the Commission to adopt a corrective opening decision to extend the period of alleged investigated aid.
(7) On 9 September 2021, Ladbrokes provided a further submission.
(8) On 28 October 2021, the Commission forwarded to the Belgian authorities the complainants’ and Ladbrokes’ submissions with a request for information, to which the Belgian authorities replied on 30 November 2021.
(9) On 7 February 2022, the Commission sent a further request for information to the Belgian authorities, to which the Belgian authorities replied on 9 March 2022, 5 March and 22 April 2022.
(10) On 23 February 2023, the Commission services held a meeting with the complainants. On 9 March 2023, the Commission received an additional submission from the complainants regarding the selective character of the alleged aid. On 23 February 2024, the Commission received a submission by The Faculty, a Belgian company active in the gaming sector, regarding the same contested measure.
(11) On 8 March 2024, the Commission sent a request for information to the Belgian authorities asking for,inter alia, additional clarifications on the factual and legal situation for offline and online virtual betting following the retroactive annulment of the 2018 Royal Decree.
(12) On 8 March 2024, the Commission informed The Faculty that it registered its submission as general market information. On 14 March 2024, The Faculty sent another letter asking to be qualified as a formal complainant. On 20 March 2024, the Commission sent a second letter to The Faculty asking for additional information on the complaint.
(13) On 29 April 2024, the complainants Rocoluc and EAC submitted a letter requesting the Commission to act within the meaning of Article 265(2) TFEU.
(14) On 21 May 2024, the Belgian authorities submitted a reply to the request for information sent by the Commission on 8 March 2024, following a reminder on 3 May 2024.
(15) On 14 June 2024, the Commission sent additional questions to the Belgian authorities to which the Belgian authorities replied on 19 June 2024. On 20 June 2024 the Commission requested additional clarifications per e-mail, to which the Belgian authorities replied on 28 June 2024.
(16) On 31 July 2024, following the above-listed information received from the complainants, the alleged beneficiary Ladbrokes and the Belgian authorities, the Commission decided to extend the scope of its in-depth investigation and adopted a Supplementary Opening Decision(3)(hereinafter ‘the Supplementary Opening Decision’).
(17) The Commission called on interested parties to submit their comments on the findings in the Supplementary Opening Decision, which they provided on 25 November 2024, whereas the Belgian authorities did not provide any comments.
(18) On 12 November 2024, the Commission services requested further information from Ladbrokes and on 22 November 2024, 9 December 2024 and 21 January 2025, Ladbrokes provided, respectively, its comments on the Supplementary Opening Decision and additional information.
(19) On 23 January 2025, the Commission forwarded the third parties’ comments on the Supplementary Opening Decision to the Belgian authorities. The Belgian authorities replied on 4 February 2025 with no comments.
(20) The Belgian authorities agreed exceptionally to waive the rights deriving from Article 342 TFEU in conjunction with Article 3 of Council Regulation No 1/1958(4)and to have this decision adopted and notified pursuant to Article 297 TFEU in English.
(21) The complainants contest a preferential treatment, and an ‘exclusive authorisation’ which would have been granted by the Belgian authorities to Ladbrokes to offer online and offline virtual betting in Belgium (the contested measure). According to the complainants, that ‘authorisation’ resulted in Ladbrokes enjoying ade factoexclusive right (since 2014) to operate virtual betting in Belgium without an appropriate remuneration.
(22) The complainants also claim that the 2018 Royal Decree of 4 May 2018 and the judgment of the Council of State (‘Conseil d’État’, which is the Belgian Supreme Administrative Court) of 7 May 2021 confer a benefit to Ladbrokes which amounts to unlawful State aid from the Belgian State, by way of tolerating Ladbrokes’ virtual betting activities while those activities would have been illegal under Belgian law.
(23) Before describing the legal framework for virtual betting and its evolution in Belgium, the wider context of the legal framework for the gaming sector is addressed first.
(24) The games of chance (‘jeux d’hasard’) are a broad concept covers both gaming and betting (‘paris’).
(25) The sector of games of chance in Belgium has been regulated and organised by the Act of 7 May 1999 on games of chance, betting, gaming establishments and the protection of players(5), as amended by an Act of 10 January 2010(6)(hereinafter the ‘Gaming Act’). In addition, numerous implementing acts, Royal decrees (more than 100 to date), implement the provisions of the Gaming Act.
(26) In Belgium, according to Article 4 § 1 of the Gaming Act, there is a prohibition on games of chance, unless a licence is granted to operate, or an exception from the licence requirement is foreseen. The Gaming Commission grants different types of licences for the operation of games of chance.
(27) The activities involving ‘automatic games of chance’ are defined as follows: ‘Any game or bet, where a stake of any kind, either the loss of that stake by at least one of the players or bettors, or a profit of any kind for at least one of the players, bettors or organizers of the game or bet and where chance is an even incidental element in the course of the game, the designation of the winner or the determination of the winning size’(7).
(28) The definition of games of chance (jeux d’hasard) covers a wide range of activities. In other words, in games of chance the player bets on the outcome of a game or event that has an uncertain, randomly determined, result that depends on probabilities (e.g. slot machines). Games of chance are a specific subset of games of chance where the outcome is determined entirely or partially by chance. These games do not require skill and involve a random outcome (such as rolling dice, drawing cards, or spinning a wheel).
(29) Betting, on the other hand, can be regarded as a category of games of chance, which is about predicting the outcome of a future, real event, based on certain criteria (e.g. betting on the outcome of a football match based on the relative strength of the teams). Unlike games of chance, betting may involve an element of skill, as it is based on knowledge and analysis of the event being bet upon.Games of chanceBettingDefinitionGames where outcomes are determined by chance.Predicting outcomes of events and staking money.Outcome DeterminantsPurely or mainly random chance.Predominantly influenced by chance but may involve skill.ExamplesRoulette, slot machines, lotteries.Sports betting, horse racing, fixed-odds betting.RegulationStrictly regulated as games of chance.Regulated as a form of game of chance, requiring a betting licence. Games of chance Betting Definition Games where outcomes are determined by chance. Predicting outcomes of events and staking money. Outcome Determinants Purely or mainly random chance. Predominantly influenced by chance but may involve skill. Examples Roulette, slot machines, lotteries. Sports betting, horse racing, fixed-odds betting. Regulation Strictly regulated as games of chance. Regulated as a form of game of chance, requiring a betting licence.
Games of chance Betting
Definition Games where outcomes are determined by chance. Predicting outcomes of events and staking money.
Outcome Determinants Purely or mainly random chance. Predominantly influenced by chance but may involve skill.
Examples Roulette, slot machines, lotteries. Sports betting, horse racing, fixed-odds betting.
Regulation Strictly regulated as games of chance. Regulated as a form of game of chance, requiring a betting licence.
Games of chance Betting
Definition Games where outcomes are determined by chance. Predicting outcomes of events and staking money.
Outcome Determinants Purely or mainly random chance. Predominantly influenced by chance but may involve skill.
Examples Roulette, slot machines, lotteries. Sports betting, horse racing, fixed-odds betting.
Regulation Strictly regulated as games of chance. Regulated as a form of game of chance, requiring a betting licence.
(30) Regarding virtual betting, the Belgian legal framework has evolved. First, the regulatory and legislative framework has changed over time, marked in particular by the 2018 Royal Decree. This led to litigation before national courts, which has resulted to suspensions and annulments of the 2018 Royal Decree, as well as the Framework Notes of the Gaming Commission of 2012 and 2015 (see below in recital 59). Second, the approach by the Gaming Commission evolved, considering virtual betting as falling under the categories of betting or automatic games of chance. This evolving interpretation of virtual betting within different periods reflects its complex nature in the context of Belgian gaming legislation. It is noteworthy that the discussion on how to define and qualify virtual betting is still pending today in Belgium.
(31) The Gaming Act provides for a limited number of types of licences, which allow the operation of certain games of chance and gaming establishments laid down by law. According to Article 25 of the Gaming Act (‘Chapter III –Licences’) there are nine categories of licences (A, B, C, D, E, F1, F2, G1 and G2) and additional licences (A +, B +, C + and F+).
(32) There are four classes of gaming establishments in Belgium:i.Class I: for casinos. A casino is a gaming establishment where the operation of games of chance, whether or not automatic, is authorized. Only nine casinos are allowed on the Belgian territory. The Gaming Act lists the territories of the communes/cities where a casino can be operated. A casino operator must hold a class A licence.ii.Class II: for gaming arcades. Gaming arcades are establishments which operate only games of chance authorised by the King of Belgium. The operating rules for the automatic games of chance that can be offered in class II gaming establishments are laid down in a Royal Decree of 8 April 2003. A gaming arcade operator must hold a class B licence and can offer automatic games of chance can be offered mainly by class II establishments with a B licence.iii.Class III: drinking establishments, which provide for games of chance and reduced-stakes automatic games of chance. Drinking establishments such as cafés must hold a class C licence.iv.Class IV: for betting offices. Class IV gaming establishments are places where operators with an F2 licence are exclusively permitted to accept bets on behalf of an F1 licence holder (the organizer of betting activities). Class IV establishments may also offer automatic games of chances under certain conditions. It is prohibited to accept bets outside a class IV gaming establishment. There are, however, a limited number of exceptions to this prohibition. A class IV gaming establishment can be fixed or mobile. A fixed class IV gaming establishment is a clearly demarcated permanent establishment where bets are offered. A mobile class IV gaming establishment is a temporary establishment, also clearly demarcated, where bets are offered during and at an event, sports game or sports competition. F2 licences may also be granted to newspaper shops, which can offer bets as an ancillary activity. Betting is offered mainly by class IV gaming establishments, and it requires an F1 or F2 licence(8). i. Class I: for casinos. A casino is a gaming establishment where the operation of games of chance, whether or not automatic, is authorized. Only nine casinos are allowed on the Belgian territory. The Gaming Act lists the territories of the communes/cities where a casino can be operated. A casino operator must hold a class A licence. ii. Class II: for gaming arcades. Gaming arcades are establishments which operate only games of chance authorised by the King of Belgium. The operating rules for the automatic games of chance that can be offered in class II gaming establishments are laid down in a Royal Decree of 8 April 2003. A gaming arcade operator must hold a class B licence and can offer automatic games of chance can be offered mainly by class II establishments with a B licence. iii. Class III: drinking establishments, which provide for games of chance and reduced-stakes automatic games of chance. Drinking establishments such as cafés must hold a class C licence. iv. Class IV: for betting offices. Class IV gaming establishments are places where operators with an F2 licence are exclusively permitted to accept bets on behalf of an F1 licence holder (the organizer of betting activities). Class IV establishments may also offer automatic games of chances under certain conditions. It is prohibited to accept bets outside a class IV gaming establishment. There are, however, a limited number of exceptions to this prohibition. A class IV gaming establishment can be fixed or mobile. A fixed class IV gaming establishment is a clearly demarcated permanent establishment where bets are offered. A mobile class IV gaming establishment is a temporary establishment, also clearly demarcated, where bets are offered during and at an event, sports game or sports competition. F2 licences may also be granted to newspaper shops, which can offer bets as an ancillary activity. Betting is offered mainly by class IV gaming establishments, and it requires an F1 or F2 licence(8).
i. Class I: for casinos. A casino is a gaming establishment where the operation of games of chance, whether or not automatic, is authorized. Only nine casinos are allowed on the Belgian territory. The Gaming Act lists the territories of the communes/cities where a casino can be operated. A casino operator must hold a class A licence.
ii. Class II: for gaming arcades. Gaming arcades are establishments which operate only games of chance authorised by the King of Belgium. The operating rules for the automatic games of chance that can be offered in class II gaming establishments are laid down in a Royal Decree of 8 April 2003. A gaming arcade operator must hold a class B licence and can offer automatic games of chance can be offered mainly by class II establishments with a B licence.
iii. Class III: drinking establishments, which provide for games of chance and reduced-stakes automatic games of chance. Drinking establishments such as cafés must hold a class C licence.
iv. Class IV: for betting offices. Class IV gaming establishments are places where operators with an F2 licence are exclusively permitted to accept bets on behalf of an F1 licence holder (the organizer of betting activities). Class IV establishments may also offer automatic games of chances under certain conditions. It is prohibited to accept bets outside a class IV gaming establishment. There are, however, a limited number of exceptions to this prohibition. A class IV gaming establishment can be fixed or mobile. A fixed class IV gaming establishment is a clearly demarcated permanent establishment where bets are offered. A mobile class IV gaming establishment is a temporary establishment, also clearly demarcated, where bets are offered during and at an event, sports game or sports competition. F2 licences may also be granted to newspaper shops, which can offer bets as an ancillary activity. Betting is offered mainly by class IV gaming establishments, and it requires an F1 or F2 licence(8).
i. Class I: for casinos. A casino is a gaming establishment where the operation of games of chance, whether or not automatic, is authorized. Only nine casinos are allowed on the Belgian territory. The Gaming Act lists the territories of the communes/cities where a casino can be operated. A casino operator must hold a class A licence.
ii. Class II: for gaming arcades. Gaming arcades are establishments which operate only games of chance authorised by the King of Belgium. The operating rules for the automatic games of chance that can be offered in class II gaming establishments are laid down in a Royal Decree of 8 April 2003. A gaming arcade operator must hold a class B licence and can offer automatic games of chance can be offered mainly by class II establishments with a B licence.
iii. Class III: drinking establishments, which provide for games of chance and reduced-stakes automatic games of chance. Drinking establishments such as cafés must hold a class C licence.
iv. Class IV: for betting offices. Class IV gaming establishments are places where operators with an F2 licence are exclusively permitted to accept bets on behalf of an F1 licence holder (the organizer of betting activities). Class IV establishments may also offer automatic games of chances under certain conditions. It is prohibited to accept bets outside a class IV gaming establishment. There are, however, a limited number of exceptions to this prohibition. A class IV gaming establishment can be fixed or mobile. A fixed class IV gaming establishment is a clearly demarcated permanent establishment where bets are offered. A mobile class IV gaming establishment is a temporary establishment, also clearly demarcated, where bets are offered during and at an event, sports game or sports competition. F2 licences may also be granted to newspaper shops, which can offer bets as an ancillary activity. Betting is offered mainly by class IV gaming establishments, and it requires an F1 or F2 licence(8).
(33) The Belgian legislature has set up a closed licensing system. Offering online games of chance and bets requires an online licence (A+ licence for online casinos, B+ licence for online gaming arcades and F1+ licence for online bets).
(34) In addition, an online licence requires a mandatory physical connection to the Belgian territory. Only those operators licenced to operate in the real world (and holding a principal A, B or F1 licence) can obtain a licence to offer the same games of chance and bets online (an ‘additional’ A+, B+ or F1+ online licence).
(35) The Gaming Commission(9)was established by the Gaming Act of 7 May 1999 as a federal supervisor within the Federal Public Service of Justice (formerly, the Ministry of Justice). Its main task is to ensure channeling to legal gaming, with the primary aim of protecting players. The Gaming Commission’s main responsibilities include:—providing advice to the Government and Parliament on all matters related to the Gaming Act;—granting the licences necessary for the operation of games of chance and betting, as well as ensuring their proactive management;—monitoring compliance with the Gaming Act and exercising sanctioning power, which include imposing administrative sanctions (warning, suspension or licence revocation) and administrative fines. — providing advice to the Government and Parliament on all matters related to the Gaming Act; — granting the licences necessary for the operation of games of chance and betting, as well as ensuring their proactive management; — monitoring compliance with the Gaming Act and exercising sanctioning power, which include imposing administrative sanctions (warning, suspension or licence revocation) and administrative fines.
— providing advice to the Government and Parliament on all matters related to the Gaming Act;
— granting the licences necessary for the operation of games of chance and betting, as well as ensuring their proactive management;
— monitoring compliance with the Gaming Act and exercising sanctioning power, which include imposing administrative sanctions (warning, suspension or licence revocation) and administrative fines.
— providing advice to the Government and Parliament on all matters related to the Gaming Act;
— granting the licences necessary for the operation of games of chance and betting, as well as ensuring their proactive management;
— monitoring compliance with the Gaming Act and exercising sanctioning power, which include imposing administrative sanctions (warning, suspension or licence revocation) and administrative fines.
(36) Virtual betting is a game of chance, which has taken shape in Belgium since 2011, whereby players can bet on the outcome of a fictional sport event (e.g. a fictional horse race) and where the results are determined by a random number generator.
(37) Virtual betting combines characteristics of both automatic games of chance and betting. While the outcomes are determined by chance (games of chance), predicting these outcomes may also require some degree of skill (betting).
(38) The Gaming Act does not provide a definition of virtual betting, nor does it consequently foresee a (special) licence for it. It was only that the Gaming Commission first provided an interpretation on how to categorize virtual betting following its appearance in Belgium in 2011, but their interpretation was later annulled by the Council of State(10)on the basis that the Gaming Commission thereby actedultra vires.
(39) The concept of virtual betting was assessed by the Gaming Commission in three ‘Framework Notes’ or ‘memoranda’ (‘omkaderingsnota’ and ‘nota’) dated 12 January 2012(11), 17 April 2013(12)and 1 July 2015(13). They considered virtual betting to be betting on (virtual) events(14). Furthermore, all legal and regulatory obligations applicable to betting also applied to virtual (sporting) betting (for example, recording obligation from EUR 1 000, computer protocol, etc.)(15). Virtual betting was therefore regarded as ‘bets’ which could be exploited by the holders of the F1, F2 and F1+ licences. It follows that the class F1 licence and class F1+ licence holders were allowed to operate online and offline virtual betting only via class IV gaming establishments.
(40) The Gaming Commission’s views on offline and online virtual betting.—As to the offline operation of virtual betting, on 12 January 2012 the Gaming Commission examined in its ‘Framework note on the possibility of betting on virtual events’, ‘whether the amended Gaming Act or its implementing regulations contain legal objections to the organization of betting on virtual (sports) events’. The Gaming Commission concluded that ‘the organization/offer of betting on virtual (sports) events complies with the provisions of the Gaming Act in so far as such betting is considered to be betting on events’. The Gaming Commission stated, among others, that ‘in order to be able to closely monitor this development – which brings additional profitability to the sector in compensation for the investments required as a result of the law on games of chance, its implementing decrees and technical protocols -, […] each F1 [licence holder] wishing to organize such bets should send a prior request for authorisation [“goedkeuring”] to this end to the secretariat of the [Gaming Commission] […].’—As to online virtual betting, the Gaming Commission issued guidelines on it through its internet group website in 2012. For offering online virtual betting, a mere communication to the Gaming Commission from the class F1+ licence holder was sufficient. — As to the offline operation of virtual betting, on 12 January 2012 the Gaming Commission examined in its ‘Framework note on the possibility of betting on virtual events’, ‘whether the amended Gaming Act or its implementing regulations contain legal objections to the organization of betting on virtual (sports) events’. The Gaming Commission concluded that ‘the organization/offer of betting on virtual (sports) events complies with the provisions of the Gaming Act in so far as such betting is considered to be betting on events’. The Gaming Commission stated, among others, that ‘in order to be able to closely monitor this development – which brings additional profitability to the sector in compensation for the investments required as a result of the law on games of chance, its implementing decrees and technical protocols -, […] each F1 [licence holder] wishing to organize such bets should send a prior request for authorisation [“goedkeuring”] to this end to the secretariat of the [Gaming Commission] […].’ — As to online virtual betting, the Gaming Commission issued guidelines on it through its internet group website in 2012. For offering online virtual betting, a mere communication to the Gaming Commission from the class F1+ licence holder was sufficient.
— As to the offline operation of virtual betting, on 12 January 2012 the Gaming Commission examined in its ‘Framework note on the possibility of betting on virtual events’, ‘whether the amended Gaming Act or its implementing regulations contain legal objections to the organization of betting on virtual (sports) events’. The Gaming Commission concluded that ‘the organization/offer of betting on virtual (sports) events complies with the provisions of the Gaming Act in so far as such betting is considered to be betting on events’. The Gaming Commission stated, among others, that ‘in order to be able to closely monitor this development – which brings additional profitability to the sector in compensation for the investments required as a result of the law on games of chance, its implementing decrees and technical protocols -, […] each F1 [licence holder] wishing to organize such bets should send a prior request for authorisation [“goedkeuring”] to this end to the secretariat of the [Gaming Commission] […].’
— As to online virtual betting, the Gaming Commission issued guidelines on it through its internet group website in 2012. For offering online virtual betting, a mere communication to the Gaming Commission from the class F1+ licence holder was sufficient.
— As to the offline operation of virtual betting, on 12 January 2012 the Gaming Commission examined in its ‘Framework note on the possibility of betting on virtual events’, ‘whether the amended Gaming Act or its implementing regulations contain legal objections to the organization of betting on virtual (sports) events’. The Gaming Commission concluded that ‘the organization/offer of betting on virtual (sports) events complies with the provisions of the Gaming Act in so far as such betting is considered to be betting on events’. The Gaming Commission stated, among others, that ‘in order to be able to closely monitor this development – which brings additional profitability to the sector in compensation for the investments required as a result of the law on games of chance, its implementing decrees and technical protocols -, […] each F1 [licence holder] wishing to organize such bets should send a prior request for authorisation [“goedkeuring”] to this end to the secretariat of the [Gaming Commission] […].’
— As to online virtual betting, the Gaming Commission issued guidelines on it through its internet group website in 2012. For offering online virtual betting, a mere communication to the Gaming Commission from the class F1+ licence holder was sufficient.
(41) On 1 July 2015, the Gaming Commission reaffirmed in its ‘Framework note on the possibility of setting up bets on virtual events’ that there were no legal objections to offering bets on virtual events that the Gaming Commission still considered as bets. On 9 September 2015, the Gaming Commission confirmed the position taken in the Framework note of 1 July 2015. It noted that virtual betting was advantageous for the ‘operators’ and decided to set up a subcommittee with the aim to ‘further analyse’ the issue of virtual betting.
(42) Regarding the regulation of online virtual betting, the subcommittee noted ‘first of all, that none of the parties fundamentally objected to the current regulation of online virtual betting by means of the internet group’s guidelines on the subject, which allows the present advice to be limited further to the current regulation of offline betting by means of the note of 1 July 2015.’ Regarding the regulation of offline virtual betting, the subcommittee, as a policy consideration, advised that offline virtual betting should be regulated by way of a Royal Decree as an automatic game of chance, and no longer as betting, and proposed to suspend the Framework note of 1 July 2015.
(43) On 4 May 2018, the Royal Decree on ‘games of chance on virtual sporting events in fixed class IV gaming establishments’(16)(‘the 2018 Royal Decree’) was adopted. It classified virtual betting as an ‘automatic game of chance’ and allowed only existing class IV operators to offer virtual betting in Belgium. Indeed, pursuant to Article 2 of the 2018 Royal Decree, ‘[g]ames of chance on virtual sporting events are automatic games of chance where the stakes of a player or several players in several places can be accepted at the same time for a virtual sports event, the existence of which, the odds associated with the event and the chances of winning are determined by a remote server’. Article 3 provided that ‘[g]ames of chance on virtual sporting events are automatic games of chance authorised in class IV fixed gaming establishments’. Article 4 specified that the number of automatic gaming machines on virtual sports events in class IV fixed gaming establishments is limited to two. Indeed, in light of the Gaming Act(17), the 2018 Royal Decree implements the conditions under which a maximum of two automatic games of chance offering bets on ‘activities similar to those engaged in the betting agency’ (i.e. virtual betting games) may be operated in a fixed class IV gaming establishment(18). According to the 2018 Royal Decree, by explicitly classifying games of chance on virtual sporting events as automatic games of chance in class IV fixed gaming establishments, the essential protection of players is guaranteed. It follows that no authorisation was required to operate virtual betting. Inasmuch as an operator holds a valid F1 or F2 licence and has fixed class IV gaming establishments, the gaming operator can operate a maximum of two virtual betting games in the class IV fixed gaming establishment.
(44) Virtual betting as described by the 2018 Royal Decree (Article 2) needs ‘multiplayer’ gaming machines, which allow multiple players to bet in different betting shops at the same time on the same virtual sports event. As of 30 January 2020, there were at least five operators providing offline virtual betting in Belgium, including Ladbrokes.
(45) The Belgian Council of State retroactively annulled the 2018 Royal Decree on 7 May 2021.
(46) Rocoluc, EAC and The Faculty are linked Belgian companies who also share the same majority owner and the headquarters. Rocoluc is since 2005 owned for 50 % by a physical person and for 50 % by others. EAC is owned in half (50 %) by Rocoluc, and half by others. The Faculty is also headed by the same physical person as a Managing Director since 15 April 2020. The same physical person again owns 99,92 % of the shares in The Faculty.
(47) Rocoluc and EAC are all class II establishments and held offline B and online B+ licences at the time of the submission of the complaint.
(48) By judgment of 25 June 2024, the Council of State declared unlawful the licences of Rocoluc, namely licences B3892 (offline) and B3892 + (online). The litigation on the validity of these licences is still pending(19).
(49) The Faculty is a class III establishment which holds a C licence allowing it to operate a maximum of two automatic gaming machines and a maximum of two machines with reduced stakes in a class III or drinking establishment.
(50) Ladbrokes is a class IV establishment and holds the following licences:—A class F1 licence, with number FA116428, which was granted by the Gaming Commission on 2 February 2011, which allows the operation of a class IV betting establishment.—A class F2 licence, which allows bets to be taken on behalf of the licencee of class F1, in a class IV fixed or mobile gaming establishment. That licence also makes it possible to take bets outside a class IV gaming establishment in the cases referred to in Article 43/4 (1), (5) and (2) of the Gaming Act.—An additional class F1+ licence allowing the exploitation of bets via an information society tools (‘online’) with number FA+116482 granted by the Gaming Commission on 2 April 2014. — A class F1 licence, with number FA116428, which was granted by the Gaming Commission on 2 February 2011, which allows the operation of a class IV betting establishment. — A class F2 licence, which allows bets to be taken on behalf of the licencee of class F1, in a class IV fixed or mobile gaming establishment. That licence also makes it possible to take bets outside a class IV gaming establishment in the cases referred to in Article 43/4 (1), (5) and (2) of the Gaming Act. — An additional class F1+ licence allowing the exploitation of bets via an information society tools (‘online’) with number FA+116482 granted by the Gaming Commission on 2 April 2014.
— A class F1 licence, with number FA116428, which was granted by the Gaming Commission on 2 February 2011, which allows the operation of a class IV betting establishment.
— A class F2 licence, which allows bets to be taken on behalf of the licencee of class F1, in a class IV fixed or mobile gaming establishment. That licence also makes it possible to take bets outside a class IV gaming establishment in the cases referred to in Article 43/4 (1), (5) and (2) of the Gaming Act.
— An additional class F1+ licence allowing the exploitation of bets via an information society tools (‘online’) with number FA+116482 granted by the Gaming Commission on 2 April 2014.
— A class F1 licence, with number FA116428, which was granted by the Gaming Commission on 2 February 2011, which allows the operation of a class IV betting establishment.
— A class F2 licence, which allows bets to be taken on behalf of the licencee of class F1, in a class IV fixed or mobile gaming establishment. That licence also makes it possible to take bets outside a class IV gaming establishment in the cases referred to in Article 43/4 (1), (5) and (2) of the Gaming Act.
— An additional class F1+ licence allowing the exploitation of bets via an information society tools (‘online’) with number FA+116482 granted by the Gaming Commission on 2 April 2014.
(51) On 9 February 2014, Ladbrokes requested by e-mail the Gaming Commission’s view on its plans to proceed with the launch of a new product, betting on virtual sports events (regarding land-based or ‘offline’ virtual betting, i.e. in betting outlets).
(52) On 10 February 2014, an official at the Gaming Commission with no power of representation, replied by way of an e-mail to Ladbrokes: ‘After internal consultation, I can tell you that your project complies with the Gaming Commission's note on offline virtual betting. I can therefore give you the go-ahead for this’.
(53) Following another enquiry by e-mail from Ladbrokes dated 5 March 2015 (regarding online virtual betting), the Gaming Commission confirmed by e-mail on the same day that Ladbrokes could operate online virtual betting.
(54) On 9 September 2015, following reactions received from the sector, the Gaming Commission came to ‘new insights’ as to the classification of virtual betting and set up a sub-commission to investigate whether legal action was required to regulate virtual betting.
(55) In addition, Ladbrokes, two other class IV operators, Stanleybet(20)and Sagevas(21)submitted requests for an authorisation to offer virtual betting to the Gaming Commission in 2015 and 2016.
(56) Specifically, on 28 October 2015, Stanleybet requested ‘authorisation’ to operate virtual betting. The Gaming Commission replied that given the recent establishment of the sub-commission, it would only deal with the request once the results of the activities of the sub-commission were known. Stanleybet submitted a second request on 17 June 2016. The Gaming Commission replied initially the submitted file was incomplete. Then, because of a planned meeting on virtual betting announced for next month, it replied on 3 November 2016 that a regulatory initiative on virtual betting was being discussed.
(57) In 2016, another operator Sagevas also wrote to the Gaming Commission on 23 August 2016. Its request was considered by the Gaming Commission to be incomplete. Later, on 3 November 2016, the same day as to Stanleybet, the Gaming Commission replied to Sagevas along the same line as to Stanleybet that a regulatory initiative on virtual betting was being discussed.
(58) In a report dated January 2016(22), the sub-commission recommended the creation of a specific legal framework for offline virtual betting and the suspension of the Framework note of 1 July 2015. It also recommended the suspension of the ‘authorisation’ granted to Ladbrokes, to take effect as of 1 April 2016, in order to provide for a transitional period in line with usual administrative practices(23).
(59) On 13 January 2016, following the advice of the sub-commission on the need to adapt the regulatory framework, the Gaming Commission adopted a first transitional decision(24), whereby it suspended the 2015 Framework note effectively as from 1 June 2016, along the interpretation of the existing rules in the Gaming Act provided to Ladbrokes (the so-called ‘authorisation’). In its decision to do so, the Gaming Commission stated that ‘the current regulation on virtual offline betting, by means of the note of 1 July 2015, does not provide an adequate Framework for such games.’
(60) On 1 June 2016(25)and on 2 January 2017(26), the Gaming Commission adopted two other transitional decisions delaying the suspension of the Framework note and of Ladbrokes’ right to operate virtual betting until 30 June 2017‘for reasons of legal certainty’.
(61) On 31 May 2017, the Dutch-speaking Court of First Instance of Brussels(27)handed down an interlocutory judgment against the Belgian State, at the request of the complainants. The court considered that virtual betting hadprima faciethe characteristics of both betting and automatic games of chance, without, however, defining virtual betting as falling with certainty under one of these two categories. Subject to a decision on the merits of the case or to the setting-up of a regulatory framework for virtual betting, the court ordered the Belgian State to suspend the ‘authorisation’ granted to Ladbrokes. The Belgian State lodged an appeal against that judgment, which had no suspensory effect. In order to comply with this judgment, the Gaming Commission decided to stop postponing the suspension of the Note of 1 July 2015, which was thus suspended on 1 July 2017.
(62) As a result, no operator, including Ladbrokes, was permitted to provide virtual betting in Belgium.
(63) Notwithstanding that suspension, Ladbrokes did not stop offering virtual betting in its betting outlets. As a result, several gaming operators brought legal proceedings against Ladbrokes to ensure that it would refrain from operating virtual betting machines(28).
(64) In a judgment of 19 September 2019, the Council of State ruled that, through the Framework Note of 1 July 2015, the Gaming Commission ‘allowed, without being empowered, the organisation of [virtual betting], while the Act of 7 May 1999 did not allow it.’ Therefore, the Council of State annulled the three Framework Notes of 12 January 2012, 17 April 2013 and 1 July 2015 and the transitional decision of 2 January 2017, which according to the Council prolonged the effects of the note of 1 July 2015 and in which explicit reference is made to the fact that no request for the operation of virtual betting can be put on the agenda of the Gaming Commission.
(65) Based on the information provided by the complainants, Ladbrokes and the Belgian authorities, in the Opening Decision the Commission assessed the allegations as to a possible aid to Ladbrokes for the alleged exclusive right to operate virtual betting services in Belgium.
(66) The Opening Decision was based on the information at the disposal of the Commission at the moment of its adoption, as provided by the Belgian authorities and third parties. The Commission took the preliminary view that the contested measure may constitute State aid, since it may:—confer Ladbrokes an advantage granted from State resources in the form of ade factoexclusive right to provide virtual betting in Belgium without paying adequate consideration for that right,—be selective, since the contested measure applied only to Ladbrokes,—be imputable to Belgium, since the authorisation granted to Ladbrokes as well as the Framework Note on the basis of which that authorisation was granted were adopted by the Gaming Commission, a public body.—be liable to distort competition and affect trade between Member States, since the aid in question is operating aid that strengthens Ladbrokes’ position as compared to its competitors and gaming is a liberalised, competitive market, with several operators besides Ladbrokes, such as the complainants, active in Belgium, and with Ladbrokes active in several other Member States. — confer Ladbrokes an advantage granted from State resources in the form of ade factoexclusive right to provide virtual betting in Belgium without paying adequate consideration for that right, — be selective, since the contested measure applied only to Ladbrokes, — be imputable to Belgium, since the authorisation granted to Ladbrokes as well as the Framework Note on the basis of which that authorisation was granted were adopted by the Gaming Commission, a public body. — be liable to distort competition and affect trade between Member States, since the aid in question is operating aid that strengthens Ladbrokes’ position as compared to its competitors and gaming is a liberalised, competitive market, with several operators besides Ladbrokes, such as the complainants, active in Belgium, and with Ladbrokes active in several other Member States.
— confer Ladbrokes an advantage granted from State resources in the form of ade factoexclusive right to provide virtual betting in Belgium without paying adequate consideration for that right,
— be selective, since the contested measure applied only to Ladbrokes,
— be imputable to Belgium, since the authorisation granted to Ladbrokes as well as the Framework Note on the basis of which that authorisation was granted were adopted by the Gaming Commission, a public body.
— be liable to distort competition and affect trade between Member States, since the aid in question is operating aid that strengthens Ladbrokes’ position as compared to its competitors and gaming is a liberalised, competitive market, with several operators besides Ladbrokes, such as the complainants, active in Belgium, and with Ladbrokes active in several other Member States.
— confer Ladbrokes an advantage granted from State resources in the form of ade factoexclusive right to provide virtual betting in Belgium without paying adequate consideration for that right,
— be selective, since the contested measure applied only to Ladbrokes,
— be imputable to Belgium, since the authorisation granted to Ladbrokes as well as the Framework Note on the basis of which that authorisation was granted were adopted by the Gaming Commission, a public body.
— be liable to distort competition and affect trade between Member States, since the aid in question is operating aid that strengthens Ladbrokes’ position as compared to its competitors and gaming is a liberalised, competitive market, with several operators besides Ladbrokes, such as the complainants, active in Belgium, and with Ladbrokes active in several other Member States.
(67) On that basis, the Commission preliminarily concluded that Ladbrokes would have enjoyed ade factoexclusive right without paying any specific (licence) fee to provide virtual betting in Belgium during a certain period between 10 February 2014 (i.e. e-mail granting authorisation to operate to Ladbrokes) and 4 May 2018 (i.e. adoption of the 2018 Royal Decree regulating the offline virtual betting and the establishments allowed to operate).
(68) It is noteworthy that some of the facts described in the Opening Decision changed after the adoption of that decision. Following proceedings lodged at national level by the complainants, on 7 May 2021 the Belgian Council of State retroactively annulled the 2018 Royal Decree(29). It found that:—the conditions for operating automatic games of chance on virtual sports events set out in the 2018 Royal Decree were incomplete. Therefore, by allowing, through the transitional regime established by Articles 19 and 20 of the 2018 Royal Decree(30), the operation of Gaming on virtual sports events while all the conditions for its operation had not yet been established, the 2018 Royal Decree violated Article 43/4, § 2, paragraph 3, of the Gaming Act;—no sufficient legal basis allows the King to delegate to the Gaming Commission the power to adopt a protocol (provided for by Article 15 of the 2018 Royal Decree)(31)containing regulatory standards, whether they pertain to detailed or technical matters. Since the annulment of Article 15 alone would result in a revision of the 2018 Royal Decree, as it would leave it in effect without requiring all the operating conditions that the King deems necessary, it was necessary to annul the entire 2018 Royal Decree. — the conditions for operating automatic games of chance on virtual sports events set out in the 2018 Royal Decree were incomplete. Therefore, by allowing, through the transitional regime established by Articles 19 and 20 of the 2018 Royal Decree(30), the operation of Gaming on virtual sports events while all the conditions for its operation had not yet been established, the 2018 Royal Decree violated Article 43/4, § 2, paragraph 3, of the Gaming Act; — no sufficient legal basis allows the King to delegate to the Gaming Commission the power to adopt a protocol (provided for by Article 15 of the 2018 Royal Decree)(31)containing regulatory standards, whether they pertain to detailed or technical matters. Since the annulment of Article 15 alone would result in a revision of the 2018 Royal Decree, as it would leave it in effect without requiring all the operating conditions that the King deems necessary, it was necessary to annul the entire 2018 Royal Decree.
— the conditions for operating automatic games of chance on virtual sports events set out in the 2018 Royal Decree were incomplete. Therefore, by allowing, through the transitional regime established by Articles 19 and 20 of the 2018 Royal Decree(30), the operation of Gaming on virtual sports events while all the conditions for its operation had not yet been established, the 2018 Royal Decree violated Article 43/4, § 2, paragraph 3, of the Gaming Act;
— no sufficient legal basis allows the King to delegate to the Gaming Commission the power to adopt a protocol (provided for by Article 15 of the 2018 Royal Decree)(31)containing regulatory standards, whether they pertain to detailed or technical matters. Since the annulment of Article 15 alone would result in a revision of the 2018 Royal Decree, as it would leave it in effect without requiring all the operating conditions that the King deems necessary, it was necessary to annul the entire 2018 Royal Decree.
— the conditions for operating automatic games of chance on virtual sports events set out in the 2018 Royal Decree were incomplete. Therefore, by allowing, through the transitional regime established by Articles 19 and 20 of the 2018 Royal Decree(30), the operation of Gaming on virtual sports events while all the conditions for its operation had not yet been established, the 2018 Royal Decree violated Article 43/4, § 2, paragraph 3, of the Gaming Act;
— no sufficient legal basis allows the King to delegate to the Gaming Commission the power to adopt a protocol (provided for by Article 15 of the 2018 Royal Decree)(31)containing regulatory standards, whether they pertain to detailed or technical matters. Since the annulment of Article 15 alone would result in a revision of the 2018 Royal Decree, as it would leave it in effect without requiring all the operating conditions that the King deems necessary, it was necessary to annul the entire 2018 Royal Decree.
(69) Following the annulment of the 2018 Royal Decree, the complainants and the Belgian authorities submitted further comments and information described in chapters 3 and 4 below. On that basis, the Commission adopted a Supplementary Opening Decision.
(70) The initial preliminary view of the Commission was that Ladbrokes possibly benefitted from ade factoexclusive right and therefore aid at earliest from 10 February 2014 and at latest until 4 May 2018. The Commission amended this preliminary view by extending the possible duration of the measure in the Supplementary Opening Decision until today.
(71) The Commission found that it would need to investigate whether the implications of the transitional measure included in Articles 19 and 20 of the 2018 Royal Decree preferentially advantaged Ladbrokes, as it was the only operator who could continue exploiting the virtual betting terminals it was operating before the adoption of the 2018 Royal Decree, without having to bring these games into conformity with the protocol to be adopted by the Gaming Commission pursuant to Article 15 of the 2018 Royal Decree (recital 39 of the Supplementary Opening Decision).
(72) Therefore, the Commission’s amended provisional conclusion was that Ladbrokes possibly enjoyed ade factoexclusive right to provide virtual betting in Belgium during a period starting on 10 February 2014 at the earliest (recital 49 of the Supplementary Opening Decision).
(73) It is noteworthy that both in the Opening Decision (recital 60) and the Supplementary Opening Decision (recital 42), the Commission found that the Belgian authorities have not offered any grounds in support of declaring that the contested measure could be compatible with the internal market. Nor did the Commission have any indication that that measure, if it would constitute State aid, could be considered compatible with the internal market.
(74) The complainants Rocoluc and EAC submitted their comments on the Opening Decision on 18 November 2020, while their sister company The Faculty sent its complaint on 23 February 2024. The summary of all three complaints as well as their subsequent additional comments and information provided in the investigation is set out below.
(75) In their submission of 18 November 2020, the complainants Rocoluc and EAC submitted that both Ladbrokes and the Belgian State had been acting to preserve Ladbrokes’s unlawful right to operate virtual betting and to dissuade Rocoluc and EAC from taking action against that unlawful situation.
(76) Rocoluc and EAC claim that the 2018 Royal Decree does not allow class IV operators to lawfully offer virtual betting in Belgium. Accordingly, the 2018 Royal Decree cannot be considered as having put an end to the unlawful State aid. Rocoluc and EAC also provide additional information with regard to the amount of unlawful State aid that the Commission should order the Belgian authorities to recover from Ladbrokes.
(77) In its complaint of 23 February 2024, The Faculty nonetheless points out that, unlike the complaint submitted by Rocoluc and EAC, its complaint is specifically targeted at the aid linked to the offering of the so-called ‘offline’ or ‘land-based’ virtual betting games in Ladbrokes’ betting offices. In addition, The Faculty notes that as an operator of a class III gaming establishment, it cannot be active online and, therefore, has not been negatively affected by the offering of virtual betting games via Ladbrokes’ website(s).
(78) According to the complainants, Ladbrokes obtained anad hocauthorisation outside of the legal framework by means of two e-mails from the Gaming Commission dated 10 February 2014 (for offline virtual betting in Ladbrokes’ betting offices) and 5 March of 2015 (for online virtual betting on Ladbrokes’ website).
(79) In the complainants’ view, the alleged aid at issue involves State resources because thead hocauthorisation in favour of Ladbrokes has been granted free of charge. Hence, the Belgian authorities waived their right to a significant part of State revenues and granted an economic advantage to Ladbrokes. As to the imputability of the alleged aid, the complainants underline that the Gaming Commission is an administrative public authority established within the Federal Public Service for Justice and thus falls under the responsibility of the Minister of Justice.
(80) The complainants bring forward that the exclusive right and the corresponding alleged State aid in relation to the offline virtual betting games was granted on 10 February 2014 because the unlawful Framework Notes of the Gaming Commission were specifically designed to allow Ladbrokes to exclusively operate virtual betting. Accordingly, the basic error of the Gaming Commission was not the refusal to withdraw Ladbrokes’ad hocauthorisation in January 2016 but the initial granting of the authorisation in February 2014.
(81) Moreover, in relation to the end date of the aid, the complainants underline that following the annulment of the 2018 Royal Decree by means of the judgment of the Council of State of 7 May 2021, the 2018 Royal Decree must be regarded as non-existent and cannot be considered as an act allowing the exploitation of virtual betting in Belgium. This also means that the date of 4 May 2018, on which the annulled 2018 Royal Decree was adopted, is no longer relevant to assess the duration of the alleged State aid granted to Ladbrokes.
(82) In that context, the complainants argue that the judgment of the Council of State would confirm that Ladbrokes has in fact benefited from a selective aid measure until at least 7 May 2021 for offline virtual betting. In their view, the Council of State stated that the sole purpose of the transitional measure laid down in Article 19 of the 2018 Royal Decree was to allow the F2 licence holder, meaning Ladbrokes, to resume the exploitation of the virtual betting terminals it was operating before the adoption of the 2018 Royal Decree and not to have to bring these games into conformity with the protocol to be adopted by the Gaming Commission pursuant to Article 15 of the 2018 Royal Decree.
(83) Accordingly, except for Ladbrokes that benefitted from the aforementioned transitional measure, the 2018 Royal Decree stated that no virtual betting could be offered, awaiting the adoption of the protocol. Therefore, in the complainants’ view, the 2018 Royal Decree merely formalised Ladbrokes’de factomonopoly. However, they inform that this position would not have been accepted by the Belgian Council of State. The Council took the view that the transitional measure allowing Ladbrokes to offer virtual betting games before virtual betting has been finally legally regulated with the adoption of the legal act, which will lay down the necessary conditions of virtual betting (among others where it can be offered), would not be in line with the Gaming Act.
(84) The Faculty also argues that several gaming operators have successfully brought proceedings against the Belgian State and/or Ladbrokes. It cites a judgment of 28 March 2018 in which the Brussels Commercial Court decided in favour of the Belgian professional federation of pub owners (La Fédération des cafés de BelgiqueASBL) and ordered Ladbrokes to cease its offline virtual betting activities. According to The Faculty, this judgment was later confirmed by the Court of Appeal by means of a judgment of 9 August 2019.
(85) Firstly, as regards the applicable legal framework, Rocoluc and EAC underline that virtual betting is a ‘hybrid’ game of chance that is at the interference between betting and automatic games of chance. In that context, they cite the statement of the submission by the Belgian authorities according to which it is ‘not easy to classify[this hybrid product]within the existing legal Framework of the Gaming Act’.
(86) They reiterate that the alleged exclusive right granted to Ladbrokes was manifestly unlawful under Belgian law as it was based on an erroneous qualification of virtual betting.
(87) Secondly, they argue that the doubts cast by the Belgian authorities as to the legal value of the Framework Notes adopted by the Gaming Commission (recital 49 of the Opening Decision) are particularly appropriate. In particular, they point out that in the context of the ongoing proceedings before the national courts, the Belgian authorities have unequivocally confirmed that the authorisation granted to Ladbrokes to operate virtual betting in Belgium was not a ‘traditional’ gaming licence but an ‘ad hoc’ authorisation and that virtual betting is an activity ‘not regulated by the Gaming Act’. In their view, this statement clearly refutes the reasoning that Ladbrokes’ authorisation to offer virtual betting was based on and formed part of the national reference system on betting. In addition, they underline that the doubts expressed by the Belgian authorities cannot be reconcile with the fact that the Gaming Commission imposed a temporary suspension of Ladbrokes’ licence for not ceasing to provide virtual betting after 1 July 2017. They also argue that in a judgment of 19 September 2019, the Council of State ruled that the Gaming Act would not allow the organisation of virtual betting and therefore annulled the Framework Notes.
(88) Thirdly, they note that the questions as to the publicity of the Framework Notes referred to in the Opening Decision, footnotes 5 to 7 and recital 49 have already been settled in the context of the annulment proceedings against these Framework Notes before the Belgian Council of State. In the context of these proceedings, Rocoluc would have demonstrated that the initial Framework Notes dated 12 January 2012 and 17 April 2013 have not been made public but were only communicated to Rocoluc on 14 April 2017 in the context of the legal proceedings against the Belgian State. Allegedly, the Gaming Commission did not question these findings. The Council of State accordingly decided that Rocoluc could extend its action to these Framework Notes.
(89) Fourthly, they put forward that even though the 2018 Royal Decree was adopted in an attempt to remediate the illegal character of virtual betting, the Gaming Commission had still not adopted the protocol with ‘the necessary technical requirements on games of chance on virtual sporting events’ provided in Article 15 of the 2018 Royal Decree.
(90) In this context, Rocoluc and EAC argue that contrary to what the Commission seems to suggest (recital 21 of the Opening Decision), the national legal proceedings on the legality of the Framework Notes were not linked to the effective suspension of the Framework Notes and of Ladbrokes’ad hocauthorisation to operate virtual betting on 1 July 2017. They also inform on Stanleybet’s damages claim file against the Belgian State on 14 December 2016. following which the Court ordered the Belgian State to compensate Stanleybet for the damages suffered.
(91) The complainants also informed the Commission services that on 28 March 2017, Rocoluc and EAC also initiated damages claim against the Belgian authorities. The proceedings would still be pending due to backlog at the Brussels Court of Appeal.
(92) Further, they explain that the appeal brought by Ladbrokes against the cease and-desist order of 15 February 2018 is still pending before the Brussels Court of Appeal. The Brussels Court of Appeal did however render a judgment to Ladbrokes’ appeal against the decision of the Brussels Commercial Court of 28 March 2018. In its judgment of 9 August 2019, the Court of Appeal rejected Ladbrokes appeal and confirmed the previous order issued against Ladbrokes to cease virtual betting activities. Rocoluc and EAC have however been informed that Fédération des Cafés de Belgique ASBL(32)(hereinafter, ‘FedCaf’) and the Belgian authorities would have concluded an agreement whereby the latter would refrain from taking further action against Ladbrokes.
(93) Finally, Rocoluc reiterates its position that the 2018 Royal Decree ignores the hybrid character of virtual betting and that the transitional provision laid down in Article 19 of the 2018 Royal Decree illegitimately rewards Ladbrokes for not having halted the illegal exploitation of virtual betting in due time and guarantees that Ladbrokes can further benefit from its ad hoc authorisation.
(94) Rocoluc and EAC consider that the exclusive right and the corresponding alleged State aid granted to Ladbrokes would have been granted on 10 February 2014. They recall that, from the very beginning, the Framework Notes, which they consider to be unlawful, were designed to allow Ladbrokes to exclusively operate virtual betting in Belgium. The Framework Notes of 2012 and 2013 would have been adopted following a request from Ladbrokes and not made public. It was only with the announcement in September 2015 in relation to the setting-up of a special sub-commission that other gaming operators were informed about the unlawful Framework on virtual betting.
(95) In the complainants’ view, once the other operators were informed about the possibilities to offer virtual betting, the Gaming Commission denied other operators to operate virtual betting. In particular, according to the complainants, Stanleybet’s request for authorisation submitted on 28 October 2015 remained unanswered, whereas on 10 February 2014 and 5 March 2015 Ladbrokes had received a confirmation to provide land-based and online virtual betting in less than one day. They claim there is no objective justification for this different treatment.
(96) In response to the Commission’s finding that the exclusive right ended on 4 May 2018, at the latest, or 1 July 2017, at the earliest (recital 55 of the Opening Decision), Rocoluc and EAC consider that the date of 4 May 2018 (i.e. the date of the adoption of the 2018 Royal Decree) has not put an end to the preferential treatment of Ladbrokes and can therefore not be considered as the date on which Ladbrokes would no longer have benefitted from unlawful State aid.
(97) In addition, they reiterate that the Gaming Commission did not adopt the protocol provided in Article 15 of the 2018 Royal Decree with ‘the necessary technical requirements on games of chance on virtual sporting events’, meaning that any operation of virtual betting was to be considered as unlawful until then. In the absence of general, clear and transparent criteria, the Belgian authorities necessarily would have a wide margin of discretion when authorising and controlling virtual betting in Belgium. As a result, even if Ladbrokes is currently no longer the only operator offering virtual betting in Belgium, the Belgian State’s tolerance towards virtual betting services offered by one (or several) operators would still constitute a selective State aid granted to that (those) operator(s).
(98) Rocoluc and EAC consider that the Commission would be in a position to exactly identify the amount of aid received by Ladbrokes and therefore invite the Commission to determine itself the amount of the aid and the interest to be recovered by the Belgian authorities.
(99) The complainants provide a table with estimations on the aid that Ladbrokes allegedly received based on the 2017 gross gaming revenue in Ladbrokes’ betting offices. The complainants argue that reference can be made to the consideration paid by the National Lottery in exchange for the exclusive right to operate lottery games.
(100) After the adoption of the Opening Decision, on 26 May 2021 the Commission received further submissions from the complainants, informing the Commission that on 7 May 2021 the 2018 Royal Decree has been retroactively annulled (meaning that it should be considered as non-existent) and it cannot be considered as having put an end to the alleged aid granted to Ladbrokes.
(101) As regards the duration of the alleged aid, the complainants consider that, following the judgment of the Council of State of 7 May 2021, the 2018 Royal Decree would be regarded as non-existent in Belgian law and can therefore not be considered as an act allowing the exploitation of virtual betting in Belgium. This also means that the date of 4 May 2018, on which the annulled 2018 Royal Decree was adopted, is no longer relevant to assess the duration of the alleged State aid granted to Ladbrokes.
(102) In addition, the complainants put forward that the aforementioned judgment of the Council of State would confirm that Ladbrokes has benefited from a selective aid measure until at least 7 May 2021. In their view, the Belgian authorities would still tolerate Ladbrokes` virtual betting activities while those activities are illegal under Belgian law.
(103) The complainants consider that the Council of State’s judgment of 7 May 2021 would confirm that the sole purpose of the transitional measure laid down in Article 19 of the 2018 Royal Decree was to allow ‘the F2 licence holder’(33), meaning Ladbrokes, to resume the exploitation of the virtual betting terminals it was operating before the adoption of the 2018 Royal Decree and not to have to bring these games into conformity with the protocol to be adopted by the Gaming Commission pursuant to Article 15 of the 2018 Royal Decree.
(104) In the meeting held with the Commission services on 23 February 2023, the complainants EAC and Rocoluc reiterated the request for a corrective opening decision extending the duration of the alleged aid. In particular, they claimed that the retroactive annulment of the 2018 Royal Decree constitutes a substantial change. Accordingly, the relevant investigated period should be extended: (i) until 7 May 2021 for offline virtual betting, since no operators are allowed to operate nor actually operate offline virtual betting after this date, and (ii) indefinitely for online virtual betting, because even though it is currently not allowed, Ladbrokes is still offering online virtual betting.
(105) According to the complainants, the annulment of the 2018 Royal Decree, which only regulated offline virtual betting, must be considered as having the same implications for online virtual betting. However, despite the 2018 Royal Decree being annulled, Ladbrokes was still offering online virtual betting.
(106) On 23 February 2024 the Commission received a submission from The Faculty, which holds a class III with a licence C. The submission concerns the same contested measure but exclusively relating to the alleged aid linked to the offering of offline virtual betting games in Ladbrokes’ betting offices. Indeed, The Faculty argued that as an operator of a class III gaming establishment, it cannot be active online and, therefore, has not been negatively affected by the offering of virtual betting games via Ladbrokes` website(s).
(107) As a preliminary comment, Rocoluc and EAC point to a material error in the Supplementary Opening Decision Commission recitals 8 and 24, wrongly stating that the complainants and the Commission would have- held a meeting on 23 February 2023 instead on 16 February 2023.
(108) Second, as regards the definition of virtual betting, Rocoluc and EAC refer to their complaint of 1 March 2019 where they explained that virtual betting concerns a ‘hybrid’ product that takes place at the interface between real betting and automatic games of chance. Although the Belgian authorities would have explicitly confirmed that virtual betting is indeed a hybrid product, they would in fact always have denied the hybrid character of virtual betting.
(109) According to the complainants, in the context of the Framework Notes of the Gaming Commission, virtual betting was wrongfully equated with real betting, whereas in the 2018 Royal Decree it was (re)qualified as an automatic game of chance.
(110) Third, Rocoluc and EAC reiterate their comments in relation to the assessment of the duration of the unlawful State aid granted to Ladbrokes by referring to their submission of 18 November 2020.
(111) In this context, Rocoluc and EAC underlined that the alleged ‘uncertainty’ in relation to the legal framework applicable to virtual betting is solely fuelled by the Belgian State (see recitals 58-60).
(112) As for online virtual betting, Rocoluc and EAC recall that, under Article 43/8 of the Gaming Act, so-called supplementary A+, B+ or F1+ licences for online games of chance can only be granted for the operation of games of the same nature as those offered in the real world. They argue that in view of this provision, the Belgian State has previously held that Ladbrokes’ ad hoc authorisation for online virtual betting was linked to its authorisation for offline virtual betting. Accordingly, in so far as Ladbrokes would have been the only operator to have obtained anad hocauthorisation for the operation of virtual betting in its betting offices by the Belgian authorities, it would also be the only operator that could provide online virtual betting and the only operator that would actually have received an unlawfulad hocauthorisation for online virtual betting by e-mail of 5 March 2015. This preferential treatment would have logically persisted under the 2018 Royal Decree. Afterwards, despite the annulment of the 2018 Royal Decree, Ladbrokes is still offering online virtual betting. Consequently, Ladbrokes would still benefit from unlawful State aid with regard to online virtual betting.
(113) In its submission dated 18 December 2020, Ladbrokes provides comments on the Opening Decision. In the additional submissions of 22 November 2024, 9 December 2024 and 21 January 2025, it provided further comments.
(114) Ladbrokes reports that the Council of State, by judgment of 25 June 2024(34)declared unlawful the licences of Rocoluc, namely licences B3892 (offline) and B3892 + (online). In its view, the Council of State could only annul the abovementioned licences with retroactive effect.
(115) Therefore, according to Ladbrokes, Rocoluc would no longer have an interest in the present proceedings, since it is not and cannot be active in the gaming sector under Belgian law. Rocoluc could therefore not be regarded as a complainant active in the gaming sector, or at least as a legitimate competitor of Ladbrokes. Hence it would not be an ‘interested party’ within the meaning of Article 24(2) of Council Regulation (EU) 2015/1589(35).
(116) Ladbrokes stresses that it held and still holds all required classes of licences granted by the Gaming Commission, meaning F1, F1+ and several class F2 licences, allowing it to accept bets and to organize and offer bets in Belgium, both online and offline. In addition, Ladbrokes informs that at the time there were thirty-five F1 licence holders in Belgium.
(117) As to the online virtual betting, in Ladbrokes’ view, a notification to the Gaming Commission from the class F1+ licence holder was sufficient. Ladbrokes states that this explains why in February 2014 a Gaming Commission, official with no power of representation confirmed by way of a short e-mail that Ladbrokes could start offline betting on virtual events and asked for further reporting on the activity.
(118) Ladbrokes also states that for the same reason on 5 March 2015, again a Gaming Commission official with no power of representation confirmed to Ladbrokes, by way of a short e-mail, that it could offer virtual bets online via its website.
(119) Ladbrokes puts forward that the Gaming Commission would not be competent to change the applicable regulation by means of a Royal Decree, which can only be proposed and countersigned by the competent Minister.
(120) Ladbrokes explained that on 1 June 2016, the Gaming Commission changed its position. The Gaming Commission (i) confirmed that class F1 licence holders may file a new application to offer virtual betting, subject to the conditions set out in the earlier Note of 1 July 2015; (ii) decided to suspend the Framework Note of 1 July 2015 and the granted approvals as from the entry into force of the 2018 Royal Decree, and (iii) as long as this entry into force was expected on 1 January 2017, decided to postpone the date of the suspension of the said Note until 1 January 2017.
(121) On 2 January 2017, the Gaming Commission postponed again the entry into force of the suspension of the Note of 1 July 2015, this time to 30 June 2017.
(122) The Gaming Commission also decided that ‘no new authorisation to operate will be put on the agenda’. Ladbrokes informs that on 27 July 2018 the Gaming Commission sanctioned Ladbrokes by a decision, which suspended Ladbrokes’ FA116428 licence and the FA + 116428 licence for a period of one day, on 3 September 2018.
(123) Ladbrokes further claims that the question of the lawfulness of the operation of virtual betting as ‘betting’ remains open. In its view, the argument that it would indeed be ‘betting’, the exploitation of which is covered by the F1, F2 and F1 + licences, would retain all its merits. But the question would still be pending before the national court, which has not yet ruled on the matter.
(124) As a preliminary observation, Ladbrokes refers to the Opening Decision in which the Commission states that ‘the exercise of Ladbrokes’de factoexclusive right had begun: ‘not earlier than 10 February 2014, the date on which the Belgian Gaming Commission (…) granted Ladbrokes, by e-mail, the right to operate virtual offline betting (recital 53 of the Opening Decision) (…)’.
(125) Ladbrokes argues that this sentence is factually incorrect, in two respects. First, the Gaming Commission would not have granted Ladbrokes any rights. It only confirmed that the licences already held by Ladbrokes allowed the exploitation of virtual betting. Second, the e-mail message of the Gaming Commission on 10 February 2014 does not refer to exclusivity. While Ladbrokes, as the holder of licences F1, F1+ and F2, had the possibility to offer virtual betting, the same applied to the other holders of such valid licences. The fact that no other F1 licensee asked the Gaming Commission to operate virtual betting does not provide for exclusive rights to Ladbrokes.
(126) Further, Ladbrokes notes that the Gaming Commission is only authorized to deliver specific classes of licences to operate games of chance / betting in conformity with the Gaming Act. The Gaming Commission is not allowed by the Gaming Act to enact guidance with a binding effect of general application. Ladbrokes explained that it requested guidance from the Gaming Commission about a planned new activity, betting on virtual events, as early as 2011, as this is good practice in a regulated industry.
(127) Since virtual betting was considered to be betting and all legal and regulatory obligations applicable to betting are declared applicable to virtual betting, no specific licence or authorisation had to be provided for their exploitation. The exploitation of virtual betting was already covered by licences F1, F2 and F1 +. The Gaming Commission therefore did not grant Ladbrokes a licence for virtual betting.
(128) The e-mails sent by the Gaming Commission on 10 February 2014 and on 5 March 2015, were a confirmation that Ladbrokes could operate because it held the relevant licences. At any case, these e-mails, sent by a Gaming Commission’s official with no power of representation, could not be considered as a formal authorisation as they are neither foreseen within the framework of the Gaming Act, nor do they have any other legal basis. At most they could be seen as a mere recognition by the Gaming Commission that the envisaged activity was within the scope of the F1 licence already held by Ladbrokes and was therefore legal.
(129) Ladbrokes puts forward that with the aforementioned confirmative e-mails the Gaming Commission had no intention to grant Ladbrokes an exclusivity of any kind. In its view, an exclusivity would run counter to the Belgian authorities’ policy aim of ‘channelling’. With the exception of theLoterie Nationale(a company entirely held by the Belgian State), the Belgian authorities would strive to satisfy customers’ demands by having a multiplicity of regulated operators competing for that demand. Moreover, Ladbrokes refers to the Framework Notes of the Gaming Commission confirming the legality of betting on virtual events for every holder of an F1 Licence dated 12 January 2012, 17 April 2013 and 1 July 2015. All these operators could have started a virtual betting activity, none did at the time, presumably because of the size of the investments and the business risk.
(130) Moreover, as from 13 January 2016 (date of the decision to suspend the Framework Note of 1 July 2015), the ‘authorisation’ of Ladbrokes was suspended. Accordingly, Ladbrokes was supposed to effectively stop offering virtual betting from 1 June 2016, which date was later modified to 30 June 2017. Ladbrokes argues in that context that it had to operate under the uncertainty of having to stop at any time. There could therefore be no clearer confirmation that Ladbrokes was not granted any exclusivity.
(131) Ladbrokes pointed out that in 2015 and in 2016, two competitors, i.e. Stanleybet and Sagevas, choose to ask for such an ‘authorisation’ i.e. announced that they would offer virtual betting. According to Ladbrokes, the request filed by Stanleybet was deemed to be incomplete by the Gaming Commission. As for Sagevas, it made it public that it would operate the virtual betting without any ‘authorisation’ from the Gaming Commission knowing that there would be no control. In Ladbroke’s view, the Gaming Commission expressly reported this declaration in its note of 2 January 2017, without announcing that there would be no enforcement actions. The mere fact that these requests were filed would show that all class F1 licence holders fully understood that the operation of virtual betting was open to all class F1 licence holders and that no operators considered that Ladbrokes was granted exclusive rights.
(132) In addition, Tiercé Ladbrokes SA, an Entain’s subsidiary in Belgium, as Ladbrokes is, also started offering virtual betting in the bet shops it operated at the same time than Ladbrokes did. Tiercé Ladbrokes did not receive any ‘authorisation’ from the Gaming Commission. Tiercé Ladbrokes is a different legal entity and given the formality that characterizes the sector-specific regulation (if an ‘authorisation’ or licence is awarded, it is always to a specific legal entity), this fact also shows that Ladbrokes was not granted any exclusivity.
(133) Ladbrokes further clarifies that contrary to the Commission’s preliminary findings (recital 54 of the Opening Decision), it is only in January 2017 that the Gaming Commission reversed its policy and decided not to grant any new ‘authorisation’, since the government was preparing a Royal Decree setting up conditions governing virtual betting.
(134) Ladbrokes sustains that from a legal viewpoint, the decision of the Gaming Commission to stop granting ‘authorisations’ for virtual betting had no legal consequence. Namely, the ‘authorisations’ that the Gaming Commission suspended were only foreseen by the Gaming Commission’s as interpretative guidance, but they had no binding value, since in any event the Gaming Commission cannot adopt mandatory and enforceable rules of general application.
(135) Therefore, despite this change of policy, holders of class F1 licences could have proposed virtual betting to their customers under the scope of such licences. They could have fended off possible legal challenges with the argument that they were entitled to propose betting on virtual events, as was the Gaming Commission’s own view until 2016, by the mere combination of their existing licence and Article 4 of the Gaming Act. That is exactly what Ladbrokes did as from 1 July 2017. It pursued the operation of virtual betting under the benefit of its F licences alone. Sagevas declared in 2016-2017 it would also operate virtual betting without any authorisation from the Gaming Commission. The exact reason why it did not do so in the end is not known to Ladbrokes.
(136) Here again, the fact that competitors did not start virtual betting operations after January 2017 is a consequence:—of the Gaming Commission’s decision not to assess any new application for ‘authorisation’, pending the adoption of the 2018 Royal Decree (that everybody thought imminent, which was ultimately proved to be wrong), and,—of the decision of these two operators not to challenge this change of policy or to operate the activity under the benefit of their licence alone. — of the Gaming Commission’s decision not to assess any new application for ‘authorisation’, pending the adoption of the 2018 Royal Decree (that everybody thought imminent, which was ultimately proved to be wrong), and, — of the decision of these two operators not to challenge this change of policy or to operate the activity under the benefit of their licence alone.
— of the Gaming Commission’s decision not to assess any new application for ‘authorisation’, pending the adoption of the 2018 Royal Decree (that everybody thought imminent, which was ultimately proved to be wrong), and,
— of the decision of these two operators not to challenge this change of policy or to operate the activity under the benefit of their licence alone.
— of the Gaming Commission’s decision not to assess any new application for ‘authorisation’, pending the adoption of the 2018 Royal Decree (that everybody thought imminent, which was ultimately proved to be wrong), and,
— of the decision of these two operators not to challenge this change of policy or to operate the activity under the benefit of their licence alone.
(137) Ladbrokes claims that it effectively faced competition. It provided information, gathered from written pleadings and web searches, with regard to virtual betting services.
(138) Ladbrokes claims that online activity represents significant competition to Ladbrokes` offline activity, acknowledged by the Commission in its Decision for Online Gaming in the Danish Gaming Duties Act(36)in which the Commission concluded that ‘online and land-based casinos should be perceived as legally and factually comparable. As both online and land-based gaming pose the same risks, the notified measure addresses both online and land-based gaming’.
(139) Ladbrokes submits factual evidence on the existence of several operators offering virtual betting online. In particular, its submission includes screenshots of the websites operated by several betting operators in Belgium. There was an offer by the operator BetFirst.be, which provided different kinds of virtual betting for events such as sports and other events in December 2014. Other evidence shows the screenshots of the online offer for virtual betting events of several other operators:—the website Circus(37)offered ‘Virtual Sports Events’, with a clear indication of virtual betting under ‘sports betting’, as a clear counterpart of ‘live betting’.—the website Golden Vegas(38)offered virtual betting.—the website Bingoal!(39)offered as well ‘virtueel’ in Dutch in the form of ‘virtual football’, ‘virtual horse racing’, ‘virtual tennis’ and ‘virtual dog running’.—the website 36win(40)offered ‘virtual’. — the website Circus(37)offered ‘Virtual Sports Events’, with a clear indication of virtual betting under ‘sports betting’, as a clear counterpart of ‘live betting’. — the website Golden Vegas(38)offered virtual betting. — the website Bingoal!(39)offered as well ‘virtueel’ in Dutch in the form of ‘virtual football’, ‘virtual horse racing’, ‘virtual tennis’ and ‘virtual dog running’. — the website 36win(40)offered ‘virtual’.
— the website Circus(37)offered ‘Virtual Sports Events’, with a clear indication of virtual betting under ‘sports betting’, as a clear counterpart of ‘live betting’.
— the website Golden Vegas(38)offered virtual betting.
— the website Bingoal!(39)offered as well ‘virtueel’ in Dutch in the form of ‘virtual football’, ‘virtual horse racing’, ‘virtual tennis’ and ‘virtual dog running’.
— the website 36win(40)offered ‘virtual’.
— the website Circus(37)offered ‘Virtual Sports Events’, with a clear indication of virtual betting under ‘sports betting’, as a clear counterpart of ‘live betting’.
— the website Golden Vegas(38)offered virtual betting.
— the website Bingoal!(39)offered as well ‘virtueel’ in Dutch in the form of ‘virtual football’, ‘virtual horse racing’, ‘virtual tennis’ and ‘virtual dog running’.
— the website 36win(40)offered ‘virtual’.
(140) Ladbrokes provides copies of several tickets for virtual sports betting bought for different amounts and which gained different amounts at the physical offices of another operator Stanleybet in April, September, and October 2019. It is visible from the copies that the tickets were issued by Stanleybet in Belgium and have different serial numbers, while all of them are issued for virtual sports (betting).
(141) Ladbrokes also provided the photographs of different screens taken in the offices of Stanleybet. The screens show that the betting took place in April 2019 in one of Stanleybet’s offices in Belgium. They also clearly show that the game played was virtual sports betting.
(142) Ladbrokes argues in the alternative, assuming that Ladbrokes was granted an exclusivity (quod non), that the period during which Ladbrokes could enjoy this was shorter than the Commission states, as Ladbrokes faced several legal challenges to its activity. This is because the Gaming Commission only decided to suspend the analysis of the ‘authorisation’ requests of competitors on 2 January 2017
(143) As the ‘authorisation’ granted to Ladbrokes itself was also suspended with effect on 1 July 2017, there can also be no ‘exclusivity’ granted by the Belgian authorities to Ladbroke after that date. The fact that the Belgian State did not initiate legal proceedings against Ladbrokes after 1 July 2017 in order to have the activity stopped does not amount to the granting of an ‘exclusivity’ with a market value.
(144) Ladbrokes informs that it stopped offering virtual betting on 30 March 2018, to comply with an injunction of the Brussels Commercial Court requested byFédération des cafés de Belgique, which was served.
(145) Finally, Ladbrokes also puts forward that there would be no reason to extend the period of the alleged aid measures (see recitals 38-40 in the Supplementary Opening Decision).
(146) In the alternative, even assuming that Ladbrokes was granted an exclusivity (quod non), the profit generated by this would be significantly lower than what the Commission stated in the Opening Decision (footnote 26). Ladbrokes provides the following gross profit figures for offline and online virtual betting for the period January to June 2017:(a)the gross profit figures of the offline virtual betting activity of Ladbrokes SA from January to June 2017:LADBROKESJAN – JUN2017JANFEBMARAPRMAYJUNGGR10 391 8081 771 4591 664 1381 820 4291 358 9821 733 6872 043 114Tax-1 558 771- 265 719- 249 621- 273 064- 203 847- 260 053- 306 467RevenueShare- 556 384-91 688-86 095-94 288-70 394-89 536- 124 383Commission-1 141 556- 172 630- 162 831- 171 484- 207 163- 233 776- 193 672Gross Profit7 135 0961 241 4231 165 5911 281 592877 5781 150 3211 418 592(b)the gross profit figures for online virtual betting on the website Ladbrokes.be, from January to June 2017:JAN-JUN2017JANFEBMARAPRMAYJUNGGR182 53933 87521 43518 19938 20435 07535 750Tax-20 079-3 726-2 358-2 002-4 202-3 858-3 932Commission-11 044-2 049-1 297-1 101-2 311-2 122-2 163Gross Profit151 41628 09917 78115 09631 69129 09529 654 (a) the gross profit figures of the offline virtual betting activity of Ladbrokes SA from January to June 2017:LADBROKESJAN – JUN2017JANFEBMARAPRMAYJUNGGR10 391 8081 771 4591 664 1381 820 4291 358 9821 733 6872 043 114Tax-1 558 771- 265 719- 249 621- 273 064- 203 847- 260 053- 306 467RevenueShare- 556 384-91 688-86 095-94 288-70 394-89 536- 124 383Commission-1 141 556- 172 630- 162 831- 171 484- 207 163- 233 776- 193 672Gross Profit7 135 0961 241 4231 165 5911 281 592877 5781 150 3211 418 592 LADBROKES JAN – JUN2017 JAN FEB MAR APR MAY JUN GGR 10 391 808 1 771 459 1 664 138 1 820 429 1 358 982 1 733 687 2 043 114 Tax -1 558 771 – 265 719 – 249 621 – 273 064 – 203 847 – 260 053 – 306 467 RevenueShare – 556 384 -91 688 -86 095 -94 288 -70 394 -89 536 – 124 383 Commission -1 141 556 – 172 630 – 162 831 – 171 484 – 207 163 – 233 776 – 193 672 Gross Profit 7 135 096 1 241 423 1 165 591 1 281 592 877 578 1 150 321 1 418 592 (b) the gross profit figures for online virtual betting on the website Ladbrokes.be, from January to June 2017:JAN-JUN2017JANFEBMARAPRMAYJUNGGR182 53933 87521 43518 19938 20435 07535 750Tax-20 079-3 726-2 358-2 002-4 202-3 858-3 932Commission-11 044-2 049-1 297-1 101-2 311-2 122-2 163Gross Profit151 41628 09917 78115 09631 69129 09529 654 JAN-JUN2017 JAN FEB MAR APR MAY JUN GGR 182 539 33 875 21 435 18 199 38 204 35 075 35 750 Tax -20 079 -3 726 -2 358 -2 002 -4 202 -3 858 -3 932 Commission -11 044 -2 049 -1 297 -1 101 -2 311 -2 122 -2 163 Gross Profit 151 416 28 099 17 781 15 096 31 691 29 095 29 654
(a) the gross profit figures of the offline virtual betting activity of Ladbrokes SA from January to June 2017:LADBROKESJAN – JUN2017JANFEBMARAPRMAYJUNGGR10 391 8081 771 4591 664 1381 820 4291 358 9821 733 6872 043 114Tax-1 558 771- 265 719- 249 621- 273 064- 203 847- 260 053- 306 467RevenueShare- 556 384-91 688-86 095-94 288-70 394-89 536- 124 383Commission-1 141 556- 172 630- 162 831- 171 484- 207 163- 233 776- 193 672Gross Profit7 135 0961 241 4231 165 5911 281 592877 5781 150 3211 418 592 LADBROKES JAN – JUN2017 JAN FEB MAR APR MAY JUN GGR 10 391 808 1 771 459 1 664 138 1 820 429 1 358 982 1 733 687 2 043 114 Tax -1 558 771 – 265 719 – 249 621 – 273 064 – 203 847 – 260 053 – 306 467 RevenueShare – 556 384 -91 688 -86 095 -94 288 -70 394 -89 536 – 124 383 Commission -1 141 556 – 172 630 – 162 831 – 171 484 – 207 163 – 233 776 – 193 672 Gross Profit 7 135 096 1 241 423 1 165 591 1 281 592 877 578 1 150 321 1 418 592
LADBROKES JAN – JUN2017 JAN FEB MAR APR MAY JUN
GGR 10 391 808 1 771 459 1 664 138 1 820 429 1 358 982 1 733 687 2 043 114
Tax -1 558 771 – 265 719 – 249 621 – 273 064 – 203 847 – 260 053 – 306 467
RevenueShare – 556 384 -91 688 -86 095 -94 288 -70 394 -89 536 – 124 383
Commission -1 141 556 – 172 630 – 162 831 – 171 484 – 207 163 – 233 776 – 193 672
Gross Profit 7 135 096 1 241 423 1 165 591 1 281 592 877 578 1 150 321 1 418 592
(b) the gross profit figures for online virtual betting on the website Ladbrokes.be, from January to June 2017:JAN-JUN2017JANFEBMARAPRMAYJUNGGR182 53933 87521 43518 19938 20435 07535 750Tax-20 079-3 726-2 358-2 002-4 202-3 858-3 932Commission-11 044-2 049-1 297-1 101-2 311-2 122-2 163Gross Profit151 41628 09917 78115 09631 69129 09529 654 JAN-JUN2017 JAN FEB MAR APR MAY JUN GGR 182 539 33 875 21 435 18 199 38 204 35 075 35 750 Tax -20 079 -3 726 -2 358 -2 002 -4 202 -3 858 -3 932 Commission -11 044 -2 049 -1 297 -1 101 -2 311 -2 122 -2 163 Gross Profit 151 416 28 099 17 781 15 096 31 691 29 095 29 654
JAN-JUN2017 JAN FEB MAR APR MAY JUN
GGR 182 539 33 875 21 435 18 199 38 204 35 075 35 750
Tax -20 079 -3 726 -2 358 -2 002 -4 202 -3 858 -3 932
Commission -11 044 -2 049 -1 297 -1 101 -2 311 -2 122 -2 163
Gross Profit 151 416 28 099 17 781 15 096 31 691 29 095 29 654
(a) the gross profit figures of the offline virtual betting activity of Ladbrokes SA from January to June 2017:LADBROKESJAN – JUN2017JANFEBMARAPRMAYJUNGGR10 391 8081 771 4591 664 1381 820 4291 358 9821 733 6872 043 114Tax-1 558 771- 265 719- 249 621- 273 064- 203 847- 260 053- 306 467RevenueShare- 556 384-91 688-86 095-94 288-70 394-89 536- 124 383Commission-1 141 556- 172 630- 162 831- 171 484- 207 163- 233 776- 193 672Gross Profit7 135 0961 241 4231 165 5911 281 592877 5781 150 3211 418 592 LADBROKES JAN – JUN2017 JAN FEB MAR APR MAY JUN GGR 10 391 808 1 771 459 1 664 138 1 820 429 1 358 982 1 733 687 2 043 114 Tax -1 558 771 – 265 719 – 249 621 – 273 064 – 203 847 – 260 053 – 306 467 RevenueShare – 556 384 -91 688 -86 095 -94 288 -70 394 -89 536 – 124 383 Commission -1 141 556 – 172 630 – 162 831 – 171 484 – 207 163 – 233 776 – 193 672 Gross Profit 7 135 096 1 241 423 1 165 591 1 281 592 877 578 1 150 321 1 418 592
LADBROKES JAN – JUN2017 JAN FEB MAR APR MAY JUN
GGR 10 391 808 1 771 459 1 664 138 1 820 429 1 358 982 1 733 687 2 043 114
Tax -1 558 771 – 265 719 – 249 621 – 273 064 – 203 847 – 260 053 – 306 467
RevenueShare – 556 384 -91 688 -86 095 -94 288 -70 394 -89 536 – 124 383
Commission -1 141 556 – 172 630 – 162 831 – 171 484 – 207 163 – 233 776 – 193 672
Gross Profit 7 135 096 1 241 423 1 165 591 1 281 592 877 578 1 150 321 1 418 592
LADBROKES JAN – JUN2017 JAN FEB MAR APR MAY JUN
GGR 10 391 808 1 771 459 1 664 138 1 820 429 1 358 982 1 733 687 2 043 114
Tax -1 558 771 – 265 719 – 249 621 – 273 064 – 203 847 – 260 053 – 306 467
RevenueShare – 556 384 -91 688 -86 095 -94 288 -70 394 -89 536 – 124 383
Commission -1 141 556 – 172 630 – 162 831 – 171 484 – 207 163 – 233 776 – 193 672
Gross Profit 7 135 096 1 241 423 1 165 591 1 281 592 877 578 1 150 321 1 418 592
(b) the gross profit figures for online virtual betting on the website Ladbrokes.be, from January to June 2017:JAN-JUN2017JANFEBMARAPRMAYJUNGGR182 53933 87521 43518 19938 20435 07535 750Tax-20 079-3 726-2 358-2 002-4 202-3 858-3 932Commission-11 044-2 049-1 297-1 101-2 311-2 122-2 163Gross Profit151 41628 09917 78115 09631 69129 09529 654 JAN-JUN2017 JAN FEB MAR APR MAY JUN GGR 182 539 33 875 21 435 18 199 38 204 35 075 35 750 Tax -20 079 -3 726 -2 358 -2 002 -4 202 -3 858 -3 932 Commission -11 044 -2 049 -1 297 -1 101 -2 311 -2 122 -2 163 Gross Profit 151 416 28 099 17 781 15 096 31 691 29 095 29 654
JAN-JUN2017 JAN FEB MAR APR MAY JUN
GGR 182 539 33 875 21 435 18 199 38 204 35 075 35 750
Tax -20 079 -3 726 -2 358 -2 002 -4 202 -3 858 -3 932
Commission -11 044 -2 049 -1 297 -1 101 -2 311 -2 122 -2 163
Gross Profit 151 416 28 099 17 781 15 096 31 691 29 095 29 654
JAN-JUN2017 JAN FEB MAR APR MAY JUN
GGR 182 539 33 875 21 435 18 199 38 204 35 075 35 750
Tax -20 079 -3 726 -2 358 -2 002 -4 202 -3 858 -3 932
Commission -11 044 -2 049 -1 297 -1 101 -2 311 -2 122 -2 163
Gross Profit 151 416 28 099 17 781 15 096 31 691 29 095 29 654
(147) Ladbrokes argues that these actual figures are markedly lower than the EUR 34 600 000 quoted in Footnote 26 of the Opening Decision. In its view, even assuming that Ladbrokes enjoyed (i) an exclusivity (ii) worth compensating (both elements being not established), it would be incorrect in law and fact to assume that the market value of such exclusivity would be superior to the generated profits. Such a reasoning would otherwise imply that an operator would be ready to carry out the activity at a (very significant) loss.
(148) As to the application of the redistribution rate of theLoterie Nationale, it is unjustified, as theLoterie Nationaleis a public institution whose aim is to share all its profits with the Belgian State.
(149) The Belgian authorities submitted observations related to the legal framework governing virtual betting in Belgium and the absence of State aid. In their submissions, the Belgian authorities maintain that there was no State aid granted to Ladbrokes with regard to virtual betting because neither a legal framework existed that would have required a special licence for virtual betting, nor would the Gaming Commission have issued or have the mandate to issue a legally binding authorisation for it.
(150) The Belgian authorities explain that it is the Gaming Act which defines the types of licences to operate games of chance. The rules are further elaborated through various Royal Decrees. The Gaming Commission implements these rules within the scope of its competencies. The Gaming Commission can control compliance with the law and decide for instance to initiate sanctions proceedings against a licence holder, but only within the framework of the law and its implementing decrees. The Gaming Commission cannot create new licences or introduce new conditions for obtaining a licence(41). It could however advise the stakeholders on the interpretation of the law.
(151) As to the licence required for a betting shop, the Belgian authorities clarify that that the operation of a class IV gaming establishment requires both a licence F1 and F2.
(152) According to the Belgian authorities, there can be vertical integration between the betting shop and the betting operator, meaning that an undertaking or group of undertakings can hold both F1 and F2 licences. However, an F2 licence holder may also be entirely unrelated from the F1 betting operator whose betting products it sells. In addition to proper betting shops (i.e. class IV gaming establishments), press shops can also acquire an F2 licence and sell certain betting products (albeit under different rules) in their press shop.
(153) Furthermore, the Belgian authorities state that under the law on games of chance in Belgium, there is no definition as such for the word ‘gaming’. Gaming can be reformulated as participating in games of chance. However, the law provides a definition for ‘games of chance’ meaning any game whereby a stake is played, whatever its nature, which leads to the loss of this stake by at least one of the players, or to any type of gain for at least one of the players or organisers of the game, and whereby chance influences the game, the winners of the game or the size of the game, even if only in a secondary manner.
(154) Moreover, the Belgian authorities clarify that a ‘bet’ is defined as a game of chance whereby each player enters a stake and whereby gain, or loss does not result from an act of the players, but from the outcome of an uncertain event that materialises without intervention by the players.
(155) The Belgian authorities state that there is no one overall (automatic) ‘gaming’ market A distinction should be made between different establishment classes. First, the concept of ‘automatic games of chance’ is used to refer to games of chance played on a machine, which is most notably done in gaming establishments of class I (casinos) and class II (gaming halls), but also, to a more limited extent, in other venues i.e. establishments of class III (bars) and of class IV (betting shops). The automatic gaming products offered in class I establishments (e.g. slots) are different from those offered in class II establishments (e.g. automatic dice games) and are subject to different regulations. This difference is even more substantial when comparing the machines in class I or class II establishments with those in class III or IV establishments.
(156) Finally, given the significant moral, religious and cultural differences between the different Member States and the lack of European harmonization in the gaming sector, each Member State remains free to determine its own gaming policy and the restrictions which it deems necessary to protect its own public interest. The only requirement imposed by EU law would be that such restrictions are (i) proportionate in that they are suitable for achieving the objective or objectives invoked by the Member State concerned, and do not go beyond what is necessary to achieve those objectives, and (ii) are applied without discrimination. Restrictions would normally satisfy the proportionality test if they fit in a coherent and systematic gaming policy.
(157) According to the Belgian authoritiess, the framework notes issued by the Gaming Commission are not of a binding nature. They serve the purpose of monitoring the evolution of virtual betting on the Belgian market. This view was embedded in the second Framework Note of 17 April 2013 which recognised virtual betting as a betting game of chance allowed under the Gaming Act by stating: ‘To be able to monitor this evolution – […] – closely, it would be preferable that every F1 [licence holder] that wants to offer these bets directs a preliminary request for authorisation to the Gaming Commission’.
(158) With the so-called ‘authorisation’, the Gaming Commission committed towards Ladbrokes that it would not regard its virtual betting product as contrary to the Gaming Act and it would not enforce the law as prohibiting virtual betting. The ‘authorisations’ in question granted by the Gaming Commission to Ladbrokes must be regarded as confirmations on the interpretation of the product presented by Ladbrokes to the Gaming Commission under applicable laws. The Belgian authorities also state that the ‘authorisation’ as such was not required. They point out that it simply does not even exist in the relevant legal framework.
(159) The Belgian authorities pointed out the informal nature of the ‘authorisation’, a mere e-mail by a person from the secretariat that did not have the power to represent the Gaming Commission. This shows that such ‘authorisation’ cannot in any event be regarded as a formal requirement or a formal decision adopted by the Gaming Commission.
(160) Since such ‘authorisation’ does not establish any right for Ladbrokes, but only informs Ladbrokes that the virtual betting it intends to offer is a game of chance that the Belgian law allows any F1-licence holder to offer on the Belgian market, no advantage was conferred on Ladbrokes. Any operator could have sent an ‘authorisation’ request to the Gaming Commission at the time Ladbrokes did and it would have received the same informal interpretation.
(161) The Belgian authorities further provide information on the views taken by the Gaming Commission on two other requests received from class IV operators. Concerning Stanleybet’s request of 28 October 2015, the Gaming Commission informed Stanleybet about a newly established sub-commission and that it would only deal with the request once the results of the activities of the sub-commission were known. Another request by Stanleybet of 17 June 2016 was initially refused on the grounds of an incomplete file and later on the grounds of ongoing discussions on a regulatory initiative concerning virtual betting. As to another request by Sagevas on 23 August 2016, its request was not dealt by the Gaming Commission for the same reasons as for Stanleybet, initially due to an incomplete file, then on 3 November 2016 because a legislative initiative on virtual betting was ongoing.
(162) The Belgian authorities consider that the complainants knew that the Framework Notes on virtual betting could not legally create a framework under which the Gaming Commission would grant a proper authorisation to one licence holder and deny it to another, if these operators were both in the same situation.
(163) More generally, no operators could have reasonably believed that the Framework Notes created a proper and enforceable legal requirement to obtain some sort ofad hoc‘virtual betting licence’.
(164) The Belgian authorities also explain that it was not more difficult for others than for Ladbrokes to start operating virtual betting products of the same nature in their class IV gaming establishments with the relevant licences F1 and F2. In their view, it cannot be asserted that the Gaming Commission would have implemented a different enforcement policy towards Ladbrokes than towards other virtual betting operators. The Gaming Commission could therefore not be regarded selective in its enforcement of the Gaming Act because only Ladbrokes went ahead and operated virtual betting under the general rules of the Gaming Act.
(165) Furthermore, the Belgian authorities note that the Council of State annulled the Gaming Commission’s Framework Notes because it disagreed with the Gaming Commission’s interpretation of the Gaming Act in those Notes. The Council of State took the view that ‘the [Gaming Commission] did not just create a framework for the organization of bets on virtual events authorized by the law, but rather allowed, without having the proper competence to do so, the organization of this type of betting whereas it is not allowed under the law of 7 May 1999 [on games of chance]’.
(166) Further, the Belgian authorities disagree that the ‘authorisation’ given to Ladbrokes could be suspended since it did not produce any legal effects in the first place. Nevertheless, on 13 January 2016, the Gaming Commission adopted its decision to suspend the application of its 2015 Framework Note and the ‘authorisation’ granted to Ladbrokes effective as of 1 June 2016. As a consequence, Ladbrokes was allowed a five-month transitional period to wind down its virtual betting operations. The Gaming Commission took this advised minimal transition period and decided on a two-month longer transitional period until the suspension of Ladbrokes’ ‘authorisation’ would take effect. To this end, it relied on the fact that Ladbrokes already offered virtual betting since 2014. Therefore, account should be taken of Ladbrokes’ investment in virtual betting and the period during which Ladbrokes had already offered virtual betting.
(167) In any event, on 4 May 2018 the Royal Decree came into force. In the submission of 21 February 2021, the Belgian authorities explicitly confirmed there would multiple F1 licence holders in Belgium offering virtual betting in their class IV fixed gaming establishments under the conditions of the Royal Decree of 4 May 2018. Some of there were SRL Bingo Bet, Derby (Ladbrokes), Stanleybet and Wedwinkel-bettica.
(168) With regard to the retroactive annulment of the 2018 Royal Decree, the Belgian authorities consider that it does not have an impact on the duration of the alleged measure. Notwithstanding the fact that the 2018 Royal Decree should be considered to have never existed in Belgian law, this does not mean that the conditions for unlawful State aid would be fulfilled. The criteria in the now annulled 2018 Royal Decree were applied without discrimination to all valid F1 and F2 licence holders who aimed to offer virtual betting. They did not selectively benefit certain undertakings compared to others.
(169) The Belgian authorities submitted distinct positions on the 2018 Royal Decree and its retroactive annulment. They put forward that multiple operators on the Belgian market would now offer virtual betting under the conditions set out by the 2018 Royal Decree. Furthermore, the Belgian authorities submitted that class IV gaming establishments (betting shops) are now allowed to offer virtual betting. Indeed, virtual betting as it was described by the 2018 Royal Decree (Article 2) needs ‘multiplayer’ gaming machines, which allow multiple players to bet in different betting shops at the same time on the same virtual sport event. It is considered for virtual betting to be of sufficiently similar nature as ‘monoplayer’ betting machines and is therefore allowed under the F1 and F1+ licence. In other words, virtual betting is considered as more akin to machine gaming than actual sports betting, so it is logical that F1+ licence holders that offer land-based ‘monoplayer’ gaming machines are allowed to operate online virtual betting.
(170) As a subsidiary argument, on the benchmark for the calculation of possible aid amount, the Belgian authorities consider that the treatment of theLoterie Nationale, referred to in the Opening Decision(42), is not comparable to that of Ladbrokes. According to national law, theLoterie Nationaleis responsible for organising the public lotteries for the public benefit and under the control of its minister while being obliged to actively inform the public about gaming and betting addiction and to cooperate actively with governments and other actors to provide an active and coordinated prevention policy in particular as regards addiction. All profits are dedicated for this purpose and other humanitarian projects. The profits are not allocated to the Belgian national budget but reinvested in theLoterie Nationaleto continue serving its public service obligations. The price that theLoterie Nationalepays for its legal monopoly represents a completely different situation from the one where a Member State grants exclusive rights and decides not to maximize the revenues which could have otherwise been achieved from those grants.
(171) Moreover, theLoterie Nationale’s exclusive right existed even before the creation of European Union. The National Lottery has several public service obligations and has no right to any profits since the Belgian State is entitled to receive all profits. The Belgian authorities further note that the State maximizes the possible revenue from the National Lottery’s monopoly, i.e. the whole profits of theLoterie Nationale. Even if theLoterie Nationaleere an appropriate benchmark, which it is not, the actual revenue for the State from granting such exclusive right would be the totality of theLoterie Nationale’s profits.
(172) The subject of this decision is the alleged unlawful aid by the complainants pursuant to Article 24(2) of Regulation (EU) 2015/1589. In order to qualify as unlawful State aid, the measure should be granted without the approval by the Commission.
(173) Furthermore, for a measure to be categorised as State aid within the meaning of Article 107(1) TFEU, all the conditions set out in that provision must be fulfilled. First, the measure must be imputable to the State and financed through State resources. Second, it must confer an advantage on its recipients. Third, that advantage must be selective, in that it favours certain undertakings or the production of certain goods. Fourth, the measure must distort or threaten to distort competition and affect trade between Member States. If a least one of the four cumulative criteria is not met, the measure does not constitute State aid.
(174) The Commission considers that the interest of The Faculty may be potentially affected by the alleged measure, since it operates in the same or similar markets in games of chance as Roculuc and EAC, whose interests may also be affected by the alleged measure, as also indicated in the Opening Decision. The Commission therefore considers The Faculty, Roculuc and EAC as interested parties within the meaning of Article 1(h) and as complainants within the meaning of Article 24(2) of Regulation (EU) 2015/1589. The argument brought forward by Ladbrokes that the complainant Rocoluc would lack the status of interested party (recitals 114-115) does not detract from that conclusion(43).
(175) According to the complainants, the measure consists in the rights granted to Ladbrokes for the provision of virtual betting services on the Belgian market. The complainants consider that these rights would constitute unlawful State aid granted by the Gaming Commission through e-mails from an unauthorised official of 9 February 2014 and 5 March 2015.
(176) The Regulation (EU) 2015/1589 defines ‘unlawful aid’ as ‘new aid put into effect in contravention of Article 108(3) TFEU’. It requires that a measure needs to be put into effect by the Member State to be regarded as an unlawful aid. However, neither the Framework Notes (section 2.3.1) nor the aforementioned e-mails sent to Ladbrokes (section 2.6.) can be regarded as a granting act grating exclusive rights to Ladbrokes.
(177) Ladbrokes was the first operator that planned a virtual betting activity in Belgian authorities in 2011 (recital 126). When Ladbrokes decided to offer the service of virtual betting in Belgium, the Gaming Act did not include specific reference to either online or offline virtual betting under the system of licences for games of chance.
(178) Therefore, the Gaming Commission identified a need for interpretation on how to categorize virtual betting. On 12 January 2012, it issued its first Framework Note entitled ‘Betting on Virtual Events’ (recital 39). This Framework Note did not expressly distinguish between online and offline virtual betting, but the Belgian authorities confirmed it effectively concerned offline virtual betting (recital 169).
(179) The purpose of the 2012 Framework Note was to examine whether the amended Gaming Act or its enforcement orders contained legal objections to the organization of betting on virtual (sporting) events. The Gaming Commission concluded: ‘From a legal point of view, the organization / offer of bets on virtual (sporting) events is in accordance with the provisions of the Gaming Act insofar as this type of betting is considered to be bets on events. Indeed, the result is not known, and the event concerns an uncertain fact, thanks to the “random number generator”. Considering that bets on virtual (sporting) events are bets on events means that this type of betting can only take place in class IV fixed gaming establishments. […]’.
(180) As a preliminary comment, when it comes to rules on virtual betting, as explained in recital 28, the Commission notes that the concept of ‘automatic games of chance’ is used to refer to games of chance played on a machine, which is most notably done in gaming establishments of class I (casinos) and class II (gaming halls), but also, albeit to a more limited extent, in other venues i.e. establishments of class III (bars) and class IV (betting shops).
(181) As confirmed by Belgian authorities (recital 169), class IV gaming establishments (operated with licences F1, F1+ and F2) always maintained the possibility to offermonoplayergaming machines to their customers. This was already provided in the Royal Decree of 22 December 2010 on the operating rules of automatic games of chance authorised in class IV gaming establishments(44).
(182) The Gaming Act sets out the different types of licences and which type of gaming can be offered under these licences, and under what conditions. The rules were further elaborated through various Royal Decrees.
(183) According to Article 25 of the Gaming Act, the operation of a betting shop, which is a class IV gaming establishment, requires both a licence F1 and F2. The licence F1 is required to organise betting (i.e. create betting products for sale to players) whereas the licence F2 is required to take bets from players (i.e. directly sell the betting products to consumers). A betting shop (class IV establishment) must hold an F2 licence to take bets on behalf of a betting operator (with licence F1).
(184) Upon verification of the licences held by Ladbrokes, the Commission notes that Ladbrokes held a class F1 licence, which allows the operation of a betting establishment, a class F2 licence, which allows bets to be taken on behalf of the licencee of class F1, in a class IV fixed or mobile betting establishment and also enables Ladbrokes to take bets outside a class IV gaming establishment in the cases referred to in Article 43/4 (1), (5) and (2) of the Gaming Act, and an additional class F1 + licence allowing the exploitation of bets via information society tools, meaning online. As to the complainants’ argument on discrimination of class II operators when it comes to virtual betting, the Commission notes the position taken by the Gaming Commission to limit the activity of virtual betting only to class IV operators s. This restriction is in line with the reasoning provided by the 2018 Royal Decree, which emphasizes that it would be indispensable for the protections of players to allow this new game of chance to be offered only by class IV establishments (recital 43).
(185) The Commission also notes the information provided by the Belgian authorities that Ladbrokes was not the only operator on the Belgian market to hold the relevant licenses F1 and F1+ to operate virtual betting (recital 167). Yet, Ladbrokes’ predominance is apparent it can be attributed to the fact that Ladbrokes was a first operator to introduce and start offering virtual betting service in Belgium (recitals 126- 128). This early start and being a first of a kind brought to Ladbrokes a ‘first mover’ advantage. Other operators slowly followed the suit and showed interest in virtual betting in 2015 and 2016. Then the market for virtual betting grew, yet the regulatory setting that had to be provided by the State has been behind that development (recital 59).
(186) According to the Union courts, State aid must be regarded as being ‘granted’ within the meaning of Article 107(1) TFEU on the date on which the right to receive it is conferred on the beneficiary under the applicable national legislation(45), i.e. the national law must foresee effects for such an act to be enforceable under national law.
(187) In the case at hand, as explained in recital 35, the role of the Gaming Commission is to control compliance with the law within the framework of the Belgian law and its implementing decrees. The Gaming Commission, while being part of the Belgian public administration, has an advisory role and the task to implement the existing regulation in the gaming sector adopted by the Belgian legislator.
(188) As stated in the Gaming Act, which defines the competences of the Gaming Commission (see recital 35), the Gaming Commission does not have the power to create new rights to operators for gaming and betting operations. When it issues licences it must stay within the scope of the competences given to it by the Gaming Act and it cannot create new categories of licences (recital 150). The Framework Notes issued by the Gaming Commission (see recital 39) cannot be regarded as legal bases to legally authorise a gaming or betting activity. Moreover, these Framework Notes were annulled by the Council of State in 2019 (recital 64).
(189) Moreover, as mentioned in recital 40, the Gaming Commission explained in the Framework Note of 2012 that ‘in order to be able to closely monitor the development (…) it is preferable that each F1 [operator] wishing to organize such bets sends a prior request for authorisation for this purpose to the secretariat of the Gaming Commission’.
(190) As to the meaning of an ‘authorisation’, the wording in the 2012 Framework Note indicates that the operators were not compelled or required, but rather encouraged (‘it is preferable’) to request a specific authorisation to operate virtual betting offline. Specifically, the Gaming Commission did not refer to any provision of the Gaming Act as a basis for its ‘preference’ expressed in the note (‘it is preferable’, ‘in order to be able to closely monitor this development’). In fact, later the ‘authorisations’ were annulled by the Council of State based on the arguments ofultra viresdoctrine (recital 38).
(191) The Commission takes the view that the e-mails were a mere confirmation that it could be considered that Ladbrokes, as a class IV establishment, was holding the relevant licences to operate virtual betting. In view of the interpretation given by the Gaming Commission, all class IV establishments with the relevant licence were entitled to provide virtual betting as it was covered by these licences (see recitals 40-41). Therefore, Ladbrokes, as an operator of class IV F1, F2 and F1+ licences, was considered eligible to operate virtual betting without requiring any additional approval or a new licence by the Belgian authorities.
(192) Any class IV operator could have in principle send an ‘authorisation’ request to the Gaming Commission at around the same time as Ladbrokes did, and it would then most probably have received the same interpretation. This possibility was however not foreseen for other classes, including the class II operators like the complainants, as they were not deemed to be eligible for the operation of virtual betting. The Commission notes that none of the complainants were establishments of class IV with the relevant licences and they did not submit such a request to the Gaming Commission.
(193) Moreover, it was only at a later stage that Stanleybet and Sagevas made their request for interpretation. The legal reflection had however evolved in the meanwhile. The Gaming Commission did not want first to deal with the request because of incomplete files. Subsequently, it did not want to provide an interpretation because of an ongoing regulatory initiative on virtual betting (see recital 161). The rejection of these two more recent requests made cannot be regarded as the refusal to grant rights to this operator.
(194) In this context, the Commission concurs with the Belgian authorities’ view (see recital 162) that no operators would have reasonably believed that the Framework Notes would create an enforceable right to obtain anad hocand specific virtual betting licence that would have been granted only to Ladbroke.
(195) In view of the foregoing considerations, the Commission concludes that given that the Gaming Act did not require a special licence to be approved by the Gaming Commission for virtual betting, and that the Framework Note of 2012 did not require any specific authorisation, the administrative communication granting ‘authorisations’ did not produce a legal effect to the extent that such effect would be tantamount to a licence. Ladbrokes, as an operator of class IV F1, F2 and F1+ licences, was considered eligible to operate virtual betting without requiring any additional approval or a new licence by the Belgian authorities. Therefore, it can be concluded that the e-mail replies sent by the Gaming Commission to Ladbrokes did not confer a legally enforceable right on Ladbrokes. Hence, the e-mails cannot be qualified as a granting act within the meaning of State aid law.
(196) According to well-established case-law, Article 107 TFEU defines a State aid measure by reference to its effects. It is therefore relevant to assess the effects on the market of the alleged measure(46).
(197) As regards online virtual betting, the facts show that the e-mails sent by the Gaming Commission did not produce the effect vis-à-vis other operators of granting exclusive rights to Ladbrokes, which could be assimilated to the effects of State aid.
(198) As mentioned in recital 192, all operators of class IV with F1, F2 and F1+ licences were allowed to operate virtual betting without any additional approval or licence by the Belgian authorities.
(199) Ladbrokes submitted screenshots of the websites operated by different betting companies offering online virtual betting at certain periods of time (recital 201). This shows that other operators, such as Circus(47), Golden Vegas(48)or Bingoal(49), 36win(50), along with Ladbrokes, provided online virtual betting.
(200) Based on the information available, it appears that the Gaming Commission did not impose a sanction or undertake an enforcement action against these operators of online virtual betting. It also did not impose a prohibition on Ladbrokes, but temporarily suspended its licence for one day (recital 122).
(201) Moreover, the Belgian authorities confirmed that the retroactive annulment of the 2018 Royal Decree by the 7 May 2021 ruling of the Belgian Council of State only concerned offline virtual betting (class IV gaming establishments). The annulment had no impact on online virtual betting as several operators continued to offer it afterwards (recital 167).
(202) Based on the evidence available, it can be concluded that the e-mails sent by the Gaming Commission did not produce effects that could be assimilated to State aid vis-à-vis other operators of granting exclusive rights on online virtual betting to Ladbrokes.
(203) As expressly confirmed by the Belgian authorities, from 10 February 2014 until 1 July 2017, all class IV fixed betting establishments with licences F1 and F2 were legally allowed to operate offline virtual betting. The Belgian authorities pointed out that only Ladbrokes did so, even though all operators of a class IV fixed betting establishment with the appropriate valid licence could have provided offline virtual betting (see recital 192).
(204) The operator Sagevas made it public that it would operate virtual betting without any ‘authorisation’ from the Gaming Commission. The Gaming Commission expressly reported this declaration in its note of 2 January 2017, without announcing any enforcement actions.
(205) It is further noteworthy that Tiercé Ladbrokes SA, which is a Entain’s subsidiary and Ladbrokes’s sister entity in Belgium, also started offering virtual betting in the bet shops it operated at the same time that Ladbrokes did. Tiercé Ladbrokes did not receive any ‘authorisation’. Tiercé Ladbrokes is a different legal entity from Ladbroke. Given the formality that characterizes the sector-specific regulation, meaning that an ‘authorisation’ or a licence is awarded to a specific legal entity(51), this shows that Ladbrokes was not alone in offering virtual betting.
(206) Even though the position of the Gaming Commission evolved in the direction that virtual betting would not be a form of betting, and it therefore no longer advised that it could be offered in class IV gaming establishments (with licences F1 and F2), all class IV fixed betting establishments with the relevant licence were legally allowed to operate virtual betting.
(207) As of 1 July 2017, the Gaming Commission suspended its ‘authorisation’ granted to Ladbrokes in 2014. However, Ladbrokes continued offering virtual betting even after 1 July 2017, based on its view that it would be lawful to do so for all operators based on the licence F alone.
(208) The Belgian authorities did not take any legal action to enforce those “suspensions” or to initiate legal proceedings against Ladbrokes after 1 July 2017.
(209) The available facts as stated already in recital 31 of the Supplementary Opening Decision(52)show that some other operators (Bingoal/PMU, Betcenter Stanleybet and Sagevas) offered or intended to offer offline virtual betting.
(210) In the light of these facts, the Commission concludes that the e-mails sent by the Gaming Commission did not produce effects vis-à-vis other operators of granting exclusive rights on offline virtual betting to Ladbrokes, which could be assimilated to the effects of State aid.
(211) Ladbrokes finally stopped offering virtual betting on 28 March 2018 due to an injunction of the Brussels Commercial Court requested by FedCaf in view of the suspension of the Framework note on 1 July 2017.
(212) In any event, on 4 May 2018, the 2018 Royal Decree came into force. According to the Belgian authorities, from the adoption of the 2018 Royal Decree until the annulment of all three Framework Notes by the Council of State in 2019 (recital 64), class IV fixed betting establishments with the appropriate valid licence could offer offline virtual betting. Effectively, as already mentioned above (recital 167) several of them did so, in particular SRL Bingo Bet, Derby (Ladbrokes), Stanleybet and Wedwinkel-Bettica. These same operators offered offline virtual betting in the period from the same judgment of the Council of State of 19 September 2019 when the Council ruled that virtual betting would not be in line with the Gaming Act (recital 140) until the retroactive annulment of the 2018 Royal Decree.
(213) The Commission therefore concludes that the 2018 Royal Decree did not confer an exclusive right to Ladbrokes.
(214) It is finally noteworthy that, from the annulment of the 2018 Royal Decree on 7 May 2021 onwards, offline virtual betting has not been allowed and there is no operator offering it in Belgium, as confirmed by the Belgian authorities.
(215) The complainants argue that by failing to impose a fee for virtual betting services offered by Ladbrokes, the Belgian authorities favoured Ladbrokes by granting it a preferential treatment, hence a selective advantage (see recital 21). In doing so, the Belgian authorities would have foregone State resources.
(216) However, all class IV establishments with the relevant licence were in principle allowed to offer both offline and online virtual betting (recital 192). The Commission notes that the Gaming Commission, or any other Belgian public authority for that matter, did not exempt Ladbrokes from a fee and did not release Ladbrokes from the obligation to pay a fee that would have been due. Instead, it appears from the Belgian authorities’ interpretation of the Gaming Act that there is no obligation for the operators to pay special fees for virtual betting.
(217) It is further noteworthy that there was no obligation for class IV establishments to hold, let alone to pay for a licence special to operating virtual betting, so that not imposing a licence fee for virtual betting is merely the consequence of the non-existence of special rules on virtual betting in the Gaming Act.
(218) The Commission further notes that with the adoption of the 2018 Royal Decree, offline virtual betting became regulated, but no special fee was foreseen for it. In fact, when the regulator acted by adopting the 2018 Royal Decree, it adopted a regulation which prescribed conditions for all eligible operators and did not forgo revenues for not requiring a special fee for operating virtual betting by Ladbrokes.
(219) Therefore, the Commission concludes that the Belgian State did not waive, nor forego, any resources which should have been paid by Ladbrokes for operating virtual betting since 2014. Hence, there is no link between the alleged exclusive right of Ladbrokes and a burden on the State budget through the non-imposition of fees.
(220) In conclusion, the Commission finds that:—the informal e-mail replies sent by an employee at the Gaming Commission to Ladbrokes do not qualify as a granting act within the meaning of Article 107 (1) TFEU (see section 5.2.);—the e-mails sent by the Gaming Commission did not produce effects vis-à-vis other operators of granting exclusive rights on virtual betting to Ladbrokes, which could be assimilated to the effects of State aid within the meaning of Article 107 (1) TFEU (see section 5.3.);—the Belgian State did not waive, nor forego, any resources which should have been paid by Ladbrokes for operating virtual betting since 2014 (see section 5.4.). — the informal e-mail replies sent by an employee at the Gaming Commission to Ladbrokes do not qualify as a granting act within the meaning of Article 107 (1) TFEU (see section 5.2.); — the e-mails sent by the Gaming Commission did not produce effects vis-à-vis other operators of granting exclusive rights on virtual betting to Ladbrokes, which could be assimilated to the effects of State aid within the meaning of Article 107 (1) TFEU (see section 5.3.); — the Belgian State did not waive, nor forego, any resources which should have been paid by Ladbrokes for operating virtual betting since 2014 (see section 5.4.).
— the informal e-mail replies sent by an employee at the Gaming Commission to Ladbrokes do not qualify as a granting act within the meaning of Article 107 (1) TFEU (see section 5.2.);
— the e-mails sent by the Gaming Commission did not produce effects vis-à-vis other operators of granting exclusive rights on virtual betting to Ladbrokes, which could be assimilated to the effects of State aid within the meaning of Article 107 (1) TFEU (see section 5.3.);
— the Belgian State did not waive, nor forego, any resources which should have been paid by Ladbrokes for operating virtual betting since 2014 (see section 5.4.).
— the informal e-mail replies sent by an employee at the Gaming Commission to Ladbrokes do not qualify as a granting act within the meaning of Article 107 (1) TFEU (see section 5.2.);
— the e-mails sent by the Gaming Commission did not produce effects vis-à-vis other operators of granting exclusive rights on virtual betting to Ladbrokes, which could be assimilated to the effects of State aid within the meaning of Article 107 (1) TFEU (see section 5.3.);
— the Belgian State did not waive, nor forego, any resources which should have been paid by Ladbrokes for operating virtual betting since 2014 (see section 5.4.).
(221) The Commission therefore concludes that no unlawful State aid has been granted by Belgium to Ladbrokes within the meaning of Article 107 (1) TFEU in the absence of (i) a granting act, (ii) any exclusive rights which could be assimilated to it, and (iii) the forgoing of State resources.
(222) In the light of the above, the Commission concludes that the measure does not constitute State aid within the meaning of Article 107(1) TFEU.
— La vente de journaux spécialisés, de magazines de sport et de gadgets ;
— La vente de boissons non alcoolisées;
— L’exploitation de maximum deux jeux de hasard automatiques qui proposent des paris sur des activités similaires à celles engagées dans l’agence de paris. Le Roi fixe les conditions auxquelles ces jeux de hasard peuvent être exploités’.
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union, and in particular the first subparagraph of Article 108(2) thereof,
Having regard to the Agreement on the European Economic Area, and in particular Article 62(1)(a) thereof,
Having called on interested parties to submit their comments pursuant to the provisions cited above and having regard to their comments,
Whereas:
1. PROCEDURE
(1) By letter of 1 March 2019, the Commission services received a complaint lodged by the undertakings Rocoluc NV and European Amusement Company NV (hereafter respectively referred to as ‘Rocoluc’ and ‘EAC’) Belgian sister companies active in the gaming and betting sectors, and on 23 February 2024 another complaint by their sister company V.D.B. Faculty NV (‘The Faculty’), also active in the gaming sector with a class II licence (all three sister companies also referred to as ‘the complainants’).
(2) The complainants allege grant of State aid by the Belgian authorities through an ad hoc‘authorisation’ to the Belgian company Ladbrokes (registered as Derby S.A.) to operate virtual betting in Belgium which would have been granted to it without appropriate remuneration (hereafter the ‘contested measure’). Ladbrokes, a class IV licence holder, is the (international) brand name under which Derby S.A. a Belgian company specializing in gaming and betting activities and a subsidiary of the multinational betting and gaming company Entain Holdings PLC operates (hereafter for the purposes of this decision all together are referred to as ‘Ladbrokes’).
(3) By letter of 2 September 2020, the Commission informed the Belgian authorities that it had decided to initiate the procedure laid down in Article 108(2) of the Treaty on the Functioning of the European Union in respect of the contested measure (hereinafter the ‘Opening Decision’) (1).
(4) The Commission decision to initiate the procedure was published in the Official Journal of the European Union. The Commission called on interested parties to submit their comments.
(5) The Belgian authorities submitted comments on the Opening Decision on 9 October 2020. Rocoluc and EAC submitted comments on the Opening Decision on 18 November 2020. The Commission received comments on the Opening Decision from Ladbrokes on 18 December 2020. The Belgian authorities provided their observations on the third parties’ comments on 10 February 2021.
(6) On 26 May 2021, following the annulment without preservation of the effects (with effects ex tunc as to the date of adoption) of the Royal Decree on ‘games of chance on virtual sporting events in fixed class IV gaming establishments’ dated 4 May 2018 (hereafter the ‘2018 Royal Decree’) (2), the complainants requested the Commission to adopt a corrective opening decision to extend the period of alleged investigated aid.
(7) On 9 September 2021, Ladbrokes provided a further submission.
(8) On 28 October 2021, the Commission forwarded to the Belgian authorities the complainants’ and Ladbrokes’ submissions with a request for information, to which the Belgian authorities replied on 30 November 2021.
(9) On 7 February 2022, the Commission sent a further request for information to the Belgian authorities, to which the Belgian authorities replied on 9 March 2022, 5 March and 22 April 2022.
(10) On 23 February 2023, the Commission services held a meeting with the complainants. On 9 March 2023, the Commission received an additional submission from the complainants regarding the selective character of the alleged aid. On 23 February 2024, the Commission received a submission by The Faculty, a Belgian company active in the gaming sector, regarding the same contested measure.
(11) On 8 March 2024, the Commission sent a request for information to the Belgian authorities asking for, inter alia, additional clarifications on the factual and legal situation for offline and online virtual betting following the retroactive annulment of the 2018 Royal Decree.
(12) On 8 March 2024, the Commission informed The Faculty that it registered its submission as general market information. On 14 March 2024, The Faculty sent another letter asking to be qualified as a formal complainant. On 20 March 2024, the Commission sent a second letter to The Faculty asking for additional information on the complaint.
(13) On 29 April 2024, the complainants Rocoluc and EAC submitted a letter requesting the Commission to act within the meaning of Article 265(2) TFEU.
(14) On 21 May 2024, the Belgian authorities submitted a reply to the request for information sent by the Commission on 8 March 2024, following a reminder on 3 May 2024.
(15) On 14 June 2024, the Commission sent additional questions to the Belgian authorities to which the Belgian authorities replied on 19 June 2024. On 20 June 2024 the Commission requested additional clarifications per e-mail, to which the Belgian authorities replied on 28 June 2024.
(16) On 31 July 2024, following the above-listed information received from the complainants, the alleged beneficiary Ladbrokes and the Belgian authorities, the Commission decided to extend the scope of its in-depth investigation and adopted a Supplementary Opening Decision (3) (hereinafter ‘the Supplementary Opening Decision’).
(17) The Commission called on interested parties to submit their comments on the findings in the Supplementary Opening Decision, which they provided on 25 November 2024, whereas the Belgian authorities did not provide any comments.
(18) On 12 November 2024, the Commission services requested further information from Ladbrokes and on 22 November 2024, 9 December 2024 and 21 January 2025, Ladbrokes provided, respectively, its comments on the Supplementary Opening Decision and additional information.
(19) On 23 January 2025, the Commission forwarded the third parties’ comments on the Supplementary Opening Decision to the Belgian authorities. The Belgian authorities replied on 4 February 2025 with no comments.
(20) The Belgian authorities agreed exceptionally to waive the rights deriving from Article 342 TFEU in conjunction with Article 3 of Council Regulation No 1/1958 (4) and to have this decision adopted and notified pursuant to Article 297 TFEU in English.
2. DESCRIPTION OF THE CONTESTED MEASURE
2.1. Subject of the complaint
(21) The complainants contest a preferential treatment, and an ‘exclusive authorisation’ which would have been granted by the Belgian authorities to Ladbrokes to offer online and offline virtual betting in Belgium (the contested measure). According to the complainants, that ‘authorisation’ resulted in Ladbrokes enjoying a de facto exclusive right (since 2014) to operate virtual betting in Belgium without an appropriate remuneration.
(22) The complainants also claim that the 2018 Royal Decree of 4 May 2018 and the judgment of the Council of State (‘Conseil d’État’, which is the Belgian Supreme Administrative Court) of 7 May 2021 confer a benefit to Ladbrokes which amounts to unlawful State aid from the Belgian State, by way of tolerating Ladbrokes’ virtual betting activities while those activities would have been illegal under Belgian law.
(23) Before describing the legal framework for virtual betting and its evolution in Belgium, the wider context of the legal framework for the gaming sector is addressed first.
2.2. Legal framework on games of chance in Belgium
(24) The games of chance (‘jeux d’hasard’) are a broad concept covers both gaming and betting (‘paris’).
(25) The sector of games of chance in Belgium has been regulated and organised by the Act of 7 May 1999 on games of chance, betting, gaming establishments and the protection of players (5), as amended by an Act of 10 January 2010 (6) (hereinafter the ‘Gaming Act’). In addition, numerous implementing acts, Royal decrees (more than 100 to date), implement the provisions of the Gaming Act.
(26) In Belgium, according to Article 4 § 1 of the Gaming Act, there is a prohibition on games of chance, unless a licence is granted to operate, or an exception from the licence requirement is foreseen. The Gaming Commission grants different types of licences for the operation of games of chance.
2.2.1. Definitions of ‘games of chance’ in Belgium
(27) The activities involving ‘automatic games of chance’ are defined as follows: ‘Any game or bet, where a stake of any kind, either the loss of that stake by at least one of the players or bettors, or a profit of any kind for at least one of the players, bettors or organizers of the game or bet and where chance is an even incidental element in the course of the game, the designation of the winner or the determination of the winning size’ (7).
(28) The definition of games of chance (jeux d’hasard) covers a wide range of activities. In other words, in games of chance the player bets on the outcome of a game or event that has an uncertain, randomly determined, result that depends on probabilities (e.g. slot machines). Games of chance are a specific subset of games of chance where the outcome is determined entirely or partially by chance. These games do not require skill and involve a random outcome (such as rolling dice, drawing cards, or spinning a wheel).
(29) Betting, on the other hand, can be regarded as a category of games of chance, which is about predicting the outcome of a future, real event, based on certain criteria (e.g. betting on the outcome of a football match based on the relative strength of the teams). Unlike games of chance, betting may involve an element of skill, as it is based on knowledge and analysis of the event being bet upon.
Games of chance
Betting
Definition
Games where outcomes are determined by chance.
Predicting outcomes of events and staking money.
Outcome Determinants
Purely or mainly random chance.
Predominantly influenced by chance but may involve skill.
Examples
Roulette, slot machines, lotteries.
Sports betting, horse racing, fixed-odds betting.
Regulation
Strictly regulated as games of chance.
Regulated as a form of game of chance, requiring a betting licence.
(30) Regarding virtual betting, the Belgian legal framework has evolved. First, the regulatory and legislative framework has changed over time, marked in particular by the 2018 Royal Decree. This led to litigation before national courts, which has resulted to suspensions and annulments of the 2018 Royal Decree, as well as the Framework Notes of the Gaming Commission of 2012 and 2015 (see below in recital 59). Second, the approach by the Gaming Commission evolved, considering virtual betting as falling under the categories of betting or automatic games of chance. This evolving interpretation of virtual betting within different periods reflects its complex nature in the context of Belgian gaming legislation. It is noteworthy that the discussion on how to define and qualify virtual betting is still pending today in Belgium.
2.2.2. Licences for games of chance and betting
(31) The Gaming Act provides for a limited number of types of licences, which allow the operation of certain games of chance and gaming establishments laid down by law. According to Article 25 of the Gaming Act (‘Chapter III – Licences’) there are nine categories of licences (A, B, C, D, E, F1, F2, G1 and G2) and additional licences (A +, B +, C + and F+).
(32) There are four classes of gaming establishments in Belgium:
i.
Class I: for casinos. A casino is a gaming establishment where the operation of games of chance, whether or not automatic, is authorized. Only nine casinos are allowed on the Belgian territory. The Gaming Act lists the territories of the communes/cities where a casino can be operated. A casino operator must hold a class A licence.
ii.
Class II: for gaming arcades. Gaming arcades are establishments which operate only games of chance authorised by the King of Belgium. The operating rules for the automatic games of chance that can be offered in class II gaming establishments are laid down in a Royal Decree of 8 April 2003. A gaming arcade operator must hold a class B licence and can offer automatic games of chance can be offered mainly by class II establishments with a B licence.
iii.
Class III: drinking establishments, which provide for games of chance and reduced-stakes automatic games of chance. Drinking establishments such as cafés must hold a class C licence.
iv.
Class IV: for betting offices. Class IV gaming establishments are places where operators with an F2 licence are exclusively permitted to accept bets on behalf of an F1 licence holder (the organizer of betting activities). Class IV establishments may also offer automatic games of chances under certain conditions. It is prohibited to accept bets outside a class IV gaming establishment. There are, however, a limited number of exceptions to this prohibition. A class IV gaming establishment can be fixed or mobile. A fixed class IV gaming establishment is a clearly demarcated permanent establishment where bets are offered. A mobile class IV gaming establishment is a temporary establishment, also clearly demarcated, where bets are offered during and at an event, sports game or sports competition. F2 licences may also be granted to newspaper shops, which can offer bets as an ancillary activity. Betting is offered mainly by class IV gaming establishments, and it requires an F1 or F2 licence (8).
(33) The Belgian legislature has set up a closed licensing system. Offering online games of chance and bets requires an online licence (A+ licence for online casinos, B+ licence for online gaming arcades and F1+ licence for online bets).
(34) In addition, an online licence requires a mandatory physical connection to the Belgian territory. Only those operators licenced to operate in the real world (and holding a principal A, B or F1 licence) can obtain a licence to offer the same games of chance and bets online (an ‘additional’ A+, B+ or F1+ online licence).
2.2.3. The role of the Gaming Commission
(35) The Gaming Commission (9) was established by the Gaming Act of 7 May 1999 as a federal supervisor within the Federal Public Service of Justice (formerly, the Ministry of Justice). Its main task is to ensure channeling to legal gaming, with the primary aim of protecting players. The Gaming Commission’s main responsibilities include:
—
providing advice to the Government and Parliament on all matters related to the Gaming Act;
—
granting the licences necessary for the operation of games of chance and betting, as well as ensuring their proactive management;
—
monitoring compliance with the Gaming Act and exercising sanctioning power, which include imposing administrative sanctions (warning, suspension or licence revocation) and administrative fines.
2.3. Legal framework on virtual betting in Belgium
2.3.1. Interpretation of virtual betting as ‘betting’ by the Gaming Commission
(36) Virtual betting is a game of chance, which has taken shape in Belgium since 2011, whereby players can bet on the outcome of a fictional sport event (e.g. a fictional horse race) and where the results are determined by a random number generator.
(37) Virtual betting combines characteristics of both automatic games of chance and betting. While the outcomes are determined by chance (games of chance), predicting these outcomes may also require some degree of skill (betting).
(38) The Gaming Act does not provide a definition of virtual betting, nor does it consequently foresee a (special) licence for it. It was only that the Gaming Commission first provided an interpretation on how to categorize virtual betting following its appearance in Belgium in 2011, but their interpretation was later annulled by the Council of State (10) on the basis that the Gaming Commission thereby acted ultra vires.
(39) The concept of virtual betting was assessed by the Gaming Commission in three ‘Framework Notes’ or ‘memoranda’ (‘omkaderingsnota’ and ‘nota’) dated 12 January 2012 (11), 17 April 2013 (12) and 1 July 2015 (13). They considered virtual betting to be betting on (virtual) events (14). Furthermore, all legal and regulatory obligations applicable to betting also applied to virtual (sporting) betting (for example, recording obligation from EUR 1 000, computer protocol, etc.) (15). Virtual betting was therefore regarded as ‘bets’ which could be exploited by the holders of the F1, F2 and F1+ licences. It follows that the class F1 licence and class F1+ licence holders were allowed to operate online and offline virtual betting only via class IV gaming establishments.
(40) The Gaming Commission’s views on offline and online virtual betting.
—
As to the offline operation of virtual betting, on 12 January 2012 the Gaming Commission examined in its ‘Framework note on the possibility of betting on virtual events’, ‘whether the amended Gaming Act or its implementing regulations contain legal objections to the organization of betting on virtual (sports) events’. The Gaming Commission concluded that ‘the organization/offer of betting on virtual (sports) events complies with the provisions of the Gaming Act in so far as such betting is considered to be betting on events’. The Gaming Commission stated, among others, that ‘in order to be able to closely monitor this development – which brings additional profitability to the sector in compensation for the investments required as a result of the law on games of chance, its implementing decrees and technical protocols -, […] each F1 [licence holder] wishing to organize such bets should send a prior request for authorisation [“goedkeuring”] to this end to the secretariat of the [Gaming Commission] […].’
—
As to online virtual betting, the Gaming Commission issued guidelines on it through its internet group website in 2012. For offering online virtual betting, a mere communication to the Gaming Commission from the class F1+ licence holder was sufficient.
(41) On 1 July 2015, the Gaming Commission reaffirmed in its ‘Framework note on the possibility of setting up bets on virtual events’ that there were no legal objections to offering bets on virtual events that the Gaming Commission still considered as bets. On 9 September 2015, the Gaming Commission confirmed the position taken in the Framework note of 1 July 2015. It noted that virtual betting was advantageous for the ‘operators’ and decided to set up a subcommittee with the aim to ‘further analyse’ the issue of virtual betting.
(42) Regarding the regulation of online virtual betting, the subcommittee noted ‘first of all, that none of the parties fundamentally objected to the current regulation of online virtual betting by means of the internet group’s guidelines on the subject, which allows the present advice to be limited further to the current regulation of offline betting by means of the note of 1 July 2015.’ Regarding the regulation of offline virtual betting, the subcommittee, as a policy consideration, advised that offline virtual betting should be regulated by way of a Royal Decree as an automatic game of chance, and no longer as betting, and proposed to suspend the Framework note of 1 July 2015.
2.3.2. Adoption of the first legal framework regulating offline virtual betting as an ‘automatic game of chance’
(43) On 4 May 2018, the Royal Decree on ‘games of chance on virtual sporting events in fixed class IV gaming establishments’ (16) (‘the 2018 Royal Decree’) was adopted. It classified virtual betting as an ‘automatic game of chance’ and allowed only existing class IV operators to offer virtual betting in Belgium. Indeed, pursuant to Article 2 of the 2018 Royal Decree, ‘[g]ames of chance on virtual sporting events are automatic games of chance where the stakes of a player or several players in several places can be accepted at the same time for a virtual sports event, the existence of which, the odds associated with the event and the chances of winning are determined by a remote server’. Article 3 provided that ‘[g]ames of chance on virtual sporting events are automatic games of chance authorised in class IV fixed gaming establishments’. Article 4 specified that the number of automatic gaming machines on virtual sports events in class IV fixed gaming establishments is limited to two. Indeed, in light of the Gaming Act (17), the 2018 Royal Decree implements the conditions under which a maximum of two automatic games of chance offering bets on ‘activities similar to those engaged in the betting agency’ (i.e. virtual betting games) may be operated in a fixed class IV gaming establishment (18). According to the 2018 Royal Decree, by explicitly classifying games of chance on virtual sporting events as automatic games of chance in class IV fixed gaming establishments, the essential protection of players is guaranteed. It follows that no authorisation was required to operate virtual betting. Inasmuch as an operator holds a valid F1 or F2 licence and has fixed class IV gaming establishments, the gaming operator can operate a maximum of two virtual betting games in the class IV fixed gaming establishment.
(44) Virtual betting as described by the 2018 Royal Decree (Article 2) needs ‘multiplayer’ gaming machines, which allow multiple players to bet in different betting shops at the same time on the same virtual sports event. As of 30 January 2020, there were at least five operators providing offline virtual betting in Belgium, including Ladbrokes.
(45) The Belgian Council of State retroactively annulled the 2018 Royal Decree on 7 May 2021.
2.4. Classification of licences held by the complainants
(46) Rocoluc, EAC and The Faculty are linked Belgian companies who also share the same majority owner and the headquarters. Rocoluc is since 2005 owned for 50 % by a physical person and for 50 % by others. EAC is owned in half (50 %) by Rocoluc, and half by others. The Faculty is also headed by the same physical person as a Managing Director since 15 April 2020. The same physical person again owns 99,92 % of the shares in The Faculty.
(47) Rocoluc and EAC are all class II establishments and held offline B and online B+ licences at the time of the submission of the complaint.
(48) By judgment of 25 June 2024, the Council of State declared unlawful the licences of Rocoluc, namely licences B3892 (offline) and B3892 + (online). The litigation on the validity of these licences is still pending (19).
(49) The Faculty is a class III establishment which holds a C licence allowing it to operate a maximum of two automatic gaming machines and a maximum of two machines with reduced stakes in a class III or drinking establishment.
2.5. Classification of licences held by Ladbrokes
(50) Ladbrokes is a class IV establishment and holds the following licences:
—
A class F1 licence, with number FA116428, which was granted by the Gaming Commission on 2 February 2011, which allows the operation of a class IV betting establishment.
—
A class F2 licence, which allows bets to be taken on behalf of the licencee of class F1, in a class IV fixed or mobile gaming establishment. That licence also makes it possible to take bets outside a class IV gaming establishment in the cases referred to in Article 43/4 (1), (5) and (2) of the Gaming Act.
—
An additional class F1+ licence allowing the exploitation of bets via an information society tools (‘online’) with number FA+116482 granted by the Gaming Commission on 2 April 2014.
2.6. Ad hoc ‘authorisations’ for virtual betting
(51) On 9 February 2014, Ladbrokes requested by e-mail the Gaming Commission’s view on its plans to proceed with the launch of a new product, betting on virtual sports events (regarding land-based or ‘offline’ virtual betting, i.e. in betting outlets).
(52) On 10 February 2014, an official at the Gaming Commission with no power of representation, replied by way of an e-mail to Ladbrokes: ‘After internal consultation, I can tell you that your project complies with the Gaming Commission’s note on offline virtual betting. I can therefore give you the go-ahead for this’.
(53) Following another enquiry by e-mail from Ladbrokes dated 5 March 2015 (regarding online virtual betting), the Gaming Commission confirmed by e-mail on the same day that Ladbrokes could operate online virtual betting.
(54) On 9 September 2015, following reactions received from the sector, the Gaming Commission came to ‘new insights’ as to the classification of virtual betting and set up a sub-commission to investigate whether legal action was required to regulate virtual betting.
(55) In addition, Ladbrokes, two other class IV operators, Stanleybet (20) and Sagevas (21) submitted requests for an authorisation to offer virtual betting to the Gaming Commission in 2015 and 2016.
(56) Specifically, on 28 October 2015, Stanleybet requested ‘authorisation’ to operate virtual betting. The Gaming Commission replied that given the recent establishment of the sub-commission, it would only deal with the request once the results of the activities of the sub-commission were known. Stanleybet submitted a second request on 17 June 2016. The Gaming Commission replied initially the submitted file was incomplete. Then, because of a planned meeting on virtual betting announced for next month, it replied on 3 November 2016 that a regulatory initiative on virtual betting was being discussed.
(57) In 2016, another operator Sagevas also wrote to the Gaming Commission on 23 August 2016. Its request was considered by the Gaming Commission to be incomplete. Later, on 3 November 2016, the same day as to Stanleybet, the Gaming Commission replied to Sagevas along the same line as to Stanleybet that a regulatory initiative on virtual betting was being discussed.
(58) In a report dated January 2016 (22), the sub-commission recommended the creation of a specific legal framework for offline virtual betting and the suspension of the Framework note of 1 July 2015. It also recommended the suspension of the ‘authorisation’ granted to Ladbrokes, to take effect as of 1 April 2016, in order to provide for a transitional period in line with usual administrative practices (23).
(59) On 13 January 2016, following the advice of the sub-commission on the need to adapt the regulatory framework, the Gaming Commission adopted a first transitional decision (24), whereby it suspended the 2015 Framework note effectively as from 1 June 2016, along the interpretation of the existing rules in the Gaming Act provided to Ladbrokes (the so-called ‘authorisation’). In its decision to do so, the Gaming Commission stated that ‘the current regulation on virtual offline betting, by means of the note of 1 July 2015, does not provide an adequate Framework for such games.’
(60) On 1 June 2016 (25) and on 2 January 2017 (26), the Gaming Commission adopted two other transitional decisions delaying the suspension of the Framework note and of Ladbrokes’ right to operate virtual betting until 30 June 2017‘for reasons of legal certainty’.
2.7. Suspension of the ‘authorisations’ for virtual betting
(61) On 31 May 2017, the Dutch-speaking Court of First Instance of Brussels (27) handed down an interlocutory judgment against the Belgian State, at the request of the complainants. The court considered that virtual betting had prima facie the characteristics of both betting and automatic games of chance, without, however, defining virtual betting as falling with certainty under one of these two categories. Subject to a decision on the merits of the case or to the setting-up of a regulatory framework for virtual betting, the court ordered the Belgian State to suspend the ‘authorisation’ granted to Ladbrokes. The Belgian State lodged an appeal against that judgment, which had no suspensory effect. In order to comply with this judgment, the Gaming Commission decided to stop postponing the suspension of the Note of 1 July 2015, which was thus suspended on 1 July 2017.
(62) As a result, no operator, including Ladbrokes, was permitted to provide virtual betting in Belgium.
(63) Notwithstanding that suspension, Ladbrokes did not stop offering virtual betting in its betting outlets. As a result, several gaming operators brought legal proceedings against Ladbrokes to ensure that it would refrain from operating virtual betting machines (28).
(64) In a judgment of 19 September 2019, the Council of State ruled that, through the Framework Note of 1 July 2015, the Gaming Commission ‘allowed, without being empowered, the organisation of [virtual betting], while the Act of 7 May 1999 did not allow it.’ Therefore, the Council of State annulled the three Framework Notes of 12 January 2012, 17 April 2013 and 1 July 2015 and the transitional decision of 2 January 2017, which according to the Council prolonged the effects of the note of 1 July 2015 and in which explicit reference is made to the fact that no request for the operation of virtual betting can be put on the agenda of the Gaming Commission.
2.8. Preliminary findings in the Opening Decision and the Supplementary Opening Decision
2.8.1. Preliminary findings in the Opening Decision
(65) Based on the information provided by the complainants, Ladbrokes and the Belgian authorities, in the Opening Decision the Commission assessed the allegations as to a possible aid to Ladbrokes for the alleged exclusive right to operate virtual betting services in Belgium.
(66) The Opening Decision was based on the information at the disposal of the Commission at the moment of its adoption, as provided by the Belgian authorities and third parties. The Commission took the preliminary view that the contested measure may constitute State aid, since it may:
—
confer Ladbrokes an advantage granted from State resources in the form of a de facto exclusive right to provide virtual betting in Belgium without paying adequate consideration for that right,
—
be selective, since the contested measure applied only to Ladbrokes,
—
be imputable to Belgium, since the authorisation granted to Ladbrokes as well as the Framework Note on the basis of which that authorisation was granted were adopted by the Gaming Commission, a public body.
—
be liable to distort competition and affect trade between Member States, since the aid in question is operating aid that strengthens Ladbrokes’ position as compared to its competitors and gaming is a liberalised, competitive market, with several operators besides Ladbrokes, such as the complainants, active in Belgium, and with Ladbrokes active in several other Member States.
(67) On that basis, the Commission preliminarily concluded that Ladbrokes would have enjoyed a de facto exclusive right without paying any specific (licence) fee to provide virtual betting in Belgium during a certain period between 10 February 2014 (i.e. e-mail granting authorisation to operate to Ladbrokes) and 4 May 2018 (i.e. adoption of the 2018 Royal Decree regulating the offline virtual betting and the establishments allowed to operate).
(68) It is noteworthy that some of the facts described in the Opening Decision changed after the adoption of that decision. Following proceedings lodged at national level by the complainants, on 7 May 2021 the Belgian Council of State retroactively annulled the 2018 Royal Decree (29). It found that:
—
the conditions for operating automatic games of chance on virtual sports events set out in the 2018 Royal Decree were incomplete. Therefore, by allowing, through the transitional regime established by Articles 19 and 20 of the 2018 Royal Decree (30), the operation of Gaming on virtual sports events while all the conditions for its operation had not yet been established, the 2018 Royal Decree violated Article 43/4, § 2, paragraph 3, of the Gaming Act;
—
no sufficient legal basis allows the King to delegate to the Gaming Commission the power to adopt a protocol (provided for by Article 15 of the 2018 Royal Decree) (31) containing regulatory standards, whether they pertain to detailed or technical matters. Since the annulment of Article 15 alone would result in a revision of the 2018 Royal Decree, as it would leave it in effect without requiring all the operating conditions that the King deems necessary, it was necessary to annul the entire 2018 Royal Decree.
2.8.2. Preliminary findings in the Supplementary Opening Decision
(69) Following the annulment of the 2018 Royal Decree, the complainants and the Belgian authorities submitted further comments and information described in chapters 3 and 4 below. On that basis, the Commission adopted a Supplementary Opening Decision.
(70) The initial preliminary view of the Commission was that Ladbrokes possibly benefitted from a de facto exclusive right and therefore aid at earliest from 10 February 2014 and at latest until 4 May 2018. The Commission amended this preliminary view by extending the possible duration of the measure in the Supplementary Opening Decision until today.
(71) The Commission found that it would need to investigate whether the implications of the transitional measure included in Articles 19 and 20 of the 2018 Royal Decree preferentially advantaged Ladbrokes, as it was the only operator who could continue exploiting the virtual betting terminals it was operating before the adoption of the 2018 Royal Decree, without having to bring these games into conformity with the protocol to be adopted by the Gaming Commission pursuant to Article 15 of the 2018 Royal Decree (recital 39 of the Supplementary Opening Decision).
(72) Therefore, the Commission’s amended provisional conclusion was that Ladbrokes possibly enjoyed a de facto exclusive right to provide virtual betting in Belgium during a period starting on 10 February 2014 at the earliest (recital 49 of the Supplementary Opening Decision).
(73) It is noteworthy that both in the Opening Decision (recital 60) and the Supplementary Opening Decision (recital 42), the Commission found that the Belgian authorities have not offered any grounds in support of declaring that the contested measure could be compatible with the internal market. Nor did the Commission have any indication that that measure, if it would constitute State aid, could be considered compatible with the internal market.
3. COMMENTS FROM THIRD PARTIES ON THE OPENING AND SUPPLEMENTARY OPENING DECISIONS
3.1. Comments from the complainants
(74) The complainants Rocoluc and EAC submitted their comments on the Opening Decision on 18 November 2020, while their sister company The Faculty sent its complaint on 23 February 2024. The summary of all three complaints as well as their subsequent additional comments and information provided in the investigation is set out below.
3.1.1. Comments on the exclusivity by Ladbrokes
(75) In their submission of 18 November 2020, the complainants Rocoluc and EAC submitted that both Ladbrokes and the Belgian State had been acting to preserve Ladbrokes’s unlawful right to operate virtual betting and to dissuade Rocoluc and EAC from taking action against that unlawful situation.
(76) Rocoluc and EAC claim that the 2018 Royal Decree does not allow class IV operators to lawfully offer virtual betting in Belgium. Accordingly, the 2018 Royal Decree cannot be considered as having put an end to the unlawful State aid. Rocoluc and EAC also provide additional information with regard to the amount of unlawful State aid that the Commission should order the Belgian authorities to recover from Ladbrokes.
(77) In its complaint of 23 February 2024, The Faculty nonetheless points out that, unlike the complaint submitted by Rocoluc and EAC, its complaint is specifically targeted at the aid linked to the offering of the so-called ‘offline’ or ‘land-based’ virtual betting games in Ladbrokes’ betting offices. In addition, The Faculty notes that as an operator of a class III gaming establishment, it cannot be active online and, therefore, has not been negatively affected by the offering of virtual betting games via Ladbrokes’ website(s).
(78) According to the complainants, Ladbrokes obtained an ad hoc authorisation outside of the legal framework by means of two e-mails from the Gaming Commission dated 10 February 2014 (for offline virtual betting in Ladbrokes’ betting offices) and 5 March of 2015 (for online virtual betting on Ladbrokes’ website).
(79) In the complainants’ view, the alleged aid at issue involves State resources because the ad hoc authorisation in favour of Ladbrokes has been granted free of charge. Hence, the Belgian authorities waived their right to a significant part of State revenues and granted an economic advantage to Ladbrokes. As to the imputability of the alleged aid, the complainants underline that the Gaming Commission is an administrative public authority established within the Federal Public Service for Justice and thus falls under the responsibility of the Minister of Justice.
(80) The complainants bring forward that the exclusive right and the corresponding alleged State aid in relation to the offline virtual betting games was granted on 10 February 2014 because the unlawful Framework Notes of the Gaming Commission were specifically designed to allow Ladbrokes to exclusively operate virtual betting. Accordingly, the basic error of the Gaming Commission was not the refusal to withdraw Ladbrokes’ ad hoc authorisation in January 2016 but the initial granting of the authorisation in February 2014.
(81) Moreover, in relation to the end date of the aid, the complainants underline that following the annulment of the 2018 Royal Decree by means of the judgment of the Council of State of 7 May 2021, the 2018 Royal Decree must be regarded as non-existent and cannot be considered as an act allowing the exploitation of virtual betting in Belgium. This also means that the date of 4 May 2018, on which the annulled 2018 Royal Decree was adopted, is no longer relevant to assess the duration of the alleged State aid granted to Ladbrokes.
(82) In that context, the complainants argue that the judgment of the Council of State would confirm that Ladbrokes has in fact benefited from a selective aid measure until at least 7 May 2021 for offline virtual betting. In their view, the Council of State stated that the sole purpose of the transitional measure laid down in Article 19 of the 2018 Royal Decree was to allow the F2 licence holder, meaning Ladbrokes, to resume the exploitation of the virtual betting terminals it was operating before the adoption of the 2018 Royal Decree and not to have to bring these games into conformity with the protocol to be adopted by the Gaming Commission pursuant to Article 15 of the 2018 Royal Decree.
(83) Accordingly, except for Ladbrokes that benefitted from the aforementioned transitional measure, the 2018 Royal Decree stated that no virtual betting could be offered, awaiting the adoption of the protocol. Therefore, in the complainants’ view, the 2018 Royal Decree merely formalised Ladbrokes’ de facto monopoly. However, they inform that this position would not have been accepted by the Belgian Council of State. The Council took the view that the transitional measure allowing Ladbrokes to offer virtual betting games before virtual betting has been finally legally regulated with the adoption of the legal act, which will lay down the necessary conditions of virtual betting (among others where it can be offered), would not be in line with the Gaming Act.
(84) The Faculty also argues that several gaming operators have successfully brought proceedings against the Belgian State and/or Ladbrokes. It cites a judgment of 28 March 2018 in which the Brussels Commercial Court decided in favour of the Belgian professional federation of pub owners (La Fédération des cafés de Belgique ASBL) and ordered Ladbrokes to cease its offline virtual betting activities. According to The Faculty, this judgment was later confirmed by the Court of Appeal by means of a judgment of 9 August 2019.
3.1.2. Comments on the applicable framework on virtual betting in Belgium
(85) Firstly, as regards the applicable legal framework, Rocoluc and EAC underline that virtual betting is a ‘hybrid’ game of chance that is at the interference between betting and automatic games of chance. In that context, they cite the statement of the submission by the Belgian authorities according to which it is ‘not easy to classify [this hybrid product] within the existing legal Framework of the Gaming Act’.
(86) They reiterate that the alleged exclusive right granted to Ladbrokes was manifestly unlawful under Belgian law as it was based on an erroneous qualification of virtual betting.
(87) Secondly, they argue that the doubts cast by the Belgian authorities as to the legal value of the Framework Notes adopted by the Gaming Commission (recital 49 of the Opening Decision) are particularly appropriate. In particular, they point out that in the context of the ongoing proceedings before the national courts, the Belgian authorities have unequivocally confirmed that the authorisation granted to Ladbrokes to operate virtual betting in Belgium was not a ‘traditional’ gaming licence but an ‘ad hoc’ authorisation and that virtual betting is an activity ‘not regulated by the Gaming Act’. In their view, this statement clearly refutes the reasoning that Ladbrokes’ authorisation to offer virtual betting was based on and formed part of the national reference system on betting. In addition, they underline that the doubts expressed by the Belgian authorities cannot be reconcile with the fact that the Gaming Commission imposed a temporary suspension of Ladbrokes’ licence for not ceasing to provide virtual betting after 1 July 2017. They also argue that in a judgment of 19 September 2019, the Council of State ruled that the Gaming Act would not allow the organisation of virtual betting and therefore annulled the Framework Notes.
(88) Thirdly, they note that the questions as to the publicity of the Framework Notes referred to in the Opening Decision, footnotes 5 to 7 and recital 49 have already been settled in the context of the annulment proceedings against these Framework Notes before the Belgian Council of State. In the context of these proceedings, Rocoluc would have demonstrated that the initial Framework Notes dated 12 January 2012 and 17 April 2013 have not been made public but were only communicated to Rocoluc on 14 April 2017 in the context of the legal proceedings against the Belgian State. Allegedly, the Gaming Commission did not question these findings. The Council of State accordingly decided that Rocoluc could extend its action to these Framework Notes.
(89) Fourthly, they put forward that even though the 2018 Royal Decree was adopted in an attempt to remediate the illegal character of virtual betting, the Gaming Commission had still not adopted the protocol with ‘the necessary technical requirements on games of chance on virtual sporting events’ provided in Article 15 of the 2018 Royal Decree.
3.1.3. Comments on the national legal proceedings in relation to virtual betting
(90) In this context, Rocoluc and EAC argue that contrary to what the Commission seems to suggest (recital 21 of the Opening Decision), the national legal proceedings on the legality of the Framework Notes were not linked to the effective suspension of the Framework Notes and of Ladbrokes’ ad hoc authorisation to operate virtual betting on 1 July 2017. They also inform on Stanleybet’s damages claim file against the Belgian State on 14 December 2016. following which the Court ordered the Belgian State to compensate Stanleybet for the damages suffered.
(91) The complainants also informed the Commission services that on 28 March 2017, Rocoluc and EAC also initiated damages claim against the Belgian authorities. The proceedings would still be pending due to backlog at the Brussels Court of Appeal.
(92) Further, they explain that the appeal brought by Ladbrokes against the cease and-desist order of 15 February 2018 is still pending before the Brussels Court of Appeal. The Brussels Court of Appeal did however render a judgment to Ladbrokes’ appeal against the decision of the Brussels Commercial Court of 28 March 2018. In its judgment of 9 August 2019, the Court of Appeal rejected Ladbrokes appeal and confirmed the previous order issued against Ladbrokes to cease virtual betting activities. Rocoluc and EAC have however been informed that Fédération des Cafés de Belgique ASBL (32) (hereinafter, ‘FedCaf’) and the Belgian authorities would have concluded an agreement whereby the latter would refrain from taking further action against Ladbrokes.
(93) Finally, Rocoluc reiterates its position that the 2018 Royal Decree ignores the hybrid character of virtual betting and that the transitional provision laid down in Article 19 of the 2018 Royal Decree illegitimately rewards Ladbrokes for not having halted the illegal exploitation of virtual betting in due time and guarantees that Ladbrokes can further benefit from its ad hoc authorisation.
3.1.4. Comments on the duration of the alleged State aid to Ladbrokes
(94) Rocoluc and EAC consider that the exclusive right and the corresponding alleged State aid granted to Ladbrokes would have been granted on 10 February 2014. They recall that, from the very beginning, the Framework Notes, which they consider to be unlawful, were designed to allow Ladbrokes to exclusively operate virtual betting in Belgium. The Framework Notes of 2012 and 2013 would have been adopted following a request from Ladbrokes and not made public. It was only with the announcement in September 2015 in relation to the setting-up of a special sub-commission that other gaming operators were informed about the unlawful Framework on virtual betting.
(95) In the complainants’ view, once the other operators were informed about the possibilities to offer virtual betting, the Gaming Commission denied other operators to operate virtual betting. In particular, according to the complainants, Stanleybet’s request for authorisation submitted on 28 October 2015 remained unanswered, whereas on 10 February 2014 and 5 March 2015 Ladbrokes had received a confirmation to provide land-based and online virtual betting in less than one day. They claim there is no objective justification for this different treatment.
(96) In response to the Commission’s finding that the exclusive right ended on 4 May 2018, at the latest, or 1 July 2017, at the earliest (recital 55 of the Opening Decision), Rocoluc and EAC consider that the date of 4 May 2018 (i.e. the date of the adoption of the 2018 Royal Decree) has not put an end to the preferential treatment of Ladbrokes and can therefore not be considered as the date on which Ladbrokes would no longer have benefitted from unlawful State aid.
(97) In addition, they reiterate that the Gaming Commission did not adopt the protocol provided in Article 15 of the 2018 Royal Decree with ‘the necessary technical requirements on games of chance on virtual sporting events’, meaning that any operation of virtual betting was to be considered as unlawful until then. In the absence of general, clear and transparent criteria, the Belgian authorities necessarily would have a wide margin of discretion when authorising and controlling virtual betting in Belgium. As a result, even if Ladbrokes is currently no longer the only operator offering virtual betting in Belgium, the Belgian State’s tolerance towards virtual betting services offered by one (or several) operators would still constitute a selective State aid granted to that (those) operator(s).
3.1.5. Comments on the amount of aid
(98) Rocoluc and EAC consider that the Commission would be in a position to exactly identify the amount of aid received by Ladbrokes and therefore invite the Commission to determine itself the amount of the aid and the interest to be recovered by the Belgian authorities.
(99) The complainants provide a table with estimations on the aid that Ladbrokes allegedly received based on the 2017 gross gaming revenue in Ladbrokes’ betting offices. The complainants argue that reference can be made to the consideration paid by the National Lottery in exchange for the exclusive right to operate lottery games.
3.1.6. Comments on the retroactive annulment of the 2018 Royal Decree in 2021
(100) After the adoption of the Opening Decision, on 26 May 2021 the Commission received further submissions from the complainants, informing the Commission that on 7 May 2021 the 2018 Royal Decree has been retroactively annulled (meaning that it should be considered as non-existent) and it cannot be considered as having put an end to the alleged aid granted to Ladbrokes.
(101) As regards the duration of the alleged aid, the complainants consider that, following the judgment of the Council of State of 7 May 2021, the 2018 Royal Decree would be regarded as non-existent in Belgian law and can therefore not be considered as an act allowing the exploitation of virtual betting in Belgium. This also means that the date of 4 May 2018, on which the annulled 2018 Royal Decree was adopted, is no longer relevant to assess the duration of the alleged State aid granted to Ladbrokes.
(102) In addition, the complainants put forward that the aforementioned judgment of the Council of State would confirm that Ladbrokes has benefited from a selective aid measure until at least 7 May 2021. In their view, the Belgian authorities would still tolerate Ladbrokes` virtual betting activities while those activities are illegal under Belgian law.
(103) The complainants consider that the Council of State’s judgment of 7 May 2021 would confirm that the sole purpose of the transitional measure laid down in Article 19 of the 2018 Royal Decree was to allow ‘the F2 licence holder’ (33), meaning Ladbrokes, to resume the exploitation of the virtual betting terminals it was operating before the adoption of the 2018 Royal Decree and not to have to bring these games into conformity with the protocol to be adopted by the Gaming Commission pursuant to Article 15 of the 2018 Royal Decree.
3.1.7. The complainants’ arguments for an extension of the Opening Decision
(104) In the meeting held with the Commission services on 23 February 2023, the complainants EAC and Rocoluc reiterated the request for a corrective opening decision extending the duration of the alleged aid. In particular, they claimed that the retroactive annulment of the 2018 Royal Decree constitutes a substantial change. Accordingly, the relevant investigated period should be extended: (i) until 7 May 2021 for offline virtual betting, since no operators are allowed to operate nor actually operate offline virtual betting after this date, and (ii) indefinitely for online virtual betting, because even though it is currently not allowed, Ladbrokes is still offering online virtual betting.
(105) According to the complainants, the annulment of the 2018 Royal Decree, which only regulated offline virtual betting, must be considered as having the same implications for online virtual betting. However, despite the 2018 Royal Decree being annulled, Ladbrokes was still offering online virtual betting.
(106) On 23 February 2024 the Commission received a submission from The Faculty, which holds a class III with a licence C. The submission concerns the same contested measure but exclusively relating to the alleged aid linked to the offering of offline virtual betting games in Ladbrokes’ betting offices. Indeed, The Faculty argued that as an operator of a class III gaming establishment, it cannot be active online and, therefore, has not been negatively affected by the offering of virtual betting games via Ladbrokes` website(s).
3.1.8. Comments on the Supplementary Opening Decision
(107) As a preliminary comment, Rocoluc and EAC point to a material error in the Supplementary Opening Decision Commission recitals 8 and 24, wrongly stating that the complainants and the Commission would have- held a meeting on 23 February 2023 instead on 16 February 2023.
(108) Second, as regards the definition of virtual betting, Rocoluc and EAC refer to their complaint of 1 March 2019 where they explained that virtual betting concerns a ‘hybrid’ product that takes place at the interface between real betting and automatic games of chance. Although the Belgian authorities would have explicitly confirmed that virtual betting is indeed a hybrid product, they would in fact always have denied the hybrid character of virtual betting.
(109) According to the complainants, in the context of the Framework Notes of the Gaming Commission, virtual betting was wrongfully equated with real betting, whereas in the 2018 Royal Decree it was (re)qualified as an automatic game of chance.
(110) Third, Rocoluc and EAC reiterate their comments in relation to the assessment of the duration of the unlawful State aid granted to Ladbrokes by referring to their submission of 18 November 2020.
(111) In this context, Rocoluc and EAC underlined that the alleged ‘uncertainty’ in relation to the legal framework applicable to virtual betting is solely fuelled by the Belgian State (see recitals 58-60).
(112) As for online virtual betting, Rocoluc and EAC recall that, under Article 43/8 of the Gaming Act, so-called supplementary A+, B+ or F1+ licences for online games of chance can only be granted for the operation of games of the same nature as those offered in the real world. They argue that in view of this provision, the Belgian State has previously held that Ladbrokes’ ad hoc authorisation for online virtual betting was linked to its authorisation for offline virtual betting. Accordingly, in so far as Ladbrokes would have been the only operator to have obtained an ad hoc authorisation for the operation of virtual betting in its betting offices by the Belgian authorities, it would also be the only operator that could provide online virtual betting and the only operator that would actually have received an unlawful ad hoc authorisation for online virtual betting by e-mail of 5 March 2015. This preferential treatment would have logically persisted under the 2018 Royal Decree. Afterwards, despite the annulment of the 2018 Royal Decree, Ladbrokes is still offering online virtual betting. Consequently, Ladbrokes would still benefit from unlawful State aid with regard to online virtual betting.
3.2. Comments from Ladbrokes
(113) In its submission dated 18 December 2020, Ladbrokes provides comments on the Opening Decision. In the additional submissions of 22 November 2024, 9 December 2024 and 21 January 2025, it provided further comments.
3.2.1. Comments on the complainants lacking the status of interested parties
(114) Ladbrokes reports that the Council of State, by judgment of 25 June 2024 (34) declared unlawful the licences of Rocoluc, namely licences B3892 (offline) and B3892 + (online). In its view, the Council of State could only annul the abovementioned licences with retroactive effect.
(115) Therefore, according to Ladbrokes, Rocoluc would no longer have an interest in the present proceedings, since it is not and cannot be active in the gaming sector under Belgian law. Rocoluc could therefore not be regarded as a complainant active in the gaming sector, or at least as a legitimate competitor of Ladbrokes. Hence it would not be an ‘interested party’ within the meaning of Article 24(2) of Council Regulation (EU) 2015/1589 (35).
3.2.2. Comments on the licences held by Ladbrokes
(116) Ladbrokes stresses that it held and still holds all required classes of licences granted by the Gaming Commission, meaning F1, F1+ and several class F2 licences, allowing it to accept bets and to organize and offer bets in Belgium, both online and offline. In addition, Ladbrokes informs that at the time there were thirty-five F1 licence holders in Belgium.
3.2.3. Comments on the legal framework of virtual betting in Belgium
(117) As to the online virtual betting, in Ladbrokes’ view, a notification to the Gaming Commission from the class F1+ licence holder was sufficient. Ladbrokes states that this explains why in February 2014 a Gaming Commission, official with no power of representation confirmed by way of a short e-mail that Ladbrokes could start offline betting on virtual events and asked for further reporting on the activity.
(118) Ladbrokes also states that for the same reason on 5 March 2015, again a Gaming Commission official with no power of representation confirmed to Ladbrokes, by way of a short e-mail, that it could offer virtual bets online via its website.
(119) Ladbrokes puts forward that the Gaming Commission would not be competent to change the applicable regulation by means of a Royal Decree, which can only be proposed and countersigned by the competent Minister.
(120) Ladbrokes explained that on 1 June 2016, the Gaming Commission changed its position. The Gaming Commission (i) confirmed that class F1 licence holders may file a new application to offer virtual betting, subject to the conditions set out in the earlier Note of 1 July 2015; (ii) decided to suspend the Framework Note of 1 July 2015 and the granted approvals as from the entry into force of the 2018 Royal Decree, and (iii) as long as this entry into force was expected on 1 January 2017, decided to postpone the date of the suspension of the said Note until 1 January 2017.
(121) On 2 January 2017, the Gaming Commission postponed again the entry into force of the suspension of the Note of 1 July 2015, this time to 30 June 2017.
(122) The Gaming Commission also decided that ‘no new authorisation to operate will be put on the agenda’. Ladbrokes informs that on 27 July 2018 the Gaming Commission sanctioned Ladbrokes by a decision, which suspended Ladbrokes’ FA116428 licence and the FA + 116428 licence for a period of one day, on 3 September 2018.
(123) Ladbrokes further claims that the question of the lawfulness of the operation of virtual betting as ‘betting’ remains open. In its view, the argument that it would indeed be ‘betting’, the exploitation of which is covered by the F1, F2 and F1 + licences, would retain all its merits. But the question would still be pending before the national court, which has not yet ruled on the matter.
3.2.4. Comments on the absence of an ‘authorisation’ with valid licences required for operating virtual betting
(124) As a preliminary observation, Ladbrokes refers to the Opening Decision in which the Commission states that ‘the exercise of Ladbrokes’de facto exclusive right had begun: ‘not earlier than 10 February 2014, the date on which the Belgian Gaming Commission (…) granted Ladbrokes, by e-mail, the right to operate virtual offline betting (recital 53 of the Opening Decision) (…)’.
(125) Ladbrokes argues that this sentence is factually incorrect, in two respects. First, the Gaming Commission would not have granted Ladbrokes any rights. It only confirmed that the licences already held by Ladbrokes allowed the exploitation of virtual betting. Second, the e-mail message of the Gaming Commission on 10 February 2014 does not refer to exclusivity. While Ladbrokes, as the holder of licences F1, F1+ and F2, had the possibility to offer virtual betting, the same applied to the other holders of such valid licences. The fact that no other F1 licensee asked the Gaming Commission to operate virtual betting does not provide for exclusive rights to Ladbrokes.
(126) Further, Ladbrokes notes that the Gaming Commission is only authorized to deliver specific classes of licences to operate games of chance / betting in conformity with the Gaming Act. The Gaming Commission is not allowed by the Gaming Act to enact guidance with a binding effect of general application. Ladbrokes explained that it requested guidance from the Gaming Commission about a planned new activity, betting on virtual events, as early as 2011, as this is good practice in a regulated industry.
(127) Since virtual betting was considered to be betting and all legal and regulatory obligations applicable to betting are declared applicable to virtual betting, no specific licence or authorisation had to be provided for their exploitation. The exploitation of virtual betting was already covered by licences F1, F2 and F1 +. The Gaming Commission therefore did not grant Ladbrokes a licence for virtual betting.
(128) The e-mails sent by the Gaming Commission on 10 February 2014 and on 5 March 2015, were a confirmation that Ladbrokes could operate because it held the relevant licences. At any case, these e-mails, sent by a Gaming Commission’s official with no power of representation, could not be considered as a formal authorisation as they are neither foreseen within the framework of the Gaming Act, nor do they have any other legal basis. At most they could be seen as a mere recognition by the Gaming Commission that the envisaged activity was within the scope of the F1 licence already held by Ladbrokes and was therefore legal.
3.2.5. Comments on no intention to give exclusivity to Ladbrokes
(129) Ladbrokes puts forward that with the aforementioned confirmative e-mails the Gaming Commission had no intention to grant Ladbrokes an exclusivity of any kind. In its view, an exclusivity would run counter to the Belgian authorities’ policy aim of ‘channelling’. With the exception of the Loterie Nationale (a company entirely held by the Belgian State), the Belgian authorities would strive to satisfy customers’ demands by having a multiplicity of regulated operators competing for that demand. Moreover, Ladbrokes refers to the Framework Notes of the Gaming Commission confirming the legality of betting on virtual events for every holder of an F1 Licence dated 12 January 2012, 17 April 2013 and 1 July 2015. All these operators could have started a virtual betting activity, none did at the time, presumably because of the size of the investments and the business risk.
(130) Moreover, as from 13 January 2016 (date of the decision to suspend the Framework Note of 1 July 2015), the ‘authorisation’ of Ladbrokes was suspended. Accordingly, Ladbrokes was supposed to effectively stop offering virtual betting from 1 June 2016, which date was later modified to 30 June 2017. Ladbrokes argues in that context that it had to operate under the uncertainty of having to stop at any time. There could therefore be no clearer confirmation that Ladbrokes was not granted any exclusivity.
(131) Ladbrokes pointed out that in 2015 and in 2016, two competitors, i.e. Stanleybet and Sagevas, choose to ask for such an ‘authorisation’ i.e. announced that they would offer virtual betting. According to Ladbrokes, the request filed by Stanleybet was deemed to be incomplete by the Gaming Commission. As for Sagevas, it made it public that it would operate the virtual betting without any ‘authorisation’ from the Gaming Commission knowing that there would be no control. In Ladbroke’s view, the Gaming Commission expressly reported this declaration in its note of 2 January 2017, without announcing that there would be no enforcement actions. The mere fact that these requests were filed would show that all class F1 licence holders fully understood that the operation of virtual betting was open to all class F1 licence holders and that no operators considered that Ladbrokes was granted exclusive rights.
(132) In addition, Tiercé Ladbrokes SA, an Entain’s subsidiary in Belgium, as Ladbrokes is, also started offering virtual betting in the bet shops it operated at the same time than Ladbrokes did. Tiercé Ladbrokes did not receive any ‘authorisation’ from the Gaming Commission. Tiercé Ladbrokes is a different legal entity and given the formality that characterizes the sector-specific regulation (if an ‘authorisation’ or licence is awarded, it is always to a specific legal entity), this fact also shows that Ladbrokes was not granted any exclusivity.
(133) Ladbrokes further clarifies that contrary to the Commission’s preliminary findings (recital 54 of the Opening Decision), it is only in January 2017 that the Gaming Commission reversed its policy and decided not to grant any new ‘authorisation’, since the government was preparing a Royal Decree setting up conditions governing virtual betting.
(134) Ladbrokes sustains that from a legal viewpoint, the decision of the Gaming Commission to stop granting ‘authorisations’ for virtual betting had no legal consequence. Namely, the ‘authorisations’ that the Gaming Commission suspended were only foreseen by the Gaming Commission’s as interpretative guidance, but they had no binding value, since in any event the Gaming Commission cannot adopt mandatory and enforceable rules of general application.
(135) Therefore, despite this change of policy, holders of class F1 licences could have proposed virtual betting to their customers under the scope of such licences. They could have fended off possible legal challenges with the argument that they were entitled to propose betting on virtual events, as was the Gaming Commission’s own view until 2016, by the mere combination of their existing licence and Article 4 of the Gaming Act. That is exactly what Ladbrokes did as from 1 July 2017. It pursued the operation of virtual betting under the benefit of its F licences alone. Sagevas declared in 2016-2017 it would also operate virtual betting without any authorisation from the Gaming Commission. The exact reason why it did not do so in the end is not known to Ladbrokes.
(136) Here again, the fact that competitors did not start virtual betting operations after January 2017 is a consequence:
—
of the Gaming Commission’s decision not to assess any new application for ‘authorisation’, pending the adoption of the 2018 Royal Decree (that everybody thought imminent, which was ultimately proved to be wrong), and,
—
of the decision of these two operators not to challenge this change of policy or to operate the activity under the benefit of their licence alone.
3.2.6. Evidence on competition in the virtual betting market
(137) Ladbrokes claims that it effectively faced competition. It provided information, gathered from written pleadings and web searches, with regard to virtual betting services.
(a) Online virtual betting
(138) Ladbrokes claims that online activity represents significant competition to Ladbrokes` offline activity, acknowledged by the Commission in its Decision for Online Gaming in the Danish Gaming Duties Act (36) in which the Commission concluded that ‘online and land-based casinos should be perceived as legally and factually comparable. As both online and land-based gaming pose the same risks, the notified measure addresses both online and land-based gaming’.
(139) Ladbrokes submits factual evidence on the existence of several operators offering virtual betting online. In particular, its submission includes screenshots of the websites operated by several betting operators in Belgium. There was an offer by the operator BetFirst.be, which provided different kinds of virtual betting for events such as sports and other events in December 2014. Other evidence shows the screenshots of the online offer for virtual betting events of several other operators:
—
the website Circus (37) offered ‘Virtual Sports Events’, with a clear indication of virtual betting under ‘sports betting’, as a clear counterpart of ‘live betting’.
—
the website Golden Vegas (38) offered virtual betting.
—
the website Bingoal! (39) offered as well ‘virtueel’ in Dutch in the form of ‘virtual football’, ‘virtual horse racing’, ‘virtual tennis’ and ‘virtual dog running’.
—
the website 36win (40) offered ‘virtual’.
(b) Offline virtual betting
(140) Ladbrokes provides copies of several tickets for virtual sports betting bought for different amounts and which gained different amounts at the physical offices of another operator Stanleybet in April, September, and October 2019. It is visible from the copies that the tickets were issued by Stanleybet in Belgium and have different serial numbers, while all of them are issued for virtual sports (betting).
(141) Ladbrokes also provided the photographs of different screens taken in the offices of Stanleybet. The screens show that the betting took place in April 2019 in one of Stanleybet’s offices in Belgium. They also clearly show that the game played was virtual sports betting.
3.2.7. Subsidiary arguments concerning the ‘de facto’ exclusivity as regards the duration of the alleged aid
(142) Ladbrokes argues in the alternative, assuming that Ladbrokes was granted an exclusivity (quod non), that the period during which Ladbrokes could enjoy this was shorter than the Commission states, as Ladbrokes faced several legal challenges to its activity. This is because the Gaming Commission only decided to suspend the analysis of the ‘authorisation’ requests of competitors on 2 January 2017
(143) As the ‘authorisation’ granted to Ladbrokes itself was also suspended with effect on 1 July 2017, there can also be no ‘exclusivity’ granted by the Belgian authorities to Ladbroke after that date. The fact that the Belgian State did not initiate legal proceedings against Ladbrokes after 1 July 2017 in order to have the activity stopped does not amount to the granting of an ‘exclusivity’ with a market value.
(144) Ladbrokes informs that it stopped offering virtual betting on 30 March 2018, to comply with an injunction of the Brussels Commercial Court requested by Fédération des cafés de Belgique, which was served.
(145) Finally, Ladbrokes also puts forward that there would be no reason to extend the period of the alleged aid measures (see recitals 38-40 in the Supplementary Opening Decision).
3.2.8. Subsidiary arguments concerning the ‘de facto’ exclusivity as regards the alleged aid amount
(146) In the alternative, even assuming that Ladbrokes was granted an exclusivity (quod non), the profit generated by this would be significantly lower than what the Commission stated in the Opening Decision (footnote 26). Ladbrokes provides the following gross profit figures for offline and online virtual betting for the period January to June 2017:
(a)
the gross profit figures of the offline virtual betting activity of Ladbrokes SA from January to June 2017:
LADBROKES
JAN – JUN
2017
JAN
FEB
MAR
APR
MAY
JUN
GGR
10 391 808
1 771 459
1 664 138
1 820 429
1 358 982
1 733 687
2 043 114
Tax
-1 558 771
– 265 719
– 249 621
– 273 064
– 203 847
– 260 053
– 306 467
Revenue
Share
– 556 384
-91 688
-86 095
-94 288
-70 394
-89 536
– 124 383
Commission
-1 141 556
– 172 630
– 162 831
– 171 484
– 207 163
– 233 776
– 193 672
Gross Profit
7 135 096
1 241 423
1 165 591
1 281 592
877 578
1 150 321
1 418 592
(b)
the gross profit figures for online virtual betting on the website Ladbrokes.be, from January to June 2017:
JAN-JUN
2017
JAN
FEB
MAR
APR
MAY
JUN
GGR
182 539
33 875
21 435
18 199
38 204
35 075
35 750
Tax
-20 079
-3 726
-2 358
-2 002
-4 202
-3 858
-3 932
Commission
-11 044
-2 049
-1 297
-1 101
-2 311
-2 122
-2 163
Gross Profit
151 416
28 099
17 781
15 096
31 691
29 095
29 654
(147) Ladbrokes argues that these actual figures are markedly lower than the EUR 34 600 000 quoted in Footnote 26 of the Opening Decision. In its view, even assuming that Ladbrokes enjoyed (i) an exclusivity (ii) worth compensating (both elements being not established), it would be incorrect in law and fact to assume that the market value of such exclusivity would be superior to the generated profits. Such a reasoning would otherwise imply that an operator would be ready to carry out the activity at a (very significant) loss.
(148) As to the application of the redistribution rate of the Loterie Nationale, it is unjustified, as the Loterie Nationale is a public institution whose aim is to share all its profits with the Belgian State.
4. COMMENTS FROM THE BELGIAN AUTHORITIES
(149) The Belgian authorities submitted observations related to the legal framework governing virtual betting in Belgium and the absence of State aid. In their submissions, the Belgian authorities maintain that there was no State aid granted to Ladbrokes with regard to virtual betting because neither a legal framework existed that would have required a special licence for virtual betting, nor would the Gaming Commission have issued or have the mandate to issue a legally binding authorisation for it.
4.1. Comments on the legal framework on gaming in Belgium
(150) The Belgian authorities explain that it is the Gaming Act which defines the types of licences to operate games of chance. The rules are further elaborated through various Royal Decrees. The Gaming Commission implements these rules within the scope of its competencies. The Gaming Commission can control compliance with the law and decide for instance to initiate sanctions proceedings against a licence holder, but only within the framework of the law and its implementing decrees. The Gaming Commission cannot create new licences or introduce new conditions for obtaining a licence (41). It could however advise the stakeholders on the interpretation of the law.
(151) As to the licence required for a betting shop, the Belgian authorities clarify that that the operation of a class IV gaming establishment requires both a licence F1 and F2.
(152) According to the Belgian authorities, there can be vertical integration between the betting shop and the betting operator, meaning that an undertaking or group of undertakings can hold both F1 and F2 licences. However, an F2 licence holder may also be entirely unrelated from the F1 betting operator whose betting products it sells. In addition to proper betting shops (i.e. class IV gaming establishments), press shops can also acquire an F2 licence and sell certain betting products (albeit under different rules) in their press shop.
(153) Furthermore, the Belgian authorities state that under the law on games of chance in Belgium, there is no definition as such for the word ‘gaming’. Gaming can be reformulated as participating in games of chance. However, the law provides a definition for ‘games of chance’ meaning any game whereby a stake is played, whatever its nature, which leads to the loss of this stake by at least one of the players, or to any type of gain for at least one of the players or organisers of the game, and whereby chance influences the game, the winners of the game or the size of the game, even if only in a secondary manner.
(154) Moreover, the Belgian authorities clarify that a ‘bet’ is defined as a game of chance whereby each player enters a stake and whereby gain, or loss does not result from an act of the players, but from the outcome of an uncertain event that materialises without intervention by the players.
(155) The Belgian authorities state that there is no one overall (automatic) ‘gaming’ market A distinction should be made between different establishment classes. First, the concept of ‘automatic games of chance’ is used to refer to games of chance played on a machine, which is most notably done in gaming establishments of class I (casinos) and class II (gaming halls), but also, to a more limited extent, in other venues i.e. establishments of class III (bars) and of class IV (betting shops). The automatic gaming products offered in class I establishments (e.g. slots) are different from those offered in class II establishments (e.g. automatic dice games) and are subject to different regulations. This difference is even more substantial when comparing the machines in class I or class II establishments with those in class III or IV establishments.
(156) Finally, given the significant moral, religious and cultural differences between the different Member States and the lack of European harmonization in the gaming sector, each Member State remains free to determine its own gaming policy and the restrictions which it deems necessary to protect its own public interest. The only requirement imposed by EU law would be that such restrictions are (i) proportionate in that they are suitable for achieving the objective or objectives invoked by the Member State concerned, and do not go beyond what is necessary to achieve those objectives, and (ii) are applied without discrimination. Restrictions would normally satisfy the proportionality test if they fit in a coherent and systematic gaming policy.
4.2. Comments on the absence of exclusive rights granted to Ladbrokes
(157) According to the Belgian authoritiess, the framework notes issued by the Gaming Commission are not of a binding nature. They serve the purpose of monitoring the evolution of virtual betting on the Belgian market. This view was embedded in the second Framework Note of 17 April 2013 which recognised virtual betting as a betting game of chance allowed under the Gaming Act by stating: ‘To be able to monitor this evolution – […] – closely, it would be preferable that every F1 [licence holder] that wants to offer these bets directs a preliminary request for authorisation to the Gaming Commission’.
(158) With the so-called ‘authorisation’, the Gaming Commission committed towards Ladbrokes that it would not regard its virtual betting product as contrary to the Gaming Act and it would not enforce the law as prohibiting virtual betting. The ‘authorisations’ in question granted by the Gaming Commission to Ladbrokes must be regarded as confirmations on the interpretation of the product presented by Ladbrokes to the Gaming Commission under applicable laws. The Belgian authorities also state that the ‘authorisation’ as such was not required. They point out that it simply does not even exist in the relevant legal framework.
(159) The Belgian authorities pointed out the informal nature of the ‘authorisation’, a mere e-mail by a person from the secretariat that did not have the power to represent the Gaming Commission. This shows that such ‘authorisation’ cannot in any event be regarded as a formal requirement or a formal decision adopted by the Gaming Commission.
(160) Since such ‘authorisation’ does not establish any right for Ladbrokes, but only informs Ladbrokes that the virtual betting it intends to offer is a game of chance that the Belgian law allows any F1-licence holder to offer on the Belgian market, no advantage was conferred on Ladbrokes. Any operator could have sent an ‘authorisation’ request to the Gaming Commission at the time Ladbrokes did and it would have received the same informal interpretation.
(161) The Belgian authorities further provide information on the views taken by the Gaming Commission on two other requests received from class IV operators. Concerning Stanleybet’s request of 28 October 2015, the Gaming Commission informed Stanleybet about a newly established sub-commission and that it would only deal with the request once the results of the activities of the sub-commission were known. Another request by Stanleybet of 17 June 2016 was initially refused on the grounds of an incomplete file and later on the grounds of ongoing discussions on a regulatory initiative concerning virtual betting. As to another request by Sagevas on 23 August 2016, its request was not dealt by the Gaming Commission for the same reasons as for Stanleybet, initially due to an incomplete file, then on 3 November 2016 because a legislative initiative on virtual betting was ongoing.
(162) The Belgian authorities consider that the complainants knew that the Framework Notes on virtual betting could not legally create a framework under which the Gaming Commission would grant a proper authorisation to one licence holder and deny it to another, if these operators were both in the same situation.
(163) More generally, no operators could have reasonably believed that the Framework Notes created a proper and enforceable legal requirement to obtain some sort of ad hoc‘virtual betting licence’.
(164) The Belgian authorities also explain that it was not more difficult for others than for Ladbrokes to start operating virtual betting products of the same nature in their class IV gaming establishments with the relevant licences F1 and F2. In their view, it cannot be asserted that the Gaming Commission would have implemented a different enforcement policy towards Ladbrokes than towards other virtual betting operators. The Gaming Commission could therefore not be regarded selective in its enforcement of the Gaming Act because only Ladbrokes went ahead and operated virtual betting under the general rules of the Gaming Act.
(165) Furthermore, the Belgian authorities note that the Council of State annulled the Gaming Commission’s Framework Notes because it disagreed with the Gaming Commission’s interpretation of the Gaming Act in those Notes. The Council of State took the view that ‘the [Gaming Commission] did not just create a framework for the organization of bets on virtual events authorized by the law, but rather allowed, without having the proper competence to do so, the organization of this type of betting whereas it is not allowed under the law of 7 May 1999 [on games of chance]’.
(166) Further, the Belgian authorities disagree that the ‘authorisation’ given to Ladbrokes could be suspended since it did not produce any legal effects in the first place. Nevertheless, on 13 January 2016, the Gaming Commission adopted its decision to suspend the application of its 2015 Framework Note and the ‘authorisation’ granted to Ladbrokes effective as of 1 June 2016. As a consequence, Ladbrokes was allowed a five-month transitional period to wind down its virtual betting operations. The Gaming Commission took this advised minimal transition period and decided on a two-month longer transitional period until the suspension of Ladbrokes’ ‘authorisation’ would take effect. To this end, it relied on the fact that Ladbrokes already offered virtual betting since 2014. Therefore, account should be taken of Ladbrokes’ investment in virtual betting and the period during which Ladbrokes had already offered virtual betting.
(167) In any event, on 4 May 2018 the Royal Decree came into force. In the submission of 21 February 2021, the Belgian authorities explicitly confirmed there would multiple F1 licence holders in Belgium offering virtual betting in their class IV fixed gaming establishments under the conditions of the Royal Decree of 4 May 2018. Some of there were SRL Bingo Bet, Derby (Ladbrokes), Stanleybet and Wedwinkel-bettica.
(168) With regard to the retroactive annulment of the 2018 Royal Decree, the Belgian authorities consider that it does not have an impact on the duration of the alleged measure. Notwithstanding the fact that the 2018 Royal Decree should be considered to have never existed in Belgian law, this does not mean that the conditions for unlawful State aid would be fulfilled. The criteria in the now annulled 2018 Royal Decree were applied without discrimination to all valid F1 and F2 licence holders who aimed to offer virtual betting. They did not selectively benefit certain undertakings compared to others.
(169) The Belgian authorities submitted distinct positions on the 2018 Royal Decree and its retroactive annulment. They put forward that multiple operators on the Belgian market would now offer virtual betting under the conditions set out by the 2018 Royal Decree. Furthermore, the Belgian authorities submitted that class IV gaming establishments (betting shops) are now allowed to offer virtual betting. Indeed, virtual betting as it was described by the 2018 Royal Decree (Article 2) needs ‘multiplayer’ gaming machines, which allow multiple players to bet in different betting shops at the same time on the same virtual sport event. It is considered for virtual betting to be of sufficiently similar nature as ‘monoplayer’ betting machines and is therefore allowed under the F1 and F1+ licence. In other words, virtual betting is considered as more akin to machine gaming than actual sports betting, so it is logical that F1+ licence holders that offer land-based ‘monoplayer’ gaming machines are allowed to operate online virtual betting.
4.3. Subsidiary comments on the calculation of possible aid amount
(170) As a subsidiary argument, on the benchmark for the calculation of possible aid amount, the Belgian authorities consider that the treatment of the Loterie Nationale, referred to in the Opening Decision (42), is not comparable to that of Ladbrokes. According to national law, the Loterie Nationale is responsible for organising the public lotteries for the public benefit and under the control of its minister while being obliged to actively inform the public about gaming and betting addiction and to cooperate actively with governments and other actors to provide an active and coordinated prevention policy in particular as regards addiction. All profits are dedicated for this purpose and other humanitarian projects. The profits are not allocated to the Belgian national budget but reinvested in the Loterie Nationale to continue serving its public service obligations. The price that the Loterie Nationale pays for its legal monopoly represents a completely different situation from the one where a Member State grants exclusive rights and decides not to maximize the revenues which could have otherwise been achieved from those grants.
(171) Moreover, the Loterie Nationale’s exclusive right existed even before the creation of European Union. The National Lottery has several public service obligations and has no right to any profits since the Belgian State is entitled to receive all profits. The Belgian authorities further note that the State maximizes the possible revenue from the National Lottery’s monopoly, i.e. the whole profits of the Loterie Nationale. Even if the Loterie Nationale ere an appropriate benchmark, which it is not, the actual revenue for the State from granting such exclusive right would be the totality of the Loterie Nationale’s profits.
5. ASSESSMENT OF THE MEASURE
(172) The subject of this decision is the alleged unlawful aid by the complainants pursuant to Article 24(2) of Regulation (EU) 2015/1589. In order to qualify as unlawful State aid, the measure should be granted without the approval by the Commission.
(173) Furthermore, for a measure to be categorised as State aid within the meaning of Article 107(1) TFEU, all the conditions set out in that provision must be fulfilled. First, the measure must be imputable to the State and financed through State resources. Second, it must confer an advantage on its recipients. Third, that advantage must be selective, in that it favours certain undertakings or the production of certain goods. Fourth, the measure must distort or threaten to distort competition and affect trade between Member States. If a least one of the four cumulative criteria is not met, the measure does not constitute State aid.
5.1. Rocoluc, EAC and The Faculty as interested parties
(174) The Commission considers that the interest of The Faculty may be potentially affected by the alleged measure, since it operates in the same or similar markets in games of chance as Roculuc and EAC, whose interests may also be affected by the alleged measure, as also indicated in the Opening Decision. The Commission therefore considers The Faculty, Roculuc and EAC as interested parties within the meaning of Article 1(h) and as complainants within the meaning of Article 24(2) of Regulation (EU) 2015/1589. The argument brought forward by Ladbrokes that the complainant Rocoluc would lack the status of interested party (recitals 114-115) does not detract from that conclusion (43).
5.2. Absence of a measure conferring a legal right
(175) According to the complainants, the measure consists in the rights granted to Ladbrokes for the provision of virtual betting services on the Belgian market. The complainants consider that these rights would constitute unlawful State aid granted by the Gaming Commission through e-mails from an unauthorised official of 9 February 2014 and 5 March 2015.
(176) The Regulation (EU) 2015/1589 defines ‘unlawful aid’ as ‘new aid put into effect in contravention of Article 108(3) TFEU’. It requires that a measure needs to be put into effect by the Member State to be regarded as an unlawful aid. However, neither the Framework Notes (section 2.3.1) nor the aforementioned e-mails sent to Ladbrokes (section 2.6.) can be regarded as a granting act grating exclusive rights to Ladbrokes.
5.2.1. Framework Notes on virtual betting adopted by the Gaming Commission
(177) Ladbrokes was the first operator that planned a virtual betting activity in Belgian authorities in 2011 (recital 126). When Ladbrokes decided to offer the service of virtual betting in Belgium, the Gaming Act did not include specific reference to either online or offline virtual betting under the system of licences for games of chance.
(178) Therefore, the Gaming Commission identified a need for interpretation on how to categorize virtual betting. On 12 January 2012, it issued its first Framework Note entitled ‘Betting on Virtual Events’ (recital 39). This Framework Note did not expressly distinguish between online and offline virtual betting, but the Belgian authorities confirmed it effectively concerned offline virtual betting (recital 169).
(179) The purpose of the 2012 Framework Note was to examine whether the amended Gaming Act or its enforcement orders contained legal objections to the organization of betting on virtual (sporting) events. The Gaming Commission concluded: ‘From a legal point of view, the organization / offer of bets on virtual (sporting) events is in accordance with the provisions of the Gaming Act insofar as this type of betting is considered to be bets on events. Indeed, the result is not known, and the event concerns an uncertain fact, thanks to the “random number generator”. Considering that bets on virtual (sporting) events are bets on events means that this type of betting can only take place in class IV fixed gaming establishments. […]’.
5.2.2. Licences relevant for virtual betting in Belgium
(180) As a preliminary comment, when it comes to rules on virtual betting, as explained in recital 28, the Commission notes that the concept of ‘automatic games of chance’ is used to refer to games of chance played on a machine, which is most notably done in gaming establishments of class I (casinos) and class II (gaming halls), but also, albeit to a more limited extent, in other venues i.e. establishments of class III (bars) and class IV (betting shops).
(181) As confirmed by Belgian authorities (recital 169), class IV gaming establishments (operated with licences F1, F1+ and F2) always maintained the possibility to offer monoplayer gaming machines to their customers. This was already provided in the Royal Decree of 22 December 2010 on the operating rules of automatic games of chance authorised in class IV gaming establishments (44).
(182) The Gaming Act sets out the different types of licences and which type of gaming can be offered under these licences, and under what conditions. The rules were further elaborated through various Royal Decrees.
(183) According to Article 25 of the Gaming Act, the operation of a betting shop, which is a class IV gaming establishment, requires both a licence F1 and F2. The licence F1 is required to organise betting (i.e. create betting products for sale to players) whereas the licence F2 is required to take bets from players (i.e. directly sell the betting products to consumers). A betting shop (class IV establishment) must hold an F2 licence to take bets on behalf of a betting operator (with licence F1).
(184) Upon verification of the licences held by Ladbrokes, the Commission notes that Ladbrokes held a class F1 licence, which allows the operation of a betting establishment, a class F2 licence, which allows bets to be taken on behalf of the licencee of class F1, in a class IV fixed or mobile betting establishment and also enables Ladbrokes to take bets outside a class IV gaming establishment in the cases referred to in Article 43/4 (1), (5) and (2) of the Gaming Act, and an additional class F1 + licence allowing the exploitation of bets via information society tools, meaning online. As to the complainants’ argument on discrimination of class II operators when it comes to virtual betting, the Commission notes the position taken by the Gaming Commission to limit the activity of virtual betting only to class IV operators s. This restriction is in line with the reasoning provided by the 2018 Royal Decree, which emphasizes that it would be indispensable for the protections of players to allow this new game of chance to be offered only by class IV establishments (recital 43).
(185) The Commission also notes the information provided by the Belgian authorities that Ladbrokes was not the only operator on the Belgian market to hold the relevant licenses F1 and F1+ to operate virtual betting (recital 167). Yet, Ladbrokes’ predominance is apparent it can be attributed to the fact that Ladbrokes was a first operator to introduce and start offering virtual betting service in Belgium (recitals 126- 128). This early start and being a first of a kind brought to Ladbrokes a ‘first mover’ advantage. Other operators slowly followed the suit and showed interest in virtual betting in 2015 and 2016. Then the market for virtual betting grew, yet the regulatory setting that had to be provided by the State has been behind that development (recital 59).
5.2.3. Absence of a granting act through the ‘authorisations’ for virtual betting
(186) According to the Union courts, State aid must be regarded as being ‘granted’ within the meaning of Article 107(1) TFEU on the date on which the right to receive it is conferred on the beneficiary under the applicable national legislation (45), i.e. the national law must foresee effects for such an act to be enforceable under national law.
(187) In the case at hand, as explained in recital 35, the role of the Gaming Commission is to control compliance with the law within the framework of the Belgian law and its implementing decrees. The Gaming Commission, while being part of the Belgian public administration, has an advisory role and the task to implement the existing regulation in the gaming sector adopted by the Belgian legislator.
(188) As stated in the Gaming Act, which defines the competences of the Gaming Commission (see recital 35), the Gaming Commission does not have the power to create new rights to operators for gaming and betting operations. When it issues licences it must stay within the scope of the competences given to it by the Gaming Act and it cannot create new categories of licences (recital 150). The Framework Notes issued by the Gaming Commission (see recital 39) cannot be regarded as legal bases to legally authorise a gaming or betting activity. Moreover, these Framework Notes were annulled by the Council of State in 2019 (recital 64).
(189) Moreover, as mentioned in recital 40, the Gaming Commission explained in the Framework Note of 2012 that ‘in order to be able to closely monitor the development (…) it is preferable that each F1 [operator] wishing to organize such bets sends a prior request for authorisation for this purpose to the secretariat of the Gaming Commission’.
(190) As to the meaning of an ‘authorisation’, the wording in the 2012 Framework Note indicates that the operators were not compelled or required, but rather encouraged (‘it is preferable’) to request a specific authorisation to operate virtual betting offline. Specifically, the Gaming Commission did not refer to any provision of the Gaming Act as a basis for its ‘preference’ expressed in the note (‘it is preferable’, ‘in order to be able to closely monitor this development’). In fact, later the ‘authorisations’ were annulled by the Council of State based on the arguments of ultra vires doctrine (recital 38).
(191) The Commission takes the view that the e-mails were a mere confirmation that it could be considered that Ladbrokes, as a class IV establishment, was holding the relevant licences to operate virtual betting. In view of the interpretation given by the Gaming Commission, all class IV establishments with the relevant licence were entitled to provide virtual betting as it was covered by these licences (see recitals 40-41). Therefore, Ladbrokes, as an operator of class IV F1, F2 and F1+ licences, was considered eligible to operate virtual betting without requiring any additional approval or a new licence by the Belgian authorities.
(192) Any class IV operator could have in principle send an ‘authorisation’ request to the Gaming Commission at around the same time as Ladbrokes did, and it would then most probably have received the same interpretation. This possibility was however not foreseen for other classes, including the class II operators like the complainants, as they were not deemed to be eligible for the operation of virtual betting. The Commission notes that none of the complainants were establishments of class IV with the relevant licences and they did not submit such a request to the Gaming Commission.
(193) Moreover, it was only at a later stage that Stanleybet and Sagevas made their request for interpretation. The legal reflection had however evolved in the meanwhile. The Gaming Commission did not want first to deal with the request because of incomplete files. Subsequently, it did not want to provide an interpretation because of an ongoing regulatory initiative on virtual betting (see recital 161). The rejection of these two more recent requests made cannot be regarded as the refusal to grant rights to this operator.
(194) In this context, the Commission concurs with the Belgian authorities’ view (see recital 162) that no operators would have reasonably believed that the Framework Notes would create an enforceable right to obtain an ad hoc and specific virtual betting licence that would have been granted only to Ladbroke.
(195) In view of the foregoing considerations, the Commission concludes that given that the Gaming Act did not require a special licence to be approved by the Gaming Commission for virtual betting, and that the Framework Note of 2012 did not require any specific authorisation, the administrative communication granting ‘authorisations’ did not produce a legal effect to the extent that such effect would be tantamount to a licence. Ladbrokes, as an operator of class IV F1, F2 and F1+ licences, was considered eligible to operate virtual betting without requiring any additional approval or a new licence by the Belgian authorities. Therefore, it can be concluded that the e-mail replies sent by the Gaming Commission to Ladbrokes did not confer a legally enforceable right on Ladbrokes. Hence, the e-mails cannot be qualified as a granting act within the meaning of State aid law.
5.3. Absence of a measure having the effects of granting exclusive rights
5.3.1. No effects of exclusivity in the market for online virtual betting
(196) According to well-established case-law, Article 107 TFEU defines a State aid measure by reference to its effects. It is therefore relevant to assess the effects on the market of the alleged measure (46).
(197) As regards online virtual betting, the facts show that the e-mails sent by the Gaming Commission did not produce the effect vis-à-vis other operators of granting exclusive rights to Ladbrokes, which could be assimilated to the effects of State aid.
(198) As mentioned in recital 192, all operators of class IV with F1, F2 and F1+ licences were allowed to operate virtual betting without any additional approval or licence by the Belgian authorities.
(199) Ladbrokes submitted screenshots of the websites operated by different betting companies offering online virtual betting at certain periods of time (recital 201). This shows that other operators, such as Circus (47), Golden Vegas (48) or Bingoal (49), 36win (50), along with Ladbrokes, provided online virtual betting.
(200) Based on the information available, it appears that the Gaming Commission did not impose a sanction or undertake an enforcement action against these operators of online virtual betting. It also did not impose a prohibition on Ladbrokes, but temporarily suspended its licence for one day (recital 122).
(201) Moreover, the Belgian authorities confirmed that the retroactive annulment of the 2018 Royal Decree by the 7 May 2021 ruling of the Belgian Council of State only concerned offline virtual betting (class IV gaming establishments). The annulment had no impact on online virtual betting as several operators continued to offer it afterwards (recital 167).
(202) Based on the evidence available, it can be concluded that the e-mails sent by the Gaming Commission did not produce effects that could be assimilated to State aid vis-à-vis other operators of granting exclusive rights on online virtual betting to Ladbrokes.
5.3.2. No effects of exclusivity in the market for offline virtual betting
(a) No effective exclusivity based on the interpretation given by the Gaming Commission
(203) As expressly confirmed by the Belgian authorities, from 10 February 2014 until 1 July 2017, all class IV fixed betting establishments with licences F1 and F2 were legally allowed to operate offline virtual betting. The Belgian authorities pointed out that only Ladbrokes did so, even though all operators of a class IV fixed betting establishment with the appropriate valid licence could have provided offline virtual betting (see recital 192).
(204) The operator Sagevas made it public that it would operate virtual betting without any ‘authorisation’ from the Gaming Commission. The Gaming Commission expressly reported this declaration in its note of 2 January 2017, without announcing any enforcement actions.
(205) It is further noteworthy that Tiercé Ladbrokes SA, which is a Entain’s subsidiary and Ladbrokes’s sister entity in Belgium, also started offering virtual betting in the bet shops it operated at the same time that Ladbrokes did. Tiercé Ladbrokes did not receive any ‘authorisation’. Tiercé Ladbrokes is a different legal entity from Ladbroke. Given the formality that characterizes the sector-specific regulation, meaning that an ‘authorisation’ or a licence is awarded to a specific legal entity (51), this shows that Ladbrokes was not alone in offering virtual betting.
(206) Even though the position of the Gaming Commission evolved in the direction that virtual betting would not be a form of betting, and it therefore no longer advised that it could be offered in class IV gaming establishments (with licences F1 and F2), all class IV fixed betting establishments with the relevant licence were legally allowed to operate virtual betting.
(207) As of 1 July 2017, the Gaming Commission suspended its ‘authorisation’ granted to Ladbrokes in 2014. However, Ladbrokes continued offering virtual betting even after 1 July 2017, based on its view that it would be lawful to do so for all operators based on the licence F alone.
(208) The Belgian authorities did not take any legal action to enforce those “suspensions” or to initiate legal proceedings against Ladbrokes after 1 July 2017.
(209) The available facts as stated already in recital 31 of the Supplementary Opening Decision (52) show that some other operators (Bingoal/PMU, Betcenter Stanleybet and Sagevas) offered or intended to offer offline virtual betting.
(210) In the light of these facts, the Commission concludes that the e-mails sent by the Gaming Commission did not produce effects vis-à-vis other operators of granting exclusive rights on offline virtual betting to Ladbrokes, which could be assimilated to the effects of State aid.
(b) No exclusivity on offline virtual betting based on the 2018 Royal Decree
(211) Ladbrokes finally stopped offering virtual betting on 28 March 2018 due to an injunction of the Brussels Commercial Court requested by FedCaf in view of the suspension of the Framework note on 1 July 2017.
(212) In any event, on 4 May 2018, the 2018 Royal Decree came into force. According to the Belgian authorities, from the adoption of the 2018 Royal Decree until the annulment of all three Framework Notes by the Council of State in 2019 (recital 64), class IV fixed betting establishments with the appropriate valid licence could offer offline virtual betting. Effectively, as already mentioned above (recital 167) several of them did so, in particular SRL Bingo Bet, Derby (Ladbrokes), Stanleybet and Wedwinkel-Bettica. These same operators offered offline virtual betting in the period from the same judgment of the Council of State of 19 September 2019 when the Council ruled that virtual betting would not be in line with the Gaming Act (recital 140) until the retroactive annulment of the 2018 Royal Decree.
(213) The Commission therefore concludes that the 2018 Royal Decree did not confer an exclusive right to Ladbrokes.
(214) It is finally noteworthy that, from the annulment of the 2018 Royal Decree on 7 May 2021 onwards, offline virtual betting has not been allowed and there is no operator offering it in Belgium, as confirmed by the Belgian authorities.
5.4. No foregone State resources in the alleged measure since 2014 to date
(215) The complainants argue that by failing to impose a fee for virtual betting services offered by Ladbrokes, the Belgian authorities favoured Ladbrokes by granting it a preferential treatment, hence a selective advantage (see recital 21). In doing so, the Belgian authorities would have foregone State resources.
(216) However, all class IV establishments with the relevant licence were in principle allowed to offer both offline and online virtual betting (recital 192). The Commission notes that the Gaming Commission, or any other Belgian public authority for that matter, did not exempt Ladbrokes from a fee and did not release Ladbrokes from the obligation to pay a fee that would have been due. Instead, it appears from the Belgian authorities’ interpretation of the Gaming Act that there is no obligation for the operators to pay special fees for virtual betting.
(217) It is further noteworthy that there was no obligation for class IV establishments to hold, let alone to pay for a licence special to operating virtual betting, so that not imposing a licence fee for virtual betting is merely the consequence of the non-existence of special rules on virtual betting in the Gaming Act.
(218) The Commission further notes that with the adoption of the 2018 Royal Decree, offline virtual betting became regulated, but no special fee was foreseen for it. In fact, when the regulator acted by adopting the 2018 Royal Decree, it adopted a regulation which prescribed conditions for all eligible operators and did not forgo revenues for not requiring a special fee for operating virtual betting by Ladbrokes.
(219) Therefore, the Commission concludes that the Belgian State did not waive, nor forego, any resources which should have been paid by Ladbrokes for operating virtual betting since 2014. Hence, there is no link between the alleged exclusive right of Ladbrokes and a burden on the State budget through the non-imposition of fees.
5.5. Conclusion
(220) In conclusion, the Commission finds that:
—
the informal e-mail replies sent by an employee at the Gaming Commission to Ladbrokes do not qualify as a granting act within the meaning of Article 107 (1) TFEU (see section 5.2.);
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the e-mails sent by the Gaming Commission did not produce effects vis-à-vis other operators of granting exclusive rights on virtual betting to Ladbrokes, which could be assimilated to the effects of State aid within the meaning of Article 107 (1) TFEU (see section 5.3.);
—
the Belgian State did not waive, nor forego, any resources which should have been paid by Ladbrokes for operating virtual betting since 2014 (see section 5.4.).
(221) The Commission therefore concludes that no unlawful State aid has been granted by Belgium to Ladbrokes within the meaning of Article 107 (1) TFEU in the absence of (i) a granting act, (ii) any exclusive rights which could be assimilated to it, and (iii) the forgoing of State resources.
6. CONCLUSION
(222) In the light of the above, the Commission concludes that the measure does not constitute State aid within the meaning of Article 107(1) TFEU.
HAS ADOPTED THE DECISION
The Kingdom of Belgium has not provided to Ladbrokes unlawful aid in the form of exclusive rights on virtual betting as of 10 February 2014. The alleged measure does not qualify as State aid within the meaning of Article 107 (1) of the Treaty on the Functioning of the European Union.
This Decision is addressed to the Kingdom of Belgium.

Commission Implementing Decision (EU) 2025/1764 of 25 August 2025 amending Implementing Decision (EU) 2025/1582 concerning certain emergency measures relating to infection with lumpy skin disease virus in Italy (notified under document C(2025) 5881)

January 13, 2026
Official Journalof the European Union ENL series
2025/1764 27.8.2025
(1) Infection with lumpy skin disease virus is an infectious, vector-borne disease affecting bovine animals. Its occurrence can have a severe impact on the concerned animal population and on the profitability of farming, also causing disturbance to movements of those animals and products thereof within the Union and exports to third countries.
(2) In the event of an outbreak of an infection with lumpy skin disease virus in bovine animals, there is a serious risk of the spread of that disease to other establishments of bovine animals particularly due its main mode of transmission through vectors.
(3) Commission Delegated Regulation (EU) 2020/687(2)supplements the rules for the control of the listed diseases referred to in Article 9(1), points (a), (b) and (c), of Regulation (EU) 2016/429, and defined as category A, B and C diseases in Commission Implementing Regulation (EU) 2018/1882(3). In particular, Articles 21 and 22 of Delegated Regulation (EU) 2020/687 provide for the establishment of a restricted zone in the event of an outbreak of a category A disease, including infection with lumpy skin disease virus, and for certain measures to be applied therein. In addition, Article 21(1) of that Delegated Regulation provides that the restricted zone is to comprise at least a protection zone, a surveillance zone, and, if necessary, further restricted zones around or adjacent to the protection and surveillance zones.
(4) Commission Implementing Decision (EU) 2025/1582(4)lays down certain emergency measures related to outbreaks of infection with lumpy skin disease virus in Italy. Article 1 of Implementing Decision (EU) 2025/1582 provides for the establishment, in Italy, of restricted zones, comprising protection, surveillance, and further restricted zones, in accordance with Article 21 of Delegated Regulation (EU) 2020/687, as well as the establishment of vaccination zones, in accordance with Part 1 of Annex IX to Commission Delegated Regulation (EU) 2023/361(5). In addition, Article 1 of Implementing Decision 2025/1582 provides that those protection, surveillance, and further restricted zones, as well as the vaccination zones, are to comprise at least the areas listed in Annexes I and III thereto, and the measures required to be applied in those zones are to be applied at least until the dates set out in those Annexes.
(5) Since the adoption of Implementing Decision (EU) 2025/1582, Italy has notified the Commission of 26 additional confirmed outbreaks of infection with lumpy skin disease virus in establishments keeping bovine animals in the provinces of Nuoro and Sassari, in the region of Sardinia, which were reported between 25 July and 8 August 2025. In addition, France has notified 22 outbreaks of infection with lumpy skin disease virus in establishments keeping bovine animals in areas which are near the region of Valle d’Aosta, in Italy, during the same period. In response to these outbreaks in Italy and France, Italy has established protection, surveillance, and further restricted zones, in the provinces of Nuoro and Sassari, in the region of Sardinia, and a surveillance zone in the Valle d’Aosta region where the disease control measures laid down in Delegated Regulation (EU) 2020/687 are applied.
(6) In order to prevent any unnecessary disturbance to trade within the Union, and to avoid unjustified barriers to trade being imposed by third countries, the areas indicated as protection, surveillance and further restricted zones in Annex I to Implementing Decision (EU) 2025/1582 should, therefore, be updated by this Decision, and the duration of the measures to be applied in these zones fixed.
(7) The size of the areas indicated as protection zones and surveillance zones as well as of the further restricted zone in Annex I to Implementing Decision (EU) 2025/1582, as amended by this Decision, as well as the duration of the measures to be applied therein, are based on the criteria laid down in Article 64(1) of Regulation (EU) 2016/429 as well as on the rules laid down in Delegated Regulation (EU) 2020/687. The criteria applied for the choice of the size of the protection, surveillance, and further restricted zones, as well as of the duration of the measures to be applied therein, include the consideration of not only the epidemiological situation as regards infection with lumpy skin disease virus in the areas affected by that disease, but also of other epidemiological factors, including geographical parameters and the risk for the further spread of the disease in view of the presence of insect vectors. The chosen duration of the measures foreseen in this Decision has also taken into account the international standards of the Terrestrial Animal Health Code of the World Organisation for Animal Health(6).
(8) Article 3 of Implementing Decision (EU) 2025/1582 provides for the application of the measures applicable to further restricted zones as well as the prohibition on movements of bovine animals from the areas set out in Annex II to destinations outside those areas. In view of the continuing outbreaks of infection with lumpy skin disease virus in Sardinia region, and in order to prevent further spread of the disease as well as to avoid unnecessary disturbance to trade within the Union and unjustified barriers to trade with third countries, it is necessary to prolong also these measures and Annex II to Implementing Decision (EU) 2025/1582 should be amended.
(9) Therefore, Annexes I and II to Implementing Decision (EU) 2025/1582 should be amended accordingly.
(10) In addition, Article 69 of Regulation (EU) 2016/429 provides that the competent authority of a Member State may develop a vaccination plan or establish vaccination zones, where relevant for the effective control of a listed disease in kept animals. Article 6 of Delegated Regulation (EU) 2023/361 lays down detailed rules for official vaccination plans. That Delegated Regulation also provides, in Article 9, for rules for the implementation of emergency protective vaccination. Detailed conditions for the use of emergency protective vaccination against lumpy skin disease are laid down in Annex IX thereof.
(11) On 23 July 2025, Italy provided the Commission with its official vaccination plan for infection with lumpy skin disease for the Sardinia region, in accordance with Article 6(4), point (b), of Delegated Regulation (EU) 2023/361, together with updated data regarding the implementation of that plan. In addition, Italy decided to implement emergency protective vaccination against infection with lumpy skin disease in the region of Valle d’Aosta, in response to the outbreaks confirmed by France close to the Italian border, and submitted the preliminary information for its official vaccination plan for the region of Valle d’Aosta in accordance with Article 6(4), point (a) of that Delegated Regulation.
(12) In order to ensure coordinated disease control and to safeguard trade within the Union and with third countries, it is necessary to establish vaccination zones for infection with lumpy skin disease for Valle d’Aosta and to adjust the vaccination zones laid down in Annex III to Implementing Decision (EU) 2025/1582 for Sardinia, at Union level.
(13) The type, size and duration of vaccination zones I and II set out in Annex III to Implementing Decision (EU) 2025/1582 are based on the epidemiological situation and the progress of the vaccination campaigns, particularly taking into account the level of vaccine coverage achieved, the Member State’s official vaccination plans and the progress reports submitted in accordance with Article 11 of Delegated Regulation (EU) 2023/361. Accordingly, Annex III to this Decision should indicate for each area concerned, the dates for during which the vaccination zones are to apply.
(14) Therefore, Annex III to Implementing Decision (EU) 2025/1582 should be amended accordingly.
(15) In light of the epidemiological situation the amendments to Implementing Decision (EU) 2025/1582 should apply as soon as possible to prevent further spread of the disease within Italy, to other Member States, or to third countries and to avoid unnecessary disturbance to trade within the Union or unjustified barriers to trade with third countries.
(16) The measures provided for in this Decision are in accordance with the opinion of the Standing Committee on Plants, Animals, Food and Feed,
Administrative area and ADIS reference number of the outbreak Areas established as protection and surveillance zones, part of the restricted zone, referred to in Article 1 Date until applicable
Sardinia regionIT-LSD-2025-00001IT-LSD-2025-00003IT-LSD-2025-00004IT-LSD-2025-00005IT-LSD-2025-00006IT-LSD-2025-00007IT-LSD-2025-00008IT-LSD-2025-00009IT-LSD-2025-00010IT-LSD-2025-00011IT-LSD-2025-00012IT-LSD-2025-00013IT-LSD-2025-00014IT-LSD-2025-00015IT-LSD-2025-00016IT-LSD-2025-00017IT-LSD-2025-00018IT-LSD-2025-00019IT-LSD-2025-00020IT-LSD-2025-00021IT-LSD-2025-00022IT-LSD-2025-00023IT-LSD-2025-00024IT-LSD-2025-00025IT-LSD-2025-00026IT-LSD-2025-00027IT-LSD-2025-00028IT-LSD-2025-00029IT-LSD-2025-00030IT-LSD-2025-00031IT-LSD-2025-00032IT-LSD-2025-00033IT-LSD-2025-00034IT-LSD-2025-00035IT-LSD-2025-00036IT-LSD-2025-00037IT-LSD-2025-00038IT-LSD-2025-00039IT-LSD-2025-00040IT-LSD-2025-00041IT-LSD-2025-00042IT-LSD-2025-00043IT-LSD-2025-00044IT-LSD-2025-00045IT-LSD-2025-00046IT-LSD-2025-00047IT-LSD-2025-00048IT-LSD-2025-00049IT-LSD-2025-00050IT-LSD-2025-00051IT-LSD-2025-00052IT-LSD -2025-00053 Protection zone:Those parts of the region of Sardinia, contained within a circle of a radius of 20 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 40.30429, Long. 9.22154 (2025/1), Lat. 40.31139, Long. 9.09821 (2025/3), Lat. 40.24291, Long. 9.22451 (2025/4), Lat. 40.392626, Long. 9.018567 (2025/5), Lat. 40.2623, Long. 9.082244 (2025/6), Lat. 40.22246, Long. 9.19132 (2025/7), Lat. 40.335997, Long. 9.123835 (2025/8), Lat. 40.28903, 9.102816 Long.(2025/9), Lat. 40.209698, Long. 9.177213 (2025/10), Lat. 40.24404, Long. 9.13817 (2025/11), Lat. 40.33445, Long. 9.15608 (2025/12), Lat. 40.319967 Long. 9.100123 (2025/13), Lat. 40.3451 Long. 9.2594 (2025/14), Lat. 40.3121, Long. 9.2046 (2025/15), Lat. 40.34778, Long. 9.16083 (2025/16), Lat. 40.24096, Long. 9.093 (2025/17), Lat. 40.35071, Long. 9.132964 (2025/18), Lat. 40.3399, Long. 9.167 (2025/19), Lat. 40.725228, Long. 9.485748 (2025/20), Lat. 40.467998, Long. 9.151939 (2025/21), Lat. 40.28833, Long. 9.157329 (2025/22), Lat. 40.24569, Long. 9.20289 (2025/23), Lat. 40.260758, Long. 9.168392 (2025/24), Lat. 40.33221, Long. 9.08099 (2025/25), Lat. 40.280527, Long. 9.116003 (2025/26), Lat. 40.3192, Long. 9.1386 (2025/27), Lat. 40.34618, Long. 9.110074 (2025/28), Lat. 40.304711, Long. 9.068162 (2025/29), Lat. 40.25499, Long. 9.12552 (2025/30), Lat. 40.24738, Long. 9.12763 (2025/31), Lat. 40.28341, Long. 9.22293 (2025/32), Lat. 40.25851, Long. 9.20678 (2025/33), Lat. 40.306593, Long. 9.071998 (2025/34), Lat. 40.33359, Long. 9.16725 (2025/35), Lat. 40.3092, Long. 9.2079 (2025/36), Lat., 40.30125 Long. 9.04641 (2025/37), Lat. 40.25888, Long. 9.2727 (2025/38), Lat. 40.26065, Long. 9.27494 (2025/39), Lat. 40.397264, Long. 9.172869 (2025/40), Lat. 40.30794, Long. 9.07156 (2025/41), Lat. 40.29275, Long. 9.116667 (2025/42), Lat. 40.28273, Long. 9.26401 (2025/43), Lat. 40.284756, Long. 9.303752 (2025/44), Lat. 40.32509, Long. 9.133142 (2025/45), Lat. 40.20129, Long. 9.18471 (2025/46), Lat. 40.23263, Long. 9.15369 (2025/47), Lat. 40.27775, Long. 9.03683 (2025/48), Lat. 40.400795, Long. 9.171361 (2025/49), Lat. 40.38841, Long. 9.00316 (2025/50), Lat. 40.30071, Long. 9.15876 (2025/51), Lat. 40.315906, Long. 9.213706 (2025/52), Lat. 40.1822, Long. 8.5336 (2025/53). 31.11.2025
Surveillance zone:Those parts of the region of Sardinia, contained within a circle of a radius of 50 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 40.30429, Long. 9.22154 (2025/1), Lat. 40.30429, Long. 9.22154 (2025/1), Lat. 40.31139, Long. 9.09821 (2025/3), Lat. 40.24291, Long. 9.22451 (2025/4), Lat. 40.392626, Long. 9.018567 (2025/5), Lat. 40.2623, Long. 9.082244 (2025/6), Lat. 40.22246, Long. 9.19132 (2025/7), Lat. 40.335997, Long. 9.123835 (2025/8), Lat. 40.28903, Long. 9.102816 (2025/9), Lat. 40.209698 Long. 9.177213 (2025/10), Lat. 40.24404, Long. 9.13817 (2025/11), Lat. 40.33445, Long. 9.15608 (2025/12), Lat. 40.319967, Long. 9.100123 (2025/13), Lat. 40.3451, Long. 9.2594 (2025/14), Lat. 40.3121, Long. 9.2046 (2025/15), Lat. 40.34778, Long. 9.16083 (2025/16), Lat. 40.24096, Long. 9.093 (2025/17), Lat. 40.35071, Long. 9.132964 (2025/18), Lat. 40.3399, Long. 9.167 (2025/19), Lat. 40.725228 Long. 9.485748 (2025/20), Lat. 40.467998, Long. 9.151939 (2025/21), Lat. 40.28833, Long. 9.157329 (2025/22), Lat. 40.24569, Long. 9.20289 (2025/23), Lat. 40.260758, Long. 9.168392 (2025/24), Lat. 40.33221, Long. 9.08099 (2025/25), Lat. 40.280527, Long. 9.116003 (2025/26), Lat. 40.3192, Long. 9.1386 (2025/27), Lat. 40.34618, Long. 9.110074 (2025/28), Lat. 40.304711, Long. 9.068162 (2025/29), Lat. 40.25499, Long. 9.12552 (2025/30), Lat. 40.24738, Long. 9.12763 (2025/31), Lat. 40.28341, Long. 9.22293 (2025/32), Lat. 40.25851, Long. 9.20678 (2025/33), Lat. 40.306593, Long. 9.071998 (2025/34), Lat. 40.33359, Long. 9.16725 (2025/35), Lat. 40.3092, Long. 9.2079 (2025/36), Lat., 40.30125 Long. 9.04641 (2025/37), Lat. 40.25888, Long. 9.2727 (2025/38), Lat. 40.26065, Long. 9.27494 (2025/39), Lat. 40.397264, Long. 9.172869 (2025/40), Lat. 40.30794, Long. 9.07156 (2025/41), Lat. 40.29275, Long. 9.116667 (2025/42), Lat. 40.28273, Long. 9.26401 (2025/43), Lat. 40.284756, Long. 9.303752 (2025/44), Lat. 40.32509, Long. 9.133142 (2025/45), Lat. 40.20129, Long. 9.18471 (2025/46), Lat. 40.23263, Long. 9.15369 (2025/47), Lat. 40.27775, Long. 9.03683 (2025/48), Lat. 40.400795, Long. 9.171361 (2025/49), Lat. 40.38841, Long. 9.00316 (2025/50), Lat. 40.30071, Long. 9.15876 (2025/51), Lat. 40.315906, Long. 9.213706 (2025/52), Lat. 40.1822, Long. 8.5336 (2025/53). 1.12.2025- 17.12.2025
Surveillance zone:Those parts of the region of Sardinia, contained within a circle of a radius of 20 kilometres, centred on UTM 30, ETRS89 coordinates 40.30429, Long. 9.22154 (2025/1), Lat. 40.30429, Long. 9.22154 (2025/1), Lat. 40.31139, Long. 9.09821 (2025/3), Lat. 40.24291, Long. 9.22451 (2025/4), Lat. 40.392626, Long. 9.018567 (2025/5), Lat. 40.2623, Long. 9.082244 (2025/6), Lat. 40.22246, Long. 9.19132 (2025/7), Lat. 40.335997, Long. 9.123835 (2025/8), Lat. 40.28903, Long. 9.102816 (2025/9), Lat. 40.209698, Long. 9.177213 (2025/10), Lat. 40.24404, Long. 9.13817 (2025/11), Lat. 40.33445, Long. 9.15608 (2025/12), Lat. 40.319967, Long. 9.100123 (2025/13), Lat. 40.3451, Long. 9.2594 (2025/14), Lat. 40.3121, Long. 9.2046 (2025/15), Lat. 40.34778, Long. 9.16083 (2025/16), Lat. 40.24096, Long. 9.093 (2025/17), Lat. 40.35071, Long. 9.132964 (2025/18), Lat. 40.3399, Long. 9.167 (2025/19), Lat. 40.725228, Long. 9.485748 (2025/20), Lat. 40.467998, Long. 9.151939 (2025/21), Lat. 40.28833, Long. 9.157329 (2025/22), Lat. 40.24569, Long. 9.20289 (2025/23), Lat. 40.260758, Long. 9.168392 (2025/24), Lat. 40.33221, Long. 9.08099 (2025/25), Lat. 40.280527, Long. 9.116003 (2025/26), Lat. 40.3192, Long. 9.1386 (2025/27), Lat. 40.34618, Long. 9.110074 (2025/28), Lat. 40.304711, Long. 9.068162 (2025/29), Lat. 40.25499, Long. 9.12552 (2025/30), Lat. 40.24738, Long. 9.12763 (2025/31), Lat. 40.28341, Long. 9.22293 (2025/32), Lat. 40.25851, Long. 9.20678 (2025/33), Lat. 40.306593, Long. 9.071998 (2025/34), Lat. 40.33359, Long. 9.16725 (2025/35), Lat. 40.3092, Long. 9.2079 (2025/36), Lat., 40.30125 Long. 9.04641 (2025/37), Lat. 40.25888, Long. 9.2727 (2025/38), Lat. 40.26065, Long. 9.27494 (2025/39), Lat. 40.397264, Long. 9.172869 (2025/40), Lat. 40.30794, Long. 9.07156 (2025/41), Lat. 40.29275, Long. 9.116667 (2025/42), Lat. 40.28273, Long. 9.26401 (2025/43), Lat. 40.284756, Long. 9.303752 (2025/44), Lat. 40.32509, Long. 9.133142 (2025/45), Lat. 40.20129, Long. 9.18471 (2025/46), Lat. 40.23263, Long. 9.15369 (2025/47), Lat. 40.27775, Long. 9.03683 (2025/48), Lat. 40.400795, Long. 9.171361 (2025/49), Lat. 40.38841, Long. 9.00316 (2025/50), Lat. 40.30071, Long. 9.15876 (2025/51), Lat. 40.315906, Long. 9.213706 (2025/52), Lat. 40.1822, Long. 8.5336 (2025/53), excluding the areas included in the protection zone. 17.12.2025
Valle d’Aosta regionFR-LSD-2025-00017FR-LSD-2025-00018FR-LSD-2025-00022FR-LSD-2025-00026FR-LSD-2025-00027FR-LSD-2025-00028FR-LSD-2025-00029FR-LSD-2025-00030FR-LSD-2025-00031FR-LSD-2025-00032FR-LSD-2025-00033FR-LSD-2025-00034FR-LSD-2025-00038FR-LSD-2025-00048FR-LSD-2025-00049FR-LSD-2025-00051FR-LSD-2025-00053FR-LSD-2025-00054FR-LSD-2025-00061FR-LSD-2025-00064FR-LSD-2025-00069FR-LSD-2025-00073FR-LSD-2025-00075 Surveillance zone:Those parts of the region of Valle d’Aosta, contained within a circle of a radius of 50 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 45.739081, Long 6.309311 (FR-LSD-2025-00017) Lat. 45.742, Long. 6.290 (FR-LSD-2025-00018), Lat. 45.788, Long. 6.204 (FR-LSD-2025-00022), Lat. 45.753, Long. 6.272 (FR-LSD-2025-00026), Lat. 45.747, Long. 6.284 (FR-LSD-2025-00027), Lat. 45.731, Long. 6.294 (FR-LSD-2025-00028), Lat. 45.748, Long. 6.294 (FR-LSD-2025-00029), Lat. 45.761, Long. 6.310 (FR-LSD-2025-00030), Lat. 45.762, Long. 6.309 (FR-LSD-2025-00031), Lat. 45.732, Long. 6.296 (FR-LSD-2025-00032), Lat. 45.748, Long. 6.294 (FR-LSD-2025-00033), Lat. 45.767, Long. 6.535 (FR-LSD-2025-00034), Lat. 45.728, Long. 6.269 (FR-LSD-2025-00038), Lat. 45.788, Long. 6.204 (FR-LSD-2025-00048), Lat. 45.741, Long. 6.306 (FR-LSD-2025-00049), Lat. 45.750, Long. 6.318 (FR-LSD-2025-00051), Lat. 45.773, Long. 6.254 (FR-LSD-2025-00053), Lat. 45.771, Long. 6.252 (FR-LSD-2025-00054), Lat. 45.749, Long. 6.317 (FR-LSD-2025-00061), Lat. 45.748, Long. 6.297 (FR-LSD-2025-00064), Lat 45.729, Long. 6.267 (FR-LSD-2025-00069), Lat. 45.705, Long. 6.305 (FR-LSD-2025-00073), Lat. 45.728, Long. 6.262 (FR-LSD-2025-00075) 27.9.2025
Administrative area Areas established as further restricted zone, part of the restricted zone, referred to in Article 1 Date until applicable
Sardinia region The entire territory of the region of Sardinia, excluding the areas included in any protection or surveillance zone. 18.12.2025
Administrative area Areas referred to in Article 3 Date until applicable
Sardinia region The entire territory of the region of Sardinia 19.12.2025-18.01.2026
— the region of Sardinia until 21.10.2025.
— those areas contained the surveillance zone of the region of Valle D’Aosta until 30.09.2025.
— the region of Sardina as of 22.10.2025 until last day of the recovery period, chosen by Italy, referred to in Part 4 of Annex IX to Delegated Regulation (EU) 2023/361.
— the region of Valle D’Aosta excluding the surveillance zone in that region until 30.09.2025.
— the region of Valle D’Aosta as of 1.10.2025 until last day of the recovery period, chosen by Italy, referred to in Part 4 of Annex IX to Delegated Regulation (EU) 2023/361.
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EU) 2016/429 of the European Parliament and of the Council of 9 March 2016 on transmissible animal diseases and amending and repealing certain acts in the area of animal health (‘Animal Health Law’) (1), and in particular Article 259(1) thereof,
Whereas:
(1) Infection with lumpy skin disease virus is an infectious, vector-borne disease affecting bovine animals. Its occurrence can have a severe impact on the concerned animal population and on the profitability of farming, also causing disturbance to movements of those animals and products thereof within the Union and exports to third countries.
(2) In the event of an outbreak of an infection with lumpy skin disease virus in bovine animals, there is a serious risk of the spread of that disease to other establishments of bovine animals particularly due its main mode of transmission through vectors.
(3) Commission Delegated Regulation (EU) 2020/687 (2) supplements the rules for the control of the listed diseases referred to in Article 9(1), points (a), (b) and (c), of Regulation (EU) 2016/429, and defined as category A, B and C diseases in Commission Implementing Regulation (EU) 2018/1882 (3). In particular, Articles 21 and 22 of Delegated Regulation (EU) 2020/687 provide for the establishment of a restricted zone in the event of an outbreak of a category A disease, including infection with lumpy skin disease virus, and for certain measures to be applied therein. In addition, Article 21(1) of that Delegated Regulation provides that the restricted zone is to comprise at least a protection zone, a surveillance zone, and, if necessary, further restricted zones around or adjacent to the protection and surveillance zones.
(4) Commission Implementing Decision (EU) 2025/1582 (4) lays down certain emergency measures related to outbreaks of infection with lumpy skin disease virus in Italy. Article 1 of Implementing Decision (EU) 2025/1582 provides for the establishment, in Italy, of restricted zones, comprising protection, surveillance, and further restricted zones, in accordance with Article 21 of Delegated Regulation (EU) 2020/687, as well as the establishment of vaccination zones, in accordance with Part 1 of Annex IX to Commission Delegated Regulation (EU) 2023/361 (5). In addition, Article 1 of Implementing Decision 2025/1582 provides that those protection, surveillance, and further restricted zones, as well as the vaccination zones, are to comprise at least the areas listed in Annexes I and III thereto, and the measures required to be applied in those zones are to be applied at least until the dates set out in those Annexes.
(5) Since the adoption of Implementing Decision (EU) 2025/1582, Italy has notified the Commission of 26 additional confirmed outbreaks of infection with lumpy skin disease virus in establishments keeping bovine animals in the provinces of Nuoro and Sassari, in the region of Sardinia, which were reported between 25 July and 8 August 2025. In addition, France has notified 22 outbreaks of infection with lumpy skin disease virus in establishments keeping bovine animals in areas which are near the region of Valle d’Aosta, in Italy, during the same period. In response to these outbreaks in Italy and France, Italy has established protection, surveillance, and further restricted zones, in the provinces of Nuoro and Sassari, in the region of Sardinia, and a surveillance zone in the Valle d’Aosta region where the disease control measures laid down in Delegated Regulation (EU) 2020/687 are applied.
(6) In order to prevent any unnecessary disturbance to trade within the Union, and to avoid unjustified barriers to trade being imposed by third countries, the areas indicated as protection, surveillance and further restricted zones in Annex I to Implementing Decision (EU) 2025/1582 should, therefore, be updated by this Decision, and the duration of the measures to be applied in these zones fixed.
(7) The size of the areas indicated as protection zones and surveillance zones as well as of the further restricted zone in Annex I to Implementing Decision (EU) 2025/1582, as amended by this Decision, as well as the duration of the measures to be applied therein, are based on the criteria laid down in Article 64(1) of Regulation (EU) 2016/429 as well as on the rules laid down in Delegated Regulation (EU) 2020/687. The criteria applied for the choice of the size of the protection, surveillance, and further restricted zones, as well as of the duration of the measures to be applied therein, include the consideration of not only the epidemiological situation as regards infection with lumpy skin disease virus in the areas affected by that disease, but also of other epidemiological factors, including geographical parameters and the risk for the further spread of the disease in view of the presence of insect vectors. The chosen duration of the measures foreseen in this Decision has also taken into account the international standards of the Terrestrial Animal Health Code of the World Organisation for Animal Health (6).
(8) Article 3 of Implementing Decision (EU) 2025/1582 provides for the application of the measures applicable to further restricted zones as well as the prohibition on movements of bovine animals from the areas set out in Annex II to destinations outside those areas. In view of the continuing outbreaks of infection with lumpy skin disease virus in Sardinia region, and in order to prevent further spread of the disease as well as to avoid unnecessary disturbance to trade within the Union and unjustified barriers to trade with third countries, it is necessary to prolong also these measures and Annex II to Implementing Decision (EU) 2025/1582 should be amended.
(9) Therefore, Annexes I and II to Implementing Decision (EU) 2025/1582 should be amended accordingly.
(10) In addition, Article 69 of Regulation (EU) 2016/429 provides that the competent authority of a Member State may develop a vaccination plan or establish vaccination zones, where relevant for the effective control of a listed disease in kept animals. Article 6 of Delegated Regulation (EU) 2023/361 lays down detailed rules for official vaccination plans. That Delegated Regulation also provides, in Article 9, for rules for the implementation of emergency protective vaccination. Detailed conditions for the use of emergency protective vaccination against lumpy skin disease are laid down in Annex IX thereof.
(11) On 23 July 2025, Italy provided the Commission with its official vaccination plan for infection with lumpy skin disease for the Sardinia region, in accordance with Article 6(4), point (b), of Delegated Regulation (EU) 2023/361, together with updated data regarding the implementation of that plan. In addition, Italy decided to implement emergency protective vaccination against infection with lumpy skin disease in the region of Valle d’Aosta, in response to the outbreaks confirmed by France close to the Italian border, and submitted the preliminary information for its official vaccination plan for the region of Valle d’Aosta in accordance with Article 6(4), point (a) of that Delegated Regulation.
(12) In order to ensure coordinated disease control and to safeguard trade within the Union and with third countries, it is necessary to establish vaccination zones for infection with lumpy skin disease for Valle d’Aosta and to adjust the vaccination zones laid down in Annex III to Implementing Decision (EU) 2025/1582 for Sardinia, at Union level.
(13) The type, size and duration of vaccination zones I and II set out in Annex III to Implementing Decision (EU) 2025/1582 are based on the epidemiological situation and the progress of the vaccination campaigns, particularly taking into account the level of vaccine coverage achieved, the Member State’s official vaccination plans and the progress reports submitted in accordance with Article 11 of Delegated Regulation (EU) 2023/361. Accordingly, Annex III to this Decision should indicate for each area concerned, the dates for during which the vaccination zones are to apply.
(14) Therefore, Annex III to Implementing Decision (EU) 2025/1582 should be amended accordingly.
(15) In light of the epidemiological situation the amendments to Implementing Decision (EU) 2025/1582 should apply as soon as possible to prevent further spread of the disease within Italy, to other Member States, or to third countries and to avoid unnecessary disturbance to trade within the Union or unjustified barriers to trade with third countries.
(16) The measures provided for in this Decision are in accordance with the opinion of the Standing Committee on Plants, Animals, Food and Feed,
HAS ADOPTED THIS DECISION:
The Annexes to Implementing Decision (EU) 2025/1582 are replaced by the text set out in the Annex to this Decision.
This Decision is addressed to the Italian Republic.

‘ANNEX I
Part A: Protection and surveillance zones established around the confirmed outbreaks
Administrative area and ADIS reference number of the outbreak
Areas established as protection and surveillance zones, part of the restricted zone, referred to in Article 1
Date until applicable
Sardinia region
IT-LSD-2025-00001
IT-LSD-2025-00003
IT-LSD-2025-00004
IT-LSD-2025-00005
IT-LSD-2025-00006
IT-LSD-2025-00007
IT-LSD-2025-00008
IT-LSD-2025-00009
IT-LSD-2025-00010
IT-LSD-2025-00011
IT-LSD-2025-00012
IT-LSD-2025-00013
IT-LSD-2025-00014
IT-LSD-2025-00015
IT-LSD-2025-00016
IT-LSD-2025-00017
IT-LSD-2025-00018
IT-LSD-2025-00019
IT-LSD-2025-00020
IT-LSD-2025-00021
IT-LSD-2025-00022
IT-LSD-2025-00023
IT-LSD-2025-00024
IT-LSD-2025-00025
IT-LSD-2025-00026
IT-LSD-2025-00027
IT-LSD-2025-00028
IT-LSD-2025-00029
IT-LSD-2025-00030
IT-LSD-2025-00031
IT-LSD-2025-00032
IT-LSD-2025-00033
IT-LSD-2025-00034
IT-LSD-2025-00035
IT-LSD-2025-00036
IT-LSD-2025-00037
IT-LSD-2025-00038
IT-LSD-2025-00039
IT-LSD-2025-00040
IT-LSD-2025-00041
IT-LSD-2025-00042
IT-LSD-2025-00043
IT-LSD-2025-00044
IT-LSD-2025-00045
IT-LSD-2025-00046
IT-LSD-2025-00047
IT-LSD-2025-00048
IT-LSD-2025-00049
IT-LSD-2025-00050
IT-LSD-2025-00051
IT-LSD-2025-00052
IT-LSD -2025-00053
Protection zone:
Those parts of the region of Sardinia, contained within a circle of a radius of 20 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 40.30429, Long. 9.22154 (2025/1), Lat. 40.31139, Long. 9.09821 (2025/3), Lat. 40.24291, Long. 9.22451 (2025/4), Lat. 40.392626, Long. 9.018567 (2025/5), Lat. 40.2623, Long. 9.082244 (2025/6), Lat. 40.22246, Long. 9.19132 (2025/7), Lat. 40.335997, Long. 9.123835 (2025/8), Lat. 40.28903, 9.102816 Long.(2025/9), Lat. 40.209698, Long. 9.177213 (2025/10), Lat. 40.24404, Long. 9.13817 (2025/11), Lat. 40.33445, Long. 9.15608 (2025/12), Lat. 40.319967 Long. 9.100123 (2025/13), Lat. 40.3451 Long. 9.2594 (2025/14), Lat. 40.3121, Long. 9.2046 (2025/15), Lat. 40.34778, Long. 9.16083 (2025/16), Lat. 40.24096, Long. 9.093 (2025/17), Lat. 40.35071, Long. 9.132964 (2025/18), Lat. 40.3399, Long. 9.167 (2025/19), Lat. 40.725228, Long. 9.485748 (2025/20), Lat. 40.467998, Long. 9.151939 (2025/21), Lat. 40.28833, Long. 9.157329 (2025/22), Lat. 40.24569, Long. 9.20289 (2025/23), Lat. 40.260758, Long. 9.168392 (2025/24), Lat. 40.33221, Long. 9.08099 (2025/25), Lat. 40.280527, Long. 9.116003 (2025/26), Lat. 40.3192, Long. 9.1386 (2025/27), Lat. 40.34618, Long. 9.110074 (2025/28), Lat. 40.304711, Long. 9.068162 (2025/29), Lat. 40.25499, Long. 9.12552 (2025/30), Lat. 40.24738, Long. 9.12763 (2025/31), Lat. 40.28341, Long. 9.22293 (2025/32), Lat. 40.25851, Long. 9.20678 (2025/33), Lat. 40.306593, Long. 9.071998 (2025/34), Lat. 40.33359, Long. 9.16725 (2025/35), Lat. 40.3092, Long. 9.2079 (2025/36), Lat., 40.30125 Long. 9.04641 (2025/37), Lat. 40.25888, Long. 9.2727 (2025/38), Lat. 40.26065, Long. 9.27494 (2025/39), Lat. 40.397264, Long. 9.172869 (2025/40), Lat. 40.30794, Long. 9.07156 (2025/41), Lat. 40.29275, Long. 9.116667 (2025/42), Lat. 40.28273, Long. 9.26401 (2025/43), Lat. 40.284756, Long. 9.303752 (2025/44), Lat. 40.32509, Long. 9.133142 (2025/45), Lat. 40.20129, Long. 9.18471 (2025/46), Lat. 40.23263, Long. 9.15369 (2025/47), Lat. 40.27775, Long. 9.03683 (2025/48), Lat. 40.400795, Long. 9.171361 (2025/49), Lat. 40.38841, Long. 9.00316 (2025/50), Lat. 40.30071, Long. 9.15876 (2025/51), Lat. 40.315906, Long. 9.213706 (2025/52), Lat. 40.1822, Long. 8.5336 (2025/53).
31.11.2025
Surveillance zone:
Those parts of the region of Sardinia, contained within a circle of a radius of 50 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 40.30429, Long. 9.22154 (2025/1), Lat. 40.30429, Long. 9.22154 (2025/1), Lat. 40.31139, Long. 9.09821 (2025/3), Lat. 40.24291, Long. 9.22451 (2025/4), Lat. 40.392626, Long. 9.018567 (2025/5), Lat. 40.2623, Long. 9.082244 (2025/6), Lat. 40.22246, Long. 9.19132 (2025/7), Lat. 40.335997, Long. 9.123835 (2025/8), Lat. 40.28903, Long. 9.102816 (2025/9), Lat. 40.209698 Long. 9.177213 (2025/10), Lat. 40.24404, Long. 9.13817 (2025/11), Lat. 40.33445, Long. 9.15608 (2025/12), Lat. 40.319967, Long. 9.100123 (2025/13), Lat. 40.3451, Long. 9.2594 (2025/14), Lat. 40.3121, Long. 9.2046 (2025/15), Lat. 40.34778, Long. 9.16083 (2025/16), Lat. 40.24096, Long. 9.093 (2025/17), Lat. 40.35071, Long. 9.132964 (2025/18), Lat. 40.3399, Long. 9.167 (2025/19), Lat. 40.725228 Long. 9.485748 (2025/20), Lat. 40.467998, Long. 9.151939 (2025/21), Lat. 40.28833, Long. 9.157329 (2025/22), Lat. 40.24569, Long. 9.20289 (2025/23), Lat. 40.260758, Long. 9.168392 (2025/24), Lat. 40.33221, Long. 9.08099 (2025/25), Lat. 40.280527, Long. 9.116003 (2025/26), Lat. 40.3192, Long. 9.1386 (2025/27), Lat. 40.34618, Long. 9.110074 (2025/28), Lat. 40.304711, Long. 9.068162 (2025/29), Lat. 40.25499, Long. 9.12552 (2025/30), Lat. 40.24738, Long. 9.12763 (2025/31), Lat. 40.28341, Long. 9.22293 (2025/32), Lat. 40.25851, Long. 9.20678 (2025/33), Lat. 40.306593, Long. 9.071998 (2025/34), Lat. 40.33359, Long. 9.16725 (2025/35), Lat. 40.3092, Long. 9.2079 (2025/36), Lat., 40.30125 Long. 9.04641 (2025/37), Lat. 40.25888, Long. 9.2727 (2025/38), Lat. 40.26065, Long. 9.27494 (2025/39), Lat. 40.397264, Long. 9.172869 (2025/40), Lat. 40.30794, Long. 9.07156 (2025/41), Lat. 40.29275, Long. 9.116667 (2025/42), Lat. 40.28273, Long. 9.26401 (2025/43), Lat. 40.284756, Long. 9.303752 (2025/44), Lat. 40.32509, Long. 9.133142 (2025/45), Lat. 40.20129, Long. 9.18471 (2025/46), Lat. 40.23263, Long. 9.15369 (2025/47), Lat. 40.27775, Long. 9.03683 (2025/48), Lat. 40.400795, Long. 9.171361 (2025/49), Lat. 40.38841, Long. 9.00316 (2025/50), Lat. 40.30071, Long. 9.15876 (2025/51), Lat. 40.315906, Long. 9.213706 (2025/52), Lat. 40.1822, Long. 8.5336 (2025/53).
1.12.2025- 17.12.2025
Surveillance zone:
Those parts of the region of Sardinia, contained within a circle of a radius of 20 kilometres, centred on UTM 30, ETRS89 coordinates 40.30429, Long. 9.22154 (2025/1), Lat. 40.30429, Long. 9.22154 (2025/1), Lat. 40.31139, Long. 9.09821 (2025/3), Lat. 40.24291, Long. 9.22451 (2025/4), Lat. 40.392626, Long. 9.018567 (2025/5), Lat. 40.2623, Long. 9.082244 (2025/6), Lat. 40.22246, Long. 9.19132 (2025/7), Lat. 40.335997, Long. 9.123835 (2025/8), Lat. 40.28903, Long. 9.102816 (2025/9), Lat. 40.209698, Long. 9.177213 (2025/10), Lat. 40.24404, Long. 9.13817 (2025/11), Lat. 40.33445, Long. 9.15608 (2025/12), Lat. 40.319967, Long. 9.100123 (2025/13), Lat. 40.3451, Long. 9.2594 (2025/14), Lat. 40.3121, Long. 9.2046 (2025/15), Lat. 40.34778, Long. 9.16083 (2025/16), Lat. 40.24096, Long. 9.093 (2025/17), Lat. 40.35071, Long. 9.132964 (2025/18), Lat. 40.3399, Long. 9.167 (2025/19), Lat. 40.725228, Long. 9.485748 (2025/20), Lat. 40.467998, Long. 9.151939 (2025/21), Lat. 40.28833, Long. 9.157329 (2025/22), Lat. 40.24569, Long. 9.20289 (2025/23), Lat. 40.260758, Long. 9.168392 (2025/24), Lat. 40.33221, Long. 9.08099 (2025/25), Lat. 40.280527, Long. 9.116003 (2025/26), Lat. 40.3192, Long. 9.1386 (2025/27), Lat. 40.34618, Long. 9.110074 (2025/28), Lat. 40.304711, Long. 9.068162 (2025/29), Lat. 40.25499, Long. 9.12552 (2025/30), Lat. 40.24738, Long. 9.12763 (2025/31), Lat. 40.28341, Long. 9.22293 (2025/32), Lat. 40.25851, Long. 9.20678 (2025/33), Lat. 40.306593, Long. 9.071998 (2025/34), Lat. 40.33359, Long. 9.16725 (2025/35), Lat. 40.3092, Long. 9.2079 (2025/36), Lat., 40.30125 Long. 9.04641 (2025/37), Lat. 40.25888, Long. 9.2727 (2025/38), Lat. 40.26065, Long. 9.27494 (2025/39), Lat. 40.397264, Long. 9.172869 (2025/40), Lat. 40.30794, Long. 9.07156 (2025/41), Lat. 40.29275, Long. 9.116667 (2025/42), Lat. 40.28273, Long. 9.26401 (2025/43), Lat. 40.284756, Long. 9.303752 (2025/44), Lat. 40.32509, Long. 9.133142 (2025/45), Lat. 40.20129, Long. 9.18471 (2025/46), Lat. 40.23263, Long. 9.15369 (2025/47), Lat. 40.27775, Long. 9.03683 (2025/48), Lat. 40.400795, Long. 9.171361 (2025/49), Lat. 40.38841, Long. 9.00316 (2025/50), Lat. 40.30071, Long. 9.15876 (2025/51), Lat. 40.315906, Long. 9.213706 (2025/52), Lat. 40.1822, Long. 8.5336 (2025/53), excluding the areas included in the protection zone.
17.12.2025
Valle d’Aosta region
FR-LSD-2025-00017
FR-LSD-2025-00018
FR-LSD-2025-00022
FR-LSD-2025-00026
FR-LSD-2025-00027
FR-LSD-2025-00028
FR-LSD-2025-00029
FR-LSD-2025-00030
FR-LSD-2025-00031
FR-LSD-2025-00032
FR-LSD-2025-00033
FR-LSD-2025-00034
FR-LSD-2025-00038
FR-LSD-2025-00048
FR-LSD-2025-00049
FR-LSD-2025-00051
FR-LSD-2025-00053
FR-LSD-2025-00054
FR-LSD-2025-00061
FR-LSD-2025-00064
FR-LSD-2025-00069
FR-LSD-2025-00073
FR-LSD-2025-00075
Surveillance zone:
Those parts of the region of Valle d’Aosta, contained within a circle of a radius of 50 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 45.739081, Long 6.309311 (FR-LSD-2025-00017) Lat. 45.742, Long. 6.290 (FR-LSD-2025-00018), Lat. 45.788, Long. 6.204 (FR-LSD-2025-00022), Lat. 45.753, Long. 6.272 (FR-LSD-2025-00026), Lat. 45.747, Long. 6.284 (FR-LSD-2025-00027), Lat. 45.731, Long. 6.294 (FR-LSD-2025-00028), Lat. 45.748, Long. 6.294 (FR-LSD-2025-00029), Lat. 45.761, Long. 6.310 (FR-LSD-2025-00030), Lat. 45.762, Long. 6.309 (FR-LSD-2025-00031), Lat. 45.732, Long. 6.296 (FR-LSD-2025-00032), Lat. 45.748, Long. 6.294 (FR-LSD-2025-00033), Lat. 45.767, Long. 6.535 (FR-LSD-2025-00034), Lat. 45.728, Long. 6.269 (FR-LSD-2025-00038), Lat. 45.788, Long. 6.204 (FR-LSD-2025-00048), Lat. 45.741, Long. 6.306 (FR-LSD-2025-00049), Lat. 45.750, Long. 6.318 (FR-LSD-2025-00051), Lat. 45.773, Long. 6.254 (FR-LSD-2025-00053), Lat. 45.771, Long. 6.252 (FR-LSD-2025-00054), Lat. 45.749, Long. 6.317 (FR-LSD-2025-00061), Lat. 45.748, Long. 6.297 (FR-LSD-2025-00064), Lat 45.729, Long. 6.267 (FR-LSD-2025-00069), Lat. 45.705, Long. 6.305 (FR-LSD-2025-00073), Lat. 45.728, Long. 6.262 (FR-LSD-2025-00075)
27.9.2025
Part B: Further restricted zone
Administrative area
Areas established as further restricted zone, part of the restricted zone, referred to in Article 1
Date until applicable
Sardinia region
The entire territory of the region of Sardinia, excluding the areas included in any protection or surveillance zone.
18.12.2025
ANNEX II
Areas referred to in Article 3
Administrative area
Areas referred to in Article 3
Date until applicable
Sardinia region
The entire territory of the region of Sardinia
19.12.2025-18.01.2026
ANNEX III
Part A: Vaccination zone II
The entire territory of
—
the region of Sardinia until 21.10.2025. —
those areas contained the surveillance zone of the region of Valle D’Aosta until 30.09.2025. Part B: Vaccination zone I
The entire territory of:
—
the region of Sardina as of 22.10.2025 until last day of the recovery period, chosen by Italy, referred to in Part 4 of Annex IX to Delegated Regulation (EU) 2023/361. —
the region of Valle D’Aosta excluding the surveillance zone in that region until 30.09.2025. —
the region of Valle D’Aosta as of 1.10.2025 until last day of the recovery period, chosen by Italy, referred to in Part 4 of Annex IX to Delegated Regulation (EU) 2023/361. ’

Commission Implementing Decision (EU) 2025/1762 of 25 August 2025 amending Implementing Decision (EU) 2025/1708 concerning certain emergency measures relating to infection with lumpy skin disease virus in France (notified under document C(2025) 5879)

January 13, 2026
Official Journalof the European Union ENL series
2025/1762 28.8.2025
(1) Infection with lumpy skin disease virus is an infectious, vector-borne disease affecting bovine animals. Its occurrence can have a severe impact on the concerned animal population and on the profitability of farming, also causing disturbance to movements of those animals and products thereof within the Union and exports to third countries.
(2) In the event of an outbreak of infection lumpy skin disease virus in bovine animals, there is a serious risk of the spread of that disease to other establishments of bovine animals particularly due its main mode of transmission through vectors.
(3) Commission Delegated Regulation (EU) 2020/687(2)supplements the rules for the control of the listed diseases referred to in Article 9(1), points (a), (b) and (c), of Regulation (EU) 2016/429, and defined as category A, B and C diseases in Commission Implementing Regulation (EU) 2018/1882(3). In particular, Articles 21 and 22 of Delegated Regulation (EU) 2020/687 provide for the establishment of a restricted zone in the event of an outbreak of a category A disease, including infection with lumpy skin disease virus, and for certain measures to be applied therein. In addition, Article 21(1) of that Delegated Regulation provides that the restricted zone is to comprise at least a protection zone, a surveillance zone, and, if necessary, further restricted zones around or adjacent to the protection and surveillance zones.
(4) Commission Implementing Decision (EU) 2025/1708(4)lays down certain emergency measures related to outbreaks of infection with lumpy skin disease virus in France. More particularly, Implementing Decision (EU) 2025/1708 provides for the establishment, in France, of restricted zones, comprising protection and surveillance zones, in accordance with Article 21 of Delegated Regulation (EU) 2020/687 as well as of a vaccination zone in accordance with Part 1 of Annex IX to Commission Delegated Regulation (EU) 2023/361(5). In addition, Article 1 of Implementing Decision (EU) 2025/1708 provides that those protection and surveillance zones, as well as the vaccination zone, are to comprise at least the areas listed in the Annexes thereto, and the measures required to be applied in those zones are to be applied at least until the dates set out in those Annexes.
(5) Since the adoption of Implementing Decision (EU) 2025/1708, France has notified the Commission of 40 additional confirmed outbreaks of infection with lumpy skin disease virus in establishments keeping bovine animals in the communes of Chambéry and Annecy, departments of Savoie and Haute Savoie, region of Auvergne-Rhône-Alpes, which were reported between 24 July and 14 August 2025. In response to these outbreaks, France has established protection and surveillance zones in the departments of Ain, Isere, Savoie, and Haute Savoie, region of Auvergne-Rhône-Alpe, where the disease control measures laid down in accordance with Delegated Regulation (EU) 2020/687 are applied.
(6) In order to prevent any unnecessary disturbance to trade within the Union, and to avoid unjustified barriers to trade being imposed by third countries, the areas indicated as protection and surveillance zones in Annex I to Implementing Decision (EU) 2025/1708 should, therefore, be updated by this Decision, and the duration of the measures to be applied in these zones fixed.
(7) The size of the areas indicated as protection and surveillance zones in Annex I to Implementing Decision (EU) 2025/1708, as amended by this Decision, as well as the duration of the measures to be applied therein, are based on the criteria laid down in Article 64(1) of Regulation (EU) 2016/429 as well as on the rules laid down in Delegated Regulation (EU) 2020/687. The criteria applied for the choice of the size of the protection zone and the surveillance zone, as well as of the duration of the measures to be applied therein, include the consideration of not only the epidemiological situation as regards infection with lumpy skin disease virus in the areas affected by that disease, but also of other epidemiological factors, including geographical parameters and the risk for the further spread of the disease in view of the presence of insect vectors. The chosen duration of the measures foreseen in this Decision has also taken into account the international standards of the Terrestrial Animal Health Code of the World Organisation for Animal Health(6).
(8) Article 2 of Implementing Decision (EU) 2025/1708 provides for the prohibition on movements of bovine animals from the areas set out in Annex I to that Decision to destinations outside the external perimeter of those zones in France or outside that Member State until the dates listed in that Annex. In view of the continuing outbreaks of infection with lumpy skin disease virus in France, and in order to prevent further spread of the disease as well as to avoid unnecessary disturbance to trade within the Union and unjustified barriers to trade with third countries, it is necessary to prolong that prohibition.
(9) Therefore, Annex I to Implementing Decision (EU) 2025/1708 should be amended accordingly.
(10) In addition, Article 69 of Regulation (EU) 2016/429, provides that the competent authority of a Member State may develop a vaccination plan or establish vaccination zones, where relevant for the effective control of a listed disease in kept animals. Article 6 of Delegated Regulation (EU) 2023/361 lays down detailed rules for official vaccination plans. That Delegated Regulation also provides, in Article 9, for rules for the implementation of emergency protective vaccination. Detailed conditions for the use of emergency protective vaccination against lumpy skin disease are laid down in Annex IX thereof.
(11) On 1 August 2025, France provided the Commission with its official vaccination plan for infection with lumpy skin disease in the territory of the four departments of Ain, Savoie, Haute-Savoie and Isère in the Auvergne-Rhône-Alpes region of France, in accordance with Article 6(4), point (b), of Delegated Regulation (EU) 2023/361, together with updated data regarding the implementation of that plan.
(12) In order to ensure coordinated disease control and to safeguard trade within the Union and with third countries, it is necessary, to adjust the vaccination zone infection with lumpy skin disease laid down in Annex II to Implementing Decision (EU) 2025/1708, at Union level.
(13) The type, size and duration of vaccination zones I and II set out in Annex II are based on the epidemiological situation and the progress of the vaccination campaigns, particularly taking into account the evolving level of vaccine coverage achieved, the Member State’s official vaccination plan and the progress reports submitted in accordance with Article 11 of Delegated Regulation (EU) 2023/361. Accordingly, Annex II to this Decision should indicate for each area concerned, the dates for during which the vaccination zones are to apply.
(14) Therefore, Annex II to Implementing Decision (EU) 2025/1708 should be amended accordingly.
(15) In light of the epidemiological situation, the amendments to Implementing Decision (EU) 2025/1708 should apply as soon as possible to prevent further spread of the disease within France, to other Member States, or to third countries, and to avoid unnecessary disturbance to trade within the Union or unjustified barriers to trade with third countries.
(16) The measures provided for in this Decision are in accordance with the opinion of the Standing Committee on Plants, Animals, Food and Feed,
Administrative area and ADIS reference number of the outbreak Areas established as protection and surveillance zones, part of the restricted zone, referred to in Article 1 Date until applicable
Region of Auvergne-Rhône-AlpesFR-LSD-2025-00001FR-LSD-2025-00002FR-LSD-2025-00003FR-LSD-2025-00004FR-LSD-2025-00005FR-LSD-2025-00006FR-LSD-2025-00007FR-LSD-2025-00008FR-LSD-2025-00009FR-LSD-2025-00010FR-LSD-2025-00011FR-LSD-2025-00012FR-LSD-2025-00013FR-LSD-2025-00014FR-LSD-2025-00015FR-LSD-2025-00016FR-LSD-2025-00017FR-LSD-2025-00018FR-LSD-2025-00019FR-LSD-2025-00020FR-LSD-2025-00021FR-LSD-2025-00022FR-LSD-2025-00023FR-LSD-2025-00024FR-LSD-2025-00025FR-LSD-2025-00026FR-LSD-2025-00027FR-LSD-2025-00028FR-LSD-2025-00029FR-LSD-2025-00030FR-LSD-2025-00031FR-LSD-2025-00032FR-LSD-2025-00033FR-LSD-2025-00034FR-LSD-2025-00035FR-LSD-2025-00036FR-LSD-2025-00037FR-LSD-2025-00038FR-LSD-2025-00039FR-LSD-2025-00040FR-LSD-2025-00041FR-LSD-2025-00042FR-LSD-2025-00043FR-LSD-2025-00044FR-LSD-2025-00045FR-LSD-2025-00046FR-LSD-2025-00047FR-LSD-2025-00048FR-LSD-2025-00049FR-LSD-2025-00050FR-LSD-2025-00051FR-LSD-2025-00052FR-LSD-2025-00053FR-LSD-2025-00054FR-LSD-2025-00055FR-LSD-2025-00056FR-LSD-2025-00057FR-LSD-2025-00058FR-LSD-2025-00059FR-LSD-2025-00060FR-LSD-2025-00061FR-LSD-2025-00062FR-LSD-2025-00063FR-LSD-2025-00064FR-LSD-2025-00065FR-LSD-2025-00066FR-LSD-2025-00067FR-LSD-2025-00068FR-LSD-2025-00069FR-LSD-2025-00070FR-LSD-2025-00071FR-LSD-2025-00072FR-LSD-2025-00073FR-LSD-2025-00074 Protection zone:The following municipalities in the following departments from region of Auvergne-Rhône-Alpes:AIN Department—Andert-et-Condon—Anglefort—Arboys en Bugey—Artemare—Belley—Valromey-sur-Séran—Brens—Ceyzérieu—Champagne-en-Valromey—Chazey-Bons—Cheignieu-la-Balme—Contrevoz—Corbonod—Cressin-Rochefort—Culoz-Béon—Cuzieu—Flaxieu—Lavours—Magnieu—Marignieu—Massignieu-de-Rives—Parves et Nattages—Peyrieu—Pollieu—Saint-Germain-les-Paroisses—Saint-Martin-de-Bavel—Seyssel—Talissieu—Virieu-le-Grand—Arvière-en-Valromey—Virignin—VongnesSAVOIE Department—Aillon-le-Jeune—Aillon-le-Vieux—Aime-la-Plagne—Aiton—Aix-les-Bains—Entrelacs—Albertville—Allondaz—Arith—La Balme—La Bâthie—Beaufort—Bellecombe-en-Bauges—Billième—La Biolle—Bonvillard—Bonvillaret—Bourdeau—Le Bourget-du-Lac—Bourgneuf—Bourg-Saint-Maurice—Brison-Saint-Innocent—Césarches—Cevins—Chamousset—Chanaz—La Chapelle-du-Mont-du-Chat—Les Chapelles—La Chapelle-Saint-Martin—Le Châtelard—Chindrieux—Cléry—Cohennoz—La Compôte—Conjux—Crest-Voland—Les Déserts—Doucy-en-Bauges—Drumettaz-Clarafond—École—Esserts-Blay—Flumet—Fréterive—Frontenex—La Giettaz—Gilly-sur-Isère—Grésy-sur-Aix—Grésy-sur-Isère—Grignon—Hauteluce—Jarsy—Jongieux—Lescheraines—Loisieux—Lucey—La Plagne Tarentaise—Marthod—Mercury—Méry—Meyrieux-Trouet—Montailleur—Montcel—Monthion—Montsapey—La Motte-en-Bauges—La Motte-Servolex—Motz—Mouxy—Notre-Dame-de-Bellecombe—La Léchère—Notre-Dame-des-Millières—Le Noyer—Ontex—Pallud—Plancherine—Pugny-Chatenod—Queige—Val-d’Arc—Rognaix—Ruffieux—Saint-François-de-Sales—Sainte-Hélène-sur-Isère—Saint-Jean-de-Chevelu—Saint-Nicolas-la-Chapelle—Saint-Offenge—Saint-Ours—Saint-Paul-sur-Isère—Saint-Paul-sur-Yenne—Saint-Pierre-d’Albigny—Saint-Pierre-de-Curtille—Sainte-Reine—Saint-Vital—Serrières-en-Chautagne—Sonnaz—Thénésol—Tournon—Tours-en-Savoie—Traize—Tresserve—Trévignin—Ugine—Venthon—Verel-Pragondran—Verrens-Arvey—Verthemex—Villard-sur-Doron—Vions—Viviers-du-Lac—Voglans—YenneHAUTE-SAVOIE Department—Alby-sur-Chéran—Alex—Allèves—Annecy—Argonay—La Balme-de-Sillingy—La Balme-de-Thuy—Bassy—Bloye—Bluffy—Le Bouchet-Mont-Charvin—Boussy—Chainaz-les-Frasses—La Chapelle-Saint-Maurice—Chapeiry—Chavanod—Chevaline—Chilly—Choisy—Clermont—Les Clefs—La Clusaz—Combloux—Les Contamines-Montjoie—Cordon—Crempigny-Bonneguête—Cusy—Cuvat—Demi-Quartier—Desingy—Dingy-Saint-Clair—Domancy—Doussard—Droisy—Duingt—Entrevernes—Epagny Metz-Tessy—Étercy—Faverges-Seythenex—Giez—Le Grand-Bornand—Gruffy—Hauteville-sur-Fier—Héry-sur-Alby—Lathuile—Leschaux—Lornay—Lovagny—Manigod—Marcellaz-Albanais—Marigny-Saint-Marcel—Val de Chaise—Massingy—Megève—Menthon-Saint-Bernard—Menthonnex-sous-Clermont—Mésigny—Montagny-les-Lanches—Moye—Mûres—Nonglard—Poisy—Praz-sur-Arly—Quintal—Rumilly—Saint-Eusèbe—Saint-Eustache—Saint-Félix—Saint-Ferréol—Saint-Gervais-les-Bains—Saint-Jean-de-Sixt—Saint-Jorioz—Saint-Sylvestre—Sales—Sallanches—Sallenôves—Serraval—Sevrier—Seyssel—Sillingy—Talloires-Montmin—Thônes—Thusy—Vallières-sur-Fier—Vaulx—Versonnex—Veyrier-du-Lac—Les Villards-sur-Thônes—Viuz-la-Chiésaz AIN Department—Andert-et-Condon—Anglefort—Arboys en Bugey—Artemare—Belley—Valromey-sur-Séran—Brens—Ceyzérieu—Champagne-en-Valromey—Chazey-Bons—Cheignieu-la-Balme—Contrevoz—Corbonod—Cressin-Rochefort—Culoz-Béon—Cuzieu—Flaxieu—Lavours—Magnieu—Marignieu—Massignieu-de-Rives—Parves et Nattages—Peyrieu—Pollieu—Saint-Germain-les-Paroisses—Saint-Martin-de-Bavel—Seyssel—Talissieu—Virieu-le-Grand—Arvière-en-Valromey—Virignin—Vongnes — Andert-et-Condon — Anglefort — Arboys en Bugey — Artemare — Belley — Valromey-sur-Séran — Brens — Ceyzérieu — Champagne-en-Valromey — Chazey-Bons — Cheignieu-la-Balme — Contrevoz — Corbonod — Cressin-Rochefort — Culoz-Béon — Cuzieu — Flaxieu — Lavours — Magnieu — Marignieu — Massignieu-de-Rives — Parves et Nattages — Peyrieu — Pollieu — Saint-Germain-les-Paroisses — Saint-Martin-de-Bavel — Seyssel — Talissieu — Virieu-le-Grand — Arvière-en-Valromey — Virignin — Vongnes SAVOIE Department—Aillon-le-Jeune—Aillon-le-Vieux—Aime-la-Plagne—Aiton—Aix-les-Bains—Entrelacs—Albertville—Allondaz—Arith—La Balme—La Bâthie—Beaufort—Bellecombe-en-Bauges—Billième—La Biolle—Bonvillard—Bonvillaret—Bourdeau—Le Bourget-du-Lac—Bourgneuf—Bourg-Saint-Maurice—Brison-Saint-Innocent—Césarches—Cevins—Chamousset—Chanaz—La Chapelle-du-Mont-du-Chat—Les Chapelles—La Chapelle-Saint-Martin—Le Châtelard—Chindrieux—Cléry—Cohennoz—La Compôte—Conjux—Crest-Voland—Les Déserts—Doucy-en-Bauges—Drumettaz-Clarafond—École—Esserts-Blay—Flumet—Fréterive—Frontenex—La Giettaz—Gilly-sur-Isère—Grésy-sur-Aix—Grésy-sur-Isère—Grignon—Hauteluce—Jarsy—Jongieux—Lescheraines—Loisieux—Lucey—La Plagne Tarentaise—Marthod—Mercury—Méry—Meyrieux-Trouet—Montailleur—Montcel—Monthion—Montsapey—La Motte-en-Bauges—La Motte-Servolex—Motz—Mouxy—Notre-Dame-de-Bellecombe—La Léchère—Notre-Dame-des-Millières—Le Noyer—Ontex—Pallud—Plancherine—Pugny-Chatenod—Queige—Val-d’Arc—Rognaix—Ruffieux—Saint-François-de-Sales—Sainte-Hélène-sur-Isère—Saint-Jean-de-Chevelu—Saint-Nicolas-la-Chapelle—Saint-Offenge—Saint-Ours—Saint-Paul-sur-Isère—Saint-Paul-sur-Yenne—Saint-Pierre-d’Albigny—Saint-Pierre-de-Curtille—Sainte-Reine—Saint-Vital—Serrières-en-Chautagne—Sonnaz—Thénésol—Tournon—Tours-en-Savoie—Traize—Tresserve—Trévignin—Ugine—Venthon—Verel-Pragondran—Verrens-Arvey—Verthemex—Villard-sur-Doron—Vions—Viviers-du-Lac—Voglans—Yenne — Aillon-le-Jeune — Aillon-le-Vieux — Aime-la-Plagne — Aiton — Aix-les-Bains — Entrelacs — Albertville — Allondaz — Arith — La Balme — La Bâthie — Beaufort — Bellecombe-en-Bauges — Billième — La Biolle — Bonvillard — Bonvillaret — Bourdeau — Le Bourget-du-Lac — Bourgneuf — Bourg-Saint-Maurice — Brison-Saint-Innocent — Césarches — Cevins — Chamousset — Chanaz — La Chapelle-du-Mont-du-Chat — Les Chapelles — La Chapelle-Saint-Martin — Le Châtelard — Chindrieux — Cléry — Cohennoz — La Compôte — Conjux — Crest-Voland — Les Déserts — Doucy-en-Bauges — Drumettaz-Clarafond — École — Esserts-Blay — Flumet — Fréterive — Frontenex — La Giettaz — Gilly-sur-Isère — Grésy-sur-Aix — Grésy-sur-Isère — Grignon — Hauteluce — Jarsy — Jongieux — Lescheraines — Loisieux — Lucey — La Plagne Tarentaise — Marthod — Mercury — Méry — Meyrieux-Trouet — Montailleur — Montcel — Monthion — Montsapey — La Motte-en-Bauges — La Motte-Servolex — Motz — Mouxy — Notre-Dame-de-Bellecombe — La Léchère — Notre-Dame-des-Millières — Le Noyer — Ontex — Pallud — Plancherine — Pugny-Chatenod — Queige — Val-d’Arc — Rognaix — Ruffieux — Saint-François-de-Sales — Sainte-Hélène-sur-Isère — Saint-Jean-de-Chevelu — Saint-Nicolas-la-Chapelle — Saint-Offenge — Saint-Ours — Saint-Paul-sur-Isère — Saint-Paul-sur-Yenne — Saint-Pierre-d’Albigny — Saint-Pierre-de-Curtille — Sainte-Reine — Saint-Vital — Serrières-en-Chautagne — Sonnaz — Thénésol — Tournon — Tours-en-Savoie — Traize — Tresserve — Trévignin — Ugine — Venthon — Verel-Pragondran — Verrens-Arvey — Verthemex — Villard-sur-Doron — Vions — Viviers-du-Lac — Voglans — Yenne HAUTE-SAVOIE Department—Alby-sur-Chéran—Alex—Allèves—Annecy—Argonay—La Balme-de-Sillingy—La Balme-de-Thuy—Bassy—Bloye—Bluffy—Le Bouchet-Mont-Charvin—Boussy—Chainaz-les-Frasses—La Chapelle-Saint-Maurice—Chapeiry—Chavanod—Chevaline—Chilly—Choisy—Clermont—Les Clefs—La Clusaz—Combloux—Les Contamines-Montjoie—Cordon—Crempigny-Bonneguête—Cusy—Cuvat—Demi-Quartier—Desingy—Dingy-Saint-Clair—Domancy—Doussard—Droisy—Duingt—Entrevernes—Epagny Metz-Tessy—Étercy—Faverges-Seythenex—Giez—Le Grand-Bornand—Gruffy—Hauteville-sur-Fier—Héry-sur-Alby—Lathuile—Leschaux—Lornay—Lovagny—Manigod—Marcellaz-Albanais—Marigny-Saint-Marcel—Val de Chaise—Massingy—Megève—Menthon-Saint-Bernard—Menthonnex-sous-Clermont—Mésigny—Montagny-les-Lanches—Moye—Mûres—Nonglard—Poisy—Praz-sur-Arly—Quintal—Rumilly—Saint-Eusèbe—Saint-Eustache—Saint-Félix—Saint-Ferréol—Saint-Gervais-les-Bains—Saint-Jean-de-Sixt—Saint-Jorioz—Saint-Sylvestre—Sales—Sallanches—Sallenôves—Serraval—Sevrier—Seyssel—Sillingy—Talloires-Montmin—Thônes—Thusy—Vallières-sur-Fier—Vaulx—Versonnex—Veyrier-du-Lac—Les Villards-sur-Thônes—Viuz-la-Chiésaz — Alby-sur-Chéran — Alex — Allèves — Annecy — Argonay — La Balme-de-Sillingy — La Balme-de-Thuy — Bassy — Bloye — Bluffy — Le Bouchet-Mont-Charvin — Boussy — Chainaz-les-Frasses — La Chapelle-Saint-Maurice — Chapeiry — Chavanod — Chevaline — Chilly — Choisy — Clermont — Les Clefs — La Clusaz — Combloux — Les Contamines-Montjoie — Cordon — Crempigny-Bonneguête — Cusy — Cuvat — Demi-Quartier — Desingy — Dingy-Saint-Clair — Domancy — Doussard — Droisy — Duingt — Entrevernes — Epagny Metz-Tessy — Étercy — Faverges-Seythenex — Giez — Le Grand-Bornand — Gruffy — Hauteville-sur-Fier — Héry-sur-Alby — Lathuile — Leschaux — Lornay — Lovagny — Manigod — Marcellaz-Albanais — Marigny-Saint-Marcel — Val de Chaise — Massingy — Megève — Menthon-Saint-Bernard — Menthonnex-sous-Clermont — Mésigny — Montagny-les-Lanches — Moye — Mûres — Nonglard — Poisy — Praz-sur-Arly — Quintal — Rumilly — Saint-Eusèbe — Saint-Eustache — Saint-Félix — Saint-Ferréol — Saint-Gervais-les-Bains — Saint-Jean-de-Sixt — Saint-Jorioz — Saint-Sylvestre — Sales — Sallanches — Sallenôves — Serraval — Sevrier — Seyssel — Sillingy — Talloires-Montmin — Thônes — Thusy — Vallières-sur-Fier — Vaulx — Versonnex — Veyrier-du-Lac — Les Villards-sur-Thônes — Viuz-la-Chiésaz 13.9.2025
AIN Department—Andert-et-Condon—Anglefort—Arboys en Bugey—Artemare—Belley—Valromey-sur-Séran—Brens—Ceyzérieu—Champagne-en-Valromey—Chazey-Bons—Cheignieu-la-Balme—Contrevoz—Corbonod—Cressin-Rochefort—Culoz-Béon—Cuzieu—Flaxieu—Lavours—Magnieu—Marignieu—Massignieu-de-Rives—Parves et Nattages—Peyrieu—Pollieu—Saint-Germain-les-Paroisses—Saint-Martin-de-Bavel—Seyssel—Talissieu—Virieu-le-Grand—Arvière-en-Valromey—Virignin—Vongnes — Andert-et-Condon — Anglefort — Arboys en Bugey — Artemare — Belley — Valromey-sur-Séran — Brens — Ceyzérieu — Champagne-en-Valromey — Chazey-Bons — Cheignieu-la-Balme — Contrevoz — Corbonod — Cressin-Rochefort — Culoz-Béon — Cuzieu — Flaxieu — Lavours — Magnieu — Marignieu — Massignieu-de-Rives — Parves et Nattages — Peyrieu — Pollieu — Saint-Germain-les-Paroisses — Saint-Martin-de-Bavel — Seyssel — Talissieu — Virieu-le-Grand — Arvière-en-Valromey — Virignin — Vongnes
— Andert-et-Condon
— Anglefort
— Arboys en Bugey
— Artemare
— Belley
— Valromey-sur-Séran
— Brens
— Ceyzérieu
— Champagne-en-Valromey
— Chazey-Bons
— Cheignieu-la-Balme
— Contrevoz
— Corbonod
— Cressin-Rochefort
— Culoz-Béon
— Cuzieu
— Flaxieu
— Lavours
— Magnieu
— Marignieu
— Massignieu-de-Rives
— Parves et Nattages
— Peyrieu
— Pollieu
— Saint-Germain-les-Paroisses
— Saint-Martin-de-Bavel
— Seyssel
— Talissieu
— Virieu-le-Grand
— Arvière-en-Valromey
— Virignin
— Vongnes
SAVOIE Department—Aillon-le-Jeune—Aillon-le-Vieux—Aime-la-Plagne—Aiton—Aix-les-Bains—Entrelacs—Albertville—Allondaz—Arith—La Balme—La Bâthie—Beaufort—Bellecombe-en-Bauges—Billième—La Biolle—Bonvillard—Bonvillaret—Bourdeau—Le Bourget-du-Lac—Bourgneuf—Bourg-Saint-Maurice—Brison-Saint-Innocent—Césarches—Cevins—Chamousset—Chanaz—La Chapelle-du-Mont-du-Chat—Les Chapelles—La Chapelle-Saint-Martin—Le Châtelard—Chindrieux—Cléry—Cohennoz—La Compôte—Conjux—Crest-Voland—Les Déserts—Doucy-en-Bauges—Drumettaz-Clarafond—École—Esserts-Blay—Flumet—Fréterive—Frontenex—La Giettaz—Gilly-sur-Isère—Grésy-sur-Aix—Grésy-sur-Isère—Grignon—Hauteluce—Jarsy—Jongieux—Lescheraines—Loisieux—Lucey—La Plagne Tarentaise—Marthod—Mercury—Méry—Meyrieux-Trouet—Montailleur—Montcel—Monthion—Montsapey—La Motte-en-Bauges—La Motte-Servolex—Motz—Mouxy—Notre-Dame-de-Bellecombe—La Léchère—Notre-Dame-des-Millières—Le Noyer—Ontex—Pallud—Plancherine—Pugny-Chatenod—Queige—Val-d’Arc—Rognaix—Ruffieux—Saint-François-de-Sales—Sainte-Hélène-sur-Isère—Saint-Jean-de-Chevelu—Saint-Nicolas-la-Chapelle—Saint-Offenge—Saint-Ours—Saint-Paul-sur-Isère—Saint-Paul-sur-Yenne—Saint-Pierre-d’Albigny—Saint-Pierre-de-Curtille—Sainte-Reine—Saint-Vital—Serrières-en-Chautagne—Sonnaz—Thénésol—Tournon—Tours-en-Savoie—Traize—Tresserve—Trévignin—Ugine—Venthon—Verel-Pragondran—Verrens-Arvey—Verthemex—Villard-sur-Doron—Vions—Viviers-du-Lac—Voglans—Yenne — Aillon-le-Jeune — Aillon-le-Vieux — Aime-la-Plagne — Aiton — Aix-les-Bains — Entrelacs — Albertville — Allondaz — Arith — La Balme — La Bâthie — Beaufort — Bellecombe-en-Bauges — Billième — La Biolle — Bonvillard — Bonvillaret — Bourdeau — Le Bourget-du-Lac — Bourgneuf — Bourg-Saint-Maurice — Brison-Saint-Innocent — Césarches — Cevins — Chamousset — Chanaz — La Chapelle-du-Mont-du-Chat — Les Chapelles — La Chapelle-Saint-Martin — Le Châtelard — Chindrieux — Cléry — Cohennoz — La Compôte — Conjux — Crest-Voland — Les Déserts — Doucy-en-Bauges — Drumettaz-Clarafond — École — Esserts-Blay — Flumet — Fréterive — Frontenex — La Giettaz — Gilly-sur-Isère — Grésy-sur-Aix — Grésy-sur-Isère — Grignon — Hauteluce — Jarsy — Jongieux — Lescheraines — Loisieux — Lucey — La Plagne Tarentaise — Marthod — Mercury — Méry — Meyrieux-Trouet — Montailleur — Montcel — Monthion — Montsapey — La Motte-en-Bauges — La Motte-Servolex — Motz — Mouxy — Notre-Dame-de-Bellecombe — La Léchère — Notre-Dame-des-Millières — Le Noyer — Ontex — Pallud — Plancherine — Pugny-Chatenod — Queige — Val-d’Arc — Rognaix — Ruffieux — Saint-François-de-Sales — Sainte-Hélène-sur-Isère — Saint-Jean-de-Chevelu — Saint-Nicolas-la-Chapelle — Saint-Offenge — Saint-Ours — Saint-Paul-sur-Isère — Saint-Paul-sur-Yenne — Saint-Pierre-d’Albigny — Saint-Pierre-de-Curtille — Sainte-Reine — Saint-Vital — Serrières-en-Chautagne — Sonnaz — Thénésol — Tournon — Tours-en-Savoie — Traize — Tresserve — Trévignin — Ugine — Venthon — Verel-Pragondran — Verrens-Arvey — Verthemex — Villard-sur-Doron — Vions — Viviers-du-Lac — Voglans — Yenne
— Aillon-le-Jeune
— Aillon-le-Vieux
— Aime-la-Plagne
— Aiton
— Aix-les-Bains
— Entrelacs
— Albertville
— Allondaz
— Arith
— La Balme
— La Bâthie
— Beaufort
— Bellecombe-en-Bauges
— Billième
— La Biolle
— Bonvillard
— Bonvillaret
— Bourdeau
— Le Bourget-du-Lac
— Bourgneuf
— Bourg-Saint-Maurice
— Brison-Saint-Innocent
— Césarches
— Cevins
— Chamousset
— Chanaz
— La Chapelle-du-Mont-du-Chat
— Les Chapelles
— La Chapelle-Saint-Martin
— Le Châtelard
— Chindrieux
— Cléry
— Cohennoz
— La Compôte
— Conjux
— Crest-Voland
— Les Déserts
— Doucy-en-Bauges
— Drumettaz-Clarafond
— École
— Esserts-Blay
— Flumet
— Fréterive
— Frontenex
— La Giettaz
— Gilly-sur-Isère
— Grésy-sur-Aix
— Grésy-sur-Isère
— Grignon
— Hauteluce
— Jarsy
— Jongieux
— Lescheraines
— Loisieux
— Lucey
— La Plagne Tarentaise
— Marthod
— Mercury
— Méry
— Meyrieux-Trouet
— Montailleur
— Montcel
— Monthion
— Montsapey
— La Motte-en-Bauges
— La Motte-Servolex
— Motz
— Mouxy
— Notre-Dame-de-Bellecombe
— La Léchère
— Notre-Dame-des-Millières
— Le Noyer
— Ontex
— Pallud
— Plancherine
— Pugny-Chatenod
— Queige
— Val-d’Arc
— Rognaix
— Ruffieux
— Saint-François-de-Sales
— Sainte-Hélène-sur-Isère
— Saint-Jean-de-Chevelu
— Saint-Nicolas-la-Chapelle
— Saint-Offenge
— Saint-Ours
— Saint-Paul-sur-Isère
— Saint-Paul-sur-Yenne
— Saint-Pierre-d’Albigny
— Saint-Pierre-de-Curtille
— Sainte-Reine
— Saint-Vital
— Serrières-en-Chautagne
— Sonnaz
— Thénésol
— Tournon
— Tours-en-Savoie
— Traize
— Tresserve
— Trévignin
— Ugine
— Venthon
— Verel-Pragondran
— Verrens-Arvey
— Verthemex
— Villard-sur-Doron
— Vions
— Viviers-du-Lac
— Voglans
— Yenne
HAUTE-SAVOIE Department—Alby-sur-Chéran—Alex—Allèves—Annecy—Argonay—La Balme-de-Sillingy—La Balme-de-Thuy—Bassy—Bloye—Bluffy—Le Bouchet-Mont-Charvin—Boussy—Chainaz-les-Frasses—La Chapelle-Saint-Maurice—Chapeiry—Chavanod—Chevaline—Chilly—Choisy—Clermont—Les Clefs—La Clusaz—Combloux—Les Contamines-Montjoie—Cordon—Crempigny-Bonneguête—Cusy—Cuvat—Demi-Quartier—Desingy—Dingy-Saint-Clair—Domancy—Doussard—Droisy—Duingt—Entrevernes—Epagny Metz-Tessy—Étercy—Faverges-Seythenex—Giez—Le Grand-Bornand—Gruffy—Hauteville-sur-Fier—Héry-sur-Alby—Lathuile—Leschaux—Lornay—Lovagny—Manigod—Marcellaz-Albanais—Marigny-Saint-Marcel—Val de Chaise—Massingy—Megève—Menthon-Saint-Bernard—Menthonnex-sous-Clermont—Mésigny—Montagny-les-Lanches—Moye—Mûres—Nonglard—Poisy—Praz-sur-Arly—Quintal—Rumilly—Saint-Eusèbe—Saint-Eustache—Saint-Félix—Saint-Ferréol—Saint-Gervais-les-Bains—Saint-Jean-de-Sixt—Saint-Jorioz—Saint-Sylvestre—Sales—Sallanches—Sallenôves—Serraval—Sevrier—Seyssel—Sillingy—Talloires-Montmin—Thônes—Thusy—Vallières-sur-Fier—Vaulx—Versonnex—Veyrier-du-Lac—Les Villards-sur-Thônes—Viuz-la-Chiésaz — Alby-sur-Chéran — Alex — Allèves — Annecy — Argonay — La Balme-de-Sillingy — La Balme-de-Thuy — Bassy — Bloye — Bluffy — Le Bouchet-Mont-Charvin — Boussy — Chainaz-les-Frasses — La Chapelle-Saint-Maurice — Chapeiry — Chavanod — Chevaline — Chilly — Choisy — Clermont — Les Clefs — La Clusaz — Combloux — Les Contamines-Montjoie — Cordon — Crempigny-Bonneguête — Cusy — Cuvat — Demi-Quartier — Desingy — Dingy-Saint-Clair — Domancy — Doussard — Droisy — Duingt — Entrevernes — Epagny Metz-Tessy — Étercy — Faverges-Seythenex — Giez — Le Grand-Bornand — Gruffy — Hauteville-sur-Fier — Héry-sur-Alby — Lathuile — Leschaux — Lornay — Lovagny — Manigod — Marcellaz-Albanais — Marigny-Saint-Marcel — Val de Chaise — Massingy — Megève — Menthon-Saint-Bernard — Menthonnex-sous-Clermont — Mésigny — Montagny-les-Lanches — Moye — Mûres — Nonglard — Poisy — Praz-sur-Arly — Quintal — Rumilly — Saint-Eusèbe — Saint-Eustache — Saint-Félix — Saint-Ferréol — Saint-Gervais-les-Bains — Saint-Jean-de-Sixt — Saint-Jorioz — Saint-Sylvestre — Sales — Sallanches — Sallenôves — Serraval — Sevrier — Seyssel — Sillingy — Talloires-Montmin — Thônes — Thusy — Vallières-sur-Fier — Vaulx — Versonnex — Veyrier-du-Lac — Les Villards-sur-Thônes — Viuz-la-Chiésaz
— Alby-sur-Chéran
— Alex
— Allèves
— Annecy
— Argonay
— La Balme-de-Sillingy
— La Balme-de-Thuy
— Bassy
— Bloye
— Bluffy
— Le Bouchet-Mont-Charvin
— Boussy
— Chainaz-les-Frasses
— La Chapelle-Saint-Maurice
— Chapeiry
— Chavanod
— Chevaline
— Chilly
— Choisy
— Clermont
— Les Clefs
— La Clusaz
— Combloux
— Les Contamines-Montjoie
— Cordon
— Crempigny-Bonneguête
— Cusy
— Cuvat
— Demi-Quartier
— Desingy
— Dingy-Saint-Clair
— Domancy
— Doussard
— Droisy
— Duingt
— Entrevernes
— Epagny Metz-Tessy
— Étercy
— Faverges-Seythenex
— Giez
— Le Grand-Bornand
— Gruffy
— Hauteville-sur-Fier
— Héry-sur-Alby
— Lathuile
— Leschaux
— Lornay
— Lovagny
— Manigod
— Marcellaz-Albanais
— Marigny-Saint-Marcel
— Val de Chaise
— Massingy
— Megève
— Menthon-Saint-Bernard
— Menthonnex-sous-Clermont
— Mésigny
— Montagny-les-Lanches
— Moye
— Mûres
— Nonglard
— Poisy
— Praz-sur-Arly
— Quintal
— Rumilly
— Saint-Eusèbe
— Saint-Eustache
— Saint-Félix
— Saint-Ferréol
— Saint-Gervais-les-Bains
— Saint-Jean-de-Sixt
— Saint-Jorioz
— Saint-Sylvestre
— Sales
— Sallanches
— Sallenôves
— Serraval
— Sevrier
— Seyssel
— Sillingy
— Talloires-Montmin
— Thônes
— Thusy
— Vallières-sur-Fier
— Vaulx
— Versonnex
— Veyrier-du-Lac
— Les Villards-sur-Thônes
— Viuz-la-Chiésaz
Surveillance zone:The following municipalities in the following departments from region of Auvergne-Rhône-Alpes:AIN Department—Andert-et-Condon—Anglefort—Arboys en Bugey—Artemare—Belley—Valromey-sur-Séran—Brens—Ceyzérieu—Champagne-en-Valromey—Chazey-Bons—Cheignieu-la-Balme—Contrevoz—Corbonod—Cressin-Rochefort—Culoz-Béon—Cuzieu—Flaxieu—Lavours—Magnieu—Marignieu—Massignieu-de-Rives—Parves et Nattages—Peyrieu—Pollieu—Saint-Germain-les-Paroisses—Saint-Martin-de-Bavel—Seyssel—Talissieu—Virieu-le-Grand—Arvière-en-Valromey—Virignin—VongnesSAVOIE Department—Aillon-le-Jeune—Aillon-le-Vieux—Aime-la-Plagne—Aiton—Aix-les-Bains—Entrelacs—Albertville—Allondaz—Arith—La Balme—La Bâthie—Beaufort—Bellecombe-en-Bauges—Billième—La Biolle—Bonvillard—Bonvillaret—Bourdeau—Le Bourget-du-Lac—Bourgneuf—Bourg-Saint-Maurice—Brison-Saint-Innocent—Césarches—Cevins—Chamousset—Chanaz—La Chapelle-du-Mont-du-Chat—Les Chapelles—La Chapelle-Saint-Martin—Le Châtelard—Chindrieux—Cléry—Cohennoz—La Compôte—Conjux—Crest-Voland—Les Déserts—Doucy-en-Bauges—Drumettaz-Clarafond—École—Esserts-Blay—Flumet—Fréterive—Frontenex—La Giettaz—Gilly-sur-Isère—Grésy-sur-Aix—Grésy-sur-Isère—Grignon—Hauteluce—Jarsy—Jongieux—Lescheraines—Loisieux—Lucey—La Plagne Tarentaise—Marthod—Mercury—Méry—Meyrieux-Trouet—Montailleur—Montcel—Monthion—Montsapey—La Motte-en-Bauges—La Motte-Servolex—Motz—Mouxy—Notre-Dame-de-Bellecombe—La Léchère—Notre-Dame-des-Millières—Le Noyer—Ontex—Pallud—Plancherine—Pugny-Chatenod—Queige—Val-d’Arc—Rognaix—Ruffieux—Saint-François-de-Sales—Sainte-Hélène-sur-Isère—Saint-Jean-de-Chevelu—Saint-Nicolas-la-Chapelle—Saint-Offenge—Saint-Ours—Saint-Paul-sur-Isère—Saint-Paul-sur-Yenne—Saint-Pierre-d’Albigny—Saint-Pierre-de-Curtille—Sainte-Reine—Saint-Vital—Serrières-en-Chautagne—Sonnaz—Thénésol—Tournon—Tours-en-Savoie—Traize—Tresserve—Trévignin—Ugine—Venthon—Verel-Pragondran—Verrens-Arvey—Verthemex—Villard-sur-Doron—Vions—Viviers-du-Lac—Voglans—YenneHAUTE-SAVOIE Department—Alby-sur-Chéran—Alex—Allèves—Annecy—Argonay—La Balme-de-Sillingy—La Balme-de-Thuy—Bassy—Bloye—Bluffy—Le Bouchet-Mont-Charvin—Boussy—Chainaz-les-Frasses—La Chapelle-Saint-Maurice—Chapeiry—Chavanod—Chevaline—Chilly—Choisy—Clermont—Les Clefs—La Clusaz—Combloux—Les Contamines-Montjoie—Cordon—Crempigny-Bonneguête—Cusy—Cuvat—Demi-Quartier—Desingy—Dingy-Saint-Clair—Domancy—Doussard—Droisy—Duingt—Entrevernes—Epagny Metz-Tessy—Étercy—Faverges-Seythenex—Giez—Le Grand-Bornand—Gruffy—Hauteville-sur-Fier—Héry-sur-Alby—Lathuile—Leschaux—Lornay—Lovagny—Manigod—Marcellaz-Albanais—Marigny-Saint-Marcel—Val de Chaise—Massingy—Megève—Menthon-Saint-Bernard—Menthonnex-sous-Clermont—Mésigny—Montagny-les-Lanches—Moye—Mûres—Nonglard—Poisy—Praz-sur-Arly—Quintal—Rumilly—Saint-Eusèbe—Saint-Eustache—Saint-Félix—Saint-Ferréol—Saint-Gervais-les-Bains—Saint-Jean-de-Sixt—Saint-Jorioz—Saint-Sylvestre—Sales—Sallanches—Sallenôves—Serraval—Sevrier—Seyssel—Sillingy—Talloires-Montmin—Thônes—Thusy—Vallières-sur-Fier—Vaulx—Versonnex—Veyrier-du-Lac—Les Villards-sur-Thônes—Viuz-la-Chiésaz AIN Department—Andert-et-Condon—Anglefort—Arboys en Bugey—Artemare—Belley—Valromey-sur-Séran—Brens—Ceyzérieu—Champagne-en-Valromey—Chazey-Bons—Cheignieu-la-Balme—Contrevoz—Corbonod—Cressin-Rochefort—Culoz-Béon—Cuzieu—Flaxieu—Lavours—Magnieu—Marignieu—Massignieu-de-Rives—Parves et Nattages—Peyrieu—Pollieu—Saint-Germain-les-Paroisses—Saint-Martin-de-Bavel—Seyssel—Talissieu—Virieu-le-Grand—Arvière-en-Valromey—Virignin—Vongnes — Andert-et-Condon — Anglefort — Arboys en Bugey — Artemare — Belley — Valromey-sur-Séran — Brens — Ceyzérieu — Champagne-en-Valromey — Chazey-Bons — Cheignieu-la-Balme — Contrevoz — Corbonod — Cressin-Rochefort — Culoz-Béon — Cuzieu — Flaxieu — Lavours — Magnieu — Marignieu — Massignieu-de-Rives — Parves et Nattages — Peyrieu — Pollieu — Saint-Germain-les-Paroisses — Saint-Martin-de-Bavel — Seyssel — Talissieu — Virieu-le-Grand — Arvière-en-Valromey — Virignin — Vongnes SAVOIE Department—Aillon-le-Jeune—Aillon-le-Vieux—Aime-la-Plagne—Aiton—Aix-les-Bains—Entrelacs—Albertville—Allondaz—Arith—La Balme—La Bâthie—Beaufort—Bellecombe-en-Bauges—Billième—La Biolle—Bonvillard—Bonvillaret—Bourdeau—Le Bourget-du-Lac—Bourgneuf—Bourg-Saint-Maurice—Brison-Saint-Innocent—Césarches—Cevins—Chamousset—Chanaz—La Chapelle-du-Mont-du-Chat—Les Chapelles—La Chapelle-Saint-Martin—Le Châtelard—Chindrieux—Cléry—Cohennoz—La Compôte—Conjux—Crest-Voland—Les Déserts—Doucy-en-Bauges—Drumettaz-Clarafond—École—Esserts-Blay—Flumet—Fréterive—Frontenex—La Giettaz—Gilly-sur-Isère—Grésy-sur-Aix—Grésy-sur-Isère—Grignon—Hauteluce—Jarsy—Jongieux—Lescheraines—Loisieux—Lucey—La Plagne Tarentaise—Marthod—Mercury—Méry—Meyrieux-Trouet—Montailleur—Montcel—Monthion—Montsapey—La Motte-en-Bauges—La Motte-Servolex—Motz—Mouxy—Notre-Dame-de-Bellecombe—La Léchère—Notre-Dame-des-Millières—Le Noyer—Ontex—Pallud—Plancherine—Pugny-Chatenod—Queige—Val-d’Arc—Rognaix—Ruffieux—Saint-François-de-Sales—Sainte-Hélène-sur-Isère—Saint-Jean-de-Chevelu—Saint-Nicolas-la-Chapelle—Saint-Offenge—Saint-Ours—Saint-Paul-sur-Isère—Saint-Paul-sur-Yenne—Saint-Pierre-d’Albigny—Saint-Pierre-de-Curtille—Sainte-Reine—Saint-Vital—Serrières-en-Chautagne—Sonnaz—Thénésol—Tournon—Tours-en-Savoie—Traize—Tresserve—Trévignin—Ugine—Venthon—Verel-Pragondran—Verrens-Arvey—Verthemex—Villard-sur-Doron—Vions—Viviers-du-Lac—Voglans—Yenne — Aillon-le-Jeune — Aillon-le-Vieux — Aime-la-Plagne — Aiton — Aix-les-Bains — Entrelacs — Albertville — Allondaz — Arith — La Balme — La Bâthie — Beaufort — Bellecombe-en-Bauges — Billième — La Biolle — Bonvillard — Bonvillaret — Bourdeau — Le Bourget-du-Lac — Bourgneuf — Bourg-Saint-Maurice — Brison-Saint-Innocent — Césarches — Cevins — Chamousset — Chanaz — La Chapelle-du-Mont-du-Chat — Les Chapelles — La Chapelle-Saint-Martin — Le Châtelard — Chindrieux — Cléry — Cohennoz — La Compôte — Conjux — Crest-Voland — Les Déserts — Doucy-en-Bauges — Drumettaz-Clarafond — École — Esserts-Blay — Flumet — Fréterive — Frontenex — La Giettaz — Gilly-sur-Isère — Grésy-sur-Aix — Grésy-sur-Isère — Grignon — Hauteluce — Jarsy — Jongieux — Lescheraines — Loisieux — Lucey — La Plagne Tarentaise — Marthod — Mercury — Méry — Meyrieux-Trouet — Montailleur — Montcel — Monthion — Montsapey — La Motte-en-Bauges — La Motte-Servolex — Motz — Mouxy — Notre-Dame-de-Bellecombe — La Léchère — Notre-Dame-des-Millières — Le Noyer — Ontex — Pallud — Plancherine — Pugny-Chatenod — Queige — Val-d’Arc — Rognaix — Ruffieux — Saint-François-de-Sales — Sainte-Hélène-sur-Isère — Saint-Jean-de-Chevelu — Saint-Nicolas-la-Chapelle — Saint-Offenge — Saint-Ours — Saint-Paul-sur-Isère — Saint-Paul-sur-Yenne — Saint-Pierre-d’Albigny — Saint-Pierre-de-Curtille — Sainte-Reine — Saint-Vital — Serrières-en-Chautagne — Sonnaz — Thénésol — Tournon — Tours-en-Savoie — Traize — Tresserve — Trévignin — Ugine — Venthon — Verel-Pragondran — Verrens-Arvey — Verthemex — Villard-sur-Doron — Vions — Viviers-du-Lac — Voglans — Yenne HAUTE-SAVOIE Department—Alby-sur-Chéran—Alex—Allèves—Annecy—Argonay—La Balme-de-Sillingy—La Balme-de-Thuy—Bassy—Bloye—Bluffy—Le Bouchet-Mont-Charvin—Boussy—Chainaz-les-Frasses—La Chapelle-Saint-Maurice—Chapeiry—Chavanod—Chevaline—Chilly—Choisy—Clermont—Les Clefs—La Clusaz—Combloux—Les Contamines-Montjoie—Cordon—Crempigny-Bonneguête—Cusy—Cuvat—Demi-Quartier—Desingy—Dingy-Saint-Clair—Domancy—Doussard—Droisy—Duingt—Entrevernes—Epagny Metz-Tessy—Étercy—Faverges-Seythenex—Giez—Le Grand-Bornand—Gruffy—Hauteville-sur-Fier—Héry-sur-Alby—Lathuile—Leschaux—Lornay—Lovagny—Manigod—Marcellaz-Albanais—Marigny-Saint-Marcel—Val de Chaise—Massingy—Megève—Menthon-Saint-Bernard—Menthonnex-sous-Clermont—Mésigny—Montagny-les-Lanches—Moye—Mûres—Nonglard—Poisy—Praz-sur-Arly—Quintal—Rumilly—Saint-Eusèbe—Saint-Eustache—Saint-Félix—Saint-Ferréol—Saint-Gervais-les-Bains—Saint-Jean-de-Sixt—Saint-Jorioz—Saint-Sylvestre—Sales—Sallanches—Sallenôves—Serraval—Sevrier—Seyssel—Sillingy—Talloires-Montmin—Thônes—Thusy—Vallières-sur-Fier—Vaulx—Versonnex—Veyrier-du-Lac—Les Villards-sur-Thônes—Viuz-la-Chiésaz — Alby-sur-Chéran — Alex — Allèves — Annecy — Argonay — La Balme-de-Sillingy — La Balme-de-Thuy — Bassy — Bloye — Bluffy — Le Bouchet-Mont-Charvin — Boussy — Chainaz-les-Frasses — La Chapelle-Saint-Maurice — Chapeiry — Chavanod — Chevaline — Chilly — Choisy — Clermont — Les Clefs — La Clusaz — Combloux — Les Contamines-Montjoie — Cordon — Crempigny-Bonneguête — Cusy — Cuvat — Demi-Quartier — Desingy — Dingy-Saint-Clair — Domancy — Doussard — Droisy — Duingt — Entrevernes — Epagny Metz-Tessy — Étercy — Faverges-Seythenex — Giez — Le Grand-Bornand — Gruffy — Hauteville-sur-Fier — Héry-sur-Alby — Lathuile — Leschaux — Lornay — Lovagny — Manigod — Marcellaz-Albanais — Marigny-Saint-Marcel — Val de Chaise — Massingy — Megève — Menthon-Saint-Bernard — Menthonnex-sous-Clermont — Mésigny — Montagny-les-Lanches — Moye — Mûres — Nonglard — Poisy — Praz-sur-Arly — Quintal — Rumilly — Saint-Eusèbe — Saint-Eustache — Saint-Félix — Saint-Ferréol — Saint-Gervais-les-Bains — Saint-Jean-de-Sixt — Saint-Jorioz — Saint-Sylvestre — Sales — Sallanches — Sallenôves — Serraval — Sevrier — Seyssel — Sillingy — Talloires-Montmin — Thônes — Thusy — Vallières-sur-Fier — Vaulx — Versonnex — Veyrier-du-Lac — Les Villards-sur-Thônes — Viuz-la-Chiésaz 14.9.2025 – 30.9.2025
AIN Department—Andert-et-Condon—Anglefort—Arboys en Bugey—Artemare—Belley—Valromey-sur-Séran—Brens—Ceyzérieu—Champagne-en-Valromey—Chazey-Bons—Cheignieu-la-Balme—Contrevoz—Corbonod—Cressin-Rochefort—Culoz-Béon—Cuzieu—Flaxieu—Lavours—Magnieu—Marignieu—Massignieu-de-Rives—Parves et Nattages—Peyrieu—Pollieu—Saint-Germain-les-Paroisses—Saint-Martin-de-Bavel—Seyssel—Talissieu—Virieu-le-Grand—Arvière-en-Valromey—Virignin—Vongnes — Andert-et-Condon — Anglefort — Arboys en Bugey — Artemare — Belley — Valromey-sur-Séran — Brens — Ceyzérieu — Champagne-en-Valromey — Chazey-Bons — Cheignieu-la-Balme — Contrevoz — Corbonod — Cressin-Rochefort — Culoz-Béon — Cuzieu — Flaxieu — Lavours — Magnieu — Marignieu — Massignieu-de-Rives — Parves et Nattages — Peyrieu — Pollieu — Saint-Germain-les-Paroisses — Saint-Martin-de-Bavel — Seyssel — Talissieu — Virieu-le-Grand — Arvière-en-Valromey — Virignin — Vongnes
— Andert-et-Condon
— Anglefort
— Arboys en Bugey
— Artemare
— Belley
— Valromey-sur-Séran
— Brens
— Ceyzérieu
— Champagne-en-Valromey
— Chazey-Bons
— Cheignieu-la-Balme
— Contrevoz
— Corbonod
— Cressin-Rochefort
— Culoz-Béon
— Cuzieu
— Flaxieu
— Lavours
— Magnieu
— Marignieu
— Massignieu-de-Rives
— Parves et Nattages
— Peyrieu
— Pollieu
— Saint-Germain-les-Paroisses
— Saint-Martin-de-Bavel
— Seyssel
— Talissieu
— Virieu-le-Grand
— Arvière-en-Valromey
— Virignin
— Vongnes
SAVOIE Department—Aillon-le-Jeune—Aillon-le-Vieux—Aime-la-Plagne—Aiton—Aix-les-Bains—Entrelacs—Albertville—Allondaz—Arith—La Balme—La Bâthie—Beaufort—Bellecombe-en-Bauges—Billième—La Biolle—Bonvillard—Bonvillaret—Bourdeau—Le Bourget-du-Lac—Bourgneuf—Bourg-Saint-Maurice—Brison-Saint-Innocent—Césarches—Cevins—Chamousset—Chanaz—La Chapelle-du-Mont-du-Chat—Les Chapelles—La Chapelle-Saint-Martin—Le Châtelard—Chindrieux—Cléry—Cohennoz—La Compôte—Conjux—Crest-Voland—Les Déserts—Doucy-en-Bauges—Drumettaz-Clarafond—École—Esserts-Blay—Flumet—Fréterive—Frontenex—La Giettaz—Gilly-sur-Isère—Grésy-sur-Aix—Grésy-sur-Isère—Grignon—Hauteluce—Jarsy—Jongieux—Lescheraines—Loisieux—Lucey—La Plagne Tarentaise—Marthod—Mercury—Méry—Meyrieux-Trouet—Montailleur—Montcel—Monthion—Montsapey—La Motte-en-Bauges—La Motte-Servolex—Motz—Mouxy—Notre-Dame-de-Bellecombe—La Léchère—Notre-Dame-des-Millières—Le Noyer—Ontex—Pallud—Plancherine—Pugny-Chatenod—Queige—Val-d’Arc—Rognaix—Ruffieux—Saint-François-de-Sales—Sainte-Hélène-sur-Isère—Saint-Jean-de-Chevelu—Saint-Nicolas-la-Chapelle—Saint-Offenge—Saint-Ours—Saint-Paul-sur-Isère—Saint-Paul-sur-Yenne—Saint-Pierre-d’Albigny—Saint-Pierre-de-Curtille—Sainte-Reine—Saint-Vital—Serrières-en-Chautagne—Sonnaz—Thénésol—Tournon—Tours-en-Savoie—Traize—Tresserve—Trévignin—Ugine—Venthon—Verel-Pragondran—Verrens-Arvey—Verthemex—Villard-sur-Doron—Vions—Viviers-du-Lac—Voglans—Yenne — Aillon-le-Jeune — Aillon-le-Vieux — Aime-la-Plagne — Aiton — Aix-les-Bains — Entrelacs — Albertville — Allondaz — Arith — La Balme — La Bâthie — Beaufort — Bellecombe-en-Bauges — Billième — La Biolle — Bonvillard — Bonvillaret — Bourdeau — Le Bourget-du-Lac — Bourgneuf — Bourg-Saint-Maurice — Brison-Saint-Innocent — Césarches — Cevins — Chamousset — Chanaz — La Chapelle-du-Mont-du-Chat — Les Chapelles — La Chapelle-Saint-Martin — Le Châtelard — Chindrieux — Cléry — Cohennoz — La Compôte — Conjux — Crest-Voland — Les Déserts — Doucy-en-Bauges — Drumettaz-Clarafond — École — Esserts-Blay — Flumet — Fréterive — Frontenex — La Giettaz — Gilly-sur-Isère — Grésy-sur-Aix — Grésy-sur-Isère — Grignon — Hauteluce — Jarsy — Jongieux — Lescheraines — Loisieux — Lucey — La Plagne Tarentaise — Marthod — Mercury — Méry — Meyrieux-Trouet — Montailleur — Montcel — Monthion — Montsapey — La Motte-en-Bauges — La Motte-Servolex — Motz — Mouxy — Notre-Dame-de-Bellecombe — La Léchère — Notre-Dame-des-Millières — Le Noyer — Ontex — Pallud — Plancherine — Pugny-Chatenod — Queige — Val-d’Arc — Rognaix — Ruffieux — Saint-François-de-Sales — Sainte-Hélène-sur-Isère — Saint-Jean-de-Chevelu — Saint-Nicolas-la-Chapelle — Saint-Offenge — Saint-Ours — Saint-Paul-sur-Isère — Saint-Paul-sur-Yenne — Saint-Pierre-d’Albigny — Saint-Pierre-de-Curtille — Sainte-Reine — Saint-Vital — Serrières-en-Chautagne — Sonnaz — Thénésol — Tournon — Tours-en-Savoie — Traize — Tresserve — Trévignin — Ugine — Venthon — Verel-Pragondran — Verrens-Arvey — Verthemex — Villard-sur-Doron — Vions — Viviers-du-Lac — Voglans — Yenne
— Aillon-le-Jeune
— Aillon-le-Vieux
— Aime-la-Plagne
— Aiton
— Aix-les-Bains
— Entrelacs
— Albertville
— Allondaz
— Arith
— La Balme
— La Bâthie
— Beaufort
— Bellecombe-en-Bauges
— Billième
— La Biolle
— Bonvillard
— Bonvillaret
— Bourdeau
— Le Bourget-du-Lac
— Bourgneuf
— Bourg-Saint-Maurice
— Brison-Saint-Innocent
— Césarches
— Cevins
— Chamousset
— Chanaz
— La Chapelle-du-Mont-du-Chat
— Les Chapelles
— La Chapelle-Saint-Martin
— Le Châtelard
— Chindrieux
— Cléry
— Cohennoz
— La Compôte
— Conjux
— Crest-Voland
— Les Déserts
— Doucy-en-Bauges
— Drumettaz-Clarafond
— École
— Esserts-Blay
— Flumet
— Fréterive
— Frontenex
— La Giettaz
— Gilly-sur-Isère
— Grésy-sur-Aix
— Grésy-sur-Isère
— Grignon
— Hauteluce
— Jarsy
— Jongieux
— Lescheraines
— Loisieux
— Lucey
— La Plagne Tarentaise
— Marthod
— Mercury
— Méry
— Meyrieux-Trouet
— Montailleur
— Montcel
— Monthion
— Montsapey
— La Motte-en-Bauges
— La Motte-Servolex
— Motz
— Mouxy
— Notre-Dame-de-Bellecombe
— La Léchère
— Notre-Dame-des-Millières
— Le Noyer
— Ontex
— Pallud
— Plancherine
— Pugny-Chatenod
— Queige
— Val-d’Arc
— Rognaix
— Ruffieux
— Saint-François-de-Sales
— Sainte-Hélène-sur-Isère
— Saint-Jean-de-Chevelu
— Saint-Nicolas-la-Chapelle
— Saint-Offenge
— Saint-Ours
— Saint-Paul-sur-Isère
— Saint-Paul-sur-Yenne
— Saint-Pierre-d’Albigny
— Saint-Pierre-de-Curtille
— Sainte-Reine
— Saint-Vital
— Serrières-en-Chautagne
— Sonnaz
— Thénésol
— Tournon
— Tours-en-Savoie
— Traize
— Tresserve
— Trévignin
— Ugine
— Venthon
— Verel-Pragondran
— Verrens-Arvey
— Verthemex
— Villard-sur-Doron
— Vions
— Viviers-du-Lac
— Voglans
— Yenne
HAUTE-SAVOIE Department—Alby-sur-Chéran—Alex—Allèves—Annecy—Argonay—La Balme-de-Sillingy—La Balme-de-Thuy—Bassy—Bloye—Bluffy—Le Bouchet-Mont-Charvin—Boussy—Chainaz-les-Frasses—La Chapelle-Saint-Maurice—Chapeiry—Chavanod—Chevaline—Chilly—Choisy—Clermont—Les Clefs—La Clusaz—Combloux—Les Contamines-Montjoie—Cordon—Crempigny-Bonneguête—Cusy—Cuvat—Demi-Quartier—Desingy—Dingy-Saint-Clair—Domancy—Doussard—Droisy—Duingt—Entrevernes—Epagny Metz-Tessy—Étercy—Faverges-Seythenex—Giez—Le Grand-Bornand—Gruffy—Hauteville-sur-Fier—Héry-sur-Alby—Lathuile—Leschaux—Lornay—Lovagny—Manigod—Marcellaz-Albanais—Marigny-Saint-Marcel—Val de Chaise—Massingy—Megève—Menthon-Saint-Bernard—Menthonnex-sous-Clermont—Mésigny—Montagny-les-Lanches—Moye—Mûres—Nonglard—Poisy—Praz-sur-Arly—Quintal—Rumilly—Saint-Eusèbe—Saint-Eustache—Saint-Félix—Saint-Ferréol—Saint-Gervais-les-Bains—Saint-Jean-de-Sixt—Saint-Jorioz—Saint-Sylvestre—Sales—Sallanches—Sallenôves—Serraval—Sevrier—Seyssel—Sillingy—Talloires-Montmin—Thônes—Thusy—Vallières-sur-Fier—Vaulx—Versonnex—Veyrier-du-Lac—Les Villards-sur-Thônes—Viuz-la-Chiésaz — Alby-sur-Chéran — Alex — Allèves — Annecy — Argonay — La Balme-de-Sillingy — La Balme-de-Thuy — Bassy — Bloye — Bluffy — Le Bouchet-Mont-Charvin — Boussy — Chainaz-les-Frasses — La Chapelle-Saint-Maurice — Chapeiry — Chavanod — Chevaline — Chilly — Choisy — Clermont — Les Clefs — La Clusaz — Combloux — Les Contamines-Montjoie — Cordon — Crempigny-Bonneguête — Cusy — Cuvat — Demi-Quartier — Desingy — Dingy-Saint-Clair — Domancy — Doussard — Droisy — Duingt — Entrevernes — Epagny Metz-Tessy — Étercy — Faverges-Seythenex — Giez — Le Grand-Bornand — Gruffy — Hauteville-sur-Fier — Héry-sur-Alby — Lathuile — Leschaux — Lornay — Lovagny — Manigod — Marcellaz-Albanais — Marigny-Saint-Marcel — Val de Chaise — Massingy — Megève — Menthon-Saint-Bernard — Menthonnex-sous-Clermont — Mésigny — Montagny-les-Lanches — Moye — Mûres — Nonglard — Poisy — Praz-sur-Arly — Quintal — Rumilly — Saint-Eusèbe — Saint-Eustache — Saint-Félix — Saint-Ferréol — Saint-Gervais-les-Bains — Saint-Jean-de-Sixt — Saint-Jorioz — Saint-Sylvestre — Sales — Sallanches — Sallenôves — Serraval — Sevrier — Seyssel — Sillingy — Talloires-Montmin — Thônes — Thusy — Vallières-sur-Fier — Vaulx — Versonnex — Veyrier-du-Lac — Les Villards-sur-Thônes — Viuz-la-Chiésaz
— Alby-sur-Chéran
— Alex
— Allèves
— Annecy
— Argonay
— La Balme-de-Sillingy
— La Balme-de-Thuy
— Bassy
— Bloye
— Bluffy
— Le Bouchet-Mont-Charvin
— Boussy
— Chainaz-les-Frasses
— La Chapelle-Saint-Maurice
— Chapeiry
— Chavanod
— Chevaline
— Chilly
— Choisy
— Clermont
— Les Clefs
— La Clusaz
— Combloux
— Les Contamines-Montjoie
— Cordon
— Crempigny-Bonneguête
— Cusy
— Cuvat
— Demi-Quartier
— Desingy
— Dingy-Saint-Clair
— Domancy
— Doussard
— Droisy
— Duingt
— Entrevernes
— Epagny Metz-Tessy
— Étercy
— Faverges-Seythenex
— Giez
— Le Grand-Bornand
— Gruffy
— Hauteville-sur-Fier
— Héry-sur-Alby
— Lathuile
— Leschaux
— Lornay
— Lovagny
— Manigod
— Marcellaz-Albanais
— Marigny-Saint-Marcel
— Val de Chaise
— Massingy
— Megève
— Menthon-Saint-Bernard
— Menthonnex-sous-Clermont
— Mésigny
— Montagny-les-Lanches
— Moye
— Mûres
— Nonglard
— Poisy
— Praz-sur-Arly
— Quintal
— Rumilly
— Saint-Eusèbe
— Saint-Eustache
— Saint-Félix
— Saint-Ferréol
— Saint-Gervais-les-Bains
— Saint-Jean-de-Sixt
— Saint-Jorioz
— Saint-Sylvestre
— Sales
— Sallanches
— Sallenôves
— Serraval
— Sevrier
— Seyssel
— Sillingy
— Talloires-Montmin
— Thônes
— Thusy
— Vallières-sur-Fier
— Vaulx
— Versonnex
— Veyrier-du-Lac
— Les Villards-sur-Thônes
— Viuz-la-Chiésaz
Surveillance zone:The following municipalities in the following departments from region of Auvergne-Rhône-Alpes:AIN Department—L’Abergement-de-Varey—Ambérieu-en-Bugey—Ambléon—Ambronay—Ambutrix—Apremont—Aranc—Arandas—Argis—Armix—Bellignat—Valserhône—Belleydoux—Bénonces—Bettant—Billiat—Blyes—Boyeux-Saint-Jérôme—Brégnier-Cordon—Brénod—Brion—Briord—La Burbanche—Ceignes—Cerdon—Chaley—Challes-la-Montagne—Challex—Champdor-Corcelles—Champfromier—Chanay—Charix—Château-Gaillard—Chazey-sur-Ain—Chevillard—Chevry—Chézery-Forens—Cleyzieu—Collonges—Colomieu—Conand—Condamine—Confort—Conzieu—Corlier—Crozet—Douvres—Échallon—Évosges—Farges—Ferney-Voltaire—Béard-Géovreissiat—Giron—Groissiat—Hautecourt-Romanèche—Plateau d’Hauteville—Haut Valromey—Injoux-Génissiat—Innimond—Izenave—Izernore—Izieu—Jujurieux—Labalme—Lagnieu—Le Poizat-Lalleyriat—Lantenay—Léaz—Lélex—Leyment—Leyssard—Surjoux-Lhopital—Lhuis—Lompnas—Loyettes—Maillat—Marchamp—Martignat—Mérignat—Montagnieu—Montanges—Montréal-la-Cluse—Nurieux-Volognat—Murs-et-Gélignieux—Nantua—Neuville-sur-Ain—Les Neyrolles—Nivollet-Montgriffon—Oncieu—Ordonnaz—Outriaz—Oyonnax—Péron—Peyriat—Plagne—Poncin—Pont-d’Ain—Port—Pougny—Prémeyzel—Prémillieu—Prévessin-Moëns—Priay—Rossillon—Saint-Alban—Groslée-Saint-Benoit—Saint-Denis-en-Bugey—Saint-Genis-Pouilly—Saint-Germain-de-Joux—Saint-Jean-de-Gonville—Saint-Jean-de-Niost—Saint-Jean-le-Vieux—Sainte-Julie—Saint-Martin-du-Frêne—Saint-Maurice-de-Rémens—Saint-Rambert-en-Bugey—Saint-Sorlin-en-Bugey—Saint-Vulbas—Sault-Brénaz—Seillonnaz—Sergy—Serrières-de-Briord—Serrières-sur-Ain—Souclin—Tenay—Thoiry—Torcieu—Vaux-en-Bugey—Vieu-d’Izenave—Villebois—Villes—Les Abrets en DauphinéISERE Department—Les Abrets en Dauphiné—Allevard—Annoisin-Chatelans—Aoste—Les Avenières Veyrins-Thuellin—La Balme-les-Grottes—Barraux—La Bâtie-Montgascon—Bilieu—Blandin—Le Bouchage—Bourgoin-Jallieu—Bouvesse-Quirieu—Brangues—La Buissière—Cessieu—Chapareillan—La Chapelle-de-la-Tour—La Chapelle-du-Bard—Charancieu—Charavines—Charette—Chassignieu—Chélieu—Le Cheylas—Chimilin—Chirens—Corbelin—Courtenay—Crémieu—Creys-Mépieu—Dizimieu—Doissin—Dolomieu—Entre-deux-Guiers—Faverges-de-la-Tour—Le Haut-Bréda—La Flachère—Goncelin—Granieu—Hières-sur-Amby—Leyrieu—Massieu—Merlas—Miribel-les-Échelles—Montagnieu—Montalieu-Vercieu—Montcarra—Montferrat—Moras—Morestel—Le Moutaret—Optevoz—Oyeu—Villages du Lac de Paladru—Parmilieu—Le Passage—Arandon-Passins—Pontcharra—Le Pont-de-Beauvoisin—Porcieu-Amblagnieu—Pressins—Rochetoirin—Romagnieu—Ruy-Montceau—Saint-Albin-de-Vaulserre—Saint-André-le-Gaz—Saint-Aupre—Saint-Baudille-de-la-Tour—Sainte-Blandine—Saint-Bueil—Saint-Chef—Saint-Christophe-sur-Guiers—Saint-Clair-de-la-Tour—Saint-Didier-de-la-Tour—Saint-Étienne-de-Crossey—Saint-Geoire-en-Valdaine—Saint-Hilaire-de-Brens—Plateau-des-Petites-Roches—Saint-Jean-d’Avelanne—Saint-Jean-de-Soudain—Saint-Joseph-de-Rivière—Saint-Laurent-du-Pont—Sainte-Marie-d’Alloix—Sainte-Marie-du-Mont—Saint-Martin-de-Vaulserre—Saint-Maximin—Saint-Nicolas-de-Macherin—Saint-Ondras—Crêts en Belledonne—Saint-Pierre-de-Chartreuse—Saint-Pierre-d’Entremont—Saint-Savin—Saint-Sorlin-de-Morestel—Saint-Sulpice-des-Rivoires—Saint-Victor-de-Cessieu—Saint-Victor-de-Morestel—Saint-Vincent-de-Mercuze—Salagnon—Sérézin-de-la-Tour—Sermérieu—Siccieu-Saint-Julien-et-Carisieu—Soleymieu—Theys—Torchefelon—La Tour-du-Pin—Le Touvet—Trept—Valencogne—Vasselin—Velanne—Vénérieu—Vernas—Vertrieu—Vézeronce-Curtin—Vignieu—Villemoirieu—Val-de-Virieu—Voiron—VoissantSAVOIE Department—Aiguebelette-le-Lac—Grand-Aigueblanche—Les Allues—Apremont—Arbin—Argentine—Arvillard—Attignat-Oncin—Les Avanchers-Valmorel—Avressieux—Ayn—Barberaz—Barby—Bassens—La Bauche—Belmont-Tramonet—Betton-Bettonet—Bourget-en-Huile—Bozel—Brides-les-Bains—La Bridoire—Challes-les-Eaux—Chambéry—La Chambre—Chamoux-sur-Gelon—Champagneux—Champagny-en-Vanoise—Champ-Laurent—La Chapelle—La Chapelle-Blanche—Châteauneuf—La Chavanne—Les Chavannes-en-Maurienne—Chignin—Cognin—Coise-Saint-Jean-Pied-Gauthier—Corbel—La Croix-de-la-Rochette—Cruet—Curienne—Détrier—Domessin—Dullin—Les Échelles—Entremont-le-Vieux—Épierre—Feissons-sur-Salins—Gerbaix—Hautecour—Hauteville—La Tour-en-Maurienne—Jacob-Bellecombette—Jarrier—Laissaud—Landry—Lépin-le-Lac—Porte-de-Savoie—Marcieux—Les Mollettes—Montagnole—Montagny—Montendry—Montgilbert—Montmélian—Montvalezan—Montvernier—Moûtiers—Myans—Nances—Notre-Dame-du-Cruet—Notre-Dame-du-Pré—Novalaise—Peisey-Nancroix—Planaise—Planay—Le Pont-de-Beauvoisin—Le Pontet—Pralognan-la-Vanoise—Presle—Puygros—La Ravoire—Rochefort—Valgelon-La Rochette—Rotherens—Saint-Alban-de-Montbel—Saint-Alban-d’Hurtières—Saint-Alban-des-Villards—Saint-Alban-Leysse—Saint-Avre—Saint-Baldoph—Saint-Béron—Courchevel—Saint-Cassin—Saint-Christophe—Saint-Colomban-des-Villards—Saint-Étienne-de-Cuines—Sainte-Foy-Tarentaise—Saint-Franc—Saint François Longchamp—Saint-Genix-les-Villages—Saint-Georges-d’Hurtières—Sainte-Hélène-du-Lac—Saint-Jean-d’Arvey—Saint-Jean-de-Couz—Saint-Jean-de-la-Porte—Saint-Jean-de-Maurienne—Saint-Jeoire-Prieuré—Saint-Julien-Mont-Denis—Saint-Léger—Saint-Marcel—Sainte-Marie-d’Alvey—Sainte-Marie-de-Cuines—Les Belleville—Saint-Martin-sur-la-Chambre—Saint-Pierre-d’Alvey—Saint-Pierre-de-Belleville—Saint-Pierre-d’Entremont—Saint-Pierre-de-Genebroz—Saint-Pierre-de-Soucy—Saint-Rémy-de-Maurienne—Saint-Sulpice—Saint-Thibaud-de-Couz—Salins-Fontaine—Séez—La Table—Thoiry—La Thuile—La Trinité—Verel-de-Montbel—Le Verneil—Villard-d’Héry—Villard-Léger—Villard-Sallet—Villaroger—Villaroux—Vimines—Val-d’Isère—TignesHAUTE-SAVOIE Department—Allonzier-la-Caille—Amancy—Ambilly—Andilly—Annemasse—Arâches-la-Frasse—Arbusigny—Archamps—Arenthon—Arthaz-Pont-Notre-Dame—Ayse—Beaumont—Bellevaux—Boëge—Bogève—Bonne—Bonneville—Bossey—Brizon—Cercier—Cernex—Challonges—Chamonix-Mont-Blanc—La Chapelle-Rambaud—Charvonnex—Châtillon-sur-Cluses—Chaumont—Chavannaz—Chêne-en-Semine—Chênex—Chessenaz—Chevrier—Clarafond-Arcine—Cluses—Collonges-sous-Salève—Contamine-Sarzin—Contamine-sur-Arve—Copponex—Cornier—La Côte-d’Arbroz—Cranves-Sales—Cruseilles—Dingy-en-Vuache—Éloise—Essert-Romand—Etaux—Étrembières—Faucigny—Feigères—Fillinges—Franclens—Frangy—Gaillard—Les Gets—Groisy—Habère-Lullin—Les Houches—Jonzier-Épagny—Juvigny—Lucinges—Magland—Marcellaz—Marignier—Marlioz—Marnaz—Mégevette—Menthonnex-en-Bornes—Mieussy—Minzier—Monnetier-Mornex—Montriond—Mont-Saxonnex—Morillon—Morzine—La Muraz—Musièges—Nancy-sur-Cluses—Nangy—Nâves-Parmelan—Neydens—Onnion—Passy—Peillonnex—Pers-Jussy—Glières-Val-de-Borne—Présilly—Reignier-Ésery—Le Reposoir—La Rivière-Enverse—La Roche-sur-Foron—Saint-André-de-Boëge—Saint-Blaise—Saint-Germain-sur-Rhône—Saint-Jean-d’Aulps—Saint-Jean-de-Tholome—Saint-Jeoire—Saint-Julien-en-Genevois—Saint-Laurent—Saint-Pierre-en-Faucigny—Saint-Sigismond—Saint-Sixt—Samoëns—Le Sappey—Savigny—Scientrier—Scionzier—Servoz—Seytroux—Sixt-Fer-à-Cheval—Taninges—Thyez—Fillière—La Tour—Usinens—Valleiry—Vallorcine—Vanzy—Verchaix—Vers—Vétraz-Monthoux—Villard—Villaz—Ville-en-Sallaz—Ville-la-Grand—Villy-le-Bouveret—Villy-le-Pelloux—Viry—Viuz-en-Sallaz—Vougy—Vovray-en-Bornes—Vulbens AIN Department—L’Abergement-de-Varey—Ambérieu-en-Bugey—Ambléon—Ambronay—Ambutrix—Apremont—Aranc—Arandas—Argis—Armix—Bellignat—Valserhône—Belleydoux—Bénonces—Bettant—Billiat—Blyes—Boyeux-Saint-Jérôme—Brégnier-Cordon—Brénod—Brion—Briord—La Burbanche—Ceignes—Cerdon—Chaley—Challes-la-Montagne—Challex—Champdor-Corcelles—Champfromier—Chanay—Charix—Château-Gaillard—Chazey-sur-Ain—Chevillard—Chevry—Chézery-Forens—Cleyzieu—Collonges—Colomieu—Conand—Condamine—Confort—Conzieu—Corlier—Crozet—Douvres—Échallon—Évosges—Farges—Ferney-Voltaire—Béard-Géovreissiat—Giron—Groissiat—Hautecourt-Romanèche—Plateau d’Hauteville—Haut Valromey—Injoux-Génissiat—Innimond—Izenave—Izernore—Izieu—Jujurieux—Labalme—Lagnieu—Le Poizat-Lalleyriat—Lantenay—Léaz—Lélex—Leyment—Leyssard—Surjoux-Lhopital—Lhuis—Lompnas—Loyettes—Maillat—Marchamp—Martignat—Mérignat—Montagnieu—Montanges—Montréal-la-Cluse—Nurieux-Volognat—Murs-et-Gélignieux—Nantua—Neuville-sur-Ain—Les Neyrolles—Nivollet-Montgriffon—Oncieu—Ordonnaz—Outriaz—Oyonnax—Péron—Peyriat—Plagne—Poncin—Pont-d’Ain—Port—Pougny—Prémeyzel—Prémillieu—Prévessin-Moëns—Priay—Rossillon—Saint-Alban—Groslée-Saint-Benoit—Saint-Denis-en-Bugey—Saint-Genis-Pouilly—Saint-Germain-de-Joux—Saint-Jean-de-Gonville—Saint-Jean-de-Niost—Saint-Jean-le-Vieux—Sainte-Julie—Saint-Martin-du-Frêne—Saint-Maurice-de-Rémens—Saint-Rambert-en-Bugey—Saint-Sorlin-en-Bugey—Saint-Vulbas—Sault-Brénaz—Seillonnaz—Sergy—Serrières-de-Briord—Serrières-sur-Ain—Souclin—Tenay—Thoiry—Torcieu—Vaux-en-Bugey—Vieu-d’Izenave—Villebois—Villes—Les Abrets en Dauphiné — L’Abergement-de-Varey — Ambérieu-en-Bugey — Ambléon — Ambronay — Ambutrix — Apremont — Aranc — Arandas — Argis — Armix — Bellignat — Valserhône — Belleydoux — Bénonces — Bettant — Billiat — Blyes — Boyeux-Saint-Jérôme — Brégnier-Cordon — Brénod — Brion — Briord — La Burbanche — Ceignes — Cerdon — Chaley — Challes-la-Montagne — Challex — Champdor-Corcelles — Champfromier — Chanay — Charix — Château-Gaillard — Chazey-sur-Ain — Chevillard — Chevry — Chézery-Forens — Cleyzieu — Collonges — Colomieu — Conand — Condamine — Confort — Conzieu — Corlier — Crozet — Douvres — Échallon — Évosges — Farges — Ferney-Voltaire — Béard-Géovreissiat — Giron — Groissiat — Hautecourt-Romanèche — Plateau d’Hauteville — Haut Valromey — Injoux-Génissiat — Innimond — Izenave — Izernore — Izieu — Jujurieux — Labalme — Lagnieu — Le Poizat-Lalleyriat — Lantenay — Léaz — Lélex — Leyment — Leyssard — Surjoux-Lhopital — Lhuis — Lompnas — Loyettes — Maillat — Marchamp — Martignat — Mérignat — Montagnieu — Montanges — Montréal-la-Cluse — Nurieux-Volognat — Murs-et-Gélignieux — Nantua — Neuville-sur-Ain — Les Neyrolles — Nivollet-Montgriffon — Oncieu — Ordonnaz — Outriaz — Oyonnax — Péron — Peyriat — Plagne — Poncin — Pont-d’Ain — Port — Pougny — Prémeyzel — Prémillieu — Prévessin-Moëns — Priay — Rossillon — Saint-Alban — Groslée-Saint-Benoit — Saint-Denis-en-Bugey — Saint-Genis-Pouilly — Saint-Germain-de-Joux — Saint-Jean-de-Gonville — Saint-Jean-de-Niost — Saint-Jean-le-Vieux — Sainte-Julie — Saint-Martin-du-Frêne — Saint-Maurice-de-Rémens — Saint-Rambert-en-Bugey — Saint-Sorlin-en-Bugey — Saint-Vulbas — Sault-Brénaz — Seillonnaz — Sergy — Serrières-de-Briord — Serrières-sur-Ain — Souclin — Tenay — Thoiry — Torcieu — Vaux-en-Bugey — Vieu-d’Izenave — Villebois — Villes — Les Abrets en Dauphiné ISERE Department—Les Abrets en Dauphiné—Allevard—Annoisin-Chatelans—Aoste—Les Avenières Veyrins-Thuellin—La Balme-les-Grottes—Barraux—La Bâtie-Montgascon—Bilieu—Blandin—Le Bouchage—Bourgoin-Jallieu—Bouvesse-Quirieu—Brangues—La Buissière—Cessieu—Chapareillan—La Chapelle-de-la-Tour—La Chapelle-du-Bard—Charancieu—Charavines—Charette—Chassignieu—Chélieu—Le Cheylas—Chimilin—Chirens—Corbelin—Courtenay—Crémieu—Creys-Mépieu—Dizimieu—Doissin—Dolomieu—Entre-deux-Guiers—Faverges-de-la-Tour—Le Haut-Bréda—La Flachère—Goncelin—Granieu—Hières-sur-Amby—Leyrieu—Massieu—Merlas—Miribel-les-Échelles—Montagnieu—Montalieu-Vercieu—Montcarra—Montferrat—Moras—Morestel—Le Moutaret—Optevoz—Oyeu—Villages du Lac de Paladru—Parmilieu—Le Passage—Arandon-Passins—Pontcharra—Le Pont-de-Beauvoisin—Porcieu-Amblagnieu—Pressins—Rochetoirin—Romagnieu—Ruy-Montceau—Saint-Albin-de-Vaulserre—Saint-André-le-Gaz—Saint-Aupre—Saint-Baudille-de-la-Tour—Sainte-Blandine—Saint-Bueil—Saint-Chef—Saint-Christophe-sur-Guiers—Saint-Clair-de-la-Tour—Saint-Didier-de-la-Tour—Saint-Étienne-de-Crossey—Saint-Geoire-en-Valdaine—Saint-Hilaire-de-Brens—Plateau-des-Petites-Roches—Saint-Jean-d’Avelanne—Saint-Jean-de-Soudain—Saint-Joseph-de-Rivière—Saint-Laurent-du-Pont—Sainte-Marie-d’Alloix—Sainte-Marie-du-Mont—Saint-Martin-de-Vaulserre—Saint-Maximin—Saint-Nicolas-de-Macherin—Saint-Ondras—Crêts en Belledonne—Saint-Pierre-de-Chartreuse—Saint-Pierre-d’Entremont—Saint-Savin—Saint-Sorlin-de-Morestel—Saint-Sulpice-des-Rivoires—Saint-Victor-de-Cessieu—Saint-Victor-de-Morestel—Saint-Vincent-de-Mercuze—Salagnon—Sérézin-de-la-Tour—Sermérieu—Siccieu-Saint-Julien-et-Carisieu—Soleymieu—Theys—Torchefelon—La Tour-du-Pin—Le Touvet—Trept—Valencogne—Vasselin—Velanne—Vénérieu—Vernas—Vertrieu—Vézeronce-Curtin—Vignieu—Villemoirieu—Val-de-Virieu—Voiron—Voissant — Les Abrets en Dauphiné — Allevard — Annoisin-Chatelans — Aoste — Les Avenières Veyrins-Thuellin — La Balme-les-Grottes — Barraux — La Bâtie-Montgascon — Bilieu — Blandin — Le Bouchage — Bourgoin-Jallieu — Bouvesse-Quirieu — Brangues — La Buissière — Cessieu — Chapareillan — La Chapelle-de-la-Tour — La Chapelle-du-Bard — Charancieu — Charavines — Charette — Chassignieu — Chélieu — Le Cheylas — Chimilin — Chirens — Corbelin — Courtenay — Crémieu — Creys-Mépieu — Dizimieu — Doissin — Dolomieu — Entre-deux-Guiers — Faverges-de-la-Tour — Le Haut-Bréda — La Flachère — Goncelin — Granieu — Hières-sur-Amby — Leyrieu — Massieu — Merlas — Miribel-les-Échelles — Montagnieu — Montalieu-Vercieu — Montcarra — Montferrat — Moras — Morestel — Le Moutaret — Optevoz — Oyeu — Villages du Lac de Paladru — Parmilieu — Le Passage — Arandon-Passins — Pontcharra — Le Pont-de-Beauvoisin — Porcieu-Amblagnieu — Pressins — Rochetoirin — Romagnieu — Ruy-Montceau — Saint-Albin-de-Vaulserre — Saint-André-le-Gaz — Saint-Aupre — Saint-Baudille-de-la-Tour — Sainte-Blandine — Saint-Bueil — Saint-Chef — Saint-Christophe-sur-Guiers — Saint-Clair-de-la-Tour — Saint-Didier-de-la-Tour — Saint-Étienne-de-Crossey — Saint-Geoire-en-Valdaine — Saint-Hilaire-de-Brens — Plateau-des-Petites-Roches — Saint-Jean-d’Avelanne — Saint-Jean-de-Soudain — Saint-Joseph-de-Rivière — Saint-Laurent-du-Pont — Sainte-Marie-d’Alloix — Sainte-Marie-du-Mont — Saint-Martin-de-Vaulserre — Saint-Maximin — Saint-Nicolas-de-Macherin — Saint-Ondras — Crêts en Belledonne — Saint-Pierre-de-Chartreuse — Saint-Pierre-d’Entremont — Saint-Savin — Saint-Sorlin-de-Morestel — Saint-Sulpice-des-Rivoires — Saint-Victor-de-Cessieu — Saint-Victor-de-Morestel — Saint-Vincent-de-Mercuze — Salagnon — Sérézin-de-la-Tour — Sermérieu — Siccieu-Saint-Julien-et-Carisieu — Soleymieu — Theys — Torchefelon — La Tour-du-Pin — Le Touvet — Trept — Valencogne — Vasselin — Velanne — Vénérieu — Vernas — Vertrieu — Vézeronce-Curtin — Vignieu — Villemoirieu — Val-de-Virieu — Voiron — Voissant SAVOIE Department—Aiguebelette-le-Lac—Grand-Aigueblanche—Les Allues—Apremont—Arbin—Argentine—Arvillard—Attignat-Oncin—Les Avanchers-Valmorel—Avressieux—Ayn—Barberaz—Barby—Bassens—La Bauche—Belmont-Tramonet—Betton-Bettonet—Bourget-en-Huile—Bozel—Brides-les-Bains—La Bridoire—Challes-les-Eaux—Chambéry—La Chambre—Chamoux-sur-Gelon—Champagneux—Champagny-en-Vanoise—Champ-Laurent—La Chapelle—La Chapelle-Blanche—Châteauneuf—La Chavanne—Les Chavannes-en-Maurienne—Chignin—Cognin—Coise-Saint-Jean-Pied-Gauthier—Corbel—La Croix-de-la-Rochette—Cruet—Curienne—Détrier—Domessin—Dullin—Les Échelles—Entremont-le-Vieux—Épierre—Feissons-sur-Salins—Gerbaix—Hautecour—Hauteville—La Tour-en-Maurienne—Jacob-Bellecombette—Jarrier—Laissaud—Landry—Lépin-le-Lac—Porte-de-Savoie—Marcieux—Les Mollettes—Montagnole—Montagny—Montendry—Montgilbert—Montmélian—Montvalezan—Montvernier—Moûtiers—Myans—Nances—Notre-Dame-du-Cruet—Notre-Dame-du-Pré—Novalaise—Peisey-Nancroix—Planaise—Planay—Le Pont-de-Beauvoisin—Le Pontet—Pralognan-la-Vanoise—Presle—Puygros—La Ravoire—Rochefort—Valgelon-La Rochette—Rotherens—Saint-Alban-de-Montbel—Saint-Alban-d’Hurtières—Saint-Alban-des-Villards—Saint-Alban-Leysse—Saint-Avre—Saint-Baldoph—Saint-Béron—Courchevel—Saint-Cassin—Saint-Christophe—Saint-Colomban-des-Villards—Saint-Étienne-de-Cuines—Sainte-Foy-Tarentaise—Saint-Franc—Saint François Longchamp—Saint-Genix-les-Villages—Saint-Georges-d’Hurtières—Sainte-Hélène-du-Lac—Saint-Jean-d’Arvey—Saint-Jean-de-Couz—Saint-Jean-de-la-Porte—Saint-Jean-de-Maurienne—Saint-Jeoire-Prieuré—Saint-Julien-Mont-Denis—Saint-Léger—Saint-Marcel—Sainte-Marie-d’Alvey—Sainte-Marie-de-Cuines—Les Belleville—Saint-Martin-sur-la-Chambre—Saint-Pierre-d’Alvey—Saint-Pierre-de-Belleville—Saint-Pierre-d’Entremont—Saint-Pierre-de-Genebroz—Saint-Pierre-de-Soucy—Saint-Rémy-de-Maurienne—Saint-Sulpice—Saint-Thibaud-de-Couz—Salins-Fontaine—Séez—La Table—Thoiry—La Thuile—La Trinité—Verel-de-Montbel—Le Verneil—Villard-d’Héry—Villard-Léger—Villard-Sallet—Villaroger—Villaroux—Vimines—Val-d’Isère—Tignes — Aiguebelette-le-Lac — Grand-Aigueblanche — Les Allues — Apremont — Arbin — Argentine — Arvillard — Attignat-Oncin — Les Avanchers-Valmorel — Avressieux — Ayn — Barberaz — Barby — Bassens — La Bauche — Belmont-Tramonet — Betton-Bettonet — Bourget-en-Huile — Bozel — Brides-les-Bains — La Bridoire — Challes-les-Eaux — Chambéry — La Chambre — Chamoux-sur-Gelon — Champagneux — Champagny-en-Vanoise — Champ-Laurent — La Chapelle — La Chapelle-Blanche — Châteauneuf — La Chavanne — Les Chavannes-en-Maurienne — Chignin — Cognin — Coise-Saint-Jean-Pied-Gauthier — Corbel — La Croix-de-la-Rochette — Cruet — Curienne — Détrier — Domessin — Dullin — Les Échelles — Entremont-le-Vieux — Épierre — Feissons-sur-Salins — Gerbaix — Hautecour — Hauteville — La Tour-en-Maurienne — Jacob-Bellecombette — Jarrier — Laissaud — Landry — Lépin-le-Lac — Porte-de-Savoie — Marcieux — Les Mollettes — Montagnole — Montagny — Montendry — Montgilbert — Montmélian — Montvalezan — Montvernier — Moûtiers — Myans — Nances — Notre-Dame-du-Cruet — Notre-Dame-du-Pré — Novalaise — Peisey-Nancroix — Planaise — Planay — Le Pont-de-Beauvoisin — Le Pontet — Pralognan-la-Vanoise — Presle — Puygros — La Ravoire — Rochefort — Valgelon-La Rochette — Rotherens — Saint-Alban-de-Montbel — Saint-Alban-d’Hurtières — Saint-Alban-des-Villards — Saint-Alban-Leysse — Saint-Avre — Saint-Baldoph — Saint-Béron — Courchevel — Saint-Cassin — Saint-Christophe — Saint-Colomban-des-Villards — Saint-Étienne-de-Cuines — Sainte-Foy-Tarentaise — Saint-Franc — Saint François Longchamp — Saint-Genix-les-Villages — Saint-Georges-d’Hurtières — Sainte-Hélène-du-Lac — Saint-Jean-d’Arvey — Saint-Jean-de-Couz — Saint-Jean-de-la-Porte — Saint-Jean-de-Maurienne — Saint-Jeoire-Prieuré — Saint-Julien-Mont-Denis — Saint-Léger — Saint-Marcel — Sainte-Marie-d’Alvey — Sainte-Marie-de-Cuines — Les Belleville — Saint-Martin-sur-la-Chambre — Saint-Pierre-d’Alvey — Saint-Pierre-de-Belleville — Saint-Pierre-d’Entremont — Saint-Pierre-de-Genebroz — Saint-Pierre-de-Soucy — Saint-Rémy-de-Maurienne — Saint-Sulpice — Saint-Thibaud-de-Couz — Salins-Fontaine — Séez — La Table — Thoiry — La Thuile — La Trinité — Verel-de-Montbel — Le Verneil — Villard-d’Héry — Villard-Léger — Villard-Sallet — Villaroger — Villaroux — Vimines — Val-d’Isère — Tignes HAUTE-SAVOIE Department—Allonzier-la-Caille—Amancy—Ambilly—Andilly—Annemasse—Arâches-la-Frasse—Arbusigny—Archamps—Arenthon—Arthaz-Pont-Notre-Dame—Ayse—Beaumont—Bellevaux—Boëge—Bogève—Bonne—Bonneville—Bossey—Brizon—Cercier—Cernex—Challonges—Chamonix-Mont-Blanc—La Chapelle-Rambaud—Charvonnex—Châtillon-sur-Cluses—Chaumont—Chavannaz—Chêne-en-Semine—Chênex—Chessenaz—Chevrier—Clarafond-Arcine—Cluses—Collonges-sous-Salève—Contamine-Sarzin—Contamine-sur-Arve—Copponex—Cornier—La Côte-d’Arbroz—Cranves-Sales—Cruseilles—Dingy-en-Vuache—Éloise—Essert-Romand—Etaux—Étrembières—Faucigny—Feigères—Fillinges—Franclens—Frangy—Gaillard—Les Gets—Groisy—Habère-Lullin—Les Houches—Jonzier-Épagny—Juvigny—Lucinges—Magland—Marcellaz—Marignier—Marlioz—Marnaz—Mégevette—Menthonnex-en-Bornes—Mieussy—Minzier—Monnetier-Mornex—Montriond—Mont-Saxonnex—Morillon—Morzine—La Muraz—Musièges—Nancy-sur-Cluses—Nangy—Nâves-Parmelan—Neydens—Onnion—Passy—Peillonnex—Pers-Jussy—Glières-Val-de-Borne—Présilly—Reignier-Ésery—Le Reposoir—La Rivière-Enverse—La Roche-sur-Foron—Saint-André-de-Boëge—Saint-Blaise—Saint-Germain-sur-Rhône—Saint-Jean-d’Aulps—Saint-Jean-de-Tholome—Saint-Jeoire—Saint-Julien-en-Genevois—Saint-Laurent—Saint-Pierre-en-Faucigny—Saint-Sigismond—Saint-Sixt—Samoëns—Le Sappey—Savigny—Scientrier—Scionzier—Servoz—Seytroux—Sixt-Fer-à-Cheval—Taninges—Thyez—Fillière—La Tour—Usinens—Valleiry—Vallorcine—Vanzy—Verchaix—Vers—Vétraz-Monthoux—Villard—Villaz—Ville-en-Sallaz—Ville-la-Grand—Villy-le-Bouveret—Villy-le-Pelloux—Viry—Viuz-en-Sallaz—Vougy—Vovray-en-Bornes—Vulbens — Allonzier-la-Caille — Amancy — Ambilly — Andilly — Annemasse — Arâches-la-Frasse — Arbusigny — Archamps — Arenthon — Arthaz-Pont-Notre-Dame — Ayse — Beaumont — Bellevaux — Boëge — Bogève — Bonne — Bonneville — Bossey — Brizon — Cercier — Cernex — Challonges — Chamonix-Mont-Blanc — La Chapelle-Rambaud — Charvonnex — Châtillon-sur-Cluses — Chaumont — Chavannaz — Chêne-en-Semine — Chênex — Chessenaz — Chevrier — Clarafond-Arcine — Cluses — Collonges-sous-Salève — Contamine-Sarzin — Contamine-sur-Arve — Copponex — Cornier — La Côte-d’Arbroz — Cranves-Sales — Cruseilles — Dingy-en-Vuache — Éloise — Essert-Romand — Etaux — Étrembières — Faucigny — Feigères — Fillinges — Franclens — Frangy — Gaillard — Les Gets — Groisy — Habère-Lullin — Les Houches — Jonzier-Épagny — Juvigny — Lucinges — Magland — Marcellaz — Marignier — Marlioz — Marnaz — Mégevette — Menthonnex-en-Bornes — Mieussy — Minzier — Monnetier-Mornex — Montriond — Mont-Saxonnex — Morillon — Morzine — La Muraz — Musièges — Nancy-sur-Cluses — Nangy — Nâves-Parmelan — Neydens — Onnion — Passy — Peillonnex — Pers-Jussy — Glières-Val-de-Borne — Présilly — Reignier-Ésery — Le Reposoir — La Rivière-Enverse — La Roche-sur-Foron — Saint-André-de-Boëge — Saint-Blaise — Saint-Germain-sur-Rhône — Saint-Jean-d’Aulps — Saint-Jean-de-Tholome — Saint-Jeoire — Saint-Julien-en-Genevois — Saint-Laurent — Saint-Pierre-en-Faucigny — Saint-Sigismond — Saint-Sixt — Samoëns — Le Sappey — Savigny — Scientrier — Scionzier — Servoz — Seytroux — Sixt-Fer-à-Cheval — Taninges — Thyez — Fillière — La Tour — Usinens — Valleiry — Vallorcine — Vanzy — Verchaix — Vers — Vétraz-Monthoux — Villard — Villaz — Ville-en-Sallaz — Ville-la-Grand — Villy-le-Bouveret — Villy-le-Pelloux — Viry — Viuz-en-Sallaz — Vougy — Vovray-en-Bornes — Vulbens 30.09.2025
AIN Department—L’Abergement-de-Varey—Ambérieu-en-Bugey—Ambléon—Ambronay—Ambutrix—Apremont—Aranc—Arandas—Argis—Armix—Bellignat—Valserhône—Belleydoux—Bénonces—Bettant—Billiat—Blyes—Boyeux-Saint-Jérôme—Brégnier-Cordon—Brénod—Brion—Briord—La Burbanche—Ceignes—Cerdon—Chaley—Challes-la-Montagne—Challex—Champdor-Corcelles—Champfromier—Chanay—Charix—Château-Gaillard—Chazey-sur-Ain—Chevillard—Chevry—Chézery-Forens—Cleyzieu—Collonges—Colomieu—Conand—Condamine—Confort—Conzieu—Corlier—Crozet—Douvres—Échallon—Évosges—Farges—Ferney-Voltaire—Béard-Géovreissiat—Giron—Groissiat—Hautecourt-Romanèche—Plateau d’Hauteville—Haut Valromey—Injoux-Génissiat—Innimond—Izenave—Izernore—Izieu—Jujurieux—Labalme—Lagnieu—Le Poizat-Lalleyriat—Lantenay—Léaz—Lélex—Leyment—Leyssard—Surjoux-Lhopital—Lhuis—Lompnas—Loyettes—Maillat—Marchamp—Martignat—Mérignat—Montagnieu—Montanges—Montréal-la-Cluse—Nurieux-Volognat—Murs-et-Gélignieux—Nantua—Neuville-sur-Ain—Les Neyrolles—Nivollet-Montgriffon—Oncieu—Ordonnaz—Outriaz—Oyonnax—Péron—Peyriat—Plagne—Poncin—Pont-d’Ain—Port—Pougny—Prémeyzel—Prémillieu—Prévessin-Moëns—Priay—Rossillon—Saint-Alban—Groslée-Saint-Benoit—Saint-Denis-en-Bugey—Saint-Genis-Pouilly—Saint-Germain-de-Joux—Saint-Jean-de-Gonville—Saint-Jean-de-Niost—Saint-Jean-le-Vieux—Sainte-Julie—Saint-Martin-du-Frêne—Saint-Maurice-de-Rémens—Saint-Rambert-en-Bugey—Saint-Sorlin-en-Bugey—Saint-Vulbas—Sault-Brénaz—Seillonnaz—Sergy—Serrières-de-Briord—Serrières-sur-Ain—Souclin—Tenay—Thoiry—Torcieu—Vaux-en-Bugey—Vieu-d’Izenave—Villebois—Villes—Les Abrets en Dauphiné — L’Abergement-de-Varey — Ambérieu-en-Bugey — Ambléon — Ambronay — Ambutrix — Apremont — Aranc — Arandas — Argis — Armix — Bellignat — Valserhône — Belleydoux — Bénonces — Bettant — Billiat — Blyes — Boyeux-Saint-Jérôme — Brégnier-Cordon — Brénod — Brion — Briord — La Burbanche — Ceignes — Cerdon — Chaley — Challes-la-Montagne — Challex — Champdor-Corcelles — Champfromier — Chanay — Charix — Château-Gaillard — Chazey-sur-Ain — Chevillard — Chevry — Chézery-Forens — Cleyzieu — Collonges — Colomieu — Conand — Condamine — Confort — Conzieu — Corlier — Crozet — Douvres — Échallon — Évosges — Farges — Ferney-Voltaire — Béard-Géovreissiat — Giron — Groissiat — Hautecourt-Romanèche — Plateau d’Hauteville — Haut Valromey — Injoux-Génissiat — Innimond — Izenave — Izernore — Izieu — Jujurieux — Labalme — Lagnieu — Le Poizat-Lalleyriat — Lantenay — Léaz — Lélex — Leyment — Leyssard — Surjoux-Lhopital — Lhuis — Lompnas — Loyettes — Maillat — Marchamp — Martignat — Mérignat — Montagnieu — Montanges — Montréal-la-Cluse — Nurieux-Volognat — Murs-et-Gélignieux — Nantua — Neuville-sur-Ain — Les Neyrolles — Nivollet-Montgriffon — Oncieu — Ordonnaz — Outriaz — Oyonnax — Péron — Peyriat — Plagne — Poncin — Pont-d’Ain — Port — Pougny — Prémeyzel — Prémillieu — Prévessin-Moëns — Priay — Rossillon — Saint-Alban — Groslée-Saint-Benoit — Saint-Denis-en-Bugey — Saint-Genis-Pouilly — Saint-Germain-de-Joux — Saint-Jean-de-Gonville — Saint-Jean-de-Niost — Saint-Jean-le-Vieux — Sainte-Julie — Saint-Martin-du-Frêne — Saint-Maurice-de-Rémens — Saint-Rambert-en-Bugey — Saint-Sorlin-en-Bugey — Saint-Vulbas — Sault-Brénaz — Seillonnaz — Sergy — Serrières-de-Briord — Serrières-sur-Ain — Souclin — Tenay — Thoiry — Torcieu — Vaux-en-Bugey — Vieu-d’Izenave — Villebois — Villes — Les Abrets en Dauphiné
— L’Abergement-de-Varey
— Ambérieu-en-Bugey
— Ambléon
— Ambronay
— Ambutrix
— Apremont
— Aranc
— Arandas
— Argis
— Armix
— Bellignat
— Valserhône
— Belleydoux
— Bénonces
— Bettant
— Billiat
— Blyes
— Boyeux-Saint-Jérôme
— Brégnier-Cordon
— Brénod
— Brion
— Briord
— La Burbanche
— Ceignes
— Cerdon
— Chaley
— Challes-la-Montagne
— Challex
— Champdor-Corcelles
— Champfromier
— Chanay
— Charix
— Château-Gaillard
— Chazey-sur-Ain
— Chevillard
— Chevry
— Chézery-Forens
— Cleyzieu
— Collonges
— Colomieu
— Conand
— Condamine
— Confort
— Conzieu
— Corlier
— Crozet
— Douvres
— Échallon
— Évosges
— Farges
— Ferney-Voltaire
— Béard-Géovreissiat
— Giron
— Groissiat
— Hautecourt-Romanèche
— Plateau d’Hauteville
— Haut Valromey
— Injoux-Génissiat
— Innimond
— Izenave
— Izernore
— Izieu
— Jujurieux
— Labalme
— Lagnieu
— Le Poizat-Lalleyriat
— Lantenay
— Léaz
— Lélex
— Leyment
— Leyssard
— Surjoux-Lhopital
— Lhuis
— Lompnas
— Loyettes
— Maillat
— Marchamp
— Martignat
— Mérignat
— Montagnieu
— Montanges
— Montréal-la-Cluse
— Nurieux-Volognat
— Murs-et-Gélignieux
— Nantua
— Neuville-sur-Ain
— Les Neyrolles
— Nivollet-Montgriffon
— Oncieu
— Ordonnaz
— Outriaz
— Oyonnax
— Péron
— Peyriat
— Plagne
— Poncin
— Pont-d’Ain
— Port
— Pougny
— Prémeyzel
— Prémillieu
— Prévessin-Moëns
— Priay
— Rossillon
— Saint-Alban
— Groslée-Saint-Benoit
— Saint-Denis-en-Bugey
— Saint-Genis-Pouilly
— Saint-Germain-de-Joux
— Saint-Jean-de-Gonville
— Saint-Jean-de-Niost
— Saint-Jean-le-Vieux
— Sainte-Julie
— Saint-Martin-du-Frêne
— Saint-Maurice-de-Rémens
— Saint-Rambert-en-Bugey
— Saint-Sorlin-en-Bugey
— Saint-Vulbas
— Sault-Brénaz
— Seillonnaz
— Sergy
— Serrières-de-Briord
— Serrières-sur-Ain
— Souclin
— Tenay
— Thoiry
— Torcieu
— Vaux-en-Bugey
— Vieu-d’Izenave
— Villebois
— Villes
— Les Abrets en Dauphiné
ISERE Department—Les Abrets en Dauphiné—Allevard—Annoisin-Chatelans—Aoste—Les Avenières Veyrins-Thuellin—La Balme-les-Grottes—Barraux—La Bâtie-Montgascon—Bilieu—Blandin—Le Bouchage—Bourgoin-Jallieu—Bouvesse-Quirieu—Brangues—La Buissière—Cessieu—Chapareillan—La Chapelle-de-la-Tour—La Chapelle-du-Bard—Charancieu—Charavines—Charette—Chassignieu—Chélieu—Le Cheylas—Chimilin—Chirens—Corbelin—Courtenay—Crémieu—Creys-Mépieu—Dizimieu—Doissin—Dolomieu—Entre-deux-Guiers—Faverges-de-la-Tour—Le Haut-Bréda—La Flachère—Goncelin—Granieu—Hières-sur-Amby—Leyrieu—Massieu—Merlas—Miribel-les-Échelles—Montagnieu—Montalieu-Vercieu—Montcarra—Montferrat—Moras—Morestel—Le Moutaret—Optevoz—Oyeu—Villages du Lac de Paladru—Parmilieu—Le Passage—Arandon-Passins—Pontcharra—Le Pont-de-Beauvoisin—Porcieu-Amblagnieu—Pressins—Rochetoirin—Romagnieu—Ruy-Montceau—Saint-Albin-de-Vaulserre—Saint-André-le-Gaz—Saint-Aupre—Saint-Baudille-de-la-Tour—Sainte-Blandine—Saint-Bueil—Saint-Chef—Saint-Christophe-sur-Guiers—Saint-Clair-de-la-Tour—Saint-Didier-de-la-Tour—Saint-Étienne-de-Crossey—Saint-Geoire-en-Valdaine—Saint-Hilaire-de-Brens—Plateau-des-Petites-Roches—Saint-Jean-d’Avelanne—Saint-Jean-de-Soudain—Saint-Joseph-de-Rivière—Saint-Laurent-du-Pont—Sainte-Marie-d’Alloix—Sainte-Marie-du-Mont—Saint-Martin-de-Vaulserre—Saint-Maximin—Saint-Nicolas-de-Macherin—Saint-Ondras—Crêts en Belledonne—Saint-Pierre-de-Chartreuse—Saint-Pierre-d’Entremont—Saint-Savin—Saint-Sorlin-de-Morestel—Saint-Sulpice-des-Rivoires—Saint-Victor-de-Cessieu—Saint-Victor-de-Morestel—Saint-Vincent-de-Mercuze—Salagnon—Sérézin-de-la-Tour—Sermérieu—Siccieu-Saint-Julien-et-Carisieu—Soleymieu—Theys—Torchefelon—La Tour-du-Pin—Le Touvet—Trept—Valencogne—Vasselin—Velanne—Vénérieu—Vernas—Vertrieu—Vézeronce-Curtin—Vignieu—Villemoirieu—Val-de-Virieu—Voiron—Voissant — Les Abrets en Dauphiné — Allevard — Annoisin-Chatelans — Aoste — Les Avenières Veyrins-Thuellin — La Balme-les-Grottes — Barraux — La Bâtie-Montgascon — Bilieu — Blandin — Le Bouchage — Bourgoin-Jallieu — Bouvesse-Quirieu — Brangues — La Buissière — Cessieu — Chapareillan — La Chapelle-de-la-Tour — La Chapelle-du-Bard — Charancieu — Charavines — Charette — Chassignieu — Chélieu — Le Cheylas — Chimilin — Chirens — Corbelin — Courtenay — Crémieu — Creys-Mépieu — Dizimieu — Doissin — Dolomieu — Entre-deux-Guiers — Faverges-de-la-Tour — Le Haut-Bréda — La Flachère — Goncelin — Granieu — Hières-sur-Amby — Leyrieu — Massieu — Merlas — Miribel-les-Échelles — Montagnieu — Montalieu-Vercieu — Montcarra — Montferrat — Moras — Morestel — Le Moutaret — Optevoz — Oyeu — Villages du Lac de Paladru — Parmilieu — Le Passage — Arandon-Passins — Pontcharra — Le Pont-de-Beauvoisin — Porcieu-Amblagnieu — Pressins — Rochetoirin — Romagnieu — Ruy-Montceau — Saint-Albin-de-Vaulserre — Saint-André-le-Gaz — Saint-Aupre — Saint-Baudille-de-la-Tour — Sainte-Blandine — Saint-Bueil — Saint-Chef — Saint-Christophe-sur-Guiers — Saint-Clair-de-la-Tour — Saint-Didier-de-la-Tour — Saint-Étienne-de-Crossey — Saint-Geoire-en-Valdaine — Saint-Hilaire-de-Brens — Plateau-des-Petites-Roches — Saint-Jean-d’Avelanne — Saint-Jean-de-Soudain — Saint-Joseph-de-Rivière — Saint-Laurent-du-Pont — Sainte-Marie-d’Alloix — Sainte-Marie-du-Mont — Saint-Martin-de-Vaulserre — Saint-Maximin — Saint-Nicolas-de-Macherin — Saint-Ondras — Crêts en Belledonne — Saint-Pierre-de-Chartreuse — Saint-Pierre-d’Entremont — Saint-Savin — Saint-Sorlin-de-Morestel — Saint-Sulpice-des-Rivoires — Saint-Victor-de-Cessieu — Saint-Victor-de-Morestel — Saint-Vincent-de-Mercuze — Salagnon — Sérézin-de-la-Tour — Sermérieu — Siccieu-Saint-Julien-et-Carisieu — Soleymieu — Theys — Torchefelon — La Tour-du-Pin — Le Touvet — Trept — Valencogne — Vasselin — Velanne — Vénérieu — Vernas — Vertrieu — Vézeronce-Curtin — Vignieu — Villemoirieu — Val-de-Virieu — Voiron — Voissant
— Les Abrets en Dauphiné
— Allevard
— Annoisin-Chatelans
— Aoste
— Les Avenières Veyrins-Thuellin
— La Balme-les-Grottes
— Barraux
— La Bâtie-Montgascon
— Bilieu
— Blandin
— Le Bouchage
— Bourgoin-Jallieu
— Bouvesse-Quirieu
— Brangues
— La Buissière
— Cessieu
— Chapareillan
— La Chapelle-de-la-Tour
— La Chapelle-du-Bard
— Charancieu
— Charavines
— Charette
— Chassignieu
— Chélieu
— Le Cheylas
— Chimilin
— Chirens
— Corbelin
— Courtenay
— Crémieu
— Creys-Mépieu
— Dizimieu
— Doissin
— Dolomieu
— Entre-deux-Guiers
— Faverges-de-la-Tour
— Le Haut-Bréda
— La Flachère
— Goncelin
— Granieu
— Hières-sur-Amby
— Leyrieu
— Massieu
— Merlas
— Miribel-les-Échelles
— Montagnieu
— Montalieu-Vercieu
— Montcarra
— Montferrat
— Moras
— Morestel
— Le Moutaret
— Optevoz
— Oyeu
— Villages du Lac de Paladru
— Parmilieu
— Le Passage
— Arandon-Passins
— Pontcharra
— Le Pont-de-Beauvoisin
— Porcieu-Amblagnieu
— Pressins
— Rochetoirin
— Romagnieu
— Ruy-Montceau
— Saint-Albin-de-Vaulserre
— Saint-André-le-Gaz
— Saint-Aupre
— Saint-Baudille-de-la-Tour
— Sainte-Blandine
— Saint-Bueil
— Saint-Chef
— Saint-Christophe-sur-Guiers
— Saint-Clair-de-la-Tour
— Saint-Didier-de-la-Tour
— Saint-Étienne-de-Crossey
— Saint-Geoire-en-Valdaine
— Saint-Hilaire-de-Brens
— Plateau-des-Petites-Roches
— Saint-Jean-d’Avelanne
— Saint-Jean-de-Soudain
— Saint-Joseph-de-Rivière
— Saint-Laurent-du-Pont
— Sainte-Marie-d’Alloix
— Sainte-Marie-du-Mont
— Saint-Martin-de-Vaulserre
— Saint-Maximin
— Saint-Nicolas-de-Macherin
— Saint-Ondras
— Crêts en Belledonne
— Saint-Pierre-de-Chartreuse
— Saint-Pierre-d’Entremont
— Saint-Savin
— Saint-Sorlin-de-Morestel
— Saint-Sulpice-des-Rivoires
— Saint-Victor-de-Cessieu
— Saint-Victor-de-Morestel
— Saint-Vincent-de-Mercuze
— Salagnon
— Sérézin-de-la-Tour
— Sermérieu
— Siccieu-Saint-Julien-et-Carisieu
— Soleymieu
— Theys
— Torchefelon
— La Tour-du-Pin
— Le Touvet
— Trept
— Valencogne
— Vasselin
— Velanne
— Vénérieu
— Vernas
— Vertrieu
— Vézeronce-Curtin
— Vignieu
— Villemoirieu
— Val-de-Virieu
— Voiron
— Voissant
SAVOIE Department—Aiguebelette-le-Lac—Grand-Aigueblanche—Les Allues—Apremont—Arbin—Argentine—Arvillard—Attignat-Oncin—Les Avanchers-Valmorel—Avressieux—Ayn—Barberaz—Barby—Bassens—La Bauche—Belmont-Tramonet—Betton-Bettonet—Bourget-en-Huile—Bozel—Brides-les-Bains—La Bridoire—Challes-les-Eaux—Chambéry—La Chambre—Chamoux-sur-Gelon—Champagneux—Champagny-en-Vanoise—Champ-Laurent—La Chapelle—La Chapelle-Blanche—Châteauneuf—La Chavanne—Les Chavannes-en-Maurienne—Chignin—Cognin—Coise-Saint-Jean-Pied-Gauthier—Corbel—La Croix-de-la-Rochette—Cruet—Curienne—Détrier—Domessin—Dullin—Les Échelles—Entremont-le-Vieux—Épierre—Feissons-sur-Salins—Gerbaix—Hautecour—Hauteville—La Tour-en-Maurienne—Jacob-Bellecombette—Jarrier—Laissaud—Landry—Lépin-le-Lac—Porte-de-Savoie—Marcieux—Les Mollettes—Montagnole—Montagny—Montendry—Montgilbert—Montmélian—Montvalezan—Montvernier—Moûtiers—Myans—Nances—Notre-Dame-du-Cruet—Notre-Dame-du-Pré—Novalaise—Peisey-Nancroix—Planaise—Planay—Le Pont-de-Beauvoisin—Le Pontet—Pralognan-la-Vanoise—Presle—Puygros—La Ravoire—Rochefort—Valgelon-La Rochette—Rotherens—Saint-Alban-de-Montbel—Saint-Alban-d’Hurtières—Saint-Alban-des-Villards—Saint-Alban-Leysse—Saint-Avre—Saint-Baldoph—Saint-Béron—Courchevel—Saint-Cassin—Saint-Christophe—Saint-Colomban-des-Villards—Saint-Étienne-de-Cuines—Sainte-Foy-Tarentaise—Saint-Franc—Saint François Longchamp—Saint-Genix-les-Villages—Saint-Georges-d’Hurtières—Sainte-Hélène-du-Lac—Saint-Jean-d’Arvey—Saint-Jean-de-Couz—Saint-Jean-de-la-Porte—Saint-Jean-de-Maurienne—Saint-Jeoire-Prieuré—Saint-Julien-Mont-Denis—Saint-Léger—Saint-Marcel—Sainte-Marie-d’Alvey—Sainte-Marie-de-Cuines—Les Belleville—Saint-Martin-sur-la-Chambre—Saint-Pierre-d’Alvey—Saint-Pierre-de-Belleville—Saint-Pierre-d’Entremont—Saint-Pierre-de-Genebroz—Saint-Pierre-de-Soucy—Saint-Rémy-de-Maurienne—Saint-Sulpice—Saint-Thibaud-de-Couz—Salins-Fontaine—Séez—La Table—Thoiry—La Thuile—La Trinité—Verel-de-Montbel—Le Verneil—Villard-d’Héry—Villard-Léger—Villard-Sallet—Villaroger—Villaroux—Vimines—Val-d’Isère—Tignes — Aiguebelette-le-Lac — Grand-Aigueblanche — Les Allues — Apremont — Arbin — Argentine — Arvillard — Attignat-Oncin — Les Avanchers-Valmorel — Avressieux — Ayn — Barberaz — Barby — Bassens — La Bauche — Belmont-Tramonet — Betton-Bettonet — Bourget-en-Huile — Bozel — Brides-les-Bains — La Bridoire — Challes-les-Eaux — Chambéry — La Chambre — Chamoux-sur-Gelon — Champagneux — Champagny-en-Vanoise — Champ-Laurent — La Chapelle — La Chapelle-Blanche — Châteauneuf — La Chavanne — Les Chavannes-en-Maurienne — Chignin — Cognin — Coise-Saint-Jean-Pied-Gauthier — Corbel — La Croix-de-la-Rochette — Cruet — Curienne — Détrier — Domessin — Dullin — Les Échelles — Entremont-le-Vieux — Épierre — Feissons-sur-Salins — Gerbaix — Hautecour — Hauteville — La Tour-en-Maurienne — Jacob-Bellecombette — Jarrier — Laissaud — Landry — Lépin-le-Lac — Porte-de-Savoie — Marcieux — Les Mollettes — Montagnole — Montagny — Montendry — Montgilbert — Montmélian — Montvalezan — Montvernier — Moûtiers — Myans — Nances — Notre-Dame-du-Cruet — Notre-Dame-du-Pré — Novalaise — Peisey-Nancroix — Planaise — Planay — Le Pont-de-Beauvoisin — Le Pontet — Pralognan-la-Vanoise — Presle — Puygros — La Ravoire — Rochefort — Valgelon-La Rochette — Rotherens — Saint-Alban-de-Montbel — Saint-Alban-d’Hurtières — Saint-Alban-des-Villards — Saint-Alban-Leysse — Saint-Avre — Saint-Baldoph — Saint-Béron — Courchevel — Saint-Cassin — Saint-Christophe — Saint-Colomban-des-Villards — Saint-Étienne-de-Cuines — Sainte-Foy-Tarentaise — Saint-Franc — Saint François Longchamp — Saint-Genix-les-Villages — Saint-Georges-d’Hurtières — Sainte-Hélène-du-Lac — Saint-Jean-d’Arvey — Saint-Jean-de-Couz — Saint-Jean-de-la-Porte — Saint-Jean-de-Maurienne — Saint-Jeoire-Prieuré — Saint-Julien-Mont-Denis — Saint-Léger — Saint-Marcel — Sainte-Marie-d’Alvey — Sainte-Marie-de-Cuines — Les Belleville — Saint-Martin-sur-la-Chambre — Saint-Pierre-d’Alvey — Saint-Pierre-de-Belleville — Saint-Pierre-d’Entremont — Saint-Pierre-de-Genebroz — Saint-Pierre-de-Soucy — Saint-Rémy-de-Maurienne — Saint-Sulpice — Saint-Thibaud-de-Couz — Salins-Fontaine — Séez — La Table — Thoiry — La Thuile — La Trinité — Verel-de-Montbel — Le Verneil — Villard-d’Héry — Villard-Léger — Villard-Sallet — Villaroger — Villaroux — Vimines — Val-d’Isère — Tignes
— Aiguebelette-le-Lac
— Grand-Aigueblanche
— Les Allues
— Apremont
— Arbin
— Argentine
— Arvillard
— Attignat-Oncin
— Les Avanchers-Valmorel
— Avressieux
— Ayn
— Barberaz
— Barby
— Bassens
— La Bauche
— Belmont-Tramonet
— Betton-Bettonet
— Bourget-en-Huile
— Bozel
— Brides-les-Bains
— La Bridoire
— Challes-les-Eaux
— Chambéry
— La Chambre
— Chamoux-sur-Gelon
— Champagneux
— Champagny-en-Vanoise
— Champ-Laurent
— La Chapelle
— La Chapelle-Blanche
— Châteauneuf
— La Chavanne
— Les Chavannes-en-Maurienne
— Chignin
— Cognin
— Coise-Saint-Jean-Pied-Gauthier
— Corbel
— La Croix-de-la-Rochette
— Cruet
— Curienne
— Détrier
— Domessin
— Dullin
— Les Échelles
— Entremont-le-Vieux
— Épierre
— Feissons-sur-Salins
— Gerbaix
— Hautecour
— Hauteville
— La Tour-en-Maurienne
— Jacob-Bellecombette
— Jarrier
— Laissaud
— Landry
— Lépin-le-Lac
— Porte-de-Savoie
— Marcieux
— Les Mollettes
— Montagnole
— Montagny
— Montendry
— Montgilbert
— Montmélian
— Montvalezan
— Montvernier
— Moûtiers
— Myans
— Nances
— Notre-Dame-du-Cruet
— Notre-Dame-du-Pré
— Novalaise
— Peisey-Nancroix
— Planaise
— Planay
— Le Pont-de-Beauvoisin
— Le Pontet
— Pralognan-la-Vanoise
— Presle
— Puygros
— La Ravoire
— Rochefort
— Valgelon-La Rochette
— Rotherens
— Saint-Alban-de-Montbel
— Saint-Alban-d’Hurtières
— Saint-Alban-des-Villards
— Saint-Alban-Leysse
— Saint-Avre
— Saint-Baldoph
— Saint-Béron
— Courchevel
— Saint-Cassin
— Saint-Christophe
— Saint-Colomban-des-Villards
— Saint-Étienne-de-Cuines
— Sainte-Foy-Tarentaise
— Saint-Franc
— Saint François Longchamp
— Saint-Genix-les-Villages
— Saint-Georges-d’Hurtières
— Sainte-Hélène-du-Lac
— Saint-Jean-d’Arvey
— Saint-Jean-de-Couz
— Saint-Jean-de-la-Porte
— Saint-Jean-de-Maurienne
— Saint-Jeoire-Prieuré
— Saint-Julien-Mont-Denis
— Saint-Léger
— Saint-Marcel
— Sainte-Marie-d’Alvey
— Sainte-Marie-de-Cuines
— Les Belleville
— Saint-Martin-sur-la-Chambre
— Saint-Pierre-d’Alvey
— Saint-Pierre-de-Belleville
— Saint-Pierre-d’Entremont
— Saint-Pierre-de-Genebroz
— Saint-Pierre-de-Soucy
— Saint-Rémy-de-Maurienne
— Saint-Sulpice
— Saint-Thibaud-de-Couz
— Salins-Fontaine
— Séez
— La Table
— Thoiry
— La Thuile
— La Trinité
— Verel-de-Montbel
— Le Verneil
— Villard-d’Héry
— Villard-Léger
— Villard-Sallet
— Villaroger
— Villaroux
— Vimines
— Val-d’Isère
— Tignes
HAUTE-SAVOIE Department—Allonzier-la-Caille—Amancy—Ambilly—Andilly—Annemasse—Arâches-la-Frasse—Arbusigny—Archamps—Arenthon—Arthaz-Pont-Notre-Dame—Ayse—Beaumont—Bellevaux—Boëge—Bogève—Bonne—Bonneville—Bossey—Brizon—Cercier—Cernex—Challonges—Chamonix-Mont-Blanc—La Chapelle-Rambaud—Charvonnex—Châtillon-sur-Cluses—Chaumont—Chavannaz—Chêne-en-Semine—Chênex—Chessenaz—Chevrier—Clarafond-Arcine—Cluses—Collonges-sous-Salève—Contamine-Sarzin—Contamine-sur-Arve—Copponex—Cornier—La Côte-d’Arbroz—Cranves-Sales—Cruseilles—Dingy-en-Vuache—Éloise—Essert-Romand—Etaux—Étrembières—Faucigny—Feigères—Fillinges—Franclens—Frangy—Gaillard—Les Gets—Groisy—Habère-Lullin—Les Houches—Jonzier-Épagny—Juvigny—Lucinges—Magland—Marcellaz—Marignier—Marlioz—Marnaz—Mégevette—Menthonnex-en-Bornes—Mieussy—Minzier—Monnetier-Mornex—Montriond—Mont-Saxonnex—Morillon—Morzine—La Muraz—Musièges—Nancy-sur-Cluses—Nangy—Nâves-Parmelan—Neydens—Onnion—Passy—Peillonnex—Pers-Jussy—Glières-Val-de-Borne—Présilly—Reignier-Ésery—Le Reposoir—La Rivière-Enverse—La Roche-sur-Foron—Saint-André-de-Boëge—Saint-Blaise—Saint-Germain-sur-Rhône—Saint-Jean-d’Aulps—Saint-Jean-de-Tholome—Saint-Jeoire—Saint-Julien-en-Genevois—Saint-Laurent—Saint-Pierre-en-Faucigny—Saint-Sigismond—Saint-Sixt—Samoëns—Le Sappey—Savigny—Scientrier—Scionzier—Servoz—Seytroux—Sixt-Fer-à-Cheval—Taninges—Thyez—Fillière—La Tour—Usinens—Valleiry—Vallorcine—Vanzy—Verchaix—Vers—Vétraz-Monthoux—Villard—Villaz—Ville-en-Sallaz—Ville-la-Grand—Villy-le-Bouveret—Villy-le-Pelloux—Viry—Viuz-en-Sallaz—Vougy—Vovray-en-Bornes—Vulbens — Allonzier-la-Caille — Amancy — Ambilly — Andilly — Annemasse — Arâches-la-Frasse — Arbusigny — Archamps — Arenthon — Arthaz-Pont-Notre-Dame — Ayse — Beaumont — Bellevaux — Boëge — Bogève — Bonne — Bonneville — Bossey — Brizon — Cercier — Cernex — Challonges — Chamonix-Mont-Blanc — La Chapelle-Rambaud — Charvonnex — Châtillon-sur-Cluses — Chaumont — Chavannaz — Chêne-en-Semine — Chênex — Chessenaz — Chevrier — Clarafond-Arcine — Cluses — Collonges-sous-Salève — Contamine-Sarzin — Contamine-sur-Arve — Copponex — Cornier — La Côte-d’Arbroz — Cranves-Sales — Cruseilles — Dingy-en-Vuache — Éloise — Essert-Romand — Etaux — Étrembières — Faucigny — Feigères — Fillinges — Franclens — Frangy — Gaillard — Les Gets — Groisy — Habère-Lullin — Les Houches — Jonzier-Épagny — Juvigny — Lucinges — Magland — Marcellaz — Marignier — Marlioz — Marnaz — Mégevette — Menthonnex-en-Bornes — Mieussy — Minzier — Monnetier-Mornex — Montriond — Mont-Saxonnex — Morillon — Morzine — La Muraz — Musièges — Nancy-sur-Cluses — Nangy — Nâves-Parmelan — Neydens — Onnion — Passy — Peillonnex — Pers-Jussy — Glières-Val-de-Borne — Présilly — Reignier-Ésery — Le Reposoir — La Rivière-Enverse — La Roche-sur-Foron — Saint-André-de-Boëge — Saint-Blaise — Saint-Germain-sur-Rhône — Saint-Jean-d’Aulps — Saint-Jean-de-Tholome — Saint-Jeoire — Saint-Julien-en-Genevois — Saint-Laurent — Saint-Pierre-en-Faucigny — Saint-Sigismond — Saint-Sixt — Samoëns — Le Sappey — Savigny — Scientrier — Scionzier — Servoz — Seytroux — Sixt-Fer-à-Cheval — Taninges — Thyez — Fillière — La Tour — Usinens — Valleiry — Vallorcine — Vanzy — Verchaix — Vers — Vétraz-Monthoux — Villard — Villaz — Ville-en-Sallaz — Ville-la-Grand — Villy-le-Bouveret — Villy-le-Pelloux — Viry — Viuz-en-Sallaz — Vougy — Vovray-en-Bornes — Vulbens
— Allonzier-la-Caille
— Amancy
— Ambilly
— Andilly
— Annemasse
— Arâches-la-Frasse
— Arbusigny
— Archamps
— Arenthon
— Arthaz-Pont-Notre-Dame
— Ayse
— Beaumont
— Bellevaux
— Boëge
— Bogève
— Bonne
— Bonneville
— Bossey
— Brizon
— Cercier
— Cernex
— Challonges
— Chamonix-Mont-Blanc
— La Chapelle-Rambaud
— Charvonnex
— Châtillon-sur-Cluses
— Chaumont
— Chavannaz
— Chêne-en-Semine
— Chênex
— Chessenaz
— Chevrier
— Clarafond-Arcine
— Cluses
— Collonges-sous-Salève
— Contamine-Sarzin
— Contamine-sur-Arve
— Copponex
— Cornier
— La Côte-d’Arbroz
— Cranves-Sales
— Cruseilles
— Dingy-en-Vuache
— Éloise
— Essert-Romand
— Etaux
— Étrembières
— Faucigny
— Feigères
— Fillinges
— Franclens
— Frangy
— Gaillard
— Les Gets
— Groisy
— Habère-Lullin
— Les Houches
— Jonzier-Épagny
— Juvigny
— Lucinges
— Magland
— Marcellaz
— Marignier
— Marlioz
— Marnaz
— Mégevette
— Menthonnex-en-Bornes
— Mieussy
— Minzier
— Monnetier-Mornex
— Montriond
— Mont-Saxonnex
— Morillon
— Morzine
— La Muraz
— Musièges
— Nancy-sur-Cluses
— Nangy
— Nâves-Parmelan
— Neydens
— Onnion
— Passy
— Peillonnex
— Pers-Jussy
— Glières-Val-de-Borne
— Présilly
— Reignier-Ésery
— Le Reposoir
— La Rivière-Enverse
— La Roche-sur-Foron
— Saint-André-de-Boëge
— Saint-Blaise
— Saint-Germain-sur-Rhône
— Saint-Jean-d’Aulps
— Saint-Jean-de-Tholome
— Saint-Jeoire
— Saint-Julien-en-Genevois
— Saint-Laurent
— Saint-Pierre-en-Faucigny
— Saint-Sigismond
— Saint-Sixt
— Samoëns
— Le Sappey
— Savigny
— Scientrier
— Scionzier
— Servoz
— Seytroux
— Sixt-Fer-à-Cheval
— Taninges
— Thyez
— Fillière
— La Tour
— Usinens
— Valleiry
— Vallorcine
— Vanzy
— Verchaix
— Vers
— Vétraz-Monthoux
— Villard
— Villaz
— Ville-en-Sallaz
— Ville-la-Grand
— Villy-le-Bouveret
— Villy-le-Pelloux
— Viry
— Viuz-en-Sallaz
— Vougy
— Vovray-en-Bornes
— Vulbens
AIN Department—Andert-et-Condon—Anglefort—Arboys en Bugey—Artemare—Belley—Valromey-sur-Séran—Brens—Ceyzérieu—Champagne-en-Valromey—Chazey-Bons—Cheignieu-la-Balme—Contrevoz—Corbonod—Cressin-Rochefort—Culoz-Béon—Cuzieu—Flaxieu—Lavours—Magnieu—Marignieu—Massignieu-de-Rives—Parves et Nattages—Peyrieu—Pollieu—Saint-Germain-les-Paroisses—Saint-Martin-de-Bavel—Seyssel—Talissieu—Virieu-le-Grand—Arvière-en-Valromey—Virignin—Vongnes — Andert-et-Condon — Anglefort — Arboys en Bugey — Artemare — Belley — Valromey-sur-Séran — Brens — Ceyzérieu — Champagne-en-Valromey — Chazey-Bons — Cheignieu-la-Balme — Contrevoz — Corbonod — Cressin-Rochefort — Culoz-Béon — Cuzieu — Flaxieu — Lavours — Magnieu — Marignieu — Massignieu-de-Rives — Parves et Nattages — Peyrieu — Pollieu — Saint-Germain-les-Paroisses — Saint-Martin-de-Bavel — Seyssel — Talissieu — Virieu-le-Grand — Arvière-en-Valromey — Virignin — Vongnes
— Andert-et-Condon
— Anglefort
— Arboys en Bugey
— Artemare
— Belley
— Valromey-sur-Séran
— Brens
— Ceyzérieu
— Champagne-en-Valromey
— Chazey-Bons
— Cheignieu-la-Balme
— Contrevoz
— Corbonod
— Cressin-Rochefort
— Culoz-Béon
— Cuzieu
— Flaxieu
— Lavours
— Magnieu
— Marignieu
— Massignieu-de-Rives
— Parves et Nattages
— Peyrieu
— Pollieu
— Saint-Germain-les-Paroisses
— Saint-Martin-de-Bavel
— Seyssel
— Talissieu
— Virieu-le-Grand
— Arvière-en-Valromey
— Virignin
— Vongnes
— Andert-et-Condon
— Anglefort
— Arboys en Bugey
— Artemare
— Belley
— Valromey-sur-Séran
— Brens
— Ceyzérieu
— Champagne-en-Valromey
— Chazey-Bons
— Cheignieu-la-Balme
— Contrevoz
— Corbonod
— Cressin-Rochefort
— Culoz-Béon
— Cuzieu
— Flaxieu
— Lavours
— Magnieu
— Marignieu
— Massignieu-de-Rives
— Parves et Nattages
— Peyrieu
— Pollieu
— Saint-Germain-les-Paroisses
— Saint-Martin-de-Bavel
— Seyssel
— Talissieu
— Virieu-le-Grand
— Arvière-en-Valromey
— Virignin
— Vongnes
SAVOIE Department—Aillon-le-Jeune—Aillon-le-Vieux—Aime-la-Plagne—Aiton—Aix-les-Bains—Entrelacs—Albertville—Allondaz—Arith—La Balme—La Bâthie—Beaufort—Bellecombe-en-Bauges—Billième—La Biolle—Bonvillard—Bonvillaret—Bourdeau—Le Bourget-du-Lac—Bourgneuf—Bourg-Saint-Maurice—Brison-Saint-Innocent—Césarches—Cevins—Chamousset—Chanaz—La Chapelle-du-Mont-du-Chat—Les Chapelles—La Chapelle-Saint-Martin—Le Châtelard—Chindrieux—Cléry—Cohennoz—La Compôte—Conjux—Crest-Voland—Les Déserts—Doucy-en-Bauges—Drumettaz-Clarafond—École—Esserts-Blay—Flumet—Fréterive—Frontenex—La Giettaz—Gilly-sur-Isère—Grésy-sur-Aix—Grésy-sur-Isère—Grignon—Hauteluce—Jarsy—Jongieux—Lescheraines—Loisieux—Lucey—La Plagne Tarentaise—Marthod—Mercury—Méry—Meyrieux-Trouet—Montailleur—Montcel—Monthion—Montsapey—La Motte-en-Bauges—La Motte-Servolex—Motz—Mouxy—Notre-Dame-de-Bellecombe—La Léchère—Notre-Dame-des-Millières—Le Noyer—Ontex—Pallud—Plancherine—Pugny-Chatenod—Queige—Val-d’Arc—Rognaix—Ruffieux—Saint-François-de-Sales—Sainte-Hélène-sur-Isère—Saint-Jean-de-Chevelu—Saint-Nicolas-la-Chapelle—Saint-Offenge—Saint-Ours—Saint-Paul-sur-Isère—Saint-Paul-sur-Yenne—Saint-Pierre-d’Albigny—Saint-Pierre-de-Curtille—Sainte-Reine—Saint-Vital—Serrières-en-Chautagne—Sonnaz—Thénésol—Tournon—Tours-en-Savoie—Traize—Tresserve—Trévignin—Ugine—Venthon—Verel-Pragondran—Verrens-Arvey—Verthemex—Villard-sur-Doron—Vions—Viviers-du-Lac—Voglans—Yenne — Aillon-le-Jeune — Aillon-le-Vieux — Aime-la-Plagne — Aiton — Aix-les-Bains — Entrelacs — Albertville — Allondaz — Arith — La Balme — La Bâthie — Beaufort — Bellecombe-en-Bauges — Billième — La Biolle — Bonvillard — Bonvillaret — Bourdeau — Le Bourget-du-Lac — Bourgneuf — Bourg-Saint-Maurice — Brison-Saint-Innocent — Césarches — Cevins — Chamousset — Chanaz — La Chapelle-du-Mont-du-Chat — Les Chapelles — La Chapelle-Saint-Martin — Le Châtelard — Chindrieux — Cléry — Cohennoz — La Compôte — Conjux — Crest-Voland — Les Déserts — Doucy-en-Bauges — Drumettaz-Clarafond — École — Esserts-Blay — Flumet — Fréterive — Frontenex — La Giettaz — Gilly-sur-Isère — Grésy-sur-Aix — Grésy-sur-Isère — Grignon — Hauteluce — Jarsy — Jongieux — Lescheraines — Loisieux — Lucey — La Plagne Tarentaise — Marthod — Mercury — Méry — Meyrieux-Trouet — Montailleur — Montcel — Monthion — Montsapey — La Motte-en-Bauges — La Motte-Servolex — Motz — Mouxy — Notre-Dame-de-Bellecombe — La Léchère — Notre-Dame-des-Millières — Le Noyer — Ontex — Pallud — Plancherine — Pugny-Chatenod — Queige — Val-d’Arc — Rognaix — Ruffieux — Saint-François-de-Sales — Sainte-Hélène-sur-Isère — Saint-Jean-de-Chevelu — Saint-Nicolas-la-Chapelle — Saint-Offenge — Saint-Ours — Saint-Paul-sur-Isère — Saint-Paul-sur-Yenne — Saint-Pierre-d’Albigny — Saint-Pierre-de-Curtille — Sainte-Reine — Saint-Vital — Serrières-en-Chautagne — Sonnaz — Thénésol — Tournon — Tours-en-Savoie — Traize — Tresserve — Trévignin — Ugine — Venthon — Verel-Pragondran — Verrens-Arvey — Verthemex — Villard-sur-Doron — Vions — Viviers-du-Lac — Voglans — Yenne
— Aillon-le-Jeune
— Aillon-le-Vieux
— Aime-la-Plagne
— Aiton
— Aix-les-Bains
— Entrelacs
— Albertville
— Allondaz
— Arith
— La Balme
— La Bâthie
— Beaufort
— Bellecombe-en-Bauges
— Billième
— La Biolle
— Bonvillard
— Bonvillaret
— Bourdeau
— Le Bourget-du-Lac
— Bourgneuf
— Bourg-Saint-Maurice
— Brison-Saint-Innocent
— Césarches
— Cevins
— Chamousset
— Chanaz
— La Chapelle-du-Mont-du-Chat
— Les Chapelles
— La Chapelle-Saint-Martin
— Le Châtelard
— Chindrieux
— Cléry
— Cohennoz
— La Compôte
— Conjux
— Crest-Voland
— Les Déserts
— Doucy-en-Bauges
— Drumettaz-Clarafond
— École
— Esserts-Blay
— Flumet
— Fréterive
— Frontenex
— La Giettaz
— Gilly-sur-Isère
— Grésy-sur-Aix
— Grésy-sur-Isère
— Grignon
— Hauteluce
— Jarsy
— Jongieux
— Lescheraines
— Loisieux
— Lucey
— La Plagne Tarentaise
— Marthod
— Mercury
— Méry
— Meyrieux-Trouet
— Montailleur
— Montcel
— Monthion
— Montsapey
— La Motte-en-Bauges
— La Motte-Servolex
— Motz
— Mouxy
— Notre-Dame-de-Bellecombe
— La Léchère
— Notre-Dame-des-Millières
— Le Noyer
— Ontex
— Pallud
— Plancherine
— Pugny-Chatenod
— Queige
— Val-d’Arc
— Rognaix
— Ruffieux
— Saint-François-de-Sales
— Sainte-Hélène-sur-Isère
— Saint-Jean-de-Chevelu
— Saint-Nicolas-la-Chapelle
— Saint-Offenge
— Saint-Ours
— Saint-Paul-sur-Isère
— Saint-Paul-sur-Yenne
— Saint-Pierre-d’Albigny
— Saint-Pierre-de-Curtille
— Sainte-Reine
— Saint-Vital
— Serrières-en-Chautagne
— Sonnaz
— Thénésol
— Tournon
— Tours-en-Savoie
— Traize
— Tresserve
— Trévignin
— Ugine
— Venthon
— Verel-Pragondran
— Verrens-Arvey
— Verthemex
— Villard-sur-Doron
— Vions
— Viviers-du-Lac
— Voglans
— Yenne
— Aillon-le-Jeune
— Aillon-le-Vieux
— Aime-la-Plagne
— Aiton
— Aix-les-Bains
— Entrelacs
— Albertville
— Allondaz
— Arith
— La Balme
— La Bâthie
— Beaufort
— Bellecombe-en-Bauges
— Billième
— La Biolle
— Bonvillard
— Bonvillaret
— Bourdeau
— Le Bourget-du-Lac
— Bourgneuf
— Bourg-Saint-Maurice
— Brison-Saint-Innocent
— Césarches
— Cevins
— Chamousset
— Chanaz
— La Chapelle-du-Mont-du-Chat
— Les Chapelles
— La Chapelle-Saint-Martin
— Le Châtelard
— Chindrieux
— Cléry
— Cohennoz
— La Compôte
— Conjux
— Crest-Voland
— Les Déserts
— Doucy-en-Bauges
— Drumettaz-Clarafond
— École
— Esserts-Blay
— Flumet
— Fréterive
— Frontenex
— La Giettaz
— Gilly-sur-Isère
— Grésy-sur-Aix
— Grésy-sur-Isère
— Grignon
— Hauteluce
— Jarsy
— Jongieux
— Lescheraines
— Loisieux
— Lucey
— La Plagne Tarentaise
— Marthod
— Mercury
— Méry
— Meyrieux-Trouet
— Montailleur
— Montcel
— Monthion
— Montsapey
— La Motte-en-Bauges
— La Motte-Servolex
— Motz
— Mouxy
— Notre-Dame-de-Bellecombe
— La Léchère
— Notre-Dame-des-Millières
— Le Noyer
— Ontex
— Pallud
— Plancherine
— Pugny-Chatenod
— Queige
— Val-d’Arc
— Rognaix
— Ruffieux
— Saint-François-de-Sales
— Sainte-Hélène-sur-Isère
— Saint-Jean-de-Chevelu
— Saint-Nicolas-la-Chapelle
— Saint-Offenge
— Saint-Ours
— Saint-Paul-sur-Isère
— Saint-Paul-sur-Yenne
— Saint-Pierre-d’Albigny
— Saint-Pierre-de-Curtille
— Sainte-Reine
— Saint-Vital
— Serrières-en-Chautagne
— Sonnaz
— Thénésol
— Tournon
— Tours-en-Savoie
— Traize
— Tresserve
— Trévignin
— Ugine
— Venthon
— Verel-Pragondran
— Verrens-Arvey
— Verthemex
— Villard-sur-Doron
— Vions
— Viviers-du-Lac
— Voglans
— Yenne
HAUTE-SAVOIE Department—Alby-sur-Chéran—Alex—Allèves—Annecy—Argonay—La Balme-de-Sillingy—La Balme-de-Thuy—Bassy—Bloye—Bluffy—Le Bouchet-Mont-Charvin—Boussy—Chainaz-les-Frasses—La Chapelle-Saint-Maurice—Chapeiry—Chavanod—Chevaline—Chilly—Choisy—Clermont—Les Clefs—La Clusaz—Combloux—Les Contamines-Montjoie—Cordon—Crempigny-Bonneguête—Cusy—Cuvat—Demi-Quartier—Desingy—Dingy-Saint-Clair—Domancy—Doussard—Droisy—Duingt—Entrevernes—Epagny Metz-Tessy—Étercy—Faverges-Seythenex—Giez—Le Grand-Bornand—Gruffy—Hauteville-sur-Fier—Héry-sur-Alby—Lathuile—Leschaux—Lornay—Lovagny—Manigod—Marcellaz-Albanais—Marigny-Saint-Marcel—Val de Chaise—Massingy—Megève—Menthon-Saint-Bernard—Menthonnex-sous-Clermont—Mésigny—Montagny-les-Lanches—Moye—Mûres—Nonglard—Poisy—Praz-sur-Arly—Quintal—Rumilly—Saint-Eusèbe—Saint-Eustache—Saint-Félix—Saint-Ferréol—Saint-Gervais-les-Bains—Saint-Jean-de-Sixt—Saint-Jorioz—Saint-Sylvestre—Sales—Sallanches—Sallenôves—Serraval—Sevrier—Seyssel—Sillingy—Talloires-Montmin—Thônes—Thusy—Vallières-sur-Fier—Vaulx—Versonnex—Veyrier-du-Lac—Les Villards-sur-Thônes—Viuz-la-Chiésaz — Alby-sur-Chéran — Alex — Allèves — Annecy — Argonay — La Balme-de-Sillingy — La Balme-de-Thuy — Bassy — Bloye — Bluffy — Le Bouchet-Mont-Charvin — Boussy — Chainaz-les-Frasses — La Chapelle-Saint-Maurice — Chapeiry — Chavanod — Chevaline — Chilly — Choisy — Clermont — Les Clefs — La Clusaz — Combloux — Les Contamines-Montjoie — Cordon — Crempigny-Bonneguête — Cusy — Cuvat — Demi-Quartier — Desingy — Dingy-Saint-Clair — Domancy — Doussard — Droisy — Duingt — Entrevernes — Epagny Metz-Tessy — Étercy — Faverges-Seythenex — Giez — Le Grand-Bornand — Gruffy — Hauteville-sur-Fier — Héry-sur-Alby — Lathuile — Leschaux — Lornay — Lovagny — Manigod — Marcellaz-Albanais — Marigny-Saint-Marcel — Val de Chaise — Massingy — Megève — Menthon-Saint-Bernard — Menthonnex-sous-Clermont — Mésigny — Montagny-les-Lanches — Moye — Mûres — Nonglard — Poisy — Praz-sur-Arly — Quintal — Rumilly — Saint-Eusèbe — Saint-Eustache — Saint-Félix — Saint-Ferréol — Saint-Gervais-les-Bains — Saint-Jean-de-Sixt — Saint-Jorioz — Saint-Sylvestre — Sales — Sallanches — Sallenôves — Serraval — Sevrier — Seyssel — Sillingy — Talloires-Montmin — Thônes — Thusy — Vallières-sur-Fier — Vaulx — Versonnex — Veyrier-du-Lac — Les Villards-sur-Thônes — Viuz-la-Chiésaz
— Alby-sur-Chéran
— Alex
— Allèves
— Annecy
— Argonay
— La Balme-de-Sillingy
— La Balme-de-Thuy
— Bassy
— Bloye
— Bluffy
— Le Bouchet-Mont-Charvin
— Boussy
— Chainaz-les-Frasses
— La Chapelle-Saint-Maurice
— Chapeiry
— Chavanod
— Chevaline
— Chilly
— Choisy
— Clermont
— Les Clefs
— La Clusaz
— Combloux
— Les Contamines-Montjoie
— Cordon
— Crempigny-Bonneguête
— Cusy
— Cuvat
— Demi-Quartier
— Desingy
— Dingy-Saint-Clair
— Domancy
— Doussard
— Droisy
— Duingt
— Entrevernes
— Epagny Metz-Tessy
— Étercy
— Faverges-Seythenex
— Giez
— Le Grand-Bornand
— Gruffy
— Hauteville-sur-Fier
— Héry-sur-Alby
— Lathuile
— Leschaux
— Lornay
— Lovagny
— Manigod
— Marcellaz-Albanais
— Marigny-Saint-Marcel
— Val de Chaise
— Massingy
— Megève
— Menthon-Saint-Bernard
— Menthonnex-sous-Clermont
— Mésigny
— Montagny-les-Lanches
— Moye
— Mûres
— Nonglard
— Poisy
— Praz-sur-Arly
— Quintal
— Rumilly
— Saint-Eusèbe
— Saint-Eustache
— Saint-Félix
— Saint-Ferréol
— Saint-Gervais-les-Bains
— Saint-Jean-de-Sixt
— Saint-Jorioz
— Saint-Sylvestre
— Sales
— Sallanches
— Sallenôves
— Serraval
— Sevrier
— Seyssel
— Sillingy
— Talloires-Montmin
— Thônes
— Thusy
— Vallières-sur-Fier
— Vaulx
— Versonnex
— Veyrier-du-Lac
— Les Villards-sur-Thônes
— Viuz-la-Chiésaz
— Alby-sur-Chéran
— Alex
— Allèves
— Annecy
— Argonay
— La Balme-de-Sillingy
— La Balme-de-Thuy
— Bassy
— Bloye
— Bluffy
— Le Bouchet-Mont-Charvin
— Boussy
— Chainaz-les-Frasses
— La Chapelle-Saint-Maurice
— Chapeiry
— Chavanod
— Chevaline
— Chilly
— Choisy
— Clermont
— Les Clefs
— La Clusaz
— Combloux
— Les Contamines-Montjoie
— Cordon
— Crempigny-Bonneguête
— Cusy
— Cuvat
— Demi-Quartier
— Desingy
— Dingy-Saint-Clair
— Domancy
— Doussard
— Droisy
— Duingt
— Entrevernes
— Epagny Metz-Tessy
— Étercy
— Faverges-Seythenex
— Giez
— Le Grand-Bornand
— Gruffy
— Hauteville-sur-Fier
— Héry-sur-Alby
— Lathuile
— Leschaux
— Lornay
— Lovagny
— Manigod
— Marcellaz-Albanais
— Marigny-Saint-Marcel
— Val de Chaise
— Massingy
— Megève
— Menthon-Saint-Bernard
— Menthonnex-sous-Clermont
— Mésigny
— Montagny-les-Lanches
— Moye
— Mûres
— Nonglard
— Poisy
— Praz-sur-Arly
— Quintal
— Rumilly
— Saint-Eusèbe
— Saint-Eustache
— Saint-Félix
— Saint-Ferréol
— Saint-Gervais-les-Bains
— Saint-Jean-de-Sixt
— Saint-Jorioz
— Saint-Sylvestre
— Sales
— Sallanches
— Sallenôves
— Serraval
— Sevrier
— Seyssel
— Sillingy
— Talloires-Montmin
— Thônes
— Thusy
— Vallières-sur-Fier
— Vaulx
— Versonnex
— Veyrier-du-Lac
— Les Villards-sur-Thônes
— Viuz-la-Chiésaz
AIN Department—Andert-et-Condon—Anglefort—Arboys en Bugey—Artemare—Belley—Valromey-sur-Séran—Brens—Ceyzérieu—Champagne-en-Valromey—Chazey-Bons—Cheignieu-la-Balme—Contrevoz—Corbonod—Cressin-Rochefort—Culoz-Béon—Cuzieu—Flaxieu—Lavours—Magnieu—Marignieu—Massignieu-de-Rives—Parves et Nattages—Peyrieu—Pollieu—Saint-Germain-les-Paroisses—Saint-Martin-de-Bavel—Seyssel—Talissieu—Virieu-le-Grand—Arvière-en-Valromey—Virignin—Vongnes — Andert-et-Condon — Anglefort — Arboys en Bugey — Artemare — Belley — Valromey-sur-Séran — Brens — Ceyzérieu — Champagne-en-Valromey — Chazey-Bons — Cheignieu-la-Balme — Contrevoz — Corbonod — Cressin-Rochefort — Culoz-Béon — Cuzieu — Flaxieu — Lavours — Magnieu — Marignieu — Massignieu-de-Rives — Parves et Nattages — Peyrieu — Pollieu — Saint-Germain-les-Paroisses — Saint-Martin-de-Bavel — Seyssel — Talissieu — Virieu-le-Grand — Arvière-en-Valromey — Virignin — Vongnes
— Andert-et-Condon
— Anglefort
— Arboys en Bugey
— Artemare
— Belley
— Valromey-sur-Séran
— Brens
— Ceyzérieu
— Champagne-en-Valromey
— Chazey-Bons
— Cheignieu-la-Balme
— Contrevoz
— Corbonod
— Cressin-Rochefort
— Culoz-Béon
— Cuzieu
— Flaxieu
— Lavours
— Magnieu
— Marignieu
— Massignieu-de-Rives
— Parves et Nattages
— Peyrieu
— Pollieu
— Saint-Germain-les-Paroisses
— Saint-Martin-de-Bavel
— Seyssel
— Talissieu
— Virieu-le-Grand
— Arvière-en-Valromey
— Virignin
— Vongnes
— Andert-et-Condon
— Anglefort
— Arboys en Bugey
— Artemare
— Belley
— Valromey-sur-Séran
— Brens
— Ceyzérieu
— Champagne-en-Valromey
— Chazey-Bons
— Cheignieu-la-Balme
— Contrevoz
— Corbonod
— Cressin-Rochefort
— Culoz-Béon
— Cuzieu
— Flaxieu
— Lavours
— Magnieu
— Marignieu
— Massignieu-de-Rives
— Parves et Nattages
— Peyrieu
— Pollieu
— Saint-Germain-les-Paroisses
— Saint-Martin-de-Bavel
— Seyssel
— Talissieu
— Virieu-le-Grand
— Arvière-en-Valromey
— Virignin
— Vongnes
SAVOIE Department—Aillon-le-Jeune—Aillon-le-Vieux—Aime-la-Plagne—Aiton—Aix-les-Bains—Entrelacs—Albertville—Allondaz—Arith—La Balme—La Bâthie—Beaufort—Bellecombe-en-Bauges—Billième—La Biolle—Bonvillard—Bonvillaret—Bourdeau—Le Bourget-du-Lac—Bourgneuf—Bourg-Saint-Maurice—Brison-Saint-Innocent—Césarches—Cevins—Chamousset—Chanaz—La Chapelle-du-Mont-du-Chat—Les Chapelles—La Chapelle-Saint-Martin—Le Châtelard—Chindrieux—Cléry—Cohennoz—La Compôte—Conjux—Crest-Voland—Les Déserts—Doucy-en-Bauges—Drumettaz-Clarafond—École—Esserts-Blay—Flumet—Fréterive—Frontenex—La Giettaz—Gilly-sur-Isère—Grésy-sur-Aix—Grésy-sur-Isère—Grignon—Hauteluce—Jarsy—Jongieux—Lescheraines—Loisieux—Lucey—La Plagne Tarentaise—Marthod—Mercury—Méry—Meyrieux-Trouet—Montailleur—Montcel—Monthion—Montsapey—La Motte-en-Bauges—La Motte-Servolex—Motz—Mouxy—Notre-Dame-de-Bellecombe—La Léchère—Notre-Dame-des-Millières—Le Noyer—Ontex—Pallud—Plancherine—Pugny-Chatenod—Queige—Val-d’Arc—Rognaix—Ruffieux—Saint-François-de-Sales—Sainte-Hélène-sur-Isère—Saint-Jean-de-Chevelu—Saint-Nicolas-la-Chapelle—Saint-Offenge—Saint-Ours—Saint-Paul-sur-Isère—Saint-Paul-sur-Yenne—Saint-Pierre-d’Albigny—Saint-Pierre-de-Curtille—Sainte-Reine—Saint-Vital—Serrières-en-Chautagne—Sonnaz—Thénésol—Tournon—Tours-en-Savoie—Traize—Tresserve—Trévignin—Ugine—Venthon—Verel-Pragondran—Verrens-Arvey—Verthemex—Villard-sur-Doron—Vions—Viviers-du-Lac—Voglans—Yenne — Aillon-le-Jeune — Aillon-le-Vieux — Aime-la-Plagne — Aiton — Aix-les-Bains — Entrelacs — Albertville — Allondaz — Arith — La Balme — La Bâthie — Beaufort — Bellecombe-en-Bauges — Billième — La Biolle — Bonvillard — Bonvillaret — Bourdeau — Le Bourget-du-Lac — Bourgneuf — Bourg-Saint-Maurice — Brison-Saint-Innocent — Césarches — Cevins — Chamousset — Chanaz — La Chapelle-du-Mont-du-Chat — Les Chapelles — La Chapelle-Saint-Martin — Le Châtelard — Chindrieux — Cléry — Cohennoz — La Compôte — Conjux — Crest-Voland — Les Déserts — Doucy-en-Bauges — Drumettaz-Clarafond — École — Esserts-Blay — Flumet — Fréterive — Frontenex — La Giettaz — Gilly-sur-Isère — Grésy-sur-Aix — Grésy-sur-Isère — Grignon — Hauteluce — Jarsy — Jongieux — Lescheraines — Loisieux — Lucey — La Plagne Tarentaise — Marthod — Mercury — Méry — Meyrieux-Trouet — Montailleur — Montcel — Monthion — Montsapey — La Motte-en-Bauges — La Motte-Servolex — Motz — Mouxy — Notre-Dame-de-Bellecombe — La Léchère — Notre-Dame-des-Millières — Le Noyer — Ontex — Pallud — Plancherine — Pugny-Chatenod — Queige — Val-d’Arc — Rognaix — Ruffieux — Saint-François-de-Sales — Sainte-Hélène-sur-Isère — Saint-Jean-de-Chevelu — Saint-Nicolas-la-Chapelle — Saint-Offenge — Saint-Ours — Saint-Paul-sur-Isère — Saint-Paul-sur-Yenne — Saint-Pierre-d’Albigny — Saint-Pierre-de-Curtille — Sainte-Reine — Saint-Vital — Serrières-en-Chautagne — Sonnaz — Thénésol — Tournon — Tours-en-Savoie — Traize — Tresserve — Trévignin — Ugine — Venthon — Verel-Pragondran — Verrens-Arvey — Verthemex — Villard-sur-Doron — Vions — Viviers-du-Lac — Voglans — Yenne
— Aillon-le-Jeune
— Aillon-le-Vieux
— Aime-la-Plagne
— Aiton
— Aix-les-Bains
— Entrelacs
— Albertville
— Allondaz
— Arith
— La Balme
— La Bâthie
— Beaufort
— Bellecombe-en-Bauges
— Billième
— La Biolle
— Bonvillard
— Bonvillaret
— Bourdeau
— Le Bourget-du-Lac
— Bourgneuf
— Bourg-Saint-Maurice
— Brison-Saint-Innocent
— Césarches
— Cevins
— Chamousset
— Chanaz
— La Chapelle-du-Mont-du-Chat
— Les Chapelles
— La Chapelle-Saint-Martin
— Le Châtelard
— Chindrieux
— Cléry
— Cohennoz
— La Compôte
— Conjux
— Crest-Voland
— Les Déserts
— Doucy-en-Bauges
— Drumettaz-Clarafond
— École
— Esserts-Blay
— Flumet
— Fréterive
— Frontenex
— La Giettaz
— Gilly-sur-Isère
— Grésy-sur-Aix
— Grésy-sur-Isère
— Grignon
— Hauteluce
— Jarsy
— Jongieux
— Lescheraines
— Loisieux
— Lucey
— La Plagne Tarentaise
— Marthod
— Mercury
— Méry
— Meyrieux-Trouet
— Montailleur
— Montcel
— Monthion
— Montsapey
— La Motte-en-Bauges
— La Motte-Servolex
— Motz
— Mouxy
— Notre-Dame-de-Bellecombe
— La Léchère
— Notre-Dame-des-Millières
— Le Noyer
— Ontex
— Pallud
— Plancherine
— Pugny-Chatenod
— Queige
— Val-d’Arc
— Rognaix
— Ruffieux
— Saint-François-de-Sales
— Sainte-Hélène-sur-Isère
— Saint-Jean-de-Chevelu
— Saint-Nicolas-la-Chapelle
— Saint-Offenge
— Saint-Ours
— Saint-Paul-sur-Isère
— Saint-Paul-sur-Yenne
— Saint-Pierre-d’Albigny
— Saint-Pierre-de-Curtille
— Sainte-Reine
— Saint-Vital
— Serrières-en-Chautagne
— Sonnaz
— Thénésol
— Tournon
— Tours-en-Savoie
— Traize
— Tresserve
— Trévignin
— Ugine
— Venthon
— Verel-Pragondran
— Verrens-Arvey
— Verthemex
— Villard-sur-Doron
— Vions
— Viviers-du-Lac
— Voglans
— Yenne
— Aillon-le-Jeune
— Aillon-le-Vieux
— Aime-la-Plagne
— Aiton
— Aix-les-Bains
— Entrelacs
— Albertville
— Allondaz
— Arith
— La Balme
— La Bâthie
— Beaufort
— Bellecombe-en-Bauges
— Billième
— La Biolle
— Bonvillard
— Bonvillaret
— Bourdeau
— Le Bourget-du-Lac
— Bourgneuf
— Bourg-Saint-Maurice
— Brison-Saint-Innocent
— Césarches
— Cevins
— Chamousset
— Chanaz
— La Chapelle-du-Mont-du-Chat
— Les Chapelles
— La Chapelle-Saint-Martin
— Le Châtelard
— Chindrieux
— Cléry
— Cohennoz
— La Compôte
— Conjux
— Crest-Voland
— Les Déserts
— Doucy-en-Bauges
— Drumettaz-Clarafond
— École
— Esserts-Blay
— Flumet
— Fréterive
— Frontenex
— La Giettaz
— Gilly-sur-Isère
— Grésy-sur-Aix
— Grésy-sur-Isère
— Grignon
— Hauteluce
— Jarsy
— Jongieux
— Lescheraines
— Loisieux
— Lucey
— La Plagne Tarentaise
— Marthod
— Mercury
— Méry
— Meyrieux-Trouet
— Montailleur
— Montcel
— Monthion
— Montsapey
— La Motte-en-Bauges
— La Motte-Servolex
— Motz
— Mouxy
— Notre-Dame-de-Bellecombe
— La Léchère
— Notre-Dame-des-Millières
— Le Noyer
— Ontex
— Pallud
— Plancherine
— Pugny-Chatenod
— Queige
— Val-d’Arc
— Rognaix
— Ruffieux
— Saint-François-de-Sales
— Sainte-Hélène-sur-Isère
— Saint-Jean-de-Chevelu
— Saint-Nicolas-la-Chapelle
— Saint-Offenge
— Saint-Ours
— Saint-Paul-sur-Isère
— Saint-Paul-sur-Yenne
— Saint-Pierre-d’Albigny
— Saint-Pierre-de-Curtille
— Sainte-Reine
— Saint-Vital
— Serrières-en-Chautagne
— Sonnaz
— Thénésol
— Tournon
— Tours-en-Savoie
— Traize
— Tresserve
— Trévignin
— Ugine
— Venthon
— Verel-Pragondran
— Verrens-Arvey
— Verthemex
— Villard-sur-Doron
— Vions
— Viviers-du-Lac
— Voglans
— Yenne
HAUTE-SAVOIE Department—Alby-sur-Chéran—Alex—Allèves—Annecy—Argonay—La Balme-de-Sillingy—La Balme-de-Thuy—Bassy—Bloye—Bluffy—Le Bouchet-Mont-Charvin—Boussy—Chainaz-les-Frasses—La Chapelle-Saint-Maurice—Chapeiry—Chavanod—Chevaline—Chilly—Choisy—Clermont—Les Clefs—La Clusaz—Combloux—Les Contamines-Montjoie—Cordon—Crempigny-Bonneguête—Cusy—Cuvat—Demi-Quartier—Desingy—Dingy-Saint-Clair—Domancy—Doussard—Droisy—Duingt—Entrevernes—Epagny Metz-Tessy—Étercy—Faverges-Seythenex—Giez—Le Grand-Bornand—Gruffy—Hauteville-sur-Fier—Héry-sur-Alby—Lathuile—Leschaux—Lornay—Lovagny—Manigod—Marcellaz-Albanais—Marigny-Saint-Marcel—Val de Chaise—Massingy—Megève—Menthon-Saint-Bernard—Menthonnex-sous-Clermont—Mésigny—Montagny-les-Lanches—Moye—Mûres—Nonglard—Poisy—Praz-sur-Arly—Quintal—Rumilly—Saint-Eusèbe—Saint-Eustache—Saint-Félix—Saint-Ferréol—Saint-Gervais-les-Bains—Saint-Jean-de-Sixt—Saint-Jorioz—Saint-Sylvestre—Sales—Sallanches—Sallenôves—Serraval—Sevrier—Seyssel—Sillingy—Talloires-Montmin—Thônes—Thusy—Vallières-sur-Fier—Vaulx—Versonnex—Veyrier-du-Lac—Les Villards-sur-Thônes—Viuz-la-Chiésaz — Alby-sur-Chéran — Alex — Allèves — Annecy — Argonay — La Balme-de-Sillingy — La Balme-de-Thuy — Bassy — Bloye — Bluffy — Le Bouchet-Mont-Charvin — Boussy — Chainaz-les-Frasses — La Chapelle-Saint-Maurice — Chapeiry — Chavanod — Chevaline — Chilly — Choisy — Clermont — Les Clefs — La Clusaz — Combloux — Les Contamines-Montjoie — Cordon — Crempigny-Bonneguête — Cusy — Cuvat — Demi-Quartier — Desingy — Dingy-Saint-Clair — Domancy — Doussard — Droisy — Duingt — Entrevernes — Epagny Metz-Tessy — Étercy — Faverges-Seythenex — Giez — Le Grand-Bornand — Gruffy — Hauteville-sur-Fier — Héry-sur-Alby — Lathuile — Leschaux — Lornay — Lovagny — Manigod — Marcellaz-Albanais — Marigny-Saint-Marcel — Val de Chaise — Massingy — Megève — Menthon-Saint-Bernard — Menthonnex-sous-Clermont — Mésigny — Montagny-les-Lanches — Moye — Mûres — Nonglard — Poisy — Praz-sur-Arly — Quintal — Rumilly — Saint-Eusèbe — Saint-Eustache — Saint-Félix — Saint-Ferréol — Saint-Gervais-les-Bains — Saint-Jean-de-Sixt — Saint-Jorioz — Saint-Sylvestre — Sales — Sallanches — Sallenôves — Serraval — Sevrier — Seyssel — Sillingy — Talloires-Montmin — Thônes — Thusy — Vallières-sur-Fier — Vaulx — Versonnex — Veyrier-du-Lac — Les Villards-sur-Thônes — Viuz-la-Chiésaz
— Alby-sur-Chéran
— Alex
— Allèves
— Annecy
— Argonay
— La Balme-de-Sillingy
— La Balme-de-Thuy
— Bassy
— Bloye
— Bluffy
— Le Bouchet-Mont-Charvin
— Boussy
— Chainaz-les-Frasses
— La Chapelle-Saint-Maurice
— Chapeiry
— Chavanod
— Chevaline
— Chilly
— Choisy
— Clermont
— Les Clefs
— La Clusaz
— Combloux
— Les Contamines-Montjoie
— Cordon
— Crempigny-Bonneguête
— Cusy
— Cuvat
— Demi-Quartier
— Desingy
— Dingy-Saint-Clair
— Domancy
— Doussard
— Droisy
— Duingt
— Entrevernes
— Epagny Metz-Tessy
— Étercy
— Faverges-Seythenex
— Giez
— Le Grand-Bornand
— Gruffy
— Hauteville-sur-Fier
— Héry-sur-Alby
— Lathuile
— Leschaux
— Lornay
— Lovagny
— Manigod
— Marcellaz-Albanais
— Marigny-Saint-Marcel
— Val de Chaise
— Massingy
— Megève
— Menthon-Saint-Bernard
— Menthonnex-sous-Clermont
— Mésigny
— Montagny-les-Lanches
— Moye
— Mûres
— Nonglard
— Poisy
— Praz-sur-Arly
— Quintal
— Rumilly
— Saint-Eusèbe
— Saint-Eustache
— Saint-Félix
— Saint-Ferréol
— Saint-Gervais-les-Bains
— Saint-Jean-de-Sixt
— Saint-Jorioz
— Saint-Sylvestre
— Sales
— Sallanches
— Sallenôves
— Serraval
— Sevrier
— Seyssel
— Sillingy
— Talloires-Montmin
— Thônes
— Thusy
— Vallières-sur-Fier
— Vaulx
— Versonnex
— Veyrier-du-Lac
— Les Villards-sur-Thônes
— Viuz-la-Chiésaz
— Alby-sur-Chéran
— Alex
— Allèves
— Annecy
— Argonay
— La Balme-de-Sillingy
— La Balme-de-Thuy
— Bassy
— Bloye
— Bluffy
— Le Bouchet-Mont-Charvin
— Boussy
— Chainaz-les-Frasses
— La Chapelle-Saint-Maurice
— Chapeiry
— Chavanod
— Chevaline
— Chilly
— Choisy
— Clermont
— Les Clefs
— La Clusaz
— Combloux
— Les Contamines-Montjoie
— Cordon
— Crempigny-Bonneguête
— Cusy
— Cuvat
— Demi-Quartier
— Desingy
— Dingy-Saint-Clair
— Domancy
— Doussard
— Droisy
— Duingt
— Entrevernes
— Epagny Metz-Tessy
— Étercy
— Faverges-Seythenex
— Giez
— Le Grand-Bornand
— Gruffy
— Hauteville-sur-Fier
— Héry-sur-Alby
— Lathuile
— Leschaux
— Lornay
— Lovagny
— Manigod
— Marcellaz-Albanais
— Marigny-Saint-Marcel
— Val de Chaise
— Massingy
— Megève
— Menthon-Saint-Bernard
— Menthonnex-sous-Clermont
— Mésigny
— Montagny-les-Lanches
— Moye
— Mûres
— Nonglard
— Poisy
— Praz-sur-Arly
— Quintal
— Rumilly
— Saint-Eusèbe
— Saint-Eustache
— Saint-Félix
— Saint-Ferréol
— Saint-Gervais-les-Bains
— Saint-Jean-de-Sixt
— Saint-Jorioz
— Saint-Sylvestre
— Sales
— Sallanches
— Sallenôves
— Serraval
— Sevrier
— Seyssel
— Sillingy
— Talloires-Montmin
— Thônes
— Thusy
— Vallières-sur-Fier
— Vaulx
— Versonnex
— Veyrier-du-Lac
— Les Villards-sur-Thônes
— Viuz-la-Chiésaz
AIN Department—L’Abergement-de-Varey—Ambérieu-en-Bugey—Ambléon—Ambronay—Ambutrix—Apremont—Aranc—Arandas—Argis—Armix—Bellignat—Valserhône—Belleydoux—Bénonces—Bettant—Billiat—Blyes—Boyeux-Saint-Jérôme—Brégnier-Cordon—Brénod—Brion—Briord—La Burbanche—Ceignes—Cerdon—Chaley—Challes-la-Montagne—Challex—Champdor-Corcelles—Champfromier—Chanay—Charix—Château-Gaillard—Chazey-sur-Ain—Chevillard—Chevry—Chézery-Forens—Cleyzieu—Collonges—Colomieu—Conand—Condamine—Confort—Conzieu—Corlier—Crozet—Douvres—Échallon—Évosges—Farges—Ferney-Voltaire—Béard-Géovreissiat—Giron—Groissiat—Hautecourt-Romanèche—Plateau d’Hauteville—Haut Valromey—Injoux-Génissiat—Innimond—Izenave—Izernore—Izieu—Jujurieux—Labalme—Lagnieu—Le Poizat-Lalleyriat—Lantenay—Léaz—Lélex—Leyment—Leyssard—Surjoux-Lhopital—Lhuis—Lompnas—Loyettes—Maillat—Marchamp—Martignat—Mérignat—Montagnieu—Montanges—Montréal-la-Cluse—Nurieux-Volognat—Murs-et-Gélignieux—Nantua—Neuville-sur-Ain—Les Neyrolles—Nivollet-Montgriffon—Oncieu—Ordonnaz—Outriaz—Oyonnax—Péron—Peyriat—Plagne—Poncin—Pont-d’Ain—Port—Pougny—Prémeyzel—Prémillieu—Prévessin-Moëns—Priay—Rossillon—Saint-Alban—Groslée-Saint-Benoit—Saint-Denis-en-Bugey—Saint-Genis-Pouilly—Saint-Germain-de-Joux—Saint-Jean-de-Gonville—Saint-Jean-de-Niost—Saint-Jean-le-Vieux—Sainte-Julie—Saint-Martin-du-Frêne—Saint-Maurice-de-Rémens—Saint-Rambert-en-Bugey—Saint-Sorlin-en-Bugey—Saint-Vulbas—Sault-Brénaz—Seillonnaz—Sergy—Serrières-de-Briord—Serrières-sur-Ain—Souclin—Tenay—Thoiry—Torcieu—Vaux-en-Bugey—Vieu-d’Izenave—Villebois—Villes—Les Abrets en Dauphiné — L’Abergement-de-Varey — Ambérieu-en-Bugey — Ambléon — Ambronay — Ambutrix — Apremont — Aranc — Arandas — Argis — Armix — Bellignat — Valserhône — Belleydoux — Bénonces — Bettant — Billiat — Blyes — Boyeux-Saint-Jérôme — Brégnier-Cordon — Brénod — Brion — Briord — La Burbanche — Ceignes — Cerdon — Chaley — Challes-la-Montagne — Challex — Champdor-Corcelles — Champfromier — Chanay — Charix — Château-Gaillard — Chazey-sur-Ain — Chevillard — Chevry — Chézery-Forens — Cleyzieu — Collonges — Colomieu — Conand — Condamine — Confort — Conzieu — Corlier — Crozet — Douvres — Échallon — Évosges — Farges — Ferney-Voltaire — Béard-Géovreissiat — Giron — Groissiat — Hautecourt-Romanèche — Plateau d’Hauteville — Haut Valromey — Injoux-Génissiat — Innimond — Izenave — Izernore — Izieu — Jujurieux — Labalme — Lagnieu — Le Poizat-Lalleyriat — Lantenay — Léaz — Lélex — Leyment — Leyssard — Surjoux-Lhopital — Lhuis — Lompnas — Loyettes — Maillat — Marchamp — Martignat — Mérignat — Montagnieu — Montanges — Montréal-la-Cluse — Nurieux-Volognat — Murs-et-Gélignieux — Nantua — Neuville-sur-Ain — Les Neyrolles — Nivollet-Montgriffon — Oncieu — Ordonnaz — Outriaz — Oyonnax — Péron — Peyriat — Plagne — Poncin — Pont-d’Ain — Port — Pougny — Prémeyzel — Prémillieu — Prévessin-Moëns — Priay — Rossillon — Saint-Alban — Groslée-Saint-Benoit — Saint-Denis-en-Bugey — Saint-Genis-Pouilly — Saint-Germain-de-Joux — Saint-Jean-de-Gonville — Saint-Jean-de-Niost — Saint-Jean-le-Vieux — Sainte-Julie — Saint-Martin-du-Frêne — Saint-Maurice-de-Rémens — Saint-Rambert-en-Bugey — Saint-Sorlin-en-Bugey — Saint-Vulbas — Sault-Brénaz — Seillonnaz — Sergy — Serrières-de-Briord — Serrières-sur-Ain — Souclin — Tenay — Thoiry — Torcieu — Vaux-en-Bugey — Vieu-d’Izenave — Villebois — Villes — Les Abrets en Dauphiné
— L’Abergement-de-Varey
— Ambérieu-en-Bugey
— Ambléon
— Ambronay
— Ambutrix
— Apremont
— Aranc
— Arandas
— Argis
— Armix
— Bellignat
— Valserhône
— Belleydoux
— Bénonces
— Bettant
— Billiat
— Blyes
— Boyeux-Saint-Jérôme
— Brégnier-Cordon
— Brénod
— Brion
— Briord
— La Burbanche
— Ceignes
— Cerdon
— Chaley
— Challes-la-Montagne
— Challex
— Champdor-Corcelles
— Champfromier
— Chanay
— Charix
— Château-Gaillard
— Chazey-sur-Ain
— Chevillard
— Chevry
— Chézery-Forens
— Cleyzieu
— Collonges
— Colomieu
— Conand
— Condamine
— Confort
— Conzieu
— Corlier
— Crozet
— Douvres
— Échallon
— Évosges
— Farges
— Ferney-Voltaire
— Béard-Géovreissiat
— Giron
— Groissiat
— Hautecourt-Romanèche
— Plateau d’Hauteville
— Haut Valromey
— Injoux-Génissiat
— Innimond
— Izenave
— Izernore
— Izieu
— Jujurieux
— Labalme
— Lagnieu
— Le Poizat-Lalleyriat
— Lantenay
— Léaz
— Lélex
— Leyment
— Leyssard
— Surjoux-Lhopital
— Lhuis
— Lompnas
— Loyettes
— Maillat
— Marchamp
— Martignat
— Mérignat
— Montagnieu
— Montanges
— Montréal-la-Cluse
— Nurieux-Volognat
— Murs-et-Gélignieux
— Nantua
— Neuville-sur-Ain
— Les Neyrolles
— Nivollet-Montgriffon
— Oncieu
— Ordonnaz
— Outriaz
— Oyonnax
— Péron
— Peyriat
— Plagne
— Poncin
— Pont-d’Ain
— Port
— Pougny
— Prémeyzel
— Prémillieu
— Prévessin-Moëns
— Priay
— Rossillon
— Saint-Alban
— Groslée-Saint-Benoit
— Saint-Denis-en-Bugey
— Saint-Genis-Pouilly
— Saint-Germain-de-Joux
— Saint-Jean-de-Gonville
— Saint-Jean-de-Niost
— Saint-Jean-le-Vieux
— Sainte-Julie
— Saint-Martin-du-Frêne
— Saint-Maurice-de-Rémens
— Saint-Rambert-en-Bugey
— Saint-Sorlin-en-Bugey
— Saint-Vulbas
— Sault-Brénaz
— Seillonnaz
— Sergy
— Serrières-de-Briord
— Serrières-sur-Ain
— Souclin
— Tenay
— Thoiry
— Torcieu
— Vaux-en-Bugey
— Vieu-d’Izenave
— Villebois
— Villes
— Les Abrets en Dauphiné
— L’Abergement-de-Varey
— Ambérieu-en-Bugey
— Ambléon
— Ambronay
— Ambutrix
— Apremont
— Aranc
— Arandas
— Argis
— Armix
— Bellignat
— Valserhône
— Belleydoux
— Bénonces
— Bettant
— Billiat
— Blyes
— Boyeux-Saint-Jérôme
— Brégnier-Cordon
— Brénod
— Brion
— Briord
— La Burbanche
— Ceignes
— Cerdon
— Chaley
— Challes-la-Montagne
— Challex
— Champdor-Corcelles
— Champfromier
— Chanay
— Charix
— Château-Gaillard
— Chazey-sur-Ain
— Chevillard
— Chevry
— Chézery-Forens
— Cleyzieu
— Collonges
— Colomieu
— Conand
— Condamine
— Confort
— Conzieu
— Corlier
— Crozet
— Douvres
— Échallon
— Évosges
— Farges
— Ferney-Voltaire
— Béard-Géovreissiat
— Giron
— Groissiat
— Hautecourt-Romanèche
— Plateau d’Hauteville
— Haut Valromey
— Injoux-Génissiat
— Innimond
— Izenave
— Izernore
— Izieu
— Jujurieux
— Labalme
— Lagnieu
— Le Poizat-Lalleyriat
— Lantenay
— Léaz
— Lélex
— Leyment
— Leyssard
— Surjoux-Lhopital
— Lhuis
— Lompnas
— Loyettes
— Maillat
— Marchamp
— Martignat
— Mérignat
— Montagnieu
— Montanges
— Montréal-la-Cluse
— Nurieux-Volognat
— Murs-et-Gélignieux
— Nantua
— Neuville-sur-Ain
— Les Neyrolles
— Nivollet-Montgriffon
— Oncieu
— Ordonnaz
— Outriaz
— Oyonnax
— Péron
— Peyriat
— Plagne
— Poncin
— Pont-d’Ain
— Port
— Pougny
— Prémeyzel
— Prémillieu
— Prévessin-Moëns
— Priay
— Rossillon
— Saint-Alban
— Groslée-Saint-Benoit
— Saint-Denis-en-Bugey
— Saint-Genis-Pouilly
— Saint-Germain-de-Joux
— Saint-Jean-de-Gonville
— Saint-Jean-de-Niost
— Saint-Jean-le-Vieux
— Sainte-Julie
— Saint-Martin-du-Frêne
— Saint-Maurice-de-Rémens
— Saint-Rambert-en-Bugey
— Saint-Sorlin-en-Bugey
— Saint-Vulbas
— Sault-Brénaz
— Seillonnaz
— Sergy
— Serrières-de-Briord
— Serrières-sur-Ain
— Souclin
— Tenay
— Thoiry
— Torcieu
— Vaux-en-Bugey
— Vieu-d’Izenave
— Villebois
— Villes
— Les Abrets en Dauphiné
ISERE Department—Les Abrets en Dauphiné—Allevard—Annoisin-Chatelans—Aoste—Les Avenières Veyrins-Thuellin—La Balme-les-Grottes—Barraux—La Bâtie-Montgascon—Bilieu—Blandin—Le Bouchage—Bourgoin-Jallieu—Bouvesse-Quirieu—Brangues—La Buissière—Cessieu—Chapareillan—La Chapelle-de-la-Tour—La Chapelle-du-Bard—Charancieu—Charavines—Charette—Chassignieu—Chélieu—Le Cheylas—Chimilin—Chirens—Corbelin—Courtenay—Crémieu—Creys-Mépieu—Dizimieu—Doissin—Dolomieu—Entre-deux-Guiers—Faverges-de-la-Tour—Le Haut-Bréda—La Flachère—Goncelin—Granieu—Hières-sur-Amby—Leyrieu—Massieu—Merlas—Miribel-les-Échelles—Montagnieu—Montalieu-Vercieu—Montcarra—Montferrat—Moras—Morestel—Le Moutaret—Optevoz—Oyeu—Villages du Lac de Paladru—Parmilieu—Le Passage—Arandon-Passins—Pontcharra—Le Pont-de-Beauvoisin—Porcieu-Amblagnieu—Pressins—Rochetoirin—Romagnieu—Ruy-Montceau—Saint-Albin-de-Vaulserre—Saint-André-le-Gaz—Saint-Aupre—Saint-Baudille-de-la-Tour—Sainte-Blandine—Saint-Bueil—Saint-Chef—Saint-Christophe-sur-Guiers—Saint-Clair-de-la-Tour—Saint-Didier-de-la-Tour—Saint-Étienne-de-Crossey—Saint-Geoire-en-Valdaine—Saint-Hilaire-de-Brens—Plateau-des-Petites-Roches—Saint-Jean-d’Avelanne—Saint-Jean-de-Soudain—Saint-Joseph-de-Rivière—Saint-Laurent-du-Pont—Sainte-Marie-d’Alloix—Sainte-Marie-du-Mont—Saint-Martin-de-Vaulserre—Saint-Maximin—Saint-Nicolas-de-Macherin—Saint-Ondras—Crêts en Belledonne—Saint-Pierre-de-Chartreuse—Saint-Pierre-d’Entremont—Saint-Savin—Saint-Sorlin-de-Morestel—Saint-Sulpice-des-Rivoires—Saint-Victor-de-Cessieu—Saint-Victor-de-Morestel—Saint-Vincent-de-Mercuze—Salagnon—Sérézin-de-la-Tour—Sermérieu—Siccieu-Saint-Julien-et-Carisieu—Soleymieu—Theys—Torchefelon—La Tour-du-Pin—Le Touvet—Trept—Valencogne—Vasselin—Velanne—Vénérieu—Vernas—Vertrieu—Vézeronce-Curtin—Vignieu—Villemoirieu—Val-de-Virieu—Voiron—Voissant — Les Abrets en Dauphiné — Allevard — Annoisin-Chatelans — Aoste — Les Avenières Veyrins-Thuellin — La Balme-les-Grottes — Barraux — La Bâtie-Montgascon — Bilieu — Blandin — Le Bouchage — Bourgoin-Jallieu — Bouvesse-Quirieu — Brangues — La Buissière — Cessieu — Chapareillan — La Chapelle-de-la-Tour — La Chapelle-du-Bard — Charancieu — Charavines — Charette — Chassignieu — Chélieu — Le Cheylas — Chimilin — Chirens — Corbelin — Courtenay — Crémieu — Creys-Mépieu — Dizimieu — Doissin — Dolomieu — Entre-deux-Guiers — Faverges-de-la-Tour — Le Haut-Bréda — La Flachère — Goncelin — Granieu — Hières-sur-Amby — Leyrieu — Massieu — Merlas — Miribel-les-Échelles — Montagnieu — Montalieu-Vercieu — Montcarra — Montferrat — Moras — Morestel — Le Moutaret — Optevoz — Oyeu — Villages du Lac de Paladru — Parmilieu — Le Passage — Arandon-Passins — Pontcharra — Le Pont-de-Beauvoisin — Porcieu-Amblagnieu — Pressins — Rochetoirin — Romagnieu — Ruy-Montceau — Saint-Albin-de-Vaulserre — Saint-André-le-Gaz — Saint-Aupre — Saint-Baudille-de-la-Tour — Sainte-Blandine — Saint-Bueil — Saint-Chef — Saint-Christophe-sur-Guiers — Saint-Clair-de-la-Tour — Saint-Didier-de-la-Tour — Saint-Étienne-de-Crossey — Saint-Geoire-en-Valdaine — Saint-Hilaire-de-Brens — Plateau-des-Petites-Roches — Saint-Jean-d’Avelanne — Saint-Jean-de-Soudain — Saint-Joseph-de-Rivière — Saint-Laurent-du-Pont — Sainte-Marie-d’Alloix — Sainte-Marie-du-Mont — Saint-Martin-de-Vaulserre — Saint-Maximin — Saint-Nicolas-de-Macherin — Saint-Ondras — Crêts en Belledonne — Saint-Pierre-de-Chartreuse — Saint-Pierre-d’Entremont — Saint-Savin — Saint-Sorlin-de-Morestel — Saint-Sulpice-des-Rivoires — Saint-Victor-de-Cessieu — Saint-Victor-de-Morestel — Saint-Vincent-de-Mercuze — Salagnon — Sérézin-de-la-Tour — Sermérieu — Siccieu-Saint-Julien-et-Carisieu — Soleymieu — Theys — Torchefelon — La Tour-du-Pin — Le Touvet — Trept — Valencogne — Vasselin — Velanne — Vénérieu — Vernas — Vertrieu — Vézeronce-Curtin — Vignieu — Villemoirieu — Val-de-Virieu — Voiron — Voissant
— Les Abrets en Dauphiné
— Allevard
— Annoisin-Chatelans
— Aoste
— Les Avenières Veyrins-Thuellin
— La Balme-les-Grottes
— Barraux
— La Bâtie-Montgascon
— Bilieu
— Blandin
— Le Bouchage
— Bourgoin-Jallieu
— Bouvesse-Quirieu
— Brangues
— La Buissière
— Cessieu
— Chapareillan
— La Chapelle-de-la-Tour
— La Chapelle-du-Bard
— Charancieu
— Charavines
— Charette
— Chassignieu
— Chélieu
— Le Cheylas
— Chimilin
— Chirens
— Corbelin
— Courtenay
— Crémieu
— Creys-Mépieu
— Dizimieu
— Doissin
— Dolomieu
— Entre-deux-Guiers
— Faverges-de-la-Tour
— Le Haut-Bréda
— La Flachère
— Goncelin
— Granieu
— Hières-sur-Amby
— Leyrieu
— Massieu
— Merlas
— Miribel-les-Échelles
— Montagnieu
— Montalieu-Vercieu
— Montcarra
— Montferrat
— Moras
— Morestel
— Le Moutaret
— Optevoz
— Oyeu
— Villages du Lac de Paladru
— Parmilieu
— Le Passage
— Arandon-Passins
— Pontcharra
— Le Pont-de-Beauvoisin
— Porcieu-Amblagnieu
— Pressins
— Rochetoirin
— Romagnieu
— Ruy-Montceau
— Saint-Albin-de-Vaulserre
— Saint-André-le-Gaz
— Saint-Aupre
— Saint-Baudille-de-la-Tour
— Sainte-Blandine
— Saint-Bueil
— Saint-Chef
— Saint-Christophe-sur-Guiers
— Saint-Clair-de-la-Tour
— Saint-Didier-de-la-Tour
— Saint-Étienne-de-Crossey
— Saint-Geoire-en-Valdaine
— Saint-Hilaire-de-Brens
— Plateau-des-Petites-Roches
— Saint-Jean-d’Avelanne
— Saint-Jean-de-Soudain
— Saint-Joseph-de-Rivière
— Saint-Laurent-du-Pont
— Sainte-Marie-d’Alloix
— Sainte-Marie-du-Mont
— Saint-Martin-de-Vaulserre
— Saint-Maximin
— Saint-Nicolas-de-Macherin
— Saint-Ondras
— Crêts en Belledonne
— Saint-Pierre-de-Chartreuse
— Saint-Pierre-d’Entremont
— Saint-Savin
— Saint-Sorlin-de-Morestel
— Saint-Sulpice-des-Rivoires
— Saint-Victor-de-Cessieu
— Saint-Victor-de-Morestel
— Saint-Vincent-de-Mercuze
— Salagnon
— Sérézin-de-la-Tour
— Sermérieu
— Siccieu-Saint-Julien-et-Carisieu
— Soleymieu
— Theys
— Torchefelon
— La Tour-du-Pin
— Le Touvet
— Trept
— Valencogne
— Vasselin
— Velanne
— Vénérieu
— Vernas
— Vertrieu
— Vézeronce-Curtin
— Vignieu
— Villemoirieu
— Val-de-Virieu
— Voiron
— Voissant
— Les Abrets en Dauphiné
— Allevard
— Annoisin-Chatelans
— Aoste
— Les Avenières Veyrins-Thuellin
— La Balme-les-Grottes
— Barraux
— La Bâtie-Montgascon
— Bilieu
— Blandin
— Le Bouchage
— Bourgoin-Jallieu
— Bouvesse-Quirieu
— Brangues
— La Buissière
— Cessieu
— Chapareillan
— La Chapelle-de-la-Tour
— La Chapelle-du-Bard
— Charancieu
— Charavines
— Charette
— Chassignieu
— Chélieu
— Le Cheylas
— Chimilin
— Chirens
— Corbelin
— Courtenay
— Crémieu
— Creys-Mépieu
— Dizimieu
— Doissin
— Dolomieu
— Entre-deux-Guiers
— Faverges-de-la-Tour
— Le Haut-Bréda
— La Flachère
— Goncelin
— Granieu
— Hières-sur-Amby
— Leyrieu
— Massieu
— Merlas
— Miribel-les-Échelles
— Montagnieu
— Montalieu-Vercieu
— Montcarra
— Montferrat
— Moras
— Morestel
— Le Moutaret
— Optevoz
— Oyeu
— Villages du Lac de Paladru
— Parmilieu
— Le Passage
— Arandon-Passins
— Pontcharra
— Le Pont-de-Beauvoisin
— Porcieu-Amblagnieu
— Pressins
— Rochetoirin
— Romagnieu
— Ruy-Montceau
— Saint-Albin-de-Vaulserre
— Saint-André-le-Gaz
— Saint-Aupre
— Saint-Baudille-de-la-Tour
— Sainte-Blandine
— Saint-Bueil
— Saint-Chef
— Saint-Christophe-sur-Guiers
— Saint-Clair-de-la-Tour
— Saint-Didier-de-la-Tour
— Saint-Étienne-de-Crossey
— Saint-Geoire-en-Valdaine
— Saint-Hilaire-de-Brens
— Plateau-des-Petites-Roches
— Saint-Jean-d’Avelanne
— Saint-Jean-de-Soudain
— Saint-Joseph-de-Rivière
— Saint-Laurent-du-Pont
— Sainte-Marie-d’Alloix
— Sainte-Marie-du-Mont
— Saint-Martin-de-Vaulserre
— Saint-Maximin
— Saint-Nicolas-de-Macherin
— Saint-Ondras
— Crêts en Belledonne
— Saint-Pierre-de-Chartreuse
— Saint-Pierre-d’Entremont
— Saint-Savin
— Saint-Sorlin-de-Morestel
— Saint-Sulpice-des-Rivoires
— Saint-Victor-de-Cessieu
— Saint-Victor-de-Morestel
— Saint-Vincent-de-Mercuze
— Salagnon
— Sérézin-de-la-Tour
— Sermérieu
— Siccieu-Saint-Julien-et-Carisieu
— Soleymieu
— Theys
— Torchefelon
— La Tour-du-Pin
— Le Touvet
— Trept
— Valencogne
— Vasselin
— Velanne
— Vénérieu
— Vernas
— Vertrieu
— Vézeronce-Curtin
— Vignieu
— Villemoirieu
— Val-de-Virieu
— Voiron
— Voissant
SAVOIE Department—Aiguebelette-le-Lac—Grand-Aigueblanche—Les Allues—Apremont—Arbin—Argentine—Arvillard—Attignat-Oncin—Les Avanchers-Valmorel—Avressieux—Ayn—Barberaz—Barby—Bassens—La Bauche—Belmont-Tramonet—Betton-Bettonet—Bourget-en-Huile—Bozel—Brides-les-Bains—La Bridoire—Challes-les-Eaux—Chambéry—La Chambre—Chamoux-sur-Gelon—Champagneux—Champagny-en-Vanoise—Champ-Laurent—La Chapelle—La Chapelle-Blanche—Châteauneuf—La Chavanne—Les Chavannes-en-Maurienne—Chignin—Cognin—Coise-Saint-Jean-Pied-Gauthier—Corbel—La Croix-de-la-Rochette—Cruet—Curienne—Détrier—Domessin—Dullin—Les Échelles—Entremont-le-Vieux—Épierre—Feissons-sur-Salins—Gerbaix—Hautecour—Hauteville—La Tour-en-Maurienne—Jacob-Bellecombette—Jarrier—Laissaud—Landry—Lépin-le-Lac—Porte-de-Savoie—Marcieux—Les Mollettes—Montagnole—Montagny—Montendry—Montgilbert—Montmélian—Montvalezan—Montvernier—Moûtiers—Myans—Nances—Notre-Dame-du-Cruet—Notre-Dame-du-Pré—Novalaise—Peisey-Nancroix—Planaise—Planay—Le Pont-de-Beauvoisin—Le Pontet—Pralognan-la-Vanoise—Presle—Puygros—La Ravoire—Rochefort—Valgelon-La Rochette—Rotherens—Saint-Alban-de-Montbel—Saint-Alban-d’Hurtières—Saint-Alban-des-Villards—Saint-Alban-Leysse—Saint-Avre—Saint-Baldoph—Saint-Béron—Courchevel—Saint-Cassin—Saint-Christophe—Saint-Colomban-des-Villards—Saint-Étienne-de-Cuines—Sainte-Foy-Tarentaise—Saint-Franc—Saint François Longchamp—Saint-Genix-les-Villages—Saint-Georges-d’Hurtières—Sainte-Hélène-du-Lac—Saint-Jean-d’Arvey—Saint-Jean-de-Couz—Saint-Jean-de-la-Porte—Saint-Jean-de-Maurienne—Saint-Jeoire-Prieuré—Saint-Julien-Mont-Denis—Saint-Léger—Saint-Marcel—Sainte-Marie-d’Alvey—Sainte-Marie-de-Cuines—Les Belleville—Saint-Martin-sur-la-Chambre—Saint-Pierre-d’Alvey—Saint-Pierre-de-Belleville—Saint-Pierre-d’Entremont—Saint-Pierre-de-Genebroz—Saint-Pierre-de-Soucy—Saint-Rémy-de-Maurienne—Saint-Sulpice—Saint-Thibaud-de-Couz—Salins-Fontaine—Séez—La Table—Thoiry—La Thuile—La Trinité—Verel-de-Montbel—Le Verneil—Villard-d’Héry—Villard-Léger—Villard-Sallet—Villaroger—Villaroux—Vimines—Val-d’Isère—Tignes — Aiguebelette-le-Lac — Grand-Aigueblanche — Les Allues — Apremont — Arbin — Argentine — Arvillard — Attignat-Oncin — Les Avanchers-Valmorel — Avressieux — Ayn — Barberaz — Barby — Bassens — La Bauche — Belmont-Tramonet — Betton-Bettonet — Bourget-en-Huile — Bozel — Brides-les-Bains — La Bridoire — Challes-les-Eaux — Chambéry — La Chambre — Chamoux-sur-Gelon — Champagneux — Champagny-en-Vanoise — Champ-Laurent — La Chapelle — La Chapelle-Blanche — Châteauneuf — La Chavanne — Les Chavannes-en-Maurienne — Chignin — Cognin — Coise-Saint-Jean-Pied-Gauthier — Corbel — La Croix-de-la-Rochette — Cruet — Curienne — Détrier — Domessin — Dullin — Les Échelles — Entremont-le-Vieux — Épierre — Feissons-sur-Salins — Gerbaix — Hautecour — Hauteville — La Tour-en-Maurienne — Jacob-Bellecombette — Jarrier — Laissaud — Landry — Lépin-le-Lac — Porte-de-Savoie — Marcieux — Les Mollettes — Montagnole — Montagny — Montendry — Montgilbert — Montmélian — Montvalezan — Montvernier — Moûtiers — Myans — Nances — Notre-Dame-du-Cruet — Notre-Dame-du-Pré — Novalaise — Peisey-Nancroix — Planaise — Planay — Le Pont-de-Beauvoisin — Le Pontet — Pralognan-la-Vanoise — Presle — Puygros — La Ravoire — Rochefort — Valgelon-La Rochette — Rotherens — Saint-Alban-de-Montbel — Saint-Alban-d’Hurtières — Saint-Alban-des-Villards — Saint-Alban-Leysse — Saint-Avre — Saint-Baldoph — Saint-Béron — Courchevel — Saint-Cassin — Saint-Christophe — Saint-Colomban-des-Villards — Saint-Étienne-de-Cuines — Sainte-Foy-Tarentaise — Saint-Franc — Saint François Longchamp — Saint-Genix-les-Villages — Saint-Georges-d’Hurtières — Sainte-Hélène-du-Lac — Saint-Jean-d’Arvey — Saint-Jean-de-Couz — Saint-Jean-de-la-Porte — Saint-Jean-de-Maurienne — Saint-Jeoire-Prieuré — Saint-Julien-Mont-Denis — Saint-Léger — Saint-Marcel — Sainte-Marie-d’Alvey — Sainte-Marie-de-Cuines — Les Belleville — Saint-Martin-sur-la-Chambre — Saint-Pierre-d’Alvey — Saint-Pierre-de-Belleville — Saint-Pierre-d’Entremont — Saint-Pierre-de-Genebroz — Saint-Pierre-de-Soucy — Saint-Rémy-de-Maurienne — Saint-Sulpice — Saint-Thibaud-de-Couz — Salins-Fontaine — Séez — La Table — Thoiry — La Thuile — La Trinité — Verel-de-Montbel — Le Verneil — Villard-d’Héry — Villard-Léger — Villard-Sallet — Villaroger — Villaroux — Vimines — Val-d’Isère — Tignes
— Aiguebelette-le-Lac
— Grand-Aigueblanche
— Les Allues
— Apremont
— Arbin
— Argentine
— Arvillard
— Attignat-Oncin
— Les Avanchers-Valmorel
— Avressieux
— Ayn
— Barberaz
— Barby
— Bassens
— La Bauche
— Belmont-Tramonet
— Betton-Bettonet
— Bourget-en-Huile
— Bozel
— Brides-les-Bains
— La Bridoire
— Challes-les-Eaux
— Chambéry
— La Chambre
— Chamoux-sur-Gelon
— Champagneux
— Champagny-en-Vanoise
— Champ-Laurent
— La Chapelle
— La Chapelle-Blanche
— Châteauneuf
— La Chavanne
— Les Chavannes-en-Maurienne
— Chignin
— Cognin
— Coise-Saint-Jean-Pied-Gauthier
— Corbel
— La Croix-de-la-Rochette
— Cruet
— Curienne
— Détrier
— Domessin
— Dullin
— Les Échelles
— Entremont-le-Vieux
— Épierre
— Feissons-sur-Salins
— Gerbaix
— Hautecour
— Hauteville
— La Tour-en-Maurienne
— Jacob-Bellecombette
— Jarrier
— Laissaud
— Landry
— Lépin-le-Lac
— Porte-de-Savoie
— Marcieux
— Les Mollettes
— Montagnole
— Montagny
— Montendry
— Montgilbert
— Montmélian
— Montvalezan
— Montvernier
— Moûtiers
— Myans
— Nances
— Notre-Dame-du-Cruet
— Notre-Dame-du-Pré
— Novalaise
— Peisey-Nancroix
— Planaise
— Planay
— Le Pont-de-Beauvoisin
— Le Pontet
— Pralognan-la-Vanoise
— Presle
— Puygros
— La Ravoire
— Rochefort
— Valgelon-La Rochette
— Rotherens
— Saint-Alban-de-Montbel
— Saint-Alban-d’Hurtières
— Saint-Alban-des-Villards
— Saint-Alban-Leysse
— Saint-Avre
— Saint-Baldoph
— Saint-Béron
— Courchevel
— Saint-Cassin
— Saint-Christophe
— Saint-Colomban-des-Villards
— Saint-Étienne-de-Cuines
— Sainte-Foy-Tarentaise
— Saint-Franc
— Saint François Longchamp
— Saint-Genix-les-Villages
— Saint-Georges-d’Hurtières
— Sainte-Hélène-du-Lac
— Saint-Jean-d’Arvey
— Saint-Jean-de-Couz
— Saint-Jean-de-la-Porte
— Saint-Jean-de-Maurienne
— Saint-Jeoire-Prieuré
— Saint-Julien-Mont-Denis
— Saint-Léger
— Saint-Marcel
— Sainte-Marie-d’Alvey
— Sainte-Marie-de-Cuines
— Les Belleville
— Saint-Martin-sur-la-Chambre
— Saint-Pierre-d’Alvey
— Saint-Pierre-de-Belleville
— Saint-Pierre-d’Entremont
— Saint-Pierre-de-Genebroz
— Saint-Pierre-de-Soucy
— Saint-Rémy-de-Maurienne
— Saint-Sulpice
— Saint-Thibaud-de-Couz
— Salins-Fontaine
— Séez
— La Table
— Thoiry
— La Thuile
— La Trinité
— Verel-de-Montbel
— Le Verneil
— Villard-d’Héry
— Villard-Léger
— Villard-Sallet
— Villaroger
— Villaroux
— Vimines
— Val-d’Isère
— Tignes
— Aiguebelette-le-Lac
— Grand-Aigueblanche
— Les Allues
— Apremont
— Arbin
— Argentine
— Arvillard
— Attignat-Oncin
— Les Avanchers-Valmorel
— Avressieux
— Ayn
— Barberaz
— Barby
— Bassens
— La Bauche
— Belmont-Tramonet
— Betton-Bettonet
— Bourget-en-Huile
— Bozel
— Brides-les-Bains
— La Bridoire
— Challes-les-Eaux
— Chambéry
— La Chambre
— Chamoux-sur-Gelon
— Champagneux
— Champagny-en-Vanoise
— Champ-Laurent
— La Chapelle
— La Chapelle-Blanche
— Châteauneuf
— La Chavanne
— Les Chavannes-en-Maurienne
— Chignin
— Cognin
— Coise-Saint-Jean-Pied-Gauthier
— Corbel
— La Croix-de-la-Rochette
— Cruet
— Curienne
— Détrier
— Domessin
— Dullin
— Les Échelles
— Entremont-le-Vieux
— Épierre
— Feissons-sur-Salins
— Gerbaix
— Hautecour
— Hauteville
— La Tour-en-Maurienne
— Jacob-Bellecombette
— Jarrier
— Laissaud
— Landry
— Lépin-le-Lac
— Porte-de-Savoie
— Marcieux
— Les Mollettes
— Montagnole
— Montagny
— Montendry
— Montgilbert
— Montmélian
— Montvalezan
— Montvernier
— Moûtiers
— Myans
— Nances
— Notre-Dame-du-Cruet
— Notre-Dame-du-Pré
— Novalaise
— Peisey-Nancroix
— Planaise
— Planay
— Le Pont-de-Beauvoisin
— Le Pontet
— Pralognan-la-Vanoise
— Presle
— Puygros
— La Ravoire
— Rochefort
— Valgelon-La Rochette
— Rotherens
— Saint-Alban-de-Montbel
— Saint-Alban-d’Hurtières
— Saint-Alban-des-Villards
— Saint-Alban-Leysse
— Saint-Avre
— Saint-Baldoph
— Saint-Béron
— Courchevel
— Saint-Cassin
— Saint-Christophe
— Saint-Colomban-des-Villards
— Saint-Étienne-de-Cuines
— Sainte-Foy-Tarentaise
— Saint-Franc
— Saint François Longchamp
— Saint-Genix-les-Villages
— Saint-Georges-d’Hurtières
— Sainte-Hélène-du-Lac
— Saint-Jean-d’Arvey
— Saint-Jean-de-Couz
— Saint-Jean-de-la-Porte
— Saint-Jean-de-Maurienne
— Saint-Jeoire-Prieuré
— Saint-Julien-Mont-Denis
— Saint-Léger
— Saint-Marcel
— Sainte-Marie-d’Alvey
— Sainte-Marie-de-Cuines
— Les Belleville
— Saint-Martin-sur-la-Chambre
— Saint-Pierre-d’Alvey
— Saint-Pierre-de-Belleville
— Saint-Pierre-d’Entremont
— Saint-Pierre-de-Genebroz
— Saint-Pierre-de-Soucy
— Saint-Rémy-de-Maurienne
— Saint-Sulpice
— Saint-Thibaud-de-Couz
— Salins-Fontaine
— Séez
— La Table
— Thoiry
— La Thuile
— La Trinité
— Verel-de-Montbel
— Le Verneil
— Villard-d’Héry
— Villard-Léger
— Villard-Sallet
— Villaroger
— Villaroux
— Vimines
— Val-d’Isère
— Tignes
HAUTE-SAVOIE Department—Allonzier-la-Caille—Amancy—Ambilly—Andilly—Annemasse—Arâches-la-Frasse—Arbusigny—Archamps—Arenthon—Arthaz-Pont-Notre-Dame—Ayse—Beaumont—Bellevaux—Boëge—Bogève—Bonne—Bonneville—Bossey—Brizon—Cercier—Cernex—Challonges—Chamonix-Mont-Blanc—La Chapelle-Rambaud—Charvonnex—Châtillon-sur-Cluses—Chaumont—Chavannaz—Chêne-en-Semine—Chênex—Chessenaz—Chevrier—Clarafond-Arcine—Cluses—Collonges-sous-Salève—Contamine-Sarzin—Contamine-sur-Arve—Copponex—Cornier—La Côte-d’Arbroz—Cranves-Sales—Cruseilles—Dingy-en-Vuache—Éloise—Essert-Romand—Etaux—Étrembières—Faucigny—Feigères—Fillinges—Franclens—Frangy—Gaillard—Les Gets—Groisy—Habère-Lullin—Les Houches—Jonzier-Épagny—Juvigny—Lucinges—Magland—Marcellaz—Marignier—Marlioz—Marnaz—Mégevette—Menthonnex-en-Bornes—Mieussy—Minzier—Monnetier-Mornex—Montriond—Mont-Saxonnex—Morillon—Morzine—La Muraz—Musièges—Nancy-sur-Cluses—Nangy—Nâves-Parmelan—Neydens—Onnion—Passy—Peillonnex—Pers-Jussy—Glières-Val-de-Borne—Présilly—Reignier-Ésery—Le Reposoir—La Rivière-Enverse—La Roche-sur-Foron—Saint-André-de-Boëge—Saint-Blaise—Saint-Germain-sur-Rhône—Saint-Jean-d’Aulps—Saint-Jean-de-Tholome—Saint-Jeoire—Saint-Julien-en-Genevois—Saint-Laurent—Saint-Pierre-en-Faucigny—Saint-Sigismond—Saint-Sixt—Samoëns—Le Sappey—Savigny—Scientrier—Scionzier—Servoz—Seytroux—Sixt-Fer-à-Cheval—Taninges—Thyez—Fillière—La Tour—Usinens—Valleiry—Vallorcine—Vanzy—Verchaix—Vers—Vétraz-Monthoux—Villard—Villaz—Ville-en-Sallaz—Ville-la-Grand—Villy-le-Bouveret—Villy-le-Pelloux—Viry—Viuz-en-Sallaz—Vougy—Vovray-en-Bornes—Vulbens — Allonzier-la-Caille — Amancy — Ambilly — Andilly — Annemasse — Arâches-la-Frasse — Arbusigny — Archamps — Arenthon — Arthaz-Pont-Notre-Dame — Ayse — Beaumont — Bellevaux — Boëge — Bogève — Bonne — Bonneville — Bossey — Brizon — Cercier — Cernex — Challonges — Chamonix-Mont-Blanc — La Chapelle-Rambaud — Charvonnex — Châtillon-sur-Cluses — Chaumont — Chavannaz — Chêne-en-Semine — Chênex — Chessenaz — Chevrier — Clarafond-Arcine — Cluses — Collonges-sous-Salève — Contamine-Sarzin — Contamine-sur-Arve — Copponex — Cornier — La Côte-d’Arbroz — Cranves-Sales — Cruseilles — Dingy-en-Vuache — Éloise — Essert-Romand — Etaux — Étrembières — Faucigny — Feigères — Fillinges — Franclens — Frangy — Gaillard — Les Gets — Groisy — Habère-Lullin — Les Houches — Jonzier-Épagny — Juvigny — Lucinges — Magland — Marcellaz — Marignier — Marlioz — Marnaz — Mégevette — Menthonnex-en-Bornes — Mieussy — Minzier — Monnetier-Mornex — Montriond — Mont-Saxonnex — Morillon — Morzine — La Muraz — Musièges — Nancy-sur-Cluses — Nangy — Nâves-Parmelan — Neydens — Onnion — Passy — Peillonnex — Pers-Jussy — Glières-Val-de-Borne — Présilly — Reignier-Ésery — Le Reposoir — La Rivière-Enverse — La Roche-sur-Foron — Saint-André-de-Boëge — Saint-Blaise — Saint-Germain-sur-Rhône — Saint-Jean-d’Aulps — Saint-Jean-de-Tholome — Saint-Jeoire — Saint-Julien-en-Genevois — Saint-Laurent — Saint-Pierre-en-Faucigny — Saint-Sigismond — Saint-Sixt — Samoëns — Le Sappey — Savigny — Scientrier — Scionzier — Servoz — Seytroux — Sixt-Fer-à-Cheval — Taninges — Thyez — Fillière — La Tour — Usinens — Valleiry — Vallorcine — Vanzy — Verchaix — Vers — Vétraz-Monthoux — Villard — Villaz — Ville-en-Sallaz — Ville-la-Grand — Villy-le-Bouveret — Villy-le-Pelloux — Viry — Viuz-en-Sallaz — Vougy — Vovray-en-Bornes — Vulbens
— Allonzier-la-Caille
— Amancy
— Ambilly
— Andilly
— Annemasse
— Arâches-la-Frasse
— Arbusigny
— Archamps
— Arenthon
— Arthaz-Pont-Notre-Dame
— Ayse
— Beaumont
— Bellevaux
— Boëge
— Bogève
— Bonne
— Bonneville
— Bossey
— Brizon
— Cercier
— Cernex
— Challonges
— Chamonix-Mont-Blanc
— La Chapelle-Rambaud
— Charvonnex
— Châtillon-sur-Cluses
— Chaumont
— Chavannaz
— Chêne-en-Semine
— Chênex
— Chessenaz
— Chevrier
— Clarafond-Arcine
— Cluses
— Collonges-sous-Salève
— Contamine-Sarzin
— Contamine-sur-Arve
— Copponex
— Cornier
— La Côte-d’Arbroz
— Cranves-Sales
— Cruseilles
— Dingy-en-Vuache
— Éloise
— Essert-Romand
— Etaux
— Étrembières
— Faucigny
— Feigères
— Fillinges
— Franclens
— Frangy
— Gaillard
— Les Gets
— Groisy
— Habère-Lullin
— Les Houches
— Jonzier-Épagny
— Juvigny
— Lucinges
— Magland
— Marcellaz
— Marignier
— Marlioz
— Marnaz
— Mégevette
— Menthonnex-en-Bornes
— Mieussy
— Minzier
— Monnetier-Mornex
— Montriond
— Mont-Saxonnex
— Morillon
— Morzine
— La Muraz
— Musièges
— Nancy-sur-Cluses
— Nangy
— Nâves-Parmelan
— Neydens
— Onnion
— Passy
— Peillonnex
— Pers-Jussy
— Glières-Val-de-Borne
— Présilly
— Reignier-Ésery
— Le Reposoir
— La Rivière-Enverse
— La Roche-sur-Foron
— Saint-André-de-Boëge
— Saint-Blaise
— Saint-Germain-sur-Rhône
— Saint-Jean-d’Aulps
— Saint-Jean-de-Tholome
— Saint-Jeoire
— Saint-Julien-en-Genevois
— Saint-Laurent
— Saint-Pierre-en-Faucigny
— Saint-Sigismond
— Saint-Sixt
— Samoëns
— Le Sappey
— Savigny
— Scientrier
— Scionzier
— Servoz
— Seytroux
— Sixt-Fer-à-Cheval
— Taninges
— Thyez
— Fillière
— La Tour
— Usinens
— Valleiry
— Vallorcine
— Vanzy
— Verchaix
— Vers
— Vétraz-Monthoux
— Villard
— Villaz
— Ville-en-Sallaz
— Ville-la-Grand
— Villy-le-Bouveret
— Villy-le-Pelloux
— Viry
— Viuz-en-Sallaz
— Vougy
— Vovray-en-Bornes
— Vulbens
— Allonzier-la-Caille
— Amancy
— Ambilly
— Andilly
— Annemasse
— Arâches-la-Frasse
— Arbusigny
— Archamps
— Arenthon
— Arthaz-Pont-Notre-Dame
— Ayse
— Beaumont
— Bellevaux
— Boëge
— Bogève
— Bonne
— Bonneville
— Bossey
— Brizon
— Cercier
— Cernex
— Challonges
— Chamonix-Mont-Blanc
— La Chapelle-Rambaud
— Charvonnex
— Châtillon-sur-Cluses
— Chaumont
— Chavannaz
— Chêne-en-Semine
— Chênex
— Chessenaz
— Chevrier
— Clarafond-Arcine
— Cluses
— Collonges-sous-Salève
— Contamine-Sarzin
— Contamine-sur-Arve
— Copponex
— Cornier
— La Côte-d’Arbroz
— Cranves-Sales
— Cruseilles
— Dingy-en-Vuache
— Éloise
— Essert-Romand
— Etaux
— Étrembières
— Faucigny
— Feigères
— Fillinges
— Franclens
— Frangy
— Gaillard
— Les Gets
— Groisy
— Habère-Lullin
— Les Houches
— Jonzier-Épagny
— Juvigny
— Lucinges
— Magland
— Marcellaz
— Marignier
— Marlioz
— Marnaz
— Mégevette
— Menthonnex-en-Bornes
— Mieussy
— Minzier
— Monnetier-Mornex
— Montriond
— Mont-Saxonnex
— Morillon
— Morzine
— La Muraz
— Musièges
— Nancy-sur-Cluses
— Nangy
— Nâves-Parmelan
— Neydens
— Onnion
— Passy
— Peillonnex
— Pers-Jussy
— Glières-Val-de-Borne
— Présilly
— Reignier-Ésery
— Le Reposoir
— La Rivière-Enverse
— La Roche-sur-Foron
— Saint-André-de-Boëge
— Saint-Blaise
— Saint-Germain-sur-Rhône
— Saint-Jean-d’Aulps
— Saint-Jean-de-Tholome
— Saint-Jeoire
— Saint-Julien-en-Genevois
— Saint-Laurent
— Saint-Pierre-en-Faucigny
— Saint-Sigismond
— Saint-Sixt
— Samoëns
— Le Sappey
— Savigny
— Scientrier
— Scionzier
— Servoz
— Seytroux
— Sixt-Fer-à-Cheval
— Taninges
— Thyez
— Fillière
— La Tour
— Usinens
— Valleiry
— Vallorcine
— Vanzy
— Verchaix
— Vers
— Vétraz-Monthoux
— Villard
— Villaz
— Ville-en-Sallaz
— Ville-la-Grand
— Villy-le-Bouveret
— Villy-le-Pelloux
— Viry
— Viuz-en-Sallaz
— Vougy
— Vovray-en-Bornes
— Vulbens
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EU) 2016/429 of the European Parliament and of the Council of 9 March 2016 on transmissible animal diseases and amending and repealing certain acts in the area of animal health (‘Animal Health Law’) (1), and in particular Article 259(1) thereof,
Whereas:
(1) Infection with lumpy skin disease virus is an infectious, vector-borne disease affecting bovine animals. Its occurrence can have a severe impact on the concerned animal population and on the profitability of farming, also causing disturbance to movements of those animals and products thereof within the Union and exports to third countries.
(2) In the event of an outbreak of infection lumpy skin disease virus in bovine animals, there is a serious risk of the spread of that disease to other establishments of bovine animals particularly due its main mode of transmission through vectors.
(3) Commission Delegated Regulation (EU) 2020/687 (2) supplements the rules for the control of the listed diseases referred to in Article 9(1), points (a), (b) and (c), of Regulation (EU) 2016/429, and defined as category A, B and C diseases in Commission Implementing Regulation (EU) 2018/1882 (3). In particular, Articles 21 and 22 of Delegated Regulation (EU) 2020/687 provide for the establishment of a restricted zone in the event of an outbreak of a category A disease, including infection with lumpy skin disease virus, and for certain measures to be applied therein. In addition, Article 21(1) of that Delegated Regulation provides that the restricted zone is to comprise at least a protection zone, a surveillance zone, and, if necessary, further restricted zones around or adjacent to the protection and surveillance zones.
(4) Commission Implementing Decision (EU) 2025/1708 (4) lays down certain emergency measures related to outbreaks of infection with lumpy skin disease virus in France. More particularly, Implementing Decision (EU) 2025/1708 provides for the establishment, in France, of restricted zones, comprising protection and surveillance zones, in accordance with Article 21 of Delegated Regulation (EU) 2020/687 as well as of a vaccination zone in accordance with Part 1 of Annex IX to Commission Delegated Regulation (EU) 2023/361 (5). In addition, Article 1 of Implementing Decision (EU) 2025/1708 provides that those protection and surveillance zones, as well as the vaccination zone, are to comprise at least the areas listed in the Annexes thereto, and the measures required to be applied in those zones are to be applied at least until the dates set out in those Annexes.
(5) Since the adoption of Implementing Decision (EU) 2025/1708, France has notified the Commission of 40 additional confirmed outbreaks of infection with lumpy skin disease virus in establishments keeping bovine animals in the communes of Chambéry and Annecy, departments of Savoie and Haute Savoie, region of Auvergne-Rhône-Alpes, which were reported between 24 July and 14 August 2025. In response to these outbreaks, France has established protection and surveillance zones in the departments of Ain, Isere, Savoie, and Haute Savoie, region of Auvergne-Rhône-Alpe, where the disease control measures laid down in accordance with Delegated Regulation (EU) 2020/687 are applied.
(6) In order to prevent any unnecessary disturbance to trade within the Union, and to avoid unjustified barriers to trade being imposed by third countries, the areas indicated as protection and surveillance zones in Annex I to Implementing Decision (EU) 2025/1708 should, therefore, be updated by this Decision, and the duration of the measures to be applied in these zones fixed.
(7) The size of the areas indicated as protection and surveillance zones in Annex I to Implementing Decision (EU) 2025/1708, as amended by this Decision, as well as the duration of the measures to be applied therein, are based on the criteria laid down in Article 64(1) of Regulation (EU) 2016/429 as well as on the rules laid down in Delegated Regulation (EU) 2020/687. The criteria applied for the choice of the size of the protection zone and the surveillance zone, as well as of the duration of the measures to be applied therein, include the consideration of not only the epidemiological situation as regards infection with lumpy skin disease virus in the areas affected by that disease, but also of other epidemiological factors, including geographical parameters and the risk for the further spread of the disease in view of the presence of insect vectors. The chosen duration of the measures foreseen in this Decision has also taken into account the international standards of the Terrestrial Animal Health Code of the World Organisation for Animal Health (6).
(8) Article 2 of Implementing Decision (EU) 2025/1708 provides for the prohibition on movements of bovine animals from the areas set out in Annex I to that Decision to destinations outside the external perimeter of those zones in France or outside that Member State until the dates listed in that Annex. In view of the continuing outbreaks of infection with lumpy skin disease virus in France, and in order to prevent further spread of the disease as well as to avoid unnecessary disturbance to trade within the Union and unjustified barriers to trade with third countries, it is necessary to prolong that prohibition.
(9) Therefore, Annex I to Implementing Decision (EU) 2025/1708 should be amended accordingly.
(10) In addition, Article 69 of Regulation (EU) 2016/429, provides that the competent authority of a Member State may develop a vaccination plan or establish vaccination zones, where relevant for the effective control of a listed disease in kept animals. Article 6 of Delegated Regulation (EU) 2023/361 lays down detailed rules for official vaccination plans. That Delegated Regulation also provides, in Article 9, for rules for the implementation of emergency protective vaccination. Detailed conditions for the use of emergency protective vaccination against lumpy skin disease are laid down in Annex IX thereof.
(11) On 1 August 2025, France provided the Commission with its official vaccination plan for infection with lumpy skin disease in the territory of the four departments of Ain, Savoie, Haute-Savoie and Isère in the Auvergne-Rhône-Alpes region of France, in accordance with Article 6(4), point (b), of Delegated Regulation (EU) 2023/361, together with updated data regarding the implementation of that plan.
(12) In order to ensure coordinated disease control and to safeguard trade within the Union and with third countries, it is necessary, to adjust the vaccination zone infection with lumpy skin disease laid down in Annex II to Implementing Decision (EU) 2025/1708, at Union level.
(13) The type, size and duration of vaccination zones I and II set out in Annex II are based on the epidemiological situation and the progress of the vaccination campaigns, particularly taking into account the evolving level of vaccine coverage achieved, the Member State’s official vaccination plan and the progress reports submitted in accordance with Article 11 of Delegated Regulation (EU) 2023/361. Accordingly, Annex II to this Decision should indicate for each area concerned, the dates for during which the vaccination zones are to apply.
(14) Therefore, Annex II to Implementing Decision (EU) 2025/1708 should be amended accordingly.
(15) In light of the epidemiological situation, the amendments to Implementing Decision (EU) 2025/1708 should apply as soon as possible to prevent further spread of the disease within France, to other Member States, or to third countries, and to avoid unnecessary disturbance to trade within the Union or unjustified barriers to trade with third countries.
(16) The measures provided for in this Decision are in accordance with the opinion of the Standing Committee on Plants, Animals, Food and Feed,
HAS ADOPTED THIS DECISION:
The Annexes to Implementing Decision (EU) 2025/1708 are replaced by the text set out in the Annex to this Decision.
This Decision is addressed to the French Republic.

‘ANNEX I
Part A: Protection and surveillance zones established around the confirmed outbreaks
Administrative area and ADIS reference number of the outbreak
Areas established as protection and surveillance zones, part of the restricted zone, referred to in Article 1
Date until applicable
Region of Auvergne-Rhône-Alpes
FR-LSD-2025-00001
FR-LSD-2025-00002
FR-LSD-2025-00003
FR-LSD-2025-00004
FR-LSD-2025-00005
FR-LSD-2025-00006
FR-LSD-2025-00007
FR-LSD-2025-00008
FR-LSD-2025-00009
FR-LSD-2025-00010
FR-LSD-2025-00011
FR-LSD-2025-00012
FR-LSD-2025-00013
FR-LSD-2025-00014
FR-LSD-2025-00015
FR-LSD-2025-00016
FR-LSD-2025-00017
FR-LSD-2025-00018
FR-LSD-2025-00019
FR-LSD-2025-00020
FR-LSD-2025-00021
FR-LSD-2025-00022
FR-LSD-2025-00023
FR-LSD-2025-00024
FR-LSD-2025-00025
FR-LSD-2025-00026
FR-LSD-2025-00027
FR-LSD-2025-00028
FR-LSD-2025-00029
FR-LSD-2025-00030
FR-LSD-2025-00031
FR-LSD-2025-00032
FR-LSD-2025-00033
FR-LSD-2025-00034
FR-LSD-2025-00035
FR-LSD-2025-00036
FR-LSD-2025-00037
FR-LSD-2025-00038
FR-LSD-2025-00039
FR-LSD-2025-00040
FR-LSD-2025-00041
FR-LSD-2025-00042
FR-LSD-2025-00043
FR-LSD-2025-00044
FR-LSD-2025-00045
FR-LSD-2025-00046
FR-LSD-2025-00047
FR-LSD-2025-00048
FR-LSD-2025-00049
FR-LSD-2025-00050
FR-LSD-2025-00051
FR-LSD-2025-00052
FR-LSD-2025-00053
FR-LSD-2025-00054
FR-LSD-2025-00055
FR-LSD-2025-00056
FR-LSD-2025-00057
FR-LSD-2025-00058
FR-LSD-2025-00059
FR-LSD-2025-00060
FR-LSD-2025-00061
FR-LSD-2025-00062
FR-LSD-2025-00063
FR-LSD-2025-00064
FR-LSD-2025-00065
FR-LSD-2025-00066
FR-LSD-2025-00067
FR-LSD-2025-00068
FR-LSD-2025-00069
FR-LSD-2025-00070
FR-LSD-2025-00071
FR-LSD-2025-00072
FR-LSD-2025-00073
FR-LSD-2025-00074
Protection zone:
The following municipalities in the following departments from region of Auvergne-Rhône-Alpes:

AIN Department
—
Andert-et-Condon
—
Anglefort
—
Arboys en Bugey
—
Artemare
—
Belley
—
Valromey-sur-Séran
—
Brens
—
Ceyzérieu
—
Champagne-en-Valromey
—
Chazey-Bons
—
Cheignieu-la-Balme
—
Contrevoz
—
Corbonod
—
Cressin-Rochefort
—
Culoz-Béon
—
Cuzieu
—
Flaxieu
—
Lavours
—
Magnieu
—
Marignieu
—
Massignieu-de-Rives
—
Parves et Nattages
—
Peyrieu
—
Pollieu
—
Saint-Germain-les-Paroisses
—
Saint-Martin-de-Bavel
—
Seyssel
—
Talissieu
—
Virieu-le-Grand
—
Arvière-en-Valromey
—
Virignin
—
Vongnes

SAVOIE Department
—
Aillon-le-Jeune
—
Aillon-le-Vieux
—
Aime-la-Plagne
—
Aiton
—
Aix-les-Bains
—
Entrelacs
—
Albertville
—
Allondaz
—
Arith
—
La Balme
—
La Bâthie
—
Beaufort
—
Bellecombe-en-Bauges
—
Billième
—
La Biolle
—
Bonvillard
—
Bonvillaret
—
Bourdeau
—
Le Bourget-du-Lac
—
Bourgneuf
—
Bourg-Saint-Maurice
—
Brison-Saint-Innocent
—
Césarches
—
Cevins
—
Chamousset
—
Chanaz
—
La Chapelle-du-Mont-du-Chat
—
Les Chapelles
—
La Chapelle-Saint-Martin
—
Le Châtelard
—
Chindrieux
—
Cléry
—
Cohennoz
—
La Compôte
—
Conjux
—
Crest-Voland
—
Les Déserts
—
Doucy-en-Bauges
—
Drumettaz-Clarafond
—
École
—
Esserts-Blay
—
Flumet
—
Fréterive
—
Frontenex
—
La Giettaz
—
Gilly-sur-Isère
—
Grésy-sur-Aix
—
Grésy-sur-Isère
—
Grignon
—
Hauteluce
—
Jarsy
—
Jongieux
—
Lescheraines
—
Loisieux
—
Lucey
—
La Plagne Tarentaise
—
Marthod
—
Mercury
—
Méry
—
Meyrieux-Trouet
—
Montailleur
—
Montcel
—
Monthion
—
Montsapey
—
La Motte-en-Bauges
—
La Motte-Servolex
—
Motz
—
Mouxy
—
Notre-Dame-de-Bellecombe
—
La Léchère
—
Notre-Dame-des-Millières
—
Le Noyer
—
Ontex
—
Pallud
—
Plancherine
—
Pugny-Chatenod
—
Queige
—
Val-d’Arc
—
Rognaix
—
Ruffieux
—
Saint-François-de-Sales
—
Sainte-Hélène-sur-Isère
—
Saint-Jean-de-Chevelu
—
Saint-Nicolas-la-Chapelle
—
Saint-Offenge
—
Saint-Ours
—
Saint-Paul-sur-Isère
—
Saint-Paul-sur-Yenne
—
Saint-Pierre-d’Albigny
—
Saint-Pierre-de-Curtille
—
Sainte-Reine
—
Saint-Vital
—
Serrières-en-Chautagne
—
Sonnaz
—
Thénésol
—
Tournon
—
Tours-en-Savoie
—
Traize
—
Tresserve
—
Trévignin
—
Ugine
—
Venthon
—
Verel-Pragondran
—
Verrens-Arvey
—
Verthemex
—
Villard-sur-Doron
—
Vions
—
Viviers-du-Lac
—
Voglans
—
Yenne

HAUTE-SAVOIE Department
—
Alby-sur-Chéran
—
Alex
—
Allèves
—
Annecy
—
Argonay
—
La Balme-de-Sillingy
—
La Balme-de-Thuy
—
Bassy
—
Bloye
—
Bluffy
—
Le Bouchet-Mont-Charvin
—
Boussy
—
Chainaz-les-Frasses
—
La Chapelle-Saint-Maurice
—
Chapeiry
—
Chavanod
—
Chevaline
—
Chilly
—
Choisy
—
Clermont
—
Les Clefs
—
La Clusaz
—
Combloux
—
Les Contamines-Montjoie
—
Cordon
—
Crempigny-Bonneguête
—
Cusy
—
Cuvat
—
Demi-Quartier
—
Desingy
—
Dingy-Saint-Clair
—
Domancy
—
Doussard
—
Droisy
—
Duingt
—
Entrevernes
—
Epagny Metz-Tessy
—
Étercy
—
Faverges-Seythenex
—
Giez
—
Le Grand-Bornand
—
Gruffy
—
Hauteville-sur-Fier
—
Héry-sur-Alby
—
Lathuile
—
Leschaux
—
Lornay
—
Lovagny
—
Manigod
—
Marcellaz-Albanais
—
Marigny-Saint-Marcel
—
Val de Chaise
—
Massingy
—
Megève
—
Menthon-Saint-Bernard
—
Menthonnex-sous-Clermont
—
Mésigny
—
Montagny-les-Lanches
—
Moye
—
Mûres
—
Nonglard
—
Poisy
—
Praz-sur-Arly
—
Quintal
—
Rumilly
—
Saint-Eusèbe
—
Saint-Eustache
—
Saint-Félix
—
Saint-Ferréol
—
Saint-Gervais-les-Bains
—
Saint-Jean-de-Sixt
—
Saint-Jorioz
—
Saint-Sylvestre
—
Sales
—
Sallanches
—
Sallenôves
—
Serraval
—
Sevrier
—
Seyssel
—
Sillingy
—
Talloires-Montmin
—
Thônes
—
Thusy
—
Vallières-sur-Fier
—
Vaulx
—
Versonnex
—
Veyrier-du-Lac
—
Les Villards-sur-Thônes
—
Viuz-la-Chiésaz
13.9.2025

Surveillance zone:
The following municipalities in the following departments from region of Auvergne-Rhône-Alpes:

AIN Department
—
Andert-et-Condon
—
Anglefort
—
Arboys en Bugey
—
Artemare
—
Belley
—
Valromey-sur-Séran
—
Brens
—
Ceyzérieu
—
Champagne-en-Valromey
—
Chazey-Bons
—
Cheignieu-la-Balme
—
Contrevoz
—
Corbonod
—
Cressin-Rochefort
—
Culoz-Béon
—
Cuzieu
—
Flaxieu
—
Lavours
—
Magnieu
—
Marignieu
—
Massignieu-de-Rives
—
Parves et Nattages
—
Peyrieu
—
Pollieu
—
Saint-Germain-les-Paroisses
—
Saint-Martin-de-Bavel
—
Seyssel
—
Talissieu
—
Virieu-le-Grand
—
Arvière-en-Valromey
—
Virignin
—
Vongnes

SAVOIE Department
—
Aillon-le-Jeune
—
Aillon-le-Vieux
—
Aime-la-Plagne
—
Aiton
—
Aix-les-Bains
—
Entrelacs
—
Albertville
—
Allondaz
—
Arith
—
La Balme
—
La Bâthie
—
Beaufort
—
Bellecombe-en-Bauges
—
Billième
—
La Biolle
—
Bonvillard
—
Bonvillaret
—
Bourdeau
—
Le Bourget-du-Lac
—
Bourgneuf
—
Bourg-Saint-Maurice
—
Brison-Saint-Innocent
—
Césarches
—
Cevins
—
Chamousset
—
Chanaz
—
La Chapelle-du-Mont-du-Chat
—
Les Chapelles
—
La Chapelle-Saint-Martin
—
Le Châtelard
—
Chindrieux
—
Cléry
—
Cohennoz
—
La Compôte
—
Conjux
—
Crest-Voland
—
Les Déserts
—
Doucy-en-Bauges
—
Drumettaz-Clarafond
—
École
—
Esserts-Blay
—
Flumet
—
Fréterive
—
Frontenex
—
La Giettaz
—
Gilly-sur-Isère
—
Grésy-sur-Aix
—
Grésy-sur-Isère
—
Grignon
—
Hauteluce
—
Jarsy
—
Jongieux
—
Lescheraines
—
Loisieux
—
Lucey
—
La Plagne Tarentaise
—
Marthod
—
Mercury
—
Méry
—
Meyrieux-Trouet
—
Montailleur
—
Montcel
—
Monthion
—
Montsapey
—
La Motte-en-Bauges
—
La Motte-Servolex
—
Motz
—
Mouxy
—
Notre-Dame-de-Bellecombe
—
La Léchère
—
Notre-Dame-des-Millières
—
Le Noyer
—
Ontex
—
Pallud
—
Plancherine
—
Pugny-Chatenod
—
Queige
—
Val-d’Arc
—
Rognaix
—
Ruffieux
—
Saint-François-de-Sales
—
Sainte-Hélène-sur-Isère
—
Saint-Jean-de-Chevelu
—
Saint-Nicolas-la-Chapelle
—
Saint-Offenge
—
Saint-Ours
—
Saint-Paul-sur-Isère
—
Saint-Paul-sur-Yenne
—
Saint-Pierre-d’Albigny
—
Saint-Pierre-de-Curtille
—
Sainte-Reine
—
Saint-Vital
—
Serrières-en-Chautagne
—
Sonnaz
—
Thénésol
—
Tournon
—
Tours-en-Savoie
—
Traize
—
Tresserve
—
Trévignin
—
Ugine
—
Venthon
—
Verel-Pragondran
—
Verrens-Arvey
—
Verthemex
—
Villard-sur-Doron
—
Vions
—
Viviers-du-Lac
—
Voglans
—
Yenne

HAUTE-SAVOIE Department
—
Alby-sur-Chéran
—
Alex
—
Allèves
—
Annecy
—
Argonay
—
La Balme-de-Sillingy
—
La Balme-de-Thuy
—
Bassy
—
Bloye
—
Bluffy
—
Le Bouchet-Mont-Charvin
—
Boussy
—
Chainaz-les-Frasses
—
La Chapelle-Saint-Maurice
—
Chapeiry
—
Chavanod
—
Chevaline
—
Chilly
—
Choisy
—
Clermont
—
Les Clefs
—
La Clusaz
—
Combloux
—
Les Contamines-Montjoie
—
Cordon
—
Crempigny-Bonneguête
—
Cusy
—
Cuvat
—
Demi-Quartier
—
Desingy
—
Dingy-Saint-Clair
—
Domancy
—
Doussard
—
Droisy
—
Duingt
—
Entrevernes
—
Epagny Metz-Tessy
—
Étercy
—
Faverges-Seythenex
—
Giez
—
Le Grand-Bornand
—
Gruffy
—
Hauteville-sur-Fier
—
Héry-sur-Alby
—
Lathuile
—
Leschaux
—
Lornay
—
Lovagny
—
Manigod
—
Marcellaz-Albanais
—
Marigny-Saint-Marcel
—
Val de Chaise
—
Massingy
—
Megève
—
Menthon-Saint-Bernard
—
Menthonnex-sous-Clermont
—
Mésigny
—
Montagny-les-Lanches
—
Moye
—
Mûres
—
Nonglard
—
Poisy
—
Praz-sur-Arly
—
Quintal
—
Rumilly
—
Saint-Eusèbe
—
Saint-Eustache
—
Saint-Félix
—
Saint-Ferréol
—
Saint-Gervais-les-Bains
—
Saint-Jean-de-Sixt
—
Saint-Jorioz
—
Saint-Sylvestre
—
Sales
—
Sallanches
—
Sallenôves
—
Serraval
—
Sevrier
—
Seyssel
—
Sillingy
—
Talloires-Montmin
—
Thônes
—
Thusy
—
Vallières-sur-Fier
—
Vaulx
—
Versonnex
—
Veyrier-du-Lac
—
Les Villards-sur-Thônes
—
Viuz-la-Chiésaz
14.9.2025 – 30.9.2025

Surveillance zone:
The following municipalities in the following departments from region of Auvergne-Rhône-Alpes:

AIN Department
—
L’Abergement-de-Varey
—
Ambérieu-en-Bugey
—
Ambléon
—
Ambronay
—
Ambutrix
—
Apremont
—
Aranc
—
Arandas
—
Argis
—
Armix
—
Bellignat
—
Valserhône
—
Belleydoux
—
Bénonces
—
Bettant
—
Billiat
—
Blyes
—
Boyeux-Saint-Jérôme
—
Brégnier-Cordon
—
Brénod
—
Brion
—
Briord
—
La Burbanche
—
Ceignes
—
Cerdon
—
Chaley
—
Challes-la-Montagne
—
Challex
—
Champdor-Corcelles
—
Champfromier
—
Chanay
—
Charix
—
Château-Gaillard
—
Chazey-sur-Ain
—
Chevillard
—
Chevry
—
Chézery-Forens
—
Cleyzieu
—
Collonges
—
Colomieu
—
Conand
—
Condamine
—
Confort
—
Conzieu
—
Corlier
—
Crozet
—
Douvres
—
Échallon
—
Évosges
—
Farges
—
Ferney-Voltaire
—
Béard-Géovreissiat
—
Giron
—
Groissiat
—
Hautecourt-Romanèche
—
Plateau d’Hauteville
—
Haut Valromey
—
Injoux-Génissiat
—
Innimond
—
Izenave
—
Izernore
—
Izieu
—
Jujurieux
—
Labalme
—
Lagnieu
—
Le Poizat-Lalleyriat
—
Lantenay
—
Léaz
—
Lélex
—
Leyment
—
Leyssard
—
Surjoux-Lhopital
—
Lhuis
—
Lompnas
—
Loyettes
—
Maillat
—
Marchamp
—
Martignat
—
Mérignat
—
Montagnieu
—
Montanges
—
Montréal-la-Cluse
—
Nurieux-Volognat
—
Murs-et-Gélignieux
—
Nantua
—
Neuville-sur-Ain
—
Les Neyrolles
—
Nivollet-Montgriffon
—
Oncieu
—
Ordonnaz
—
Outriaz
—
Oyonnax
—
Péron
—
Peyriat
—
Plagne
—
Poncin
—
Pont-d’Ain
—
Port
—
Pougny
—
Prémeyzel
—
Prémillieu
—
Prévessin-Moëns
—
Priay
—
Rossillon
—
Saint-Alban
—
Groslée-Saint-Benoit
—
Saint-Denis-en-Bugey
—
Saint-Genis-Pouilly
—
Saint-Germain-de-Joux
—
Saint-Jean-de-Gonville
—
Saint-Jean-de-Niost
—
Saint-Jean-le-Vieux
—
Sainte-Julie
—
Saint-Martin-du-Frêne
—
Saint-Maurice-de-Rémens
—
Saint-Rambert-en-Bugey
—
Saint-Sorlin-en-Bugey
—
Saint-Vulbas
—
Sault-Brénaz
—
Seillonnaz
—
Sergy
—
Serrières-de-Briord
—
Serrières-sur-Ain
—
Souclin
—
Tenay
—
Thoiry
—
Torcieu
—
Vaux-en-Bugey
—
Vieu-d’Izenave
—
Villebois
—
Villes
—
Les Abrets en Dauphiné

ISERE Department
—
Les Abrets en Dauphiné
—
Allevard
—
Annoisin-Chatelans
—
Aoste
—
Les Avenières Veyrins-Thuellin
—
La Balme-les-Grottes
—
Barraux
—
La Bâtie-Montgascon
—
Bilieu
—
Blandin
—
Le Bouchage
—
Bourgoin-Jallieu
—
Bouvesse-Quirieu
—
Brangues
—
La Buissière
—
Cessieu
—
Chapareillan
—
La Chapelle-de-la-Tour
—
La Chapelle-du-Bard
—
Charancieu
—
Charavines
—
Charette
—
Chassignieu
—
Chélieu
—
Le Cheylas
—
Chimilin
—
Chirens
—
Corbelin
—
Courtenay
—
Crémieu
—
Creys-Mépieu
—
Dizimieu
—
Doissin
—
Dolomieu
—
Entre-deux-Guiers
—
Faverges-de-la-Tour
—
Le Haut-Bréda
—
La Flachère
—
Goncelin
—
Granieu
—
Hières-sur-Amby
—
Leyrieu
—
Massieu
—
Merlas
—
Miribel-les-Échelles
—
Montagnieu
—
Montalieu-Vercieu
—
Montcarra
—
Montferrat
—
Moras
—
Morestel
—
Le Moutaret
—
Optevoz
—
Oyeu
—
Villages du Lac de Paladru
—
Parmilieu
—
Le Passage
—
Arandon-Passins
—
Pontcharra
—
Le Pont-de-Beauvoisin
—
Porcieu-Amblagnieu
—
Pressins
—
Rochetoirin
—
Romagnieu
—
Ruy-Montceau
—
Saint-Albin-de-Vaulserre
—
Saint-André-le-Gaz
—
Saint-Aupre
—
Saint-Baudille-de-la-Tour
—
Sainte-Blandine
—
Saint-Bueil
—
Saint-Chef
—
Saint-Christophe-sur-Guiers
—
Saint-Clair-de-la-Tour
—
Saint-Didier-de-la-Tour
—
Saint-Étienne-de-Crossey
—
Saint-Geoire-en-Valdaine
—
Saint-Hilaire-de-Brens
—
Plateau-des-Petites-Roches
—
Saint-Jean-d’Avelanne
—
Saint-Jean-de-Soudain
—
Saint-Joseph-de-Rivière
—
Saint-Laurent-du-Pont
—
Sainte-Marie-d’Alloix
—
Sainte-Marie-du-Mont
—
Saint-Martin-de-Vaulserre
—
Saint-Maximin
—
Saint-Nicolas-de-Macherin
—
Saint-Ondras
—
Crêts en Belledonne
—
Saint-Pierre-de-Chartreuse
—
Saint-Pierre-d’Entremont
—
Saint-Savin
—
Saint-Sorlin-de-Morestel
—
Saint-Sulpice-des-Rivoires
—
Saint-Victor-de-Cessieu
—
Saint-Victor-de-Morestel
—
Saint-Vincent-de-Mercuze
—
Salagnon
—
Sérézin-de-la-Tour
—
Sermérieu
—
Siccieu-Saint-Julien-et-Carisieu
—
Soleymieu
—
Theys
—
Torchefelon
—
La Tour-du-Pin
—
Le Touvet
—
Trept
—
Valencogne
—
Vasselin
—
Velanne
—
Vénérieu
—
Vernas
—
Vertrieu
—
Vézeronce-Curtin
—
Vignieu
—
Villemoirieu
—
Val-de-Virieu
—
Voiron
—
Voissant

SAVOIE Department
—
Aiguebelette-le-Lac
—
Grand-Aigueblanche
—
Les Allues
—
Apremont
—
Arbin
—
Argentine
—
Arvillard
—
Attignat-Oncin
—
Les Avanchers-Valmorel
—
Avressieux
—
Ayn
—
Barberaz
—
Barby
—
Bassens
—
La Bauche
—
Belmont-Tramonet
—
Betton-Bettonet
—
Bourget-en-Huile
—
Bozel
—
Brides-les-Bains
—
La Bridoire
—
Challes-les-Eaux
—
Chambéry
—
La Chambre
—
Chamoux-sur-Gelon
—
Champagneux
—
Champagny-en-Vanoise
—
Champ-Laurent
—
La Chapelle
—
La Chapelle-Blanche
—
Châteauneuf
—
La Chavanne
—
Les Chavannes-en-Maurienne
—
Chignin
—
Cognin
—
Coise-Saint-Jean-Pied-Gauthier
—
Corbel
—
La Croix-de-la-Rochette
—
Cruet
—
Curienne
—
Détrier
—
Domessin
—
Dullin
—
Les Échelles
—
Entremont-le-Vieux
—
Épierre
—
Feissons-sur-Salins
—
Gerbaix
—
Hautecour
—
Hauteville
—
La Tour-en-Maurienne
—
Jacob-Bellecombette
—
Jarrier
—
Laissaud
—
Landry
—
Lépin-le-Lac
—
Porte-de-Savoie
—
Marcieux
—
Les Mollettes
—
Montagnole
—
Montagny
—
Montendry
—
Montgilbert
—
Montmélian
—
Montvalezan
—
Montvernier
—
Moûtiers
—
Myans
—
Nances
—
Notre-Dame-du-Cruet
—
Notre-Dame-du-Pré
—
Novalaise
—
Peisey-Nancroix
—
Planaise
—
Planay
—
Le Pont-de-Beauvoisin
—
Le Pontet
—
Pralognan-la-Vanoise
—
Presle
—
Puygros
—
La Ravoire
—
Rochefort
—
Valgelon-La Rochette
—
Rotherens
—
Saint-Alban-de-Montbel
—
Saint-Alban-d’Hurtières
—
Saint-Alban-des-Villards
—
Saint-Alban-Leysse
—
Saint-Avre
—
Saint-Baldoph
—
Saint-Béron
—
Courchevel
—
Saint-Cassin
—
Saint-Christophe
—
Saint-Colomban-des-Villards
—
Saint-Étienne-de-Cuines
—
Sainte-Foy-Tarentaise
—
Saint-Franc
—
Saint François Longchamp
—
Saint-Genix-les-Villages
—
Saint-Georges-d’Hurtières
—
Sainte-Hélène-du-Lac
—
Saint-Jean-d’Arvey
—
Saint-Jean-de-Couz
—
Saint-Jean-de-la-Porte
—
Saint-Jean-de-Maurienne
—
Saint-Jeoire-Prieuré
—
Saint-Julien-Mont-Denis
—
Saint-Léger
—
Saint-Marcel
—
Sainte-Marie-d’Alvey
—
Sainte-Marie-de-Cuines
—
Les Belleville
—
Saint-Martin-sur-la-Chambre
—
Saint-Pierre-d’Alvey
—
Saint-Pierre-de-Belleville
—
Saint-Pierre-d’Entremont
—
Saint-Pierre-de-Genebroz
—
Saint-Pierre-de-Soucy
—
Saint-Rémy-de-Maurienne
—
Saint-Sulpice
—
Saint-Thibaud-de-Couz
—
Salins-Fontaine
—
Séez
—
La Table
—
Thoiry
—
La Thuile
—
La Trinité
—
Verel-de-Montbel
—
Le Verneil
—
Villard-d’Héry
—
Villard-Léger
—
Villard-Sallet
—
Villaroger
—
Villaroux
—
Vimines
—
Val-d’Isère
—
Tignes

HAUTE-SAVOIE Department
—
Allonzier-la-Caille
—
Amancy
—
Ambilly
—
Andilly
—
Annemasse
—
Arâches-la-Frasse
—
Arbusigny
—
Archamps
—
Arenthon
—
Arthaz-Pont-Notre-Dame
—
Ayse
—
Beaumont
—
Bellevaux
—
Boëge
—
Bogève
—
Bonne
—
Bonneville
—
Bossey
—
Brizon
—
Cercier
—
Cernex
—
Challonges
—
Chamonix-Mont-Blanc
—
La Chapelle-Rambaud
—
Charvonnex
—
Châtillon-sur-Cluses
—
Chaumont
—
Chavannaz
—
Chêne-en-Semine
—
Chênex
—
Chessenaz
—
Chevrier
—
Clarafond-Arcine
—
Cluses
—
Collonges-sous-Salève
—
Contamine-Sarzin
—
Contamine-sur-Arve
—
Copponex
—
Cornier
—
La Côte-d’Arbroz
—
Cranves-Sales
—
Cruseilles
—
Dingy-en-Vuache
—
Éloise
—
Essert-Romand
—
Etaux
—
Étrembières
—
Faucigny
—
Feigères
—
Fillinges
—
Franclens
—
Frangy
—
Gaillard
—
Les Gets
—
Groisy
—
Habère-Lullin
—
Les Houches
—
Jonzier-Épagny
—
Juvigny
—
Lucinges
—
Magland
—
Marcellaz
—
Marignier
—
Marlioz
—
Marnaz
—
Mégevette
—
Menthonnex-en-Bornes
—
Mieussy
—
Minzier
—
Monnetier-Mornex
—
Montriond
—
Mont-Saxonnex
—
Morillon
—
Morzine
—
La Muraz
—
Musièges
—
Nancy-sur-Cluses
—
Nangy
—
Nâves-Parmelan
—
Neydens
—
Onnion
—
Passy
—
Peillonnex
—
Pers-Jussy
—
Glières-Val-de-Borne
—
Présilly
—
Reignier-Ésery
—
Le Reposoir
—
La Rivière-Enverse
—
La Roche-sur-Foron
—
Saint-André-de-Boëge
—
Saint-Blaise
—
Saint-Germain-sur-Rhône
—
Saint-Jean-d’Aulps
—
Saint-Jean-de-Tholome
—
Saint-Jeoire
—
Saint-Julien-en-Genevois
—
Saint-Laurent
—
Saint-Pierre-en-Faucigny
—
Saint-Sigismond
—
Saint-Sixt
—
Samoëns
—
Le Sappey
—
Savigny
—
Scientrier
—
Scionzier
—
Servoz
—
Seytroux
—
Sixt-Fer-à-Cheval
—
Taninges
—
Thyez
—
Fillière
—
La Tour
—
Usinens
—
Valleiry
—
Vallorcine
—
Vanzy
—
Verchaix
—
Vers
—
Vétraz-Monthoux
—
Villard
—
Villaz
—
Ville-en-Sallaz
—
Ville-la-Grand
—
Villy-le-Bouveret
—
Villy-le-Pelloux
—
Viry
—
Viuz-en-Sallaz
—
Vougy
—
Vovray-en-Bornes
—
Vulbens
30.09.2025
ANNEX II
Part A: Vaccination zone II
The municipalities of the departments listed in Annex I until 18.10.2025. Part B: Vaccination zone I
The municipalities of the departments listed in Annex I as of 19.10.2025 until last day of the recovery period, chosen by France, referred to in Part 4 of Annex IX to Delegated Regulation (EU) 2023/361
’.

Commission Implementing Decision (EU) 2025/1761 of 22 August 2025 amending Implementing Decision (EU) 2025/1160 concerning certain emergency measures relating to sheep pox and goat pox in Bulgaria (notified under document C(2025) 5808)

January 13, 2026
Official Journalof the European Union ENL series
2025/1761 27.8.2025
(1) Sheep pox and goat pox is an infectious viral disease affecting caprine and ovine animals and can have a severe impact on the concerned animal population and the profitability of farming causing disturbance to movements of consignments of those animals and products thereof within the Union and exports to third countries.
(2) In the event of an outbreak of sheep pox and goat pox in caprine or ovine animals, there is a serious risk of the spread of that disease to other establishments of caprine or ovine animals.
(3) Commission Delegated Regulation (EU) 2020/687(2)supplements the rules for the control of the listed diseases referred to in Article 9(1), points (a), (b) and (c), of Regulation (EU) 2016/429, and defined as category A, B and C diseases in Commission Implementing Regulation (EU) 2018/1882(3). In particular, Articles 21 and 22 of Delegated Regulation (EU) 2020/687 provide for the establishment of a restricted zone in the event of an outbreak of a category A disease, including sheep pox and goat pox, and for certain measures to be applied therein. In addition, Article 21(1) of that Delegated Regulation provides that the restricted zone is to comprise a protection zone, a surveillance zone, and, if necessary, further restricted zone around or adjacent to the protection and surveillance zones.
(4) Commission Implementing Decision (EU) 2025/1160(4)was adopted following outbreaks of sheep pox and goat pox in Bulgaria, and it lays down emergency measures to be taken by that Member State. More particularly, Implementing Decision (EU) 2025/1160 provides that the protection, surveillance, and further restricted zones to be established by Bulgaria, in accordance with Article 21 of Delegated Regulation (EU) 2020/687, are to comprise at least the areas listed in Parts A and B of Annex I to that Implementing Decision.
(5) Since the last amendment of Implementing Decision (EU) 2025/1160, Bulgaria has notified the Commission of forty additional outbreaks of sheep pox and goat pox in establishments where ovine animals were kept, located in the regions of Plovdiv, Stara Zagora, and Haskovo, within the already established restricted zones, as well as in the region of Kardzhali, outside the already established restricted zones listed in Annex I to that Implementing Decision.
(6) In the current epidemiological situation, there is a high risk for the further spread of sheep pox and goat pox, in particular due to the fact that, according to the information provided by Bulgaria, there are numerous new outbreaks in the already affected regions, mostly in the region of Plovdiv, suggesting that the disease continues to circulate. There is also the new outbreak located outside the established restricted zones set out in Annex I to Implementing Decision (EU) 2025/1160, in the region of Kardzhali, suggesting that the disease has moved outside the restricted areas, despite the disease control measures already in place.
(7) Therefore, the restricted zone, comprising protection, surveillance and further restricted zones in Bulgaria, set out in Annex I to Implementing Decision (EU) 2025/1160 should be adjusted, both spatially and temporally, in order to prevent the further spread of sheep pox and goat pox in the territory of Bulgaria and to the rest of the Union.
(8) The size of the protection, surveillance and further restricted zones, and the duration of the measures to be applied therein, is based on the criteria set out in Article 64(1) of Regulation (EU) 2016/429, as well as on the rules laid down in Delegated Regulation (EU) 2020/687. The criteria applied for the choice of the size of the protection, surveillance, and further restricted zones, as well as of the duration of the measures to be applied therein, include a consideration of not only the epidemiological situation as regards sheep pox and goat pox in the areas affected by that disease, but also of the overall epidemiological situation of sheep pox and goat pox in the entire territory of Bulgaria, and of the level of risk for the further spread of the disease. For the determination of the duration of the measures the international standards of the Terrestrial Animal Health Code of the World Organisation for Animal Health(5)have also been taken into account.
(9) In view of the epidemiological situation, it is also necessary to prolong the duration of the additional measures applicable in the restricted zones, namely the prohibition of movements of sheep and goats from the protection and surveillance zones to any destinations located outside the external perimeter of the immediately surrounding further restricted zones, and from each further restricted zone to a destination located outside the external perimeter of this further restricted zone, including to destinations located in different further restricted zones, as set out in Part B of Annex I as well as the prohibition of movements of animals originating from those areas of Bulgaria that are not subject to restrictions due to sheep pox and goat pox to any of the areas within the external perimeter of the further restricted zones.
(10) In view of the epidemiological situation, it is also necessary to amend the areas set out in Annex II to Implementing Decision (EU) 2025/1160, in the territory of Bulgaria where further emergency measures like those applicable to further restricted zones, as provided for in Delegated Regulation (EU) 2020/687, as well as the prohibition on movements of sheep and goats to a destination located outside the external perimeters of those areas should apply, after the lifting of the protection, surveillance and further restricted zones, as well as the duration of such measures.
(11) In addition, in order to minimise the risk of the further spread of the disease, it is also necessary to prolong the prohibition on the movements of goats and sheep from the territory of Bulgaria to a destination located outside Bulgaria.
(12) Given the urgency of the epidemiological situation in the Union as regards the spread of sheep pox and goat pox, and the need to prevent that disease from spreading from the affected establishments in Bulgaria to other parts of that Member State or to other Member States, the amendments to be made to Implementing Decision (EU) 2025/1160, by this Decision should take effect as soon as possible..
(13) The measures provided for in this Decision are in accordance with the opinion of the Standing Committee on Plants, Animals, Food and Feed,
(1) in Article 2, point (c), the date ‘31 October 2025’ is replaced by ‘30 November 2025’;
(2) Annex I and Annex II are replaced by the text set out in the Annex to this Decision.
Region and ADIS reference number of the outbreak Areas established as protection and surveillance zones, part of the restricted zone in Bulgaria referred to in Article 1 Date until applicable
Region of PlovdivBG-CAPRIPOX-2025-00008BG-CAPRIPOX-2025-00009BG-CAPRIPOX-2025-00010BG-CAPRIPOX-2025-00011BG-CAPRIPOX-2025-00012BG-CAPRIPOX-2025-00013BG-CAPRIPOX-2025-00014BG-CAPRIPOX-2025-00015BG-CAPRIPOX-2025-00016BG-CAPRIPOX-2025-00017BG-CAPRIPOX-2025-00018BG-CAPRIPOX-2025-00021BG-CAPRIPOX-2025-00022BG-CAPRIPOX-2025-00023BG-CAPRIPOX-2025-00024BG-CAPRIPOX-2025-00025BG-CAPRIPOX-2025-00026BG-CAPRIPOX-2025-00027BG-CAPRIPOX-2025-00028BG-CAPRIPOX-2025-00029BG-CAPRIPOX-2025-00030BG-CAPRIPOX-2025-00031BG-CAPRIPOX-2025-00032BG-CAPRIPOX-2025-00033BG-CAPRIPOX-2025-00034BG-CAPRIPOX-2025-00035BG-CAPRIPOX-2025-00036BG-CAPRIPOX-2025-00039BG-CAPRIPOX-2025-00040BG-CAPRIPOX-2025-00041BG-CAPRIPOX-2025-00042BG-CAPRIPOX-2025-00043BG-CAPRIPOX-2025-00044BG-CAPRIPOX-2025-00045BG-CAPRIPOX-2025-00046BG-CAPRIPOX-2025-00047BG-CAPRIPOX-2025-00048BG-CAPRIPOX-2025-00049BG-CAPRIPOX-2025-00050BG-CAPRIPOX-2025-00051BG-CAPRIPOX-2025-00052BG-CAPRIPOX-2025-00053BG-CAPRIPOX-2025-00054BG-CAPRIPOX-2025-00055BG-CAPRIPOX-2025-00056BG-CAPRIPOX-2025-00057BG-CAPRIPOX-2025-00058BG-CAPRIPOX-2025-00059BG-CAPRIPOX-2025-00060BG-CAPRIPOX-2025-00061BG-CAPRIPOX-2025-00062BG-CAPRIPOX-2025-00063BG-CAPRIPOX-2025-00064BG-CAPRIPOX-2025-00065BG-CAPRIPOX-2025-00067BG-CAPRIPOX-2025-00068BG-CAPRIPOX-2025-00069BG-CAPRIPOX-2025-00070BG-CAPRIPOX-2025-00071BG-CAPRIPOX-2025-00072BG-CAPRIPOX-2025-00073BG-CAPRIPOX-2025-00074BG-CAPRIPOX-2025-00075BG-CAPRIPOX-2025-00076BG-CAPRIPOX-2025-00077BG-CAPRIPOX-2025-00078BG-CAPRIPOX-2025-00079BG-CAPRIPOX-2025-00080BG-CAPRIPOX-2025-00081BG-CAPRIPOX-2025-00082BG-CAPRIPOX-2025-00083BG-CAPRIPOX-2025-00084BG-CAPRIPOX-2025-00085BG-CAPRIPOX-2025-00086BG-CAPRIPOX-2025-00087BG-CAPRIPOX-2025-00088BG-CAPRIPOX-2025-00089BG-CAPRIPOX-2025-00090BG-CAPRIPOX-2025-00091BG-CAPRIPOX-2025-00092BG-CAPRIPOX-2025-00093BG-CAPRIPOX-2025-00094BG-CAPRIPOX-2025-00095BG-CAPRIPOX-2025-00096BG-CAPRIPOX-2025-00097BG-CAPRIPOX-2025-00098BG-CAPRIPOX-2025-00099BG-CAPRIPOX-2025-00102BG-CAPRIPOX-2025-00103BG-CAPRIPOX-2025-00104BG-CAPRIPOX-2025-00105BG-CAPRIPOX-2025-00106BG-CAPRIPOX-2025-00107BG-CAPRIPOX-2025-00108BG-CAPRIPOX-2025-00110BG-CAPRIPOX-2025-00111BG-CAPRIPOX-2025-00113BG-CAPRIPOX-2025-00114BG-CAPRIPOX-2025-00115 Protection zone:Those parts of the regions of Plovdiv, Haskovo, and Stara Zagora contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat.42.1944, Long. 24.8528 (2025/8), Lat. 42.1823, Long. 24.8337 (2025/9), Lat. 42.1889, Long. 24.8137 (2025/10), Lat. 42.1862, Long. 24.8316 (2025/11), Lat. 42.1856, Long. 24.8456 (2025/12), Lat. 42.2312, Long. 24.9357 (2025/13), Lat. 42.2308, Long. 24.9368 (2025/14), Lat. 42.18222, Long. 24.86694 (2025/15), Lat. 42.1873, Long. 24.8456 (2025/16), Lat. 42.19416, Long. 24.78666 (2025/17), Lat. 42.06, Long. 25.1658 (2025/18) Lat. 42.19416, Long. 24.78666 (2025/17), Lat. 42.23, Long. 24.9391 (2025/21), Lat. 42.231703, Long. 24.938912 (2025/22), Lat. 42.2306, Long. 24.9369 (2025/23), Lat. 42.2319, Long. 24.9362 (2025/24), Lat. 42.19416, Long. 24.78666 (2025/25), Lat. 42.2051, Long. 24.87314 (2025/26), Lat. 42.2069, Long. 24.78666 (2025/27), Lat. 42.233, Long. 24.9405 (2025/28), Lat. 42.2316, Long. 24.94214 (2025/29), Lat. 42.2602, Long. 24.8751 (2025/30), Lat. 42.20922, Long. 24.95578 (2025/31), Lat. 42.2089, Long. 24.9508 (2025/32), Lat. 42.2092, Long. 24.9525 (2025/33), Lat. 42.1886, Long. 24.9265 (2025/34), Lat. 42.1886, Long. 24.9265 (2025/35), Lat. 42.1925, Long. 24.9329 (2025/36), Lat. 42.6871, Long. 25.3287 (2025/37), Lat. 42.6871, Long. 25.3287 (2025/38), Lat. 42.200845, Long. 24.790453 (2025/39), Lat. 42.2463, Long. 24.7957 (2025/40), Lat. 42.202878, Long 24.690226 (2025/41), Lat. 42.2829, Long. 24.9637 (2025/42), Lat. 42.2363, Long. 24.8297 (2025/43), Lat. 42.1872, Long. 24.9242 (2025/44), Lat. 42.2308, Long 25.0438 (2025/45), Lat. 42.2401, Long. 25.0556 (2025/46), Lat. 42.2037, Long. 25.0513 (2025/47), Lat. 42.1959, Long. 25.0566 (2025/48), Lat. 42.2977, Long. 24.9179 (2025/49), Lat. 42.1369, Long. 24.9082 (2025/50), Lat. 42.1481, Long. 24.9055 (2025/51), Lat. 42.2333, Long. 24.8135 (2025/52), Lat. 42.3188, Long. 24.8888 (2025/53), Lat. 42.1903, Long. 25.034 (2025/54), Lat. 42.19416, Long. 24.78666 (2025/55), Lat. 42.2828, Long. 24.7528 (2025/56), Lat. 42.1061, Long. 24.8812 (2025/57), Lat. 42.2116, Long. 24.9584 (2025/58), Lat. 42.2559, Long. 24.6802 (2025/59), Lat. 41.9946, Long. 25.2278 (2025/60), Lat. 42.0248, Long. 25.096 (2025/61), Lat. 42.0341, Long. 25.1186 (2025/62), Lat. 42.0973, Long. 24.8738 (2025/63), Lat. 42.2008, Long. 25.049 (2025/64), Lat. 42.21546, Long. 24.62801 (2025/65), Lat. 42.3695, Long. 24.7158 (2025/67), Lat. 42.2753, Long. 25.1217 (2025/68), Lat. 42.2883, Long. 24.6303 (2025/69), Lat. 42.3705, Long. 24.725 (2025/70), Lat. 42.371, Long. 24.7229 (2025/71), Lat. 42.3288, Long. 24.6784 (2025/72), Lat. 42.3263, Long. 24.6724 (2025/73), Lat. 42.1929, Long. 24.635 (2025/74), Lat. 42.0567, Long. 24.7664 (2025/75), Lat. 42.1295, Long. 25.04 (2025/76), Lat. 42.3826, Long. 24.7806 (2025/77), Lat. 42.0146, Long. 25.2956 (2025/78), Lat. 41.9258, Long. 25.1422 (2025/79), Lat. 41.938, Long. 25.129 (2025/80), Lat. 41.9261, Long. 25.1294 (2025/81), Lat. 41.8911, Long. 25.1336 (2025/82), Lat. 41.9271, Long. 24.7806 (2025/83), Lat. 42.3063, Long. 24.5243 (2025/84), Lat. 42.2744, Long. 24.5549 (2025/85), Lat. 42.2637, Long. 24.5568 (2025/86), Lat. 42.2622, Long. 24.5603 (2025/87), Lat. 41.9443, Long. 25.2481 (2025/88), Lat. 42.603, Long. 24.8956 (2025/89), Lat. 41.9423, Long. 25.2434 (2025/90), Lat. 41.9449, Long. 25.2471 (2025/91), Lat. 42.267, Long. 24.554 (2025/92), Lat. 42.2729, Long. 24.5329 (2025/93), Lat. 42.2848, Long. 24.5428 (2025/94), Lat. 42.2757, Long. 24.5373 (2025/95), Lat. 42.2288, Long. 24.6255 (2025/96), Lat. 41.9456, Long. 25.2427 (2025/97), Lat. 41.9675, Long. 25.0319 (2025/98), Lat. 42.2311, Long. 24.8343 (2025/99), Lat. 42.2451, Long. 24.819 (2025/102), Lat. 42.1765, Long. 24.6267 (2025/103), Lat. 42.602, Long. 24.89 (2025/104), Lat. 42.6018, Long. 24.88 (2025/105), Lat. 42.6018, Long. 24.88 (2025/106), Lat. 42.6166, Long. 24.9121 (2025/107), Lat. 42.3469, Long. 24.667 (2025/108), Lat. 42.2458, Long. 24.8194 (2025/110), Lat. 42.61821, Long. 24.90195 (2025/111), Lat. 42.1391, Long. 25.0591 (2025/113), Lat. 42.3509, Long. 24.6217 (2025/114), Lat. 42.0512, Long. 25.184 (2025/115). 10.9.2025
Surveillance zone:Those parts of the regions of Plovdiv, Lovech, Stara Zagora, Haskovo and Pazardzhik contained within a circle of a radius of 15 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 42.1944, Long. 24.8528 (2025/8), Lat. 42.1823, Long. 24.8337 (2025/9), Lat. 42.1889, Long. 24.8137 (2025/10), Lat. 42.1862, Long. 24.8316 (2025/11), Lat. 42.1856, Long. 24.8456 (2025/12), Lat. 42.2312, Long. 24.9357 (2025/13), Lat. 42.2308, Long. 24.9368 (2025/14), Lat. 42.18222, Long. 24.86694 (2025/15), Lat. 42.1873, Long. 24.8456 (2025/16), Lat. 42.19416, Long. 24.78666 (2025/17), Lat. 42.06, Long. 25.1658 (2025/18), Lat. 42.19416, Long. 24.78666 (2025/17), Lat. 42.23, Long. 24.9391 (2025/21), Lat. 42.231703, Long. 24.938912 (2025/22), Lat. 42.2306, Long. 24.9369 (2025/23), Lat. 42.2319, Long. 24.9362 (2025/24), Lat. 42.19416, Long. 24.78666 (2025/25), Lat. 42.2051, Long. 24.87314 (2025/26), Lat. 42.2069, Long. 24.78666 (2025/27), Lat. 42.233, Long. 24.9405 (2025/28), Lat. 42.2316, Long. 24.94214 (2025/29), Lat. 42.2602, Long. 24.8751 (2025/30), Lat. 42.20922, Long. 24.95578 (2025/31), Lat. 42.2089, Long. 24.9508 (2025/32), Lat. 42.2092, Long. 24.9525 (2025/33), Lat. 42.1886, Long. 24.9265 (2025/34), Lat. 42.1886, Long. 24.9265 (2025/35), Lat. 42.1925, Long. 24.9329 (2025/36), Lat. 42.200845, Long. 24.790453 (2025/39), Lat. 42.2463, Long. 24.7957 (2025/40), Lat. 42.202878, Long. 24.690226 (2025/41), Lat. 42.2829, Long. 24.9637 (2025/42), Lat. 42.2363, Long. 24.8297 (2025/43), Lat. 42.1872, Long. 24.9242 (2025/44), Lat. 42.2308, Long 25.0438 (2025/45), Lat. 42.2401, Long. 25.0556 (2025/46), Lat. 42.2037, Long. 25.0513 (2025/47), Lat. 42.1959, Long. 25.0566 (2025/48), Lat. 42.2977, Long 24.9179 (2025/49), Lat. 42.1369, Long. 24.9082 (2025/50), Lat. 42.1481, Long. 24.9055 (2025/51), Lat. 42.2333, Long. 24.8135 (2025/52), Lat. 42.3188, Long 24.8888 (2025/53), Lat. 42.1903, Long. 25.034 (2025/54), Lat. 42.19416, Long. 24.78666 (2025/55), Lat. 42.2828, Long. 24.7528 (2025/56), Lat. 42.1061, Long. 24.8812 (2025/57), Lat. 42.2116, Long. 24.9584 (2025/58), Lat. 42.2559, Long. 24.6802 (2025/59), Lat. 41.9946, Long. 25.2278 (2025/60), Lat. 42.0248, Long. 25.096 (2025/61), Lat. 42.0341, Long. 25.1186 (2025/62), Lat. 42.0973, Long. 24.8738 (2025/63), Lat. 42.2008, Long. 25.049 (2025/64), Lat. 42.21546, Long. 24.62801 (2025/65), Lat. 42.3695, Long. 24.7158 (2025/67), Lat. 42.2753, Long. 25.1217 (2025/68), Lat. 42.2883, Long. 24.6303 (2025/69), Lat. 42.3705, Long. 24.725 (2025/70), Lat. 42.371, Long. 24.7229 (2025/71), Lat. 42.3288, Long. 24.6784 (2025/72), Lat. 42.3263, Long. 24.6724 (2025/73), Lat. 42.1929, Long. 24.635 (2025/74), Lat. 42.0567, Long. 24.7664 (2025/75), Lat. 42.1295, Long. 25.04 (2025/76), Lat. 42.3826, Long. 24.7806 (2025/77) Lat. 42.0146, Long. 25.2956 (2025/78), Lat. 41.9258, Long. 25.1422 (2025/79), Lat. 41.938, Long. 25.129 (2025/80), Lat. 41.9261, Long. 25.1294 (2025/81), Lat. 41.8911, Long. 25.1336 (2025/82), Lat. 41.9271, Long. 24.7806 (2025/83), Lat. 42.3063, Long. 24.5243 (2025/84), Lat. 42.2744, Long. 24.5549 (2025/85), Lat. 42.2637, Long. 24.5568 (2025/86), Lat. 42.2622, Long. 24.5603 (2025/87), Lat. 41.9443, Long. 25.2481 (2025/88), Lat. 42.603, Long. 24.8956 (2025/89), Lat. 41.9423, Long. 25.2434 (2025/90), Lat. 41.9449, Long. 25.2471 (2025/91), Lat. 42.267, Long. 24.554 (2025/92), Lat. 42.2729, Long. 24.5329 (2025/93), Lat. 42.2848, Long. 24.5428 (2025/94), Lat. 42.2757, Long. 24.5373 (2025/95), Lat. 42.2288, Long. 24.6255 (2025/96), Lat. 41.9456, Long. 25.2427 (2025/97), Lat. 41.9675, Long. 25.0319 (2025/98), Lat. 42.2311, Long. 24.8343 (2025/99), Lat. 42.2451, Long. 24.819 (2025/102), Lat. 42.1765, Long. 24.6267 (2025/103), Lat. 42.602, Long. 24.89 (2025/104), Lat. 42.6018, Long. 24.88 (2025/105), Lat. 42.6018, Long. 24.88 (2025/106), Lat. 42.6166, Long. 24.9121 (2025/107), Lat. 42.3469, Long. 24.667 (2025/108), Lat. 42.2458, Long. 24.8194 (2025/110), Lat. 42.61821, Long. 24.90195 (2025/111), Lat. 42.1391, Long. 25.0591 (2025/113), Lat. 42.3509, Long. 24.6217 (2025/114), Lat. 42.0512, Long. 25.184 (2025/115) excluding the areas contained in the protection zone. 25.9.2025
Surveillance zone:Those parts of the regions of Plovdiv, Haskovo and Stara Zagora, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 42.1944, Long. 24.8528 (2025/8), Lat. 42.1823, Long. 24.8337 (2025/9), Lat.42.1889, Long. 24.8137(2025/10), Lat. 42.1862, Long. 24.8316 (2025/11), Lat. 42.1856, Long. 24.8456 (2025/12), Lat. 42.2312, Long. 24.9357 (2025/13), Lat. 42.2308, Long. 24.9368 (2025/14), Lat. 42.18222, Long. 24.86694 (2025/15), Lat. 42.1873, Long. 24.8456 (2025/16), Lat. 42.19416, Long. 24.78666 (2025/17), Lat. 42.06, Long. 25.1658 (2025/18), Lat. 42.19416, Long. 24.78666 (2025/17), Lat. 42.23, Long. 24.9391 (2025/21), Lat. 42.231703, Long. 24.938912 (2025/22), Lat. 42.2306, Long. 24.9369 (2025/23), Lat. 42.2319, Long. 24.9362 (2025/24), Lat. 42.19416, Long. 24.78666 (2025/25), Lat. 42.2051, Long. 24.87314 (2025/26), Lat. 42.2069, Long. 24.78666 (2025/27), Lat. 42.233, Long. 24.9405 (2025/28), Lat. 42.2316, Long. 24.94214 (2025/29), Lat. 42.2602, Long. 24.8751 (2025/30), Lat. 42.20922, Long. 24.95578 (2025/31), Lat. 42.2089, Long. 24.9508 (2025/32), Lat. 42.2092, Long. 24.9525 (2025/33), Lat. 42.1886, Long. 24.9265 (2025/34), Lat. 42.1886, Long. 24.9265 (2025/35), Lat. 42.1925, Long. 24.9329 (2025/36), Lat. 42.6871, Long. 25.3287 (2025/37), Lat. 42.6871, Long. 25.3287 (2025/38), Lat. 42.200845, Long. 24.790453 (2025/39), Lat. 42.2463, Long. 24.7957 (2025/40), Lat. 42.202878, Long 24.690226 (2025/41), Lat. 42.2829, Long. 24.9637 (2025/42), Lat. 42.2363, Long. 24.8297 (2025/43), Lat. 42.1872, Long. 24.9242 (2025/44), Lat. 42.2308, Long 25.0438 (2025/45), Lat. 42.2401, Long. 25.0556 (2025/46), Lat. 42.2037, Long. 25.0513 (2025/47), Lat. 42.1959, Long. 25.0566 (2025/48), Lat. 42.2977, Long 24.9179 (2025/49), Lat. 42.1369, Long. 24.9082 (2025/50), Lat. 42.1481, Long. 24.9055 (2025/51), Lat. 42.2333, Long. 24.8135 (2025/52), Lat. 42.3188, Long 24.8888 (2025/53), Lat. 42.1903, Long. 25.034 (2025/54), Lat. 42.19416, Long. 24.78666 (2025/55), Lat. 42.2828, Long. 24.7528 (2025/56), Lat. 42.1061, Long. 24.8812 (2025/57), Lat. 42.2116, Long. 24.9584 (2025/58), Lat. 42.2559, Long. 24.6802 (2025/59), Lat. 41.9946, Long. 25.2278 (2025/60), Lat. 42.0248, Long. 25.096 (2025/61), Lat. 42.0341, Long. 25.1186 (2025/62), Lat. 42.0973, Long. 24.8738 (2025/63), Lat. 42.2008, Long. 25.049 (2025/64), Lat. 42.21546, Long. 24.62801 (2025/65), Lat. 42.3695, Long. 24.7158 (2025/67), Lat. 42.2753, Long. 25.1217 (2025/68), Lat. 42.2883, Long. 24.6303 (2025/69), Lat. 42.3705, Long. 24.725 (2025/70), Lat. 42.371, Long. 24.7229 (2025/71), Lat. 42.3288, Long. 24.6784 (2025/72), Lat. 42.3263, Long. 24.6724 (2025/73), Lat. 42.1929, Long. 24.635 (2025/74), Lat. 42.0567, Long. 24.7664 (2025/75), Lat. 42.1295, Long. 25.04 (2025/76), Lat. 42.3826, Long. 24.7806 (2025/77), Lat. 42.0146, Long. 25.2956 (2025/78), Lat. 41.9258, Long. 25.1422 (2025/79), Lat. 41.938, Long. 25.129 (2025/80), Lat. 41.9261, Long. 25.1294 (2025/81), Lat. 41.8911, Long. 25.1336 (2025/82), Lat. 41.9271, Long. 24.7806 (2025/83), Lat. 42.3063, Long. 24.5243 (2025/84), Lat. 42.2744, Long. 24.5549 (2025/85), Lat. 42.2637, Long. 24.5568 (2025/86), Lat. 42.2622, Long. 24.5603 (2025/87), Lat. 41.9443, Long. 25.2481 (2025/88), Lat. 42.603, Long. 24.8956 (2025/89), Lat. 41.9423, Long. 25.2434 (2025/90), Lat. 41.9449, Long. 25.2471 (2025/91), Lat. 42.267, Long. 24.554 (2025/92), Lat. 42.2729, Long. 24.5329 (2025/93), Lat. 42.2848, Long. 24.5428 (2025/94), Lat. 42.2757, Long. 24.5373 (2025/95), Lat. 42.2288, Long. 24.6255 (2025/96), Lat. 41.9456, Long. 25.2427 (2025/97), Lat. 41.9675, Long. 25.0319 (2025/98), Lat. 42.2311, Long. 24.8343 (2025/99), Lat. 42.2451, Long. 24.819 (2025/102), Lat. 42.1765, Long. 24.6267 (2025/103), Lat. 42.602, Long. 24.89 (2025/104), Lat. 42.6018, Long. 24.88 (2025/105), Lat. 42.6018, Long. 24.88 (2025/106), Lat. 42.6166, Long. 24.9121 (2025/107), Lat. 42.3469, Long. 24.667 (2025/108), Lat. 42.2458, Long. 24.8194 (2025/110), Lat. 42.61821, Long. 24.90195 (2025/111), Lat. 42.1391, Long. 25.0591 (2025/113), Lat. 42.3509, Long. 24.6217 (2025/114), Lat. 42.0512, Long. 25.184 (2025/115). 11.9.2025 – 25.9.2025
Region of Stara ZagoraBG-CAPRIPOX-2025-00037BG-CAPRIPOX-2025-00038BG-CAPRIPOX-2025-00112BG-CAPRIPOX-2025-00117 Protection zone:Those parts of the region of Stara Zagora, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 42.6871, Long. 25.3287 (2025/37), Lat. 42.6871, Long. 25.3287 (2025/38), Lat. 42.6538, Long. 25.2158 (2025/112), Lat. 42.6504, Long. 25.2121 (2025/117). 11.9.2025
Surveillance zone:Those parts of the regions of Stara Zagora and Gabrovo contained within a circle of a radius of 15 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 42.6871, Long. 25.3287 (2025/37), Lat. 42.6871, Long. 25.3287 (2025/38), Lat. 42.6538, Long. 25.2158 (2025/112), Lat. 42.6504, Long. 25.2121 (2025/117) excluding the areas contained in the protection zone. 26.9.2025
Surveillance zone:Those parts of the region of Stara Zagora, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 42.6871, Long. 25.3287 (2025/37), Lat. 42.6871, Long. 25.3287 (2025/38), Lat. 42.6538, Long. 25.2158 (2025/112), Lat. 42.6504, Long. 25.2121 (2025/117). 12.9.2025-26.9.2025
Region of HaskovoBG-CAPRIPOX-2025-00066BG-CAPRIPOX-2025-00100BG-CAPRIPOX-2025-00101BG-CAPRIPOX-2025-00109 Protection zone:Those parts of the region of Haskovo, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 41.7227, Long. 26.325 (2025/66). 4.9.2025
Surveillance zone:Those parts of the region of Haskovo, contained within a circle of a radius of 15 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 41.7227, Long. 26.325 (2025/66), Lat. 41.7531, Long. 26.1991 (2025/100) Lat. 41.7577, Long. 26.1977 (2025/101), Lat. 41.77, Long. 26.27 (2025/109), excluding the areas contained in the protection zone. 19.9.2025
Surveillance zone:Those parts of the region of Haskovo, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 41.7227, Long. 26.325 (2025/66) Lat. 41.7531, Long. 26.1991 (2025/100), Lat. 41.7577, Long. 26.1977 (2025/101), Lat. 41.77, Long. 26.27 (2025/109). 5.9.2025 -19.9.2025
Region of KardzhaliBG-CAPRIPOX-2025-000116 Protection zone:Those parts of the regions of Kardzhali contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 41.4399, Long. 25.7723 (2025/116). 11.9.2025
Surveillance zone:Those parts of the region of Kardzhali and Haskovo, contained within a circle of a radius of 15 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 41.4399, Long. 25.7723 (2025/116), excluding the areas contained in the protection zone. 26.9.2025
Surveillance zone:Those parts of the region of Kardzhali, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 41.4399, Long. 25.7723 (2025/116). 12.9.2025-26.9.2025
Further restricted zone Region Areas included in the further restricted zones established in Bulgaria as referred to in Article 2 Date until applicable
Further restricted zone No 1 Region of Plovdiv The entire region of Plovdiv excluding the areas included in any protection or surveillance zone. 25.9.2025
Region of Haskovo The municipalities of Dimitrovgrad, and Mineralni Bani, excluding the areas included in any protection or surveillance zone.
Further restricted zone No 2 Region of Stara Zagora The municipalities of Pavel Bajna, Kazanlak, Bratja Daskalovi and Cirpan, excluding the areas included in any protection or surveillance zone. 26.9.2025
Region of Gabrovo The entire region of Gabrovo, excluding the areas included in any protection or surveillance zone
Further restricted zone No 3 Region of Haskovo The municipalities of Ivajlovgrad, Svilengrad, Madzharovo and Ljubimec, excluding the areas included in any protection or surveillance zone. 26.9.2025
Region of Kardzhali The municipalities of Kirkovo, Dzhebel and Krumovgrad, excluding the areas included in any protection or surveillance zone.
Area Region Areas, referred to in Article 3 Date until applicable
Area No 1 Region of Plovdiv The entire region of Plovdiv. 26.9.2025-25.10.2025
Region of Haskovo The municipalities of Dimitrovgrad, and Mineralni Bani.
Area No 2 Region of Stara Zagora The municipalities of Pavel Bajna, Kazanlak, Bratja Daskalovi and Cirpan. 27.9.2025-26.10.2025
Region of Gabrovo The entire region of Gabrovo.
Area No 3 Region of Haskovo The municipalities of Ivajlovgrad, Svilengrad, Madzharovo and Ljubimec. 27.9.2025-26.10.2025
Region of Kardzhali The municipalities of Kirkovo, Dzhebel and Krumovgrad.
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EU) 2016/429 of the European Parliament and of the Council of 9 March 2016 on transmissible animal diseases and amending and repealing certain acts in the area of animal health (‘Animal Health Law’) (1), and in particular Article 259(1) thereof,
Whereas:
(1) Sheep pox and goat pox is an infectious viral disease affecting caprine and ovine animals and can have a severe impact on the concerned animal population and the profitability of farming causing disturbance to movements of consignments of those animals and products thereof within the Union and exports to third countries.
(2) In the event of an outbreak of sheep pox and goat pox in caprine or ovine animals, there is a serious risk of the spread of that disease to other establishments of caprine or ovine animals.
(3) Commission Delegated Regulation (EU) 2020/687 (2) supplements the rules for the control of the listed diseases referred to in Article 9(1), points (a), (b) and (c), of Regulation (EU) 2016/429, and defined as category A, B and C diseases in Commission Implementing Regulation (EU) 2018/1882 (3). In particular, Articles 21 and 22 of Delegated Regulation (EU) 2020/687 provide for the establishment of a restricted zone in the event of an outbreak of a category A disease, including sheep pox and goat pox, and for certain measures to be applied therein. In addition, Article 21(1) of that Delegated Regulation provides that the restricted zone is to comprise a protection zone, a surveillance zone, and, if necessary, further restricted zone around or adjacent to the protection and surveillance zones.
(4) Commission Implementing Decision (EU) 2025/1160 (4) was adopted following outbreaks of sheep pox and goat pox in Bulgaria, and it lays down emergency measures to be taken by that Member State. More particularly, Implementing Decision (EU) 2025/1160 provides that the protection, surveillance, and further restricted zones to be established by Bulgaria, in accordance with Article 21 of Delegated Regulation (EU) 2020/687, are to comprise at least the areas listed in Parts A and B of Annex I to that Implementing Decision.
(5) Since the last amendment of Implementing Decision (EU) 2025/1160, Bulgaria has notified the Commission of forty additional outbreaks of sheep pox and goat pox in establishments where ovine animals were kept, located in the regions of Plovdiv, Stara Zagora, and Haskovo, within the already established restricted zones, as well as in the region of Kardzhali, outside the already established restricted zones listed in Annex I to that Implementing Decision.
(6) In the current epidemiological situation, there is a high risk for the further spread of sheep pox and goat pox, in particular due to the fact that, according to the information provided by Bulgaria, there are numerous new outbreaks in the already affected regions, mostly in the region of Plovdiv, suggesting that the disease continues to circulate. There is also the new outbreak located outside the established restricted zones set out in Annex I to Implementing Decision (EU) 2025/1160, in the region of Kardzhali, suggesting that the disease has moved outside the restricted areas, despite the disease control measures already in place.
(7) Therefore, the restricted zone, comprising protection, surveillance and further restricted zones in Bulgaria, set out in Annex I to Implementing Decision (EU) 2025/1160 should be adjusted, both spatially and temporally, in order to prevent the further spread of sheep pox and goat pox in the territory of Bulgaria and to the rest of the Union.
(8) The size of the protection, surveillance and further restricted zones, and the duration of the measures to be applied therein, is based on the criteria set out in Article 64(1) of Regulation (EU) 2016/429, as well as on the rules laid down in Delegated Regulation (EU) 2020/687. The criteria applied for the choice of the size of the protection, surveillance, and further restricted zones, as well as of the duration of the measures to be applied therein, include a consideration of not only the epidemiological situation as regards sheep pox and goat pox in the areas affected by that disease, but also of the overall epidemiological situation of sheep pox and goat pox in the entire territory of Bulgaria, and of the level of risk for the further spread of the disease. For the determination of the duration of the measures the international standards of the Terrestrial Animal Health Code of the World Organisation for Animal Health (5) have also been taken into account.
(9) In view of the epidemiological situation, it is also necessary to prolong the duration of the additional measures applicable in the restricted zones, namely the prohibition of movements of sheep and goats from the protection and surveillance zones to any destinations located outside the external perimeter of the immediately surrounding further restricted zones, and from each further restricted zone to a destination located outside the external perimeter of this further restricted zone, including to destinations located in different further restricted zones, as set out in Part B of Annex I as well as the prohibition of movements of animals originating from those areas of Bulgaria that are not subject to restrictions due to sheep pox and goat pox to any of the areas within the external perimeter of the further restricted zones.
(10) In view of the epidemiological situation, it is also necessary to amend the areas set out in Annex II to Implementing Decision (EU) 2025/1160, in the territory of Bulgaria where further emergency measures like those applicable to further restricted zones, as provided for in Delegated Regulation (EU) 2020/687, as well as the prohibition on movements of sheep and goats to a destination located outside the external perimeters of those areas should apply, after the lifting of the protection, surveillance and further restricted zones, as well as the duration of such measures.
(11) In addition, in order to minimise the risk of the further spread of the disease, it is also necessary to prolong the prohibition on the movements of goats and sheep from the territory of Bulgaria to a destination located outside Bulgaria.
(12) Given the urgency of the epidemiological situation in the Union as regards the spread of sheep pox and goat pox, and the need to prevent that disease from spreading from the affected establishments in Bulgaria to other parts of that Member State or to other Member States, the amendments to be made to Implementing Decision (EU) 2025/1160, by this Decision should take effect as soon as possible..
(13) The measures provided for in this Decision are in accordance with the opinion of the Standing Committee on Plants, Animals, Food and Feed,
HAS ADOPTED THIS DECISION:
Implementing Decision (EU) 2025/1160 is amended as follows:

(1) in Article 2, point (c), the date ‘31 October 2025’ is replaced by ‘30 November 2025’;
(2) Annex I and Annex II are replaced by the text set out in the Annex to this Decision.

This Decision is addressed to the Republic of Bulgaria.

Part A:   Protection and surveillance zones established around the confirmed outbreaks

Region and ADIS reference number of the outbreak
Areas established as protection and surveillance zones, part of the restricted zone in Bulgaria referred to in Article 1
Date until applicable
Region of Plovdiv
BG-CAPRIPOX-2025-00008
BG-CAPRIPOX-2025-00009
BG-CAPRIPOX-2025-00010
BG-CAPRIPOX-2025-00011
BG-CAPRIPOX-2025-00012
BG-CAPRIPOX-2025-00013
BG-CAPRIPOX-2025-00014
BG-CAPRIPOX-2025-00015
BG-CAPRIPOX-2025-00016
BG-CAPRIPOX-2025-00017
BG-CAPRIPOX-2025-00018
BG-CAPRIPOX-2025-00021
BG-CAPRIPOX-2025-00022
BG-CAPRIPOX-2025-00023
BG-CAPRIPOX-2025-00024
BG-CAPRIPOX-2025-00025
BG-CAPRIPOX-2025-00026
BG-CAPRIPOX-2025-00027
BG-CAPRIPOX-2025-00028
BG-CAPRIPOX-2025-00029
BG-CAPRIPOX-2025-00030
BG-CAPRIPOX-2025-00031
BG-CAPRIPOX-2025-00032
BG-CAPRIPOX-2025-00033
BG-CAPRIPOX-2025-00034
BG-CAPRIPOX-2025-00035
BG-CAPRIPOX-2025-00036
BG-CAPRIPOX-2025-00039
BG-CAPRIPOX-2025-00040
BG-CAPRIPOX-2025-00041
BG-CAPRIPOX-2025-00042
BG-CAPRIPOX-2025-00043
BG-CAPRIPOX-2025-00044
BG-CAPRIPOX-2025-00045
BG-CAPRIPOX-2025-00046
BG-CAPRIPOX-2025-00047
BG-CAPRIPOX-2025-00048
BG-CAPRIPOX-2025-00049
BG-CAPRIPOX-2025-00050
BG-CAPRIPOX-2025-00051
BG-CAPRIPOX-2025-00052
BG-CAPRIPOX-2025-00053
BG-CAPRIPOX-2025-00054
BG-CAPRIPOX-2025-00055
BG-CAPRIPOX-2025-00056
BG-CAPRIPOX-2025-00057
BG-CAPRIPOX-2025-00058
BG-CAPRIPOX-2025-00059
BG-CAPRIPOX-2025-00060
BG-CAPRIPOX-2025-00061
BG-CAPRIPOX-2025-00062
BG-CAPRIPOX-2025-00063
BG-CAPRIPOX-2025-00064
BG-CAPRIPOX-2025-00065
BG-CAPRIPOX-2025-00067
BG-CAPRIPOX-2025-00068
BG-CAPRIPOX-2025-00069
BG-CAPRIPOX-2025-00070
BG-CAPRIPOX-2025-00071
BG-CAPRIPOX-2025-00072
BG-CAPRIPOX-2025-00073
BG-CAPRIPOX-2025-00074
BG-CAPRIPOX-2025-00075
BG-CAPRIPOX-2025-00076
BG-CAPRIPOX-2025-00077
BG-CAPRIPOX-2025-00078
BG-CAPRIPOX-2025-00079
BG-CAPRIPOX-2025-00080
BG-CAPRIPOX-2025-00081
BG-CAPRIPOX-2025-00082
BG-CAPRIPOX-2025-00083
BG-CAPRIPOX-2025-00084
BG-CAPRIPOX-2025-00085
BG-CAPRIPOX-2025-00086
BG-CAPRIPOX-2025-00087
BG-CAPRIPOX-2025-00088
BG-CAPRIPOX-2025-00089
BG-CAPRIPOX-2025-00090
BG-CAPRIPOX-2025-00091
BG-CAPRIPOX-2025-00092
BG-CAPRIPOX-2025-00093
BG-CAPRIPOX-2025-00094
BG-CAPRIPOX-2025-00095
BG-CAPRIPOX-2025-00096
BG-CAPRIPOX-2025-00097
BG-CAPRIPOX-2025-00098
BG-CAPRIPOX-2025-00099
BG-CAPRIPOX-2025-00102
BG-CAPRIPOX-2025-00103
BG-CAPRIPOX-2025-00104
BG-CAPRIPOX-2025-00105
BG-CAPRIPOX-2025-00106
BG-CAPRIPOX-2025-00107
BG-CAPRIPOX-2025-00108
BG-CAPRIPOX-2025-00110
BG-CAPRIPOX-2025-00111
BG-CAPRIPOX-2025-00113
BG-CAPRIPOX-2025-00114
BG-CAPRIPOX-2025-00115
Protection zone:
Those parts of the regions of Plovdiv, Haskovo, and Stara Zagora contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat.42.1944, Long. 24.8528 (2025/8), Lat. 42.1823, Long. 24.8337 (2025/9), Lat. 42.1889, Long. 24.8137 (2025/10), Lat. 42.1862, Long. 24.8316 (2025/11), Lat. 42.1856, Long. 24.8456 (2025/12), Lat. 42.2312, Long. 24.9357 (2025/13), Lat. 42.2308, Long. 24.9368 (2025/14), Lat. 42.18222, Long. 24.86694 (2025/15), Lat. 42.1873, Long. 24.8456 (2025/16), Lat. 42.19416, Long. 24.78666 (2025/17), Lat. 42.06, Long. 25.1658 (2025/18) Lat. 42.19416, Long. 24.78666 (2025/17), Lat. 42.23, Long. 24.9391 (2025/21), Lat. 42.231703, Long. 24.938912 (2025/22), Lat. 42.2306, Long. 24.9369 (2025/23), Lat. 42.2319, Long. 24.9362 (2025/24), Lat. 42.19416, Long. 24.78666 (2025/25), Lat. 42.2051, Long. 24.87314 (2025/26), Lat. 42.2069, Long. 24.78666 (2025/27), Lat. 42.233, Long. 24.9405 (2025/28), Lat. 42.2316, Long. 24.94214 (2025/29), Lat. 42.2602, Long. 24.8751 (2025/30), Lat. 42.20922, Long. 24.95578 (2025/31), Lat. 42.2089, Long. 24.9508 (2025/32), Lat. 42.2092, Long. 24.9525 (2025/33), Lat. 42.1886, Long. 24.9265 (2025/34), Lat. 42.1886, Long. 24.9265 (2025/35), Lat. 42.1925, Long. 24.9329 (2025/36), Lat. 42.6871, Long. 25.3287 (2025/37), Lat. 42.6871, Long. 25.3287 (2025/38), Lat. 42.200845, Long. 24.790453 (2025/39), Lat. 42.2463, Long. 24.7957 (2025/40), Lat. 42.202878, Long 24.690226 (2025/41), Lat. 42.2829, Long. 24.9637 (2025/42), Lat. 42.2363, Long. 24.8297 (2025/43), Lat. 42.1872, Long. 24.9242 (2025/44), Lat. 42.2308, Long 25.0438 (2025/45), Lat. 42.2401, Long. 25.0556 (2025/46), Lat. 42.2037, Long. 25.0513 (2025/47), Lat. 42.1959, Long. 25.0566 (2025/48), Lat. 42.2977, Long. 24.9179 (2025/49), Lat. 42.1369, Long. 24.9082 (2025/50), Lat. 42.1481, Long. 24.9055 (2025/51), Lat. 42.2333, Long. 24.8135 (2025/52), Lat. 42.3188, Long. 24.8888 (2025/53), Lat. 42.1903, Long. 25.034 (2025/54), Lat. 42.19416, Long. 24.78666 (2025/55), Lat. 42.2828, Long. 24.7528 (2025/56), Lat. 42.1061, Long. 24.8812 (2025/57), Lat. 42.2116, Long. 24.9584 (2025/58), Lat. 42.2559, Long. 24.6802 (2025/59), Lat. 41.9946, Long. 25.2278 (2025/60), Lat. 42.0248, Long. 25.096 (2025/61), Lat. 42.0341, Long. 25.1186 (2025/62), Lat. 42.0973, Long. 24.8738 (2025/63), Lat. 42.2008, Long. 25.049 (2025/64), Lat. 42.21546, Long. 24.62801 (2025/65), Lat. 42.3695, Long. 24.7158 (2025/67), Lat. 42.2753, Long. 25.1217 (2025/68), Lat. 42.2883, Long. 24.6303 (2025/69), Lat. 42.3705, Long. 24.725 (2025/70), Lat. 42.371, Long. 24.7229 (2025/71), Lat. 42.3288, Long. 24.6784 (2025/72), Lat. 42.3263, Long. 24.6724 (2025/73), Lat. 42.1929, Long. 24.635 (2025/74), Lat. 42.0567, Long. 24.7664 (2025/75), Lat. 42.1295, Long. 25.04 (2025/76), Lat. 42.3826, Long. 24.7806 (2025/77), Lat. 42.0146, Long. 25.2956 (2025/78), Lat. 41.9258, Long. 25.1422 (2025/79), Lat. 41.938, Long. 25.129 (2025/80), Lat. 41.9261, Long. 25.1294 (2025/81), Lat. 41.8911, Long. 25.1336 (2025/82), Lat. 41.9271, Long. 24.7806 (2025/83), Lat. 42.3063, Long. 24.5243 (2025/84), Lat. 42.2744, Long. 24.5549 (2025/85), Lat. 42.2637, Long. 24.5568 (2025/86), Lat. 42.2622, Long. 24.5603 (2025/87), Lat. 41.9443, Long. 25.2481 (2025/88), Lat. 42.603, Long. 24.8956 (2025/89), Lat. 41.9423, Long. 25.2434 (2025/90), Lat. 41.9449, Long. 25.2471 (2025/91), Lat. 42.267, Long. 24.554 (2025/92), Lat. 42.2729, Long. 24.5329 (2025/93), Lat. 42.2848, Long. 24.5428 (2025/94), Lat. 42.2757, Long. 24.5373 (2025/95), Lat. 42.2288, Long. 24.6255 (2025/96), Lat. 41.9456, Long. 25.2427 (2025/97), Lat. 41.9675, Long. 25.0319 (2025/98), Lat. 42.2311, Long. 24.8343 (2025/99), Lat. 42.2451, Long. 24.819 (2025/102), Lat. 42.1765, Long. 24.6267 (2025/103), Lat. 42.602, Long. 24.89 (2025/104), Lat. 42.6018, Long. 24.88 (2025/105), Lat. 42.6018, Long. 24.88 (2025/106), Lat. 42.6166, Long. 24.9121 (2025/107), Lat. 42.3469, Long. 24.667 (2025/108), Lat. 42.2458, Long. 24.8194 (2025/110), Lat. 42.61821, Long. 24.90195 (2025/111), Lat. 42.1391, Long. 25.0591 (2025/113), Lat. 42.3509, Long. 24.6217 (2025/114), Lat. 42.0512, Long. 25.184 (2025/115).
10.9.2025
Surveillance zone:
Those parts of the regions of Plovdiv, Lovech, Stara Zagora, Haskovo and Pazardzhik contained within a circle of a radius of 15 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 42.1944, Long. 24.8528 (2025/8), Lat. 42.1823, Long. 24.8337 (2025/9), Lat. 42.1889, Long. 24.8137 (2025/10), Lat. 42.1862, Long. 24.8316 (2025/11), Lat. 42.1856, Long. 24.8456 (2025/12), Lat. 42.2312, Long. 24.9357 (2025/13), Lat. 42.2308, Long. 24.9368 (2025/14), Lat. 42.18222, Long. 24.86694 (2025/15), Lat. 42.1873, Long. 24.8456 (2025/16), Lat. 42.19416, Long. 24.78666 (2025/17), Lat. 42.06, Long. 25.1658 (2025/18), Lat. 42.19416, Long. 24.78666 (2025/17), Lat. 42.23, Long. 24.9391 (2025/21), Lat. 42.231703, Long. 24.938912 (2025/22), Lat. 42.2306, Long. 24.9369 (2025/23), Lat. 42.2319, Long. 24.9362 (2025/24), Lat. 42.19416, Long. 24.78666 (2025/25), Lat. 42.2051, Long. 24.87314 (2025/26), Lat. 42.2069, Long. 24.78666 (2025/27), Lat. 42.233, Long. 24.9405 (2025/28), Lat. 42.2316, Long. 24.94214 (2025/29), Lat. 42.2602, Long. 24.8751 (2025/30), Lat. 42.20922, Long. 24.95578 (2025/31), Lat. 42.2089, Long. 24.9508 (2025/32), Lat. 42.2092, Long. 24.9525 (2025/33), Lat. 42.1886, Long. 24.9265 (2025/34), Lat. 42.1886, Long. 24.9265 (2025/35), Lat. 42.1925, Long. 24.9329 (2025/36), Lat. 42.200845, Long. 24.790453 (2025/39), Lat. 42.2463, Long. 24.7957 (2025/40), Lat. 42.202878, Long. 24.690226 (2025/41), Lat. 42.2829, Long. 24.9637 (2025/42), Lat. 42.2363, Long. 24.8297 (2025/43), Lat. 42.1872, Long. 24.9242 (2025/44), Lat. 42.2308, Long 25.0438 (2025/45), Lat. 42.2401, Long. 25.0556 (2025/46), Lat. 42.2037, Long. 25.0513 (2025/47), Lat. 42.1959, Long. 25.0566 (2025/48), Lat. 42.2977, Long 24.9179 (2025/49), Lat. 42.1369, Long. 24.9082 (2025/50), Lat. 42.1481, Long. 24.9055 (2025/51), Lat. 42.2333, Long. 24.8135 (2025/52), Lat. 42.3188, Long 24.8888 (2025/53), Lat. 42.1903, Long. 25.034 (2025/54), Lat. 42.19416, Long. 24.78666 (2025/55), Lat. 42.2828, Long. 24.7528 (2025/56), Lat. 42.1061, Long. 24.8812 (2025/57), Lat. 42.2116, Long. 24.9584 (2025/58), Lat. 42.2559, Long. 24.6802 (2025/59), Lat. 41.9946, Long. 25.2278 (2025/60), Lat. 42.0248, Long. 25.096 (2025/61), Lat. 42.0341, Long. 25.1186 (2025/62), Lat. 42.0973, Long. 24.8738 (2025/63), Lat. 42.2008, Long. 25.049 (2025/64), Lat. 42.21546, Long. 24.62801 (2025/65), Lat. 42.3695, Long. 24.7158 (2025/67), Lat. 42.2753, Long. 25.1217 (2025/68), Lat. 42.2883, Long. 24.6303 (2025/69), Lat. 42.3705, Long. 24.725 (2025/70), Lat. 42.371, Long. 24.7229 (2025/71), Lat. 42.3288, Long. 24.6784 (2025/72), Lat. 42.3263, Long. 24.6724 (2025/73), Lat. 42.1929, Long. 24.635 (2025/74), Lat. 42.0567, Long. 24.7664 (2025/75), Lat. 42.1295, Long. 25.04 (2025/76), Lat. 42.3826, Long. 24.7806 (2025/77) Lat. 42.0146, Long. 25.2956 (2025/78), Lat. 41.9258, Long. 25.1422 (2025/79), Lat. 41.938, Long. 25.129 (2025/80), Lat. 41.9261, Long. 25.1294 (2025/81), Lat. 41.8911, Long. 25.1336 (2025/82), Lat. 41.9271, Long. 24.7806 (2025/83), Lat. 42.3063, Long. 24.5243 (2025/84), Lat. 42.2744, Long. 24.5549 (2025/85), Lat. 42.2637, Long. 24.5568 (2025/86), Lat. 42.2622, Long. 24.5603 (2025/87), Lat. 41.9443, Long. 25.2481 (2025/88), Lat. 42.603, Long. 24.8956 (2025/89), Lat. 41.9423, Long. 25.2434 (2025/90), Lat. 41.9449, Long. 25.2471 (2025/91), Lat. 42.267, Long. 24.554 (2025/92), Lat. 42.2729, Long. 24.5329 (2025/93), Lat. 42.2848, Long. 24.5428 (2025/94), Lat. 42.2757, Long. 24.5373 (2025/95), Lat. 42.2288, Long. 24.6255 (2025/96), Lat. 41.9456, Long. 25.2427 (2025/97), Lat. 41.9675, Long. 25.0319 (2025/98), Lat. 42.2311, Long. 24.8343 (2025/99), Lat. 42.2451, Long. 24.819 (2025/102), Lat. 42.1765, Long. 24.6267 (2025/103), Lat. 42.602, Long. 24.89 (2025/104), Lat. 42.6018, Long. 24.88 (2025/105), Lat. 42.6018, Long. 24.88 (2025/106), Lat. 42.6166, Long. 24.9121 (2025/107), Lat. 42.3469, Long. 24.667 (2025/108), Lat. 42.2458, Long. 24.8194 (2025/110), Lat. 42.61821, Long. 24.90195 (2025/111), Lat. 42.1391, Long. 25.0591 (2025/113), Lat. 42.3509, Long. 24.6217 (2025/114), Lat. 42.0512, Long. 25.184 (2025/115) excluding the areas contained in the protection zone.
25.9.2025
Surveillance zone:
Those parts of the regions of Plovdiv, Haskovo and Stara Zagora, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 42.1944, Long. 24.8528 (2025/8), Lat. 42.1823, Long. 24.8337 (2025/9), Lat.42.1889, Long. 24.8137(2025/10), Lat. 42.1862, Long. 24.8316 (2025/11), Lat. 42.1856, Long. 24.8456 (2025/12), Lat. 42.2312, Long. 24.9357 (2025/13), Lat. 42.2308, Long. 24.9368 (2025/14), Lat. 42.18222, Long. 24.86694 (2025/15), Lat. 42.1873, Long. 24.8456 (2025/16), Lat. 42.19416, Long. 24.78666 (2025/17), Lat. 42.06, Long. 25.1658 (2025/18), Lat. 42.19416, Long. 24.78666 (2025/17), Lat. 42.23, Long. 24.9391 (2025/21), Lat. 42.231703, Long. 24.938912 (2025/22), Lat. 42.2306, Long. 24.9369 (2025/23), Lat. 42.2319, Long. 24.9362 (2025/24), Lat. 42.19416, Long. 24.78666 (2025/25), Lat. 42.2051, Long. 24.87314 (2025/26), Lat. 42.2069, Long. 24.78666 (2025/27), Lat. 42.233, Long. 24.9405 (2025/28), Lat. 42.2316, Long. 24.94214 (2025/29), Lat. 42.2602, Long. 24.8751 (2025/30), Lat. 42.20922, Long. 24.95578 (2025/31), Lat. 42.2089, Long. 24.9508 (2025/32), Lat. 42.2092, Long. 24.9525 (2025/33), Lat. 42.1886, Long. 24.9265 (2025/34), Lat. 42.1886, Long. 24.9265 (2025/35), Lat. 42.1925, Long. 24.9329 (2025/36), Lat. 42.6871, Long. 25.3287 (2025/37), Lat. 42.6871, Long. 25.3287 (2025/38), Lat. 42.200845, Long. 24.790453 (2025/39), Lat. 42.2463, Long. 24.7957 (2025/40), Lat. 42.202878, Long 24.690226 (2025/41), Lat. 42.2829, Long. 24.9637 (2025/42), Lat. 42.2363, Long. 24.8297 (2025/43), Lat. 42.1872, Long. 24.9242 (2025/44), Lat. 42.2308, Long 25.0438 (2025/45), Lat. 42.2401, Long. 25.0556 (2025/46), Lat. 42.2037, Long. 25.0513 (2025/47), Lat. 42.1959, Long. 25.0566 (2025/48), Lat. 42.2977, Long 24.9179 (2025/49), Lat. 42.1369, Long. 24.9082 (2025/50), Lat. 42.1481, Long. 24.9055 (2025/51), Lat. 42.2333, Long. 24.8135 (2025/52), Lat. 42.3188, Long 24.8888 (2025/53), Lat. 42.1903, Long. 25.034 (2025/54), Lat. 42.19416, Long. 24.78666 (2025/55), Lat. 42.2828, Long. 24.7528 (2025/56), Lat. 42.1061, Long. 24.8812 (2025/57), Lat. 42.2116, Long. 24.9584 (2025/58), Lat. 42.2559, Long. 24.6802 (2025/59), Lat. 41.9946, Long. 25.2278 (2025/60), Lat. 42.0248, Long. 25.096 (2025/61), Lat. 42.0341, Long. 25.1186 (2025/62), Lat. 42.0973, Long. 24.8738 (2025/63), Lat. 42.2008, Long. 25.049 (2025/64), Lat. 42.21546, Long. 24.62801 (2025/65), Lat. 42.3695, Long. 24.7158 (2025/67), Lat. 42.2753, Long. 25.1217 (2025/68), Lat. 42.2883, Long. 24.6303 (2025/69), Lat. 42.3705, Long. 24.725 (2025/70), Lat. 42.371, Long. 24.7229 (2025/71), Lat. 42.3288, Long. 24.6784 (2025/72), Lat. 42.3263, Long. 24.6724 (2025/73), Lat. 42.1929, Long. 24.635 (2025/74), Lat. 42.0567, Long. 24.7664 (2025/75), Lat. 42.1295, Long. 25.04 (2025/76), Lat. 42.3826, Long. 24.7806 (2025/77), Lat. 42.0146, Long. 25.2956 (2025/78), Lat. 41.9258, Long. 25.1422 (2025/79), Lat. 41.938, Long. 25.129 (2025/80), Lat. 41.9261, Long. 25.1294 (2025/81), Lat. 41.8911, Long. 25.1336 (2025/82), Lat. 41.9271, Long. 24.7806 (2025/83), Lat. 42.3063, Long. 24.5243 (2025/84), Lat. 42.2744, Long. 24.5549 (2025/85), Lat. 42.2637, Long. 24.5568 (2025/86), Lat. 42.2622, Long. 24.5603 (2025/87), Lat. 41.9443, Long. 25.2481 (2025/88), Lat. 42.603, Long. 24.8956 (2025/89), Lat. 41.9423, Long. 25.2434 (2025/90), Lat. 41.9449, Long. 25.2471 (2025/91), Lat. 42.267, Long. 24.554 (2025/92), Lat. 42.2729, Long. 24.5329 (2025/93), Lat. 42.2848, Long. 24.5428 (2025/94), Lat. 42.2757, Long. 24.5373 (2025/95), Lat. 42.2288, Long. 24.6255 (2025/96), Lat. 41.9456, Long. 25.2427 (2025/97), Lat. 41.9675, Long. 25.0319 (2025/98), Lat. 42.2311, Long. 24.8343 (2025/99), Lat. 42.2451, Long. 24.819 (2025/102), Lat. 42.1765, Long. 24.6267 (2025/103), Lat. 42.602, Long. 24.89 (2025/104), Lat. 42.6018, Long. 24.88 (2025/105), Lat. 42.6018, Long. 24.88 (2025/106), Lat. 42.6166, Long. 24.9121 (2025/107), Lat. 42.3469, Long. 24.667 (2025/108), Lat. 42.2458, Long. 24.8194 (2025/110), Lat. 42.61821, Long. 24.90195 (2025/111), Lat. 42.1391, Long. 25.0591 (2025/113), Lat. 42.3509, Long. 24.6217 (2025/114), Lat. 42.0512, Long. 25.184 (2025/115).
11.9.2025 – 25.9.2025
Region of Stara Zagora
BG-CAPRIPOX-2025-00037
BG-CAPRIPOX-2025-00038
BG-CAPRIPOX-2025-00112
BG-CAPRIPOX-2025-00117
Protection zone:
Those parts of the region of Stara Zagora, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 42.6871, Long. 25.3287 (2025/37), Lat. 42.6871, Long. 25.3287 (2025/38), Lat. 42.6538, Long. 25.2158 (2025/112), Lat. 42.6504, Long. 25.2121 (2025/117).
11.9.2025
Surveillance zone:
Those parts of the regions of Stara Zagora and Gabrovo contained within a circle of a radius of 15 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 42.6871, Long. 25.3287 (2025/37), Lat. 42.6871, Long. 25.3287 (2025/38), Lat. 42.6538, Long. 25.2158 (2025/112), Lat. 42.6504, Long. 25.2121 (2025/117) excluding the areas contained in the protection zone.
26.9.2025
Surveillance zone:
Those parts of the region of Stara Zagora, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 42.6871, Long. 25.3287 (2025/37), Lat. 42.6871, Long. 25.3287 (2025/38), Lat. 42.6538, Long. 25.2158 (2025/112), Lat. 42.6504, Long. 25.2121 (2025/117).
12.9.2025-26.9.2025
Region of Haskovo
BG-CAPRIPOX-2025-00066
BG-CAPRIPOX-2025-00100
BG-CAPRIPOX-2025-00101
BG-CAPRIPOX-2025-00109
Protection zone:
Those parts of the region of Haskovo, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 41.7227, Long. 26.325 (2025/66).
4.9.2025
Surveillance zone:
Those parts of the region of Haskovo, contained within a circle of a radius of 15 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 41.7227, Long. 26.325 (2025/66), Lat. 41.7531, Long. 26.1991 (2025/100) Lat. 41.7577, Long. 26.1977 (2025/101), Lat. 41.77, Long. 26.27 (2025/109), excluding the areas contained in the protection zone.
19.9.2025
Surveillance zone:
Those parts of the region of Haskovo, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 41.7227, Long. 26.325 (2025/66) Lat. 41.7531, Long. 26.1991 (2025/100), Lat. 41.7577, Long. 26.1977 (2025/101), Lat. 41.77, Long. 26.27 (2025/109).
5.9.2025 -19.9.2025
Region of Kardzhali
BG-CAPRIPOX-2025-000116
Protection zone:
Those parts of the regions of Kardzhali contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 41.4399, Long. 25.7723 (2025/116).
11.9.2025
Surveillance zone:
Those parts of the region of Kardzhali and Haskovo, contained within a circle of a radius of 15 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 41.4399, Long. 25.7723 (2025/116), excluding the areas contained in the protection zone.
26.9.2025
Surveillance zone:
Those parts of the region of Kardzhali, contained within a circle of a radius of 5 kilometres, centred on UTM 30, ETRS89 coordinates Lat. 41.4399, Long. 25.7723 (2025/116).
12.9.2025-26.9.2025

Part B: Further restricted zones

Further restricted zone
Region
Areas included in the further restricted zones established in Bulgaria as referred to in Article 2
Date until applicable
Further restricted zone No 1
Region of Plovdiv
The entire region of Plovdiv excluding the areas included in any protection or surveillance zone.
25.9.2025
Region of Haskovo
The municipalities of Dimitrovgrad, and Mineralni Bani, excluding the areas included in any protection or surveillance zone.
Further restricted zone No 2
Region of Stara Zagora
The municipalities of Pavel Bajna, Kazanlak, Bratja Daskalovi and Cirpan, excluding the areas included in any protection or surveillance zone.
26.9.2025
Region of Gabrovo
The entire region of Gabrovo, excluding the areas included in any protection or surveillance zone
Further restricted zone No 3
Region of Haskovo
The municipalities of Ivajlovgrad, Svilengrad, Madzharovo and Ljubimec, excluding the areas included in any protection or surveillance zone.
26.9.2025
Region of Kardzhali
The municipalities of Kirkovo, Dzhebel and Krumovgrad, excluding the areas included in any protection or surveillance zone.

Area
Region
Areas, referred to in Article 3
Date until applicable
Area No 1
Region of Plovdiv
The entire region of Plovdiv.
26.9.2025-25.10.2025
Region of Haskovo
The municipalities of Dimitrovgrad, and Mineralni Bani.
Area No 2
Region of Stara Zagora
The municipalities of Pavel Bajna, Kazanlak, Bratja Daskalovi and Cirpan.
27.9.2025-26.10.2025
Region of Gabrovo
The entire region of Gabrovo.
Area No 3
Region of Haskovo
The municipalities of Ivajlovgrad, Svilengrad, Madzharovo and Ljubimec.
27.9.2025-26.10.2025
Region of Kardzhali
The municipalities of Kirkovo, Dzhebel and Krumovgrad.

Commission Implementing Decision (EU) 2025/1760 of 19 August 2025 determining under Article 41(1) of Directive 2014/53/EU of the European Parliament and of the Council whether a measure taken by France with respect to Apple iPhone 12 A2403 is justified (notified under document C(2025) 5736)

January 13, 2026
Official Journalof the European Union ENL series
2025/1760 1.9.2025
(1) On 5 October 2023, France, via its relevant market surveillance authority, Agence Nationale des Fréquences (‘ANFR’), notified, in accordance with Article 40(4) of Directive 2014/53/EU and via the information and communication system referred to in Article 34(1) of Regulation (EU) 2019/1020 of the European Parliament and of the Council(2)(‘ICSMS’), a measure to have the mobile phone ‘iPhone 12 A2403’ manufactured by Apple Inc. (‘Apple’) withdrawn from the French market(3)(‘the national measure’).
(2) France, via ANFR, adopted the national measure on the grounds that the iPhone 12 A2403 exceeds the limit value of 4 W/kg, the limit value for specific absorption rate (SAR) on limbs set out in harmonised standard EN 50566:2017(4)which reflects the limits established in Council Recommendation 1999/519/EC(5). In accordance with Article 16 of Directive 2014/53/EU, that harmonised standard confers, if it is applied by a manufacturer(6), a presumption of conformity with the corresponding essential requirements. SAR is the rate at which electromagnetic energy emitted by a wireless device is absorbed by the human body expressed in power absorbed per unit mass of tissue (W/kg)(7).
(3) ANFR indicated that the non-compliance with that limit value did not affect the iPhone 12 models Mini, Pro and Pro Max. ANFR concluded that the iPhone 12 A2403 is not compliant with the essential requirement set out in Article 3(1), point (a), of Directive 2014/53/EU, relating to the protection of health and safety of persons and domestic animals.
(4) Given that the national measure was communicated to the Commission and to Member States on 5 October 2023, an objection against that measure could be raised until 3 January 2024, in accordance with Article 40(7) of Directive 2014/53/EU.
(5) On 24 October 2023, Ireland, via its relevant market surveillance authority, the Commission for Communications Regulation (‘ComReg’), submitted via ICSMS an objection with respect to the national measure.
(6) In that formal objection, ComReg concluded that the iPhone 12 A2403 was compliant with the essential requirements laid down in Directive 2014/53/EU.
(7) Following the objection raised against the national measure in accordance with Article 40(7) of Directive 2014/53/EU, the Commission entered into consultation with ANFR, ComReg and Apple to evaluate the national measure as provided for in Article 41(1), first subparagraph, of that Directive.
(8) In a meeting of the Administrative Cooperation Group of market surveillance authorities in the sector of the radio equipment (ADCO RED) that took place on 18 and 19 October 2023, ANFR presented the national measure to the market surveillance authorities of the Member States. The Commission attended the meeting as an observer.
(9) In the online meeting of the Telecommunication Conformity Assessment and Market Surveillance Committee (TCAM), held on 30 November 2023, ANFR presented an overview of the national measure to the Member States. The Commission provided an explanation of the safeguard clause procedure under Chapter V of Directive 2014/53/EU.
(10) On 30 November and 1 December 2023, an online meeting of the Commission expert group on radio equipment (E03587) was held. Apple was invited to participate in the discussion on the iPhone 12 A2403 that took place during that meeting. More specifically, Apple stated that the tests performed by ANFR do not reflect the intended use of the product and they can lead to potential erroneous results.
(11) On 5 January 2024, ANFR sent a letter to the Commission expressing the view that the objection raised by ComReg in relation to the national measure should not be upheld.
(12) By letter dated 8 March 2024, the Commission invited the ANFR to submit their observations and reply to several questions regarding the national measure. ANFR replied by email on 25 March 2024. Following supplementary questions raised by the Commission on 3 May 2024, ANFR sent additional information by email on 14 May 2024. On the same date, an online meeting took place between the Commission and ANFR, in which the independent laboratory CETECOM ADVANCED GmbH (‘CETECOM’), accredited under the standard EN ISO/IEC 17025:2017(8), also participated. During that online meeting, and also by email sent on the same date, the Commission informed ANFR about the validity of the objection raised by ComReg.
(13) By letter of 22 April 2024, the Commission invited Apple to submit its observations on the national measure and to reply to questions in order to clarify its position and observations. Apple submitted its observations and replies by email on 12 May 2024. As a follow-up, the Commission and Apple held an online meeting on 4 June 2024. On 3 June 2024, the Commission sent further questions to Apple on various technical elements to which Apple sent replies and clarifications on 18 June 2024 by email.
(14) On 4 July 2024, the Commission held an online meeting with ComReg to discuss the national measure. ComReg submitted a written statement on 8 July 2024. That statement underlined that the iPhone 12 A2403 had been tested by Apple in cooperation with a notified body and was found to be within the SAR limb limits(9).
(15) The iPhone 12 A2403 model was released on the Union market in October 2020. It is the first iPhone model equipped with 5G technology and, when ANFR notified the national measure, it was still sold on the Union market.
(16) Apple incorporated in the iPhone 12 A2403 the so-called ‘Body Detect’ function. By means of that mechanism, when the device detects movement, it considers that it is being used in contact with the human body, thus setting the ‘Body Detect’ function to ‘on-body’ state. The objective is to lead to a reduction of emitted power and, in turn, to a reduction of the average SAR level so that the said device meets the relevant SAR limits set out in harmonised standard EN 50566:2017.
(17) In July 2022, ANFR conducted the first SAR measurements on the iPhone 12 A2403, for determining if the device meets the limits set out in harmonised standard EN 50566:2017.
(18) ANFR concluded, after carrying out the SAR measurement, that the device exceeded the limb SAR limit set out in the relevant harmonised standard. According to harmonised standard EN 50566:2017, the limb SAR limit is set at 4 W/kg. ANFR concluded that the limb SAR measurement presented a retained value of 5,615 W/kg, thus significantly beyond the standard’s limit.
(19) Apple disputed those conclusions, by claiming the following:—The laboratory conducting the test for France had clamped the iPhone 12 A2403 tightly against the SAR phantom(10). According to Apple, this configuration might prevent the iPhone 12 A2403 from triggering the ‘Body Detect’ algorithm and might lead to a potential lack of compliance with the SAR limit.—Apple’s proprietary engineering tools are necessary to ensure that the power control algorithms of the iPhone 12 A2403 do not produce inaccurate results. — The laboratory conducting the test for France had clamped the iPhone 12 A2403 tightly against the SAR phantom(10). According to Apple, this configuration might prevent the iPhone 12 A2403 from triggering the ‘Body Detect’ algorithm and might lead to a potential lack of compliance with the SAR limit. — Apple’s proprietary engineering tools are necessary to ensure that the power control algorithms of the iPhone 12 A2403 do not produce inaccurate results.
— The laboratory conducting the test for France had clamped the iPhone 12 A2403 tightly against the SAR phantom(10). According to Apple, this configuration might prevent the iPhone 12 A2403 from triggering the ‘Body Detect’ algorithm and might lead to a potential lack of compliance with the SAR limit.
— Apple’s proprietary engineering tools are necessary to ensure that the power control algorithms of the iPhone 12 A2403 do not produce inaccurate results.
— The laboratory conducting the test for France had clamped the iPhone 12 A2403 tightly against the SAR phantom(10). According to Apple, this configuration might prevent the iPhone 12 A2403 from triggering the ‘Body Detect’ algorithm and might lead to a potential lack of compliance with the SAR limit.
— Apple’s proprietary engineering tools are necessary to ensure that the power control algorithms of the iPhone 12 A2403 do not produce inaccurate results.
(20) Following discussions between ANFR and Apple, the latter suggested to repeat the SAR measurements under a specific testing procedure (so-called ‘protocol 1’), which was communicated to ANFR in February 2023.
(21) Protocol 1 had the following characteristics:—A separation distance of 1 mm between the device and the phantom.—An external proprietary motorised system attached to the device to produce artificial vibrations in order to properly simulate and trigger the ‘Body Detect’ function.—The set-up of a specific testing configuration to carry out a stable and accurate measurement and to ensure that the emission came only from one preselected antenna of the iPhone 12 A2403 under test. — A separation distance of 1 mm between the device and the phantom. — An external proprietary motorised system attached to the device to produce artificial vibrations in order to properly simulate and trigger the ‘Body Detect’ function. — The set-up of a specific testing configuration to carry out a stable and accurate measurement and to ensure that the emission came only from one preselected antenna of the iPhone 12 A2403 under test.
— A separation distance of 1 mm between the device and the phantom.
— An external proprietary motorised system attached to the device to produce artificial vibrations in order to properly simulate and trigger the ‘Body Detect’ function.
— The set-up of a specific testing configuration to carry out a stable and accurate measurement and to ensure that the emission came only from one preselected antenna of the iPhone 12 A2403 under test.
— A separation distance of 1 mm between the device and the phantom.
— An external proprietary motorised system attached to the device to produce artificial vibrations in order to properly simulate and trigger the ‘Body Detect’ function.
— The set-up of a specific testing configuration to carry out a stable and accurate measurement and to ensure that the emission came only from one preselected antenna of the iPhone 12 A2403 under test.
(22) ANFR did not accept protocol 1 on the following grounds:—The maximum SAR emitted by the device is more likely to occur at a distance of 0 mm from the device.—Attaching a motorised system to the device was considered as an artificial mechanism that might not reflect the real use conditions of the product.—The testing configuration used to ensure that the emission came only from one preselected antenna of the device could have an undetermined impact on SAR measurements. — The maximum SAR emitted by the device is more likely to occur at a distance of 0 mm from the device. — Attaching a motorised system to the device was considered as an artificial mechanism that might not reflect the real use conditions of the product. — The testing configuration used to ensure that the emission came only from one preselected antenna of the device could have an undetermined impact on SAR measurements.
— The maximum SAR emitted by the device is more likely to occur at a distance of 0 mm from the device.
— Attaching a motorised system to the device was considered as an artificial mechanism that might not reflect the real use conditions of the product.
— The testing configuration used to ensure that the emission came only from one preselected antenna of the device could have an undetermined impact on SAR measurements.
— The maximum SAR emitted by the device is more likely to occur at a distance of 0 mm from the device.
— Attaching a motorised system to the device was considered as an artificial mechanism that might not reflect the real use conditions of the product.
— The testing configuration used to ensure that the emission came only from one preselected antenna of the device could have an undetermined impact on SAR measurements.
(23) In June 2023, due to the lack of agreement between ANFR and Apple on protocol 1, Apple proposed a second measurement procedure (so-called ‘protocol 2’), which had the following characteristics:—A separation distance of 0 mm between the device and the phantom.—The triggering of the ‘Body Detect’ algorithm by pressing the volume button of the iPhone 12 A2403 every 20 seconds.—In order to ensure that the emission came only from one preselected antenna of the iPhone 12 A2403, the use of, two alternative methods: either the one already proposed under protocol 1 or another method involving a specific placing of the network simulator’s antenna(11). — A separation distance of 0 mm between the device and the phantom. — The triggering of the ‘Body Detect’ algorithm by pressing the volume button of the iPhone 12 A2403 every 20 seconds. — In order to ensure that the emission came only from one preselected antenna of the iPhone 12 A2403, the use of, two alternative methods: either the one already proposed under protocol 1 or another method involving a specific placing of the network simulator’s antenna(11).
— A separation distance of 0 mm between the device and the phantom.
— The triggering of the ‘Body Detect’ algorithm by pressing the volume button of the iPhone 12 A2403 every 20 seconds.
— In order to ensure that the emission came only from one preselected antenna of the iPhone 12 A2403, the use of, two alternative methods: either the one already proposed under protocol 1 or another method involving a specific placing of the network simulator’s antenna(11).
— A separation distance of 0 mm between the device and the phantom.
— The triggering of the ‘Body Detect’ algorithm by pressing the volume button of the iPhone 12 A2403 every 20 seconds.
— In order to ensure that the emission came only from one preselected antenna of the iPhone 12 A2403, the use of, two alternative methods: either the one already proposed under protocol 1 or another method involving a specific placing of the network simulator’s antenna(11).
(24) ANFR accepted the measurement procedure described in protocol 2 and decided to use the method involving a specific placing of the network simulator’s antenna.
(25) In August 2023, ANFR requested CETECOM to conduct SAR measurements on the iPhone 12 A2403 in accordance with protocol 2 on different samples. CETECOM concluded that the iPhone 12 A2403 remained non-compliant under protocol 2 (5,740 W/kg).
(26) On 12 September 2023, France, via ANFR, adopted a national decision ordering the withdrawal from the French market of the iPhone 12 A2403. That decision was adopted on the grounds that Apple refused to offer a software update to make the product compliant, as other manufacturers usually do, according to ANFR.
(27) Following the concerns expressed by ANFR and the subsequent adoption of a restrictive measure, Apple indicated it would release a software update for the iPhone 12 A2403 users in France to permanently activate the ‘on-body’ state of the ‘Body Detect’ function. That update to the iPhone 12 A2403 would reduce the emitted power, and in turn the SAR level, on a permanent basis. Apple added that that update would not be made available in other Member States since it considered that the iPhone 12 A2403 was compliant with Directive 2014/53/EU and that the national measure was groundless.
(28) New measurements conducted by CETECOM in September 2023 showed the compliance of the iPhone 12 A2403 running the updated software (iOS 17.1) with the SAR limit value set out in harmonised standard EN 50566:2017. Those measurements were carried out with test equipment simulating a mobile network located in France.
(29) Following the release of the software update, ANFR considered that the devices for which the updated software (iOS 17.1) was operational to permanently activate the ‘on-body’ state of the ‘Body Detect’ function were in compliance as it was demonstrated that such devices meet the relevant SAR limit set out in harmonised standard EN 50566:2017.
(30) ANFR, however indicated that it was informed by Apple, on 4 October 2023, that the corrective software update would only be operational on the French territory. During the meeting of the Commission services with Apple, held on 4 June 2024, Apple confirmed that the corrective software update would only be operational on the French territory.
(31) Article 40(3) of Directive 2014/53/EU requires that a corrective action is taken in respect of non-compliant radio equipment throughout the Union. If the action taken for devices found not to be compliant consists of implementing, for example, a software update, that action can be considered corrective if the software update, i.e. corrective software, is made available and being operational in the entire Union and it is thus made available for all related devices operating in the Union.
(32) In this context, the action taken for the iPhone 12 A2403 devices, to implement a software update to ensure that the ‘on-body’ state of the ‘Body Detect’ function is permanently activated, so that the said devices can meet the relevant SAR limits and can thus be compliant, can be considered corrective only when that software update is made available in all the Union territory. Therefore, such devices are considered non-compliant not only when they do not have such a corrective software installed but also when such a software is installed but the permanent activation of the ‘Body Detect Function’ is operational only in France, and not in the entire Union.
(33) On 5 October 2023, ANFR encoded the national measure on ICSMS, initiating the three-month objection period in relation to iPhones 12 A2403 operating without the software update (iOS 17.1) and as a result the ‘on-body’ state of the ‘Body Detect’ function is not permanently activated.
(34) By letter of 5 January 2024, sent by ANFR to the Commission, ANFR expressed the view that the objection raised by Ireland, via ComReg, in relation to the national measure should not be upheld.
(35) According to ANFR, that objection is not substantiated and is based only on an analysis of the technical documentation as well as on the measurement reports carried out by a notified body and communicated by the manufacturer. In other words, ANFR stated that the relevant Irish authorities neither conducted a technical investigation nor performed any tests.
(36) ANFR first referred to the general context for SAR measurements and explained that the latter are carried out systematically for head, body and limbs for smartphones. Then, ANFR provided an overview of the chain of events and facts, i.e. the specific dates when relevant tests were carried out and measures taken, which are summarised in the previous section.
(37) ANFR underlined that the SAR measurements are carried out through an accredited laboratory and that there are no specific national regulations applicable in France on SAR, outlining that, with respect to SAR measurements, the limits set out in Recommendation 1999/519/EC, which correspond to the limits set out in harmonised standard EN 50566:2017, are applied and followed when a laboratory carries out tests for ANFR. Moreover, it was indicated by ANFR that the tests for the iPhone 12 A2403 were carried out by CETECOM, which is accredited under the standard EN ISO/IEC 17025.
(38) In addition, in reply to questions submitted by the Commission services, ANFR provided the following details concerning the SAR measurements carried out in France:—Many smartphones incorporate motion sensors, however such information must be included in their technical file.—Before SAR measurements are carried out, ANFR asks the manufacturer to provide the full technical file, which must include the test reports drawn up by the manufacturer and a description of the operation of the device in question.—If the device incorporates a motion sensor-based power control device, its algorithm is to be described in the technical file.—After analysing the algorithm, the latter will be taken into account in the measurements, but only if it can ensure conformity with Directive 2014/53/EU, in particular, for safety, as regards the reasonably foreseeable use of the device, as provided for in Article 17(1) of that Directive.—Since the devices incorporate power control mechanisms, they need to be tested by using Time Averaged SAR (TAS) procedure. — Many smartphones incorporate motion sensors, however such information must be included in their technical file. — Before SAR measurements are carried out, ANFR asks the manufacturer to provide the full technical file, which must include the test reports drawn up by the manufacturer and a description of the operation of the device in question. — If the device incorporates a motion sensor-based power control device, its algorithm is to be described in the technical file. — After analysing the algorithm, the latter will be taken into account in the measurements, but only if it can ensure conformity with Directive 2014/53/EU, in particular, for safety, as regards the reasonably foreseeable use of the device, as provided for in Article 17(1) of that Directive. — Since the devices incorporate power control mechanisms, they need to be tested by using Time Averaged SAR (TAS) procedure.
— Many smartphones incorporate motion sensors, however such information must be included in their technical file.
— Before SAR measurements are carried out, ANFR asks the manufacturer to provide the full technical file, which must include the test reports drawn up by the manufacturer and a description of the operation of the device in question.
— If the device incorporates a motion sensor-based power control device, its algorithm is to be described in the technical file.
— After analysing the algorithm, the latter will be taken into account in the measurements, but only if it can ensure conformity with Directive 2014/53/EU, in particular, for safety, as regards the reasonably foreseeable use of the device, as provided for in Article 17(1) of that Directive.
— Since the devices incorporate power control mechanisms, they need to be tested by using Time Averaged SAR (TAS) procedure.
— Many smartphones incorporate motion sensors, however such information must be included in their technical file.
— Before SAR measurements are carried out, ANFR asks the manufacturer to provide the full technical file, which must include the test reports drawn up by the manufacturer and a description of the operation of the device in question.
— If the device incorporates a motion sensor-based power control device, its algorithm is to be described in the technical file.
— After analysing the algorithm, the latter will be taken into account in the measurements, but only if it can ensure conformity with Directive 2014/53/EU, in particular, for safety, as regards the reasonably foreseeable use of the device, as provided for in Article 17(1) of that Directive.
— Since the devices incorporate power control mechanisms, they need to be tested by using Time Averaged SAR (TAS) procedure.
(39) ANFR indicated that the iPhone 12 A2403 reduces the emitted power when it detects movement because, in such a case, the device considers that it is being used in contact with the human body. That approach reflects the reasonably foreseeable use of the product, according to the manufacturer. ANFR did not challenge the described power control technique as a concept. Nevertheless, ANFR considered that it was not properly configured. More specifically, it was observed by ANFR that the device does not always reduce sufficiently the power when it detects movement.
(40) According to ANFR, CETECOM performed the first SAR measurement on the iPhone 12 A2403 in July 2022, leading to a result that exceeded the limb SAR limit. More specifically, as stated by ANFR, the limb SAR measurement presented a retained value of 5,615 W/kg.
(41) For that SAR measurement, ANFR took the following position:—The measurement was carried out without taking into consideration the device mechanisms for power control.—Since the technical documentation submitted by Apple did not mention the presence of a motion sensor, or a specific power control algorithm, those measurements were carried out without taking into account the device mechanisms allowing power control. — The measurement was carried out without taking into consideration the device mechanisms for power control. — Since the technical documentation submitted by Apple did not mention the presence of a motion sensor, or a specific power control algorithm, those measurements were carried out without taking into account the device mechanisms allowing power control.
— The measurement was carried out without taking into consideration the device mechanisms for power control.
— Since the technical documentation submitted by Apple did not mention the presence of a motion sensor, or a specific power control algorithm, those measurements were carried out without taking into account the device mechanisms allowing power control.
— The measurement was carried out without taking into consideration the device mechanisms for power control.
— Since the technical documentation submitted by Apple did not mention the presence of a motion sensor, or a specific power control algorithm, those measurements were carried out without taking into account the device mechanisms allowing power control.
(42) ANFR then referred to protocol 1 proposed by Apple. ANFR clarified that the specific configuration to ensure that the maximum power is measured, as proposed under protocol 1, did not represent the reasonably foreseeable use, and it could be considered as an artificial way to pass the test.
(43) ANFR confirmed that, following the rejection of protocol 1, Apple proposed protocol 2. According to ANFR, that protocol was more in line with what is expected from a test taking into consideration the reasonably foreseeable conditions. However, by following protocol 2, ANFR noted that the limb SAR measurement performed by the accredited laboratory CETECOM showed the persistence of the non-compliance. The limit of 4 W/kg was exceeded by simulating the use of the iPhone 12 A2403 in France, more specifically, the limb SAR measured presented a retained value of 5,740 W/kg(12)(while the first measurement carried out presented a value of 5,615 W/kg)(13). Additional tests performed by ANFR concluded that the limb SAR exceeded the recommended value by simulating the use of the iPhone 12 in two other Member States.
(44) Additionally, ANFR tested in their internal laboratory(14)a different sample using the same protocol 2, which also resulted in non-compliance with the limb SAR limit value.
(45) As regards the new updated software offered by Apple, ANFR stated that a national decision taking a provisional measure was adopted ordering the withdrawal from the French market of the iPhone 12 A2403. The national decision was adopted on the grounds that, as stated by ANFR, Apple repeatedly refused to offer a software update to make the product compliant, as other manufacturers usually do.
(46) ANFR confirmed that the corrective software that was finally provided by Apple can be acceptable and can ensure compliance with the health and safety essential requirements set out in Directive 2014/53/EU. More specifically, the concrete measure implemented in this software limits the power of the device in all cases of use, thus restoring compliance and no longer making compliance of the device dependent on its performance in detecting the human body. ANFR noted that Apple provided the corrective software update only for iPhones 12 A2403 that operated on the French market and for this reason the national measure was encoded on ICSMS, initiating the three-month objection period.
(47) According to the objection raised by Ireland, via ComReg, a preliminary investigation into the iPhone 12 A2403 was carried out by ComReg, which received documentation and technical testing results from Apple demonstrating that that radio equipment is compliant with the essential requirements set out in Directive 2014/53/EU. More specifically, the objection submitted by Ireland, via ComReg, was as follows:‘ComReg objects to the measure taken by the ANFR in respect of the Apple iPhone 12 on the 12 September 2023 on the grounds outlined below:1.On the 12 September 2023, the ANFR, the Market Surveillance Authority for Directive 2014/53/EU in France, took a measure to have the Apple iPhone12 withdrawn from the market in France having found that testing measures showed the specific absorption rate (SAR) exceeds the set limits. This is a procedure provided for under Article 40 of the Directive.In accordance with Article 40.4, ANFR informed the Commission and the other Member States of this measure on 5 October 2023 by placing the requisite information on ICSMS.2.ComReg has carried out a preliminary investigation into the radio equipment in question. ComReg has received documentation and technical testing results from the economic operator demonstrating that the radio equipment is compliant with the essential requirements of the Directive. In particular, ComReg notes that when the iPhone12 was tested by Apple at a registered Notified Body, the product was found to be within the SAR Limb guidelines. ComReg has not carried out any technical testing on the iPhone12.3.Common standards across the Union ensure interoperability and safety, reduce costs and facilitate companies’ integration in the value chain and trade. Under the circumstances, ComReg believes that it would be appropriate for the European Commission to evaluate the national measure in question, and in particular the testing undertaken, and provide a common position to assist MSAs’. 1. On the 12 September 2023, the ANFR, the Market Surveillance Authority for Directive 2014/53/EU in France, took a measure to have the Apple iPhone12 withdrawn from the market in France having found that testing measures showed the specific absorption rate (SAR) exceeds the set limits. This is a procedure provided for under Article 40 of the Directive.In accordance with Article 40.4, ANFR informed the Commission and the other Member States of this measure on 5 October 2023 by placing the requisite information on ICSMS. 2. ComReg has carried out a preliminary investigation into the radio equipment in question. ComReg has received documentation and technical testing results from the economic operator demonstrating that the radio equipment is compliant with the essential requirements of the Directive. In particular, ComReg notes that when the iPhone12 was tested by Apple at a registered Notified Body, the product was found to be within the SAR Limb guidelines. ComReg has not carried out any technical testing on the iPhone12. 3. Common standards across the Union ensure interoperability and safety, reduce costs and facilitate companies’ integration in the value chain and trade. Under the circumstances, ComReg believes that it would be appropriate for the European Commission to evaluate the national measure in question, and in particular the testing undertaken, and provide a common position to assist MSAs’.
1. On the 12 September 2023, the ANFR, the Market Surveillance Authority for Directive 2014/53/EU in France, took a measure to have the Apple iPhone12 withdrawn from the market in France having found that testing measures showed the specific absorption rate (SAR) exceeds the set limits. This is a procedure provided for under Article 40 of the Directive.In accordance with Article 40.4, ANFR informed the Commission and the other Member States of this measure on 5 October 2023 by placing the requisite information on ICSMS.
2. ComReg has carried out a preliminary investigation into the radio equipment in question. ComReg has received documentation and technical testing results from the economic operator demonstrating that the radio equipment is compliant with the essential requirements of the Directive. In particular, ComReg notes that when the iPhone12 was tested by Apple at a registered Notified Body, the product was found to be within the SAR Limb guidelines. ComReg has not carried out any technical testing on the iPhone12.
3. Common standards across the Union ensure interoperability and safety, reduce costs and facilitate companies’ integration in the value chain and trade. Under the circumstances, ComReg believes that it would be appropriate for the European Commission to evaluate the national measure in question, and in particular the testing undertaken, and provide a common position to assist MSAs’.
1. On the 12 September 2023, the ANFR, the Market Surveillance Authority for Directive 2014/53/EU in France, took a measure to have the Apple iPhone12 withdrawn from the market in France having found that testing measures showed the specific absorption rate (SAR) exceeds the set limits. This is a procedure provided for under Article 40 of the Directive.In accordance with Article 40.4, ANFR informed the Commission and the other Member States of this measure on 5 October 2023 by placing the requisite information on ICSMS.
2. ComReg has carried out a preliminary investigation into the radio equipment in question. ComReg has received documentation and technical testing results from the economic operator demonstrating that the radio equipment is compliant with the essential requirements of the Directive. In particular, ComReg notes that when the iPhone12 was tested by Apple at a registered Notified Body, the product was found to be within the SAR Limb guidelines. ComReg has not carried out any technical testing on the iPhone12.
3. Common standards across the Union ensure interoperability and safety, reduce costs and facilitate companies’ integration in the value chain and trade. Under the circumstances, ComReg believes that it would be appropriate for the European Commission to evaluate the national measure in question, and in particular the testing undertaken, and provide a common position to assist MSAs’.
(48) ComReg noted that, when the iPhone 12 A2403 was tested by Apple in cooperation with a registered notified body(15), the device was found to be within the SAR limb limit. ComReg did not, however, carry out any technical testing on the iPhone 12 A2403. Moreover, ComReg did not point to any shortcomings of harmonised standard EN 50566:2017 with respect to its purpose of providing presumption of conformity with the essential requirement that it aims to cover and demonstrating, when that harmonised standard is applied, compliance with the essential requirement under Article 3(1), point (a), of Directive 2014/53/EU.
(49) According to Apple, the iPhone 12 A2403 is safe to use and has always been so. Particularly, according to Apple, the iPhone 12 A2403, which was launched in 2020, was certified and recognised as compliant with all applicable SAR regulations and standards around the world. Apple added that its power control mechanism has not been updated in any way since its launch.
(50) Apple informed the Commission that the iPhone 12 A2403 is equipped with technical mechanisms which control the emitted power based on certain parameters. The SAR level is, in turn, controlled by those mechanisms. The functioning of the latter is Apple-proprietary and was not disclosed in full to the Commission.
(51) According to Apple, the finding of ANFR on the iPhone 12 A2403 is not a compliance concern, rather a consequence of an alleged erroneous implementation of the testing protocol. More specifically, Apple considers that the test performed by ANFR does not trigger the power control mechanism in a proper way, leading to a potential lack of compliance with the SAR limb limit. Apple stated that the iPhone 12 A2403 passed a test at 5 mm separation distance (allowed by harmonised standard EN 50566:2017), executed by ANFR on 21 December 2021. Apple stated that the iPhone 12 A2403 did not comply with the test procedure performed by ANFR only for the limb exposure at 0 mm when the phone was clamped tightly to the flat phantom. The latter scenario, according to Apple, does not reflect the intended use of the device since it does not create any movement to activate the ‘Body Detect’ functionality. In other words, as noted by Apple, in the described scenario, the contact with the human body is not properly simulated.
(52) Apple added that the ‘Body Detect’ function has been used in all iPhones for over a decade and has been thoroughly tested and certified to be an effective mechanism of power control to comply with SAR requirements. Apple indicated that they provided ANFR with several reports of tests performed by independent third-party laboratories, which proved the appropriate functioning of the ‘Body Detect’ function, which proved, in turn, the compliance with SAR limb limits.
(53) Apple indicated that it developed a proprietary testing tool to activate the ‘Body Detect’ function during the tests, underling that such a tool is deemed necessary. Apple also indicated that the use of such tool was recommended by a manufacturer of SAR testing equipment.
(54) Apple considered that the tests performed by or on behalf of ANFR under protocol 2 were erroneous on the following grounds:—CETECOM added the SAR values of the 4G and 5G bands while the radiation patterns demonstrated that there was no spatial overlapping between these two technologies and, therefore, the values could not be added.—The iPhone 12 was set in a position that prevented the person performing the test from manually pushing the volume buttons as agreed in protocol 2 and leading to a lack of triggering of the ‘Body Detect’ function. — CETECOM added the SAR values of the 4G and 5G bands while the radiation patterns demonstrated that there was no spatial overlapping between these two technologies and, therefore, the values could not be added. — The iPhone 12 was set in a position that prevented the person performing the test from manually pushing the volume buttons as agreed in protocol 2 and leading to a lack of triggering of the ‘Body Detect’ function.
— CETECOM added the SAR values of the 4G and 5G bands while the radiation patterns demonstrated that there was no spatial overlapping between these two technologies and, therefore, the values could not be added.
— The iPhone 12 was set in a position that prevented the person performing the test from manually pushing the volume buttons as agreed in protocol 2 and leading to a lack of triggering of the ‘Body Detect’ function.
— CETECOM added the SAR values of the 4G and 5G bands while the radiation patterns demonstrated that there was no spatial overlapping between these two technologies and, therefore, the values could not be added.
— The iPhone 12 was set in a position that prevented the person performing the test from manually pushing the volume buttons as agreed in protocol 2 and leading to a lack of triggering of the ‘Body Detect’ function.
(55) The Commission first examined the view expressed by ANFR, in its letter of 5 January 2024, that the objection raised by Ireland, via ComReg, in relation to the national measure should not be upheld because of the lack of a deep investigation by the relevant Irish authorities.
(56) Under Article 40(7) of Directive 2014/53/EU, in the case where no objection has been raised by a Member State or the Commission, as specified in that provision, Member States are to ensure that appropriate restrictive measures, such as withdrawal of the radio equipment from the market, are taken in respect of the radio equipment concerned, without delay. However, according to Article 41(1) of Directive 2014/53/EU, if an objection has been raised, the Commission is to without delay enter into consultation with the Member States and the relevant economic operator and is to evaluate the national measure. On the basis of the results of that evaluation, the Commission is to adopt an implementing act determining whether the national measure is justified or not.
(57) While it is not disputed that the objection raised by Ireland, via ComReg, does not include technical details or technical justifications, based on Article 40(6) and (7) of Directive 2014/53/EU and considering the relevant case-law (in particular Case T-349/21(16)), the objection raised by Ireland, via ComReg, is sufficient to trigger the Commission’s obligation referred to in Articles 40(7) and 41(1) of that Directive to issue an implementing decision under Article 41(1) of that Directive.
(58) In Case T-349/21 the General Court stated that Directive 2014/33/EU of the European Parliament and of the Council(17)does not lay down any particular format requirements as regards the way in which objections may be formulated by a Member State. Similarly, Directive 2014/53/EU does not impose any specific format on how such objections can be formulated, and so the Court’s finding can be applied to it.
(59) Under Article 34 of Regulation (EU) 2019/1020, objections raised by Member States in accordance with the applicable safeguard procedure in the Union harmonisation legislation applicable to the product, and any subsequent follow-up are to be entered into the information and communication system referred to in that Article (i.e. the ICSMS). In this respect, Ireland, via ComReg, has entered the objection it raised in relation to the national measure in ICSMS.
(60) During the online meeting of 14 May 2024 with the ANFR, and also by email sent on the same date, the Commission informed ANFR about the validity of the objection raised by ComReg and of the obligation for the Commission to issue an implementing decision.
(61) Due to the concerns expressed by ANFR, and the subsequent national measure, Apple released a software update for iPhone 12 A2403 users in France to permanently activate the ‘on-body’ state of the ‘Body Detect’ function.
(62) The described modifications to the functioning of the ‘Body Detect’ function only took place on iPhone 12 A2403 devices operating in cellular networks located in France(18). According to Apple, the update would not be made available for all Union users since Apple considered that the iPhone was compliant with Directive 2014/53/EU and the national measure was groundless.
(63) The Commission observes that, following the release of the software update, and as confirmed by the additional tests carried out by ANFR, the iPhone 12 A2403’s behaviour related to SAR remained unchanged in the rest of the Union. Therefore, the potential lack of compliance would remain in the majority of the Union.
(64) Under Article 40(3) of Directive 2014/53/EU, any corrective action must be available throughout the Union. Therefore, the corrective measures taken by Apple, by making available the new software (iOS 17.1) activating permanently the ‘on-body’ state of the ‘Body Detect’ function only on devices operating in cellular networks located in France, are not in line with that Article.
(65) As the national measure in relation to the iPhone 12 A2403 operation without the software update, so that the ‘on-body’ state of the ‘Body Detect’ function is being permanently activated, was encoded in the ICSMS and has not been withdrawn by France, the Commission’s obligation to issue an implementing decision under Article 41(1) of Directive 2014/53/EU remains.
(66) Directive 2014/53/EU establishes a regulatory framework for the making available on the market and putting into service of radio equipment in the Union.
(67) Article 6 of Directive 2014/53/EU requires Member States to take appropriate measures to ensure that radio equipment is made available on the market only if it complies with that Directive. In addition, according to Article 9 of Directive 2014/53/EU, Member States are not to impede, for reasons relating to aspects covered by that Directive, the making available on the market in their territory of radio equipment which complies with that Directive.
(68) The obligations of manufacturers when placing on the Union market radio equipment are set out in Article 10 of Directive 2014/53/EU. Article 10 of that Directive requires, among other things, that manufacturers, when placing their radio equipment on the market, ensure that it has been designed and manufactured in accordance with the essential requirements set out in Article 3 of that Directive.
(69) Article 3 of Directive 2014/53/EU sets out essential requirements to ensure the protection of health and safety, as well as of certain other aspects of public interest protection. According to Article 3(1), point (a), of that Directive, radio equipment is to be constructed so as to ensure the protection of health and safety of persons and of domestic animals and the protection of property, including the objectives with respect to safety requirements set out in Directive 2014/35/EU of the European Parliament and of the Council(19), but with no voltage limit applying. Under point 2(b) of Annex I to Directive 2014/35/EU measures of technical nature must be taken so that radiation which would cause a danger is not produced.
(70) As provided for in Article 17(1) of Directive 2014/53/EU, a manufacturer is to perform a conformity assessment of the radio equipment with a view to meeting the essential requirements set out in Article 3 of that Directive. The conformity assessment is to take into account all intended operating conditions and, for the essential requirement set out in Article 3(1), point (a), of that Directive, i.e. the essential requirements relating to health and safety, the assessment is also to take into account the reasonably foreseeable conditions. In addition, where the radio equipment is capable of taking different configurations, the conformity assessment is to confirm whether the radio equipment meets the essential requirements set out in Article 3 of that Directive in all possible configurations.
(71) Under Article 40(1) of Directive 2014/53/EU, where the market surveillance authorities of a Member State have sufficient reason to believe that radio equipment covered by that Directive presents a risk to the health or safety of persons or to other aspects of public interest protection covered by that Directive, or following the amendments introduced by Directive (EU) 2022/2380 of the European Parliament and of the Council(20)that it does not comply with at least one of the applicable essential requirements set out in Article 3 of Directive 2014/53/EU, they are to carry out an evaluation in relation to the radio equipment concerned covering all relevant requirements laid down in Directive 2014/53/EU. If the market surveillance authorities find that the radio equipment does not comply with the requirements laid down in Directive 2014/53/EU, they are to without delay require the relevant economic operator to take all appropriate corrective actions to bring the radio equipment into compliance with those requirements, to withdraw the radio equipment from the market, or to recall it within a reasonable period, commensurate with the nature of the risk, as they may prescribe.
(72) Recommendation 1999/519/EC sets out limits for the exposure of the general public to electromagnetic fields in line with the International Commission on Non-Ionizing Radiation Protection (ICNIRP) guidelines. For radio equipment placed on the Union market and intended for use by the general public, those limits are set out in the harmonised standards drafted in support of Directive 2014/53/EU(21)and published in theOfficial Journal of the European Unionby Commission Implementing Decision (EU) 2022/2191(22).
(73) Pursuant to Article 16 of Directive 2014/53/EU, radio equipment which conforms with harmonised standards (or parts thereof), of which the references have been published in theOfficial Journal of the European Union, are presumed to be in conformity with the corresponding essential requirements set out in Article 3 of that Directive.
(74) Harmonised standard EN 50566:2017, which confers a presumption of conformity with the essential requirement that it aims to cover, sets out the limb SAR limit value at 4W/kg, reflecting the relevant limit established in Council Recommendation 1999/519/EC, for the purpose of demonstrating compliance with the essential requirement relating to human and animal health referred to in Article 3(1), point (a), of Directive 2014/53/EU, as far as the SAR limit value for limb is concerned.
(75) Apple’s EU declaration of conformity for the iPhone 12 A2403, which is drawn up pursuant to Article 18 of Directive 2014/53/EU, referred to that harmonised standard and therefore Apple had applied that harmonised standard, which confers a presumption of conformity with the essential requirement that it aims to cover, for demonstrating conformity with the essential requirement in question.
(76) The fact that a device, by meeting the limb SAR limit value set out in harmonised standard EN 50566:2017, which reflects the relevant limit established in Council Recommendation 1999/519/EC, can be in conformity with the essential requirement relating to human and animal health referred to in Article 3(1), point (a), of Directive 2014/53/EU, as far as the SAR limit value for limb is concerned, was not disputed by Member States.
(77) Moreover, during the online meetings held with Apple, mentioned above, the latter has never indicated that the limits, as set out in harmonised standard EN 50566:2017, are disputed. Additionally, Apple has not questioned the fact that that such exceedance for the limb SAR limit would imply non-compliance with the said essential requirement under Article 3(1), point (a), of Directive 2014/53/EU, as such, but focused instead on questioning the way in which the measurement protocol 2 was applied by or on behalf of ANFR.
(78) It is thus undisputed that a device, when it meets the relevant limb SAR limit set out in harmonised standard EN 50566:2017, is in compliance with the essential requirement set out in Article 3(1), point (a), of Directive 2014/53/EU regarding protection of health and safety of persons and domestic animals as far as the SAR limit value for limb is concerned.
(79) It is also unquestionable that a significant exceedance of the limb SAR limit value (over 40 %), as it results from the tests carried out by CETECOM on iPhone 12 A2403, would demonstrate that the device concerned is non-compliant with the essential requirement in question.
(80) As regards the SAR measurements to demonstrate equipment compliance, harmonised standard EN 50566:2017 provides that they are to be performed according to EN 62209-2:2010, Clauses 5 and 6. EN 62209-2:2010 does not, however, set out a measurement methodology for mobile communication devices featuring certain advanced functionalities that can be relevant as regards limb SAR measurement. Since the iPhone 12 A2403 has this kind of features, the development of a specific testing protocol was necessary.
(81) Firstly, the Commission agrees with the assessment and conclusion of ANFR, as described in recital 22, that protocol 1 is not an acceptable testing method.
(82) More specifically, Apple stated that SAR measurement requires the use of proprietary testing tools. Apple also indicated that the use of such tools was recommended by a manufacturer of SAR testing equipment. However, the Commission considers that the guidance issued by a testing equipment manufacturer does not have any binding value. Additionally, the Commission observes that the use of proprietary tools, especially when the algorithm governing the tools is not disclosed, is deemed inappropriate for the independent evaluation of SAR. Further, the use of proprietary engineering tools to measure the compliance of radio equipment with the relevant essential requirements not only does not ensure that the device is tested in foreseeable conditions of use, in particular when it comes to limb measurements, but also does not provide the necessary transparency and independence required in the context of market surveillance activities.
(83) Moreover, the Commission considers that the configuration suggested by Apple to ensure that the emission came only from one preselected antenna of the iPhone 12 A2403 was not duly justified.
(84) Additionally, even if harmonised standard EN 50566:2017 allows for a testing distance between 0 and 5 mm, the worst-case scenario should be considered. In other words, should the SAR level be higher at 0 mm than at 5 mm, the former testing distance should be used. Additionally, the Radio Equipment Directive Compliance Association (REDCA), formed pursuant to Article 38 of Directive 2014/53/EU, in its technical guidance note (TGN) 20, titled ‘SAR Testing and Assessment Guidance’, considers the test separation distance for head SAR, limb SAR and SAR in known accessories to be typically 0 mm or ‘contact’.
(85) Secondly, following the agreement of protocol 2 by ANFR and Apple, the Commission has evaluated the tests conducted by ANFR and the details provided by the concerned parties, in relation to iPhone 12 A2403, on the basis of extensive consultations with ANFR, ComReg and Apple.
(86) Both Apple and ANFR agreed to use protocol 2 as an alternative to the use of Apple’s proprietary testing tool.
(87) ANFR, using the services of CETECOM and carrying out measurements as set out in protocol 2, concluded that:—Prior to the software update, the iPhone 12 A2403 exceeded the limb SAR limit value as set out in harmonised standard EN 50566:2017.—After the software update, the iPhone 12 A2403 no longer exceeded the limb SAR limit value as set out in harmonised standard EN 50566:2017 when operating in cellular networks located in the French territory. — Prior to the software update, the iPhone 12 A2403 exceeded the limb SAR limit value as set out in harmonised standard EN 50566:2017. — After the software update, the iPhone 12 A2403 no longer exceeded the limb SAR limit value as set out in harmonised standard EN 50566:2017 when operating in cellular networks located in the French territory.
— Prior to the software update, the iPhone 12 A2403 exceeded the limb SAR limit value as set out in harmonised standard EN 50566:2017.
— After the software update, the iPhone 12 A2403 no longer exceeded the limb SAR limit value as set out in harmonised standard EN 50566:2017 when operating in cellular networks located in the French territory.
— Prior to the software update, the iPhone 12 A2403 exceeded the limb SAR limit value as set out in harmonised standard EN 50566:2017.
— After the software update, the iPhone 12 A2403 no longer exceeded the limb SAR limit value as set out in harmonised standard EN 50566:2017 when operating in cellular networks located in the French territory.
(88) Apple challenged the non-compliance result of the tests performed by CETECOM by stating that the device was set in a position that prevented the person performing the test from manually pushing the volume buttons to trigger the ‘Body Detect’ function as agreed in protocol 2. However, Apple did not substantiate this statement with any irrefutable evidence. Additionally, CETECOM, which is an accredited laboratory and thus a laboratory independently evaluated by an accreditation body, did not report any issues with pushing the volume button during the test and consequently triggering the ‘Body Detect’ function during the tests.
(89) Additionally, Apple indicated that CETECOM incorrectly added the SAR values of the 4G and 5G bands. That claim is deemed irrelevant since CETECOM confirmed to the Commission that the iPhone 12 A2403 exceeded the SAR limit in the 4G band alone.
(90) Apart from the concerns raised by Apple on the tests performed by CETECOM, no evidence has been identified to conclude that harmonised standard EN 50566:2017 or those tests had not been correctly applied by CETECOM.
(91) The Commission thus considers that iPhone 12 A2403 devices that do not operate with the software update iOS 17.1 are not compliant with the applicable limb SAR limit values. Therefore, such devices are not compliant with the health and safety essential requirement set out in Article 3(1), point (a), of Directive 2014/53/EU.
(92) The Commission further considers that iPhone 12 A2403 devices that operate with the software update iOS 17.1 are compliant with the applicable limb SAR limit values when the updated functionalities are fully operational, more specifically, when the software update modifies the functioning of the ‘Body Detect’ algorithm developed by Apple (iOS 17.1), by setting, in practice, the iPhone 12 A2403 in a permanent ‘on-body’ state. In that way, the software update reduces the device’s transmission power.
(93) According to the Court in its judgment of 13 September 2023, in Case T-349/21(23), in market surveillance investigations and national safeguard measures, the burden of proving that a product is not compliant with the law lies with the Member State. The Commission considers that France has met that burden of proof, as it has demonstrated the need to adopt the national measure, by testing the device and providing documented information and details.
(94) Moreover, in light of the principle of proportionality, the seriousness of the identified risks is to be weighed against the cost of the corrective measures to be applied to the product concerned (judgment in case T-152/19(24), paragraph 78). In that respect, it should be noted that iPhone 12 A2403 is an old model and is no longer placed on the Union market by Apple, although some iPhones 12 A2403 devices might still be made available by retailers. In addition, Apple can avoid the cost of withdrawal by ensuring that iPhone 12 A2403 meets the SAR levels for limb according to the protocol 2, by deploying the already developed software ensuring that those limits are respected. That software was, however, made available only for iPhones 12 A2403 operating in France, and not for any iPhone 12 A2403 operating in Member States other than France.
(95) Concerning an area in which the Commission is required to carry out complex technical assessments, in particular in order to assess the justification of national measures taken pursuant to the Union harmonisation legislation, it is allowed a broad discretion with regard to those assessments (judgment in Case T-349/21, paragraph 65).
(96) Based on the evidence available, and following a thorough assessment of the arguments of all involved parties, the technical merits of the case and the principle of proportionality, the Commission concludes that iPhone 12 A2403, when running an operating system without the software activating permanently the ‘on-body’ state of the ‘Body Detect’ function, is not compliant with the essential requirement set out in Article 3(1), point (a), of Directive 2014/53/EU.
(97) Therefore, the Commission considers that the national measure is justified.
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Directive 2014/53/EU of the European Parliament and of the Council of 16 April 2014 on the harmonisation of the laws of the Member States relating to the making available on the market of radio equipment and repealing Directive 1999/5/EC (1), and in particular Article 41(1) thereof,
Whereas:
1. PROCEDURE
(1) On 5 October 2023, France, via its relevant market surveillance authority, Agence Nationale des Fréquences (‘ANFR’), notified, in accordance with Article 40(4) of Directive 2014/53/EU and via the information and communication system referred to in Article 34(1) of Regulation (EU) 2019/1020 of the European Parliament and of the Council (2) (‘ICSMS’), a measure to have the mobile phone ‘iPhone 12 A2403’ manufactured by Apple Inc. (‘Apple’) withdrawn from the French market (3) (‘the national measure’).
(2) France, via ANFR, adopted the national measure on the grounds that the iPhone 12 A2403 exceeds the limit value of 4 W/kg, the limit value for specific absorption rate (SAR) on limbs set out in harmonised standard EN 50566:2017 (4) which reflects the limits established in Council Recommendation 1999/519/EC (5). In accordance with Article 16 of Directive 2014/53/EU, that harmonised standard confers, if it is applied by a manufacturer (6), a presumption of conformity with the corresponding essential requirements. SAR is the rate at which electromagnetic energy emitted by a wireless device is absorbed by the human body expressed in power absorbed per unit mass of tissue (W/kg) (7).
(3) ANFR indicated that the non-compliance with that limit value did not affect the iPhone 12 models Mini, Pro and Pro Max. ANFR concluded that the iPhone 12 A2403 is not compliant with the essential requirement set out in Article 3(1), point (a), of Directive 2014/53/EU, relating to the protection of health and safety of persons and domestic animals.
(4) Given that the national measure was communicated to the Commission and to Member States on 5 October 2023, an objection against that measure could be raised until 3 January 2024, in accordance with Article 40(7) of Directive 2014/53/EU.
(5) On 24 October 2023, Ireland, via its relevant market surveillance authority, the Commission for Communications Regulation (‘ComReg’), submitted via ICSMS an objection with respect to the national measure.
(6) In that formal objection, ComReg concluded that the iPhone 12 A2403 was compliant with the essential requirements laid down in Directive 2014/53/EU.
(7) Following the objection raised against the national measure in accordance with Article 40(7) of Directive 2014/53/EU, the Commission entered into consultation with ANFR, ComReg and Apple to evaluate the national measure as provided for in Article 41(1), first subparagraph, of that Directive.
(8) In a meeting of the Administrative Cooperation Group of market surveillance authorities in the sector of the radio equipment (ADCO RED) that took place on 18 and 19 October 2023, ANFR presented the national measure to the market surveillance authorities of the Member States. The Commission attended the meeting as an observer.
(9) In the online meeting of the Telecommunication Conformity Assessment and Market Surveillance Committee (TCAM), held on 30 November 2023, ANFR presented an overview of the national measure to the Member States. The Commission provided an explanation of the safeguard clause procedure under Chapter V of Directive 2014/53/EU.
(10) On 30 November and 1 December 2023, an online meeting of the Commission expert group on radio equipment (E03587) was held. Apple was invited to participate in the discussion on the iPhone 12 A2403 that took place during that meeting. More specifically, Apple stated that the tests performed by ANFR do not reflect the intended use of the product and they can lead to potential erroneous results.
(11) On 5 January 2024, ANFR sent a letter to the Commission expressing the view that the objection raised by ComReg in relation to the national measure should not be upheld.
(12) By letter dated 8 March 2024, the Commission invited the ANFR to submit their observations and reply to several questions regarding the national measure. ANFR replied by email on 25 March 2024. Following supplementary questions raised by the Commission on 3 May 2024, ANFR sent additional information by email on 14 May 2024. On the same date, an online meeting took place between the Commission and ANFR, in which the independent laboratory CETECOM ADVANCED GmbH (‘CETECOM’), accredited under the standard EN ISO/IEC 17025:2017 (8), also participated. During that online meeting, and also by email sent on the same date, the Commission informed ANFR about the validity of the objection raised by ComReg.
(13) By letter of 22 April 2024, the Commission invited Apple to submit its observations on the national measure and to reply to questions in order to clarify its position and observations. Apple submitted its observations and replies by email on 12 May 2024. As a follow-up, the Commission and Apple held an online meeting on 4 June 2024. On 3 June 2024, the Commission sent further questions to Apple on various technical elements to which Apple sent replies and clarifications on 18 June 2024 by email.
(14) On 4 July 2024, the Commission held an online meeting with ComReg to discuss the national measure. ComReg submitted a written statement on 8 July 2024. That statement underlined that the iPhone 12 A2403 had been tested by Apple in cooperation with a notified body and was found to be within the SAR limb limits (9).
2. BACKGROUND
(15) The iPhone 12 A2403 model was released on the Union market in October 2020. It is the first iPhone model equipped with 5G technology and, when ANFR notified the national measure, it was still sold on the Union market.
(16) Apple incorporated in the iPhone 12 A2403 the so-called ‘Body Detect’ function. By means of that mechanism, when the device detects movement, it considers that it is being used in contact with the human body, thus setting the ‘Body Detect’ function to ‘on-body’ state. The objective is to lead to a reduction of emitted power and, in turn, to a reduction of the average SAR level so that the said device meets the relevant SAR limits set out in harmonised standard EN 50566:2017.
(17) In July 2022, ANFR conducted the first SAR measurements on the iPhone 12 A2403, for determining if the device meets the limits set out in harmonised standard EN 50566:2017.
(18) ANFR concluded, after carrying out the SAR measurement, that the device exceeded the limb SAR limit set out in the relevant harmonised standard. According to harmonised standard EN 50566:2017, the limb SAR limit is set at 4 W/kg. ANFR concluded that the limb SAR measurement presented a retained value of 5,615 W/kg, thus significantly beyond the standard’s limit.
(19) Apple disputed those conclusions, by claiming the following:
—
The laboratory conducting the test for France had clamped the iPhone 12 A2403 tightly against the SAR phantom (10). According to Apple, this configuration might prevent the iPhone 12 A2403 from triggering the ‘Body Detect’ algorithm and might lead to a potential lack of compliance with the SAR limit.
—
Apple’s proprietary engineering tools are necessary to ensure that the power control algorithms of the iPhone 12 A2403 do not produce inaccurate results.
(20) Following discussions between ANFR and Apple, the latter suggested to repeat the SAR measurements under a specific testing procedure (so-called ‘protocol 1’), which was communicated to ANFR in February 2023.
(21) Protocol 1 had the following characteristics:
—
A separation distance of 1 mm between the device and the phantom.
—
An external proprietary motorised system attached to the device to produce artificial vibrations in order to properly simulate and trigger the ‘Body Detect’ function.
—
The set-up of a specific testing configuration to carry out a stable and accurate measurement and to ensure that the emission came only from one preselected antenna of the iPhone 12 A2403 under test.
(22) ANFR did not accept protocol 1 on the following grounds:
—
The maximum SAR emitted by the device is more likely to occur at a distance of 0 mm from the device.
—
Attaching a motorised system to the device was considered as an artificial mechanism that might not reflect the real use conditions of the product.
—
The testing configuration used to ensure that the emission came only from one preselected antenna of the device could have an undetermined impact on SAR measurements.
(23) In June 2023, due to the lack of agreement between ANFR and Apple on protocol 1, Apple proposed a second measurement procedure (so-called ‘protocol 2’), which had the following characteristics:
—
A separation distance of 0 mm between the device and the phantom.
—
The triggering of the ‘Body Detect’ algorithm by pressing the volume button of the iPhone 12 A2403 every 20 seconds.
—
In order to ensure that the emission came only from one preselected antenna of the iPhone 12 A2403, the use of, two alternative methods: either the one already proposed under protocol 1 or another method involving a specific placing of the network simulator’s antenna (11).
(24) ANFR accepted the measurement procedure described in protocol 2 and decided to use the method involving a specific placing of the network simulator’s antenna.
(25) In August 2023, ANFR requested CETECOM to conduct SAR measurements on the iPhone 12 A2403 in accordance with protocol 2 on different samples. CETECOM concluded that the iPhone 12 A2403 remained non-compliant under protocol 2 (5,740 W/kg).
(26) On 12 September 2023, France, via ANFR, adopted a national decision ordering the withdrawal from the French market of the iPhone 12 A2403. That decision was adopted on the grounds that Apple refused to offer a software update to make the product compliant, as other manufacturers usually do, according to ANFR.
(27) Following the concerns expressed by ANFR and the subsequent adoption of a restrictive measure, Apple indicated it would release a software update for the iPhone 12 A2403 users in France to permanently activate the ‘on-body’ state of the ‘Body Detect’ function. That update to the iPhone 12 A2403 would reduce the emitted power, and in turn the SAR level, on a permanent basis. Apple added that that update would not be made available in other Member States since it considered that the iPhone 12 A2403 was compliant with Directive 2014/53/EU and that the national measure was groundless.
(28) New measurements conducted by CETECOM in September 2023 showed the compliance of the iPhone 12 A2403 running the updated software (iOS 17.1) with the SAR limit value set out in harmonised standard EN 50566:2017. Those measurements were carried out with test equipment simulating a mobile network located in France.
(29) Following the release of the software update, ANFR considered that the devices for which the updated software (iOS 17.1) was operational to permanently activate the ‘on-body’ state of the ‘Body Detect’ function were in compliance as it was demonstrated that such devices meet the relevant SAR limit set out in harmonised standard EN 50566:2017.
(30) ANFR, however indicated that it was informed by Apple, on 4 October 2023, that the corrective software update would only be operational on the French territory. During the meeting of the Commission services with Apple, held on 4 June 2024, Apple confirmed that the corrective software update would only be operational on the French territory.
(31) Article 40(3) of Directive 2014/53/EU requires that a corrective action is taken in respect of non-compliant radio equipment throughout the Union. If the action taken for devices found not to be compliant consists of implementing, for example, a software update, that action can be considered corrective if the software update, i.e. corrective software, is made available and being operational in the entire Union and it is thus made available for all related devices operating in the Union.
(32) In this context, the action taken for the iPhone 12 A2403 devices, to implement a software update to ensure that the ‘on-body’ state of the ‘Body Detect’ function is permanently activated, so that the said devices can meet the relevant SAR limits and can thus be compliant, can be considered corrective only when that software update is made available in all the Union territory. Therefore, such devices are considered non-compliant not only when they do not have such a corrective software installed but also when such a software is installed but the permanent activation of the ‘Body Detect Function’ is operational only in France, and not in the entire Union.
(33) On 5 October 2023, ANFR encoded the national measure on ICSMS, initiating the three-month objection period in relation to iPhones 12 A2403 operating without the software update (iOS 17.1) and as a result the ‘on-body’ state of the ‘Body Detect’ function is not permanently activated.
3. ARGUMENTS OF THE PARTIES
3.1. ANFR
3.1.1. Procedural point
(34) By letter of 5 January 2024, sent by ANFR to the Commission, ANFR expressed the view that the objection raised by Ireland, via ComReg, in relation to the national measure should not be upheld.
(35) According to ANFR, that objection is not substantiated and is based only on an analysis of the technical documentation as well as on the measurement reports carried out by a notified body and communicated by the manufacturer. In other words, ANFR stated that the relevant Irish authorities neither conducted a technical investigation nor performed any tests.
3.1.2. Substantive points
(36) ANFR first referred to the general context for SAR measurements and explained that the latter are carried out systematically for head, body and limbs for smartphones. Then, ANFR provided an overview of the chain of events and facts, i.e. the specific dates when relevant tests were carried out and measures taken, which are summarised in the previous section.
(37) ANFR underlined that the SAR measurements are carried out through an accredited laboratory and that there are no specific national regulations applicable in France on SAR, outlining that, with respect to SAR measurements, the limits set out in Recommendation 1999/519/EC, which correspond to the limits set out in harmonised standard EN 50566:2017, are applied and followed when a laboratory carries out tests for ANFR. Moreover, it was indicated by ANFR that the tests for the iPhone 12 A2403 were carried out by CETECOM, which is accredited under the standard EN ISO/IEC 17025.
(38) In addition, in reply to questions submitted by the Commission services, ANFR provided the following details concerning the SAR measurements carried out in France:
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Many smartphones incorporate motion sensors, however such information must be included in their technical file.
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Before SAR measurements are carried out, ANFR asks the manufacturer to provide the full technical file, which must include the test reports drawn up by the manufacturer and a description of the operation of the device in question.
—
If the device incorporates a motion sensor-based power control device, its algorithm is to be described in the technical file.
—
After analysing the algorithm, the latter will be taken into account in the measurements, but only if it can ensure conformity with Directive 2014/53/EU, in particular, for safety, as regards the reasonably foreseeable use of the device, as provided for in Article 17(1) of that Directive.
—
Since the devices incorporate power control mechanisms, they need to be tested by using Time Averaged SAR (TAS) procedure.
(39) ANFR indicated that the iPhone 12 A2403 reduces the emitted power when it detects movement because, in such a case, the device considers that it is being used in contact with the human body. That approach reflects the reasonably foreseeable use of the product, according to the manufacturer. ANFR did not challenge the described power control technique as a concept. Nevertheless, ANFR considered that it was not properly configured. More specifically, it was observed by ANFR that the device does not always reduce sufficiently the power when it detects movement.
(40) According to ANFR, CETECOM performed the first SAR measurement on the iPhone 12 A2403 in July 2022, leading to a result that exceeded the limb SAR limit. More specifically, as stated by ANFR, the limb SAR measurement presented a retained value of 5,615 W/kg.
(41) For that SAR measurement, ANFR took the following position:
—
The measurement was carried out without taking into consideration the device mechanisms for power control.
—
Since the technical documentation submitted by Apple did not mention the presence of a motion sensor, or a specific power control algorithm, those measurements were carried out without taking into account the device mechanisms allowing power control.
(42) ANFR then referred to protocol 1 proposed by Apple. ANFR clarified that the specific configuration to ensure that the maximum power is measured, as proposed under protocol 1, did not represent the reasonably foreseeable use, and it could be considered as an artificial way to pass the test.
(43) ANFR confirmed that, following the rejection of protocol 1, Apple proposed protocol 2. According to ANFR, that protocol was more in line with what is expected from a test taking into consideration the reasonably foreseeable conditions. However, by following protocol 2, ANFR noted that the limb SAR measurement performed by the accredited laboratory CETECOM showed the persistence of the non-compliance. The limit of 4 W/kg was exceeded by simulating the use of the iPhone 12 A2403 in France, more specifically, the limb SAR measured presented a retained value of 5,740 W/kg (12) (while the first measurement carried out presented a value of 5,615 W/kg) (13). Additional tests performed by ANFR concluded that the limb SAR exceeded the recommended value by simulating the use of the iPhone 12 in two other Member States.
(44) Additionally, ANFR tested in their internal laboratory (14) a different sample using the same protocol 2, which also resulted in non-compliance with the limb SAR limit value.
(45) As regards the new updated software offered by Apple, ANFR stated that a national decision taking a provisional measure was adopted ordering the withdrawal from the French market of the iPhone 12 A2403. The national decision was adopted on the grounds that, as stated by ANFR, Apple repeatedly refused to offer a software update to make the product compliant, as other manufacturers usually do.
(46) ANFR confirmed that the corrective software that was finally provided by Apple can be acceptable and can ensure compliance with the health and safety essential requirements set out in Directive 2014/53/EU. More specifically, the concrete measure implemented in this software limits the power of the device in all cases of use, thus restoring compliance and no longer making compliance of the device dependent on its performance in detecting the human body. ANFR noted that Apple provided the corrective software update only for iPhones 12 A2403 that operated on the French market and for this reason the national measure was encoded on ICSMS, initiating the three-month objection period.
3.2. ComReg
(47) According to the objection raised by Ireland, via ComReg, a preliminary investigation into the iPhone 12 A2403 was carried out by ComReg, which received documentation and technical testing results from Apple demonstrating that that radio equipment is compliant with the essential requirements set out in Directive 2014/53/EU. More specifically, the objection submitted by Ireland, via ComReg, was as follows:
‘
ComReg objects to the measure taken by the ANFR in respect of the Apple iPhone 12 on the 12 September 2023 on the grounds outlined below:
1.
On the 12 September 2023, the ANFR, the Market Surveillance Authority for Directive 2014/53/EU in France, took a measure to have the Apple iPhone12 withdrawn from the market in France having found that testing measures showed the specific absorption rate (SAR) exceeds the set limits. This is a procedure provided for under Article 40 of the Directive.
In accordance with Article 40.4, ANFR informed the Commission and the other Member States of this measure on 5 October 2023 by placing the requisite information on ICSMS.
2.
ComReg has carried out a preliminary investigation into the radio equipment in question. ComReg has received documentation and technical testing results from the economic operator demonstrating that the radio equipment is compliant with the essential requirements of the Directive. In particular, ComReg notes that when the iPhone12 was tested by Apple at a registered Notified Body, the product was found to be within the SAR Limb guidelines. ComReg has not carried out any technical testing on the iPhone12.
3.
Common standards across the Union ensure interoperability and safety, reduce costs and facilitate companies’ integration in the value chain and trade. Under the circumstances, ComReg believes that it would be appropriate for the European Commission to evaluate the national measure in question, and in particular the testing undertaken, and provide a common position to assist MSAs’.
(48) ComReg noted that, when the iPhone 12 A2403 was tested by Apple in cooperation with a registered notified body (15), the device was found to be within the SAR limb limit. ComReg did not, however, carry out any technical testing on the iPhone 12 A2403. Moreover, ComReg did not point to any shortcomings of harmonised standard EN 50566:2017 with respect to its purpose of providing presumption of conformity with the essential requirement that it aims to cover and demonstrating, when that harmonised standard is applied, compliance with the essential requirement under Article 3(1), point (a), of Directive 2014/53/EU.
3.3. Apple
(49) According to Apple, the iPhone 12 A2403 is safe to use and has always been so. Particularly, according to Apple, the iPhone 12 A2403, which was launched in 2020, was certified and recognised as compliant with all applicable SAR regulations and standards around the world. Apple added that its power control mechanism has not been updated in any way since its launch.
(50) Apple informed the Commission that the iPhone 12 A2403 is equipped with technical mechanisms which control the emitted power based on certain parameters. The SAR level is, in turn, controlled by those mechanisms. The functioning of the latter is Apple-proprietary and was not disclosed in full to the Commission.
(51) According to Apple, the finding of ANFR on the iPhone 12 A2403 is not a compliance concern, rather a consequence of an alleged erroneous implementation of the testing protocol. More specifically, Apple considers that the test performed by ANFR does not trigger the power control mechanism in a proper way, leading to a potential lack of compliance with the SAR limb limit. Apple stated that the iPhone 12 A2403 passed a test at 5 mm separation distance (allowed by harmonised standard EN 50566:2017), executed by ANFR on 21 December 2021. Apple stated that the iPhone 12 A2403 did not comply with the test procedure performed by ANFR only for the limb exposure at 0 mm when the phone was clamped tightly to the flat phantom. The latter scenario, according to Apple, does not reflect the intended use of the device since it does not create any movement to activate the ‘Body Detect’ functionality. In other words, as noted by Apple, in the described scenario, the contact with the human body is not properly simulated.
(52) Apple added that the ‘Body Detect’ function has been used in all iPhones for over a decade and has been thoroughly tested and certified to be an effective mechanism of power control to comply with SAR requirements. Apple indicated that they provided ANFR with several reports of tests performed by independent third-party laboratories, which proved the appropriate functioning of the ‘Body Detect’ function, which proved, in turn, the compliance with SAR limb limits.
(53) Apple indicated that it developed a proprietary testing tool to activate the ‘Body Detect’ function during the tests, underling that such a tool is deemed necessary. Apple also indicated that the use of such tool was recommended by a manufacturer of SAR testing equipment.
(54) Apple considered that the tests performed by or on behalf of ANFR under protocol 2 were erroneous on the following grounds:
—
CETECOM added the SAR values of the 4G and 5G bands while the radiation patterns demonstrated that there was no spatial overlapping between these two technologies and, therefore, the values could not be added.
—
The iPhone 12 was set in a position that prevented the person performing the test from manually pushing the volume buttons as agreed in protocol 2 and leading to a lack of triggering of the ‘Body Detect’ function.
4. COMMISSION’S ASSESSMENT
4.1. Procedure
(55) The Commission first examined the view expressed by ANFR, in its letter of 5 January 2024, that the objection raised by Ireland, via ComReg, in relation to the national measure should not be upheld because of the lack of a deep investigation by the relevant Irish authorities.
(56) Under Article 40(7) of Directive 2014/53/EU, in the case where no objection has been raised by a Member State or the Commission, as specified in that provision, Member States are to ensure that appropriate restrictive measures, such as withdrawal of the radio equipment from the market, are taken in respect of the radio equipment concerned, without delay. However, according to Article 41(1) of Directive 2014/53/EU, if an objection has been raised, the Commission is to without delay enter into consultation with the Member States and the relevant economic operator and is to evaluate the national measure. On the basis of the results of that evaluation, the Commission is to adopt an implementing act determining whether the national measure is justified or not.
(57) While it is not disputed that the objection raised by Ireland, via ComReg, does not include technical details or technical justifications, based on Article 40(6) and (7) of Directive 2014/53/EU and considering the relevant case-law (in particular Case T-349/21 (16)), the objection raised by Ireland, via ComReg, is sufficient to trigger the Commission’s obligation referred to in Articles 40(7) and 41(1) of that Directive to issue an implementing decision under Article 41(1) of that Directive.
(58) In Case T-349/21 the General Court stated that Directive 2014/33/EU of the European Parliament and of the Council (17) does not lay down any particular format requirements as regards the way in which objections may be formulated by a Member State. Similarly, Directive 2014/53/EU does not impose any specific format on how such objections can be formulated, and so the Court’s finding can be applied to it.
(59) Under Article 34 of Regulation (EU) 2019/1020, objections raised by Member States in accordance with the applicable safeguard procedure in the Union harmonisation legislation applicable to the product, and any subsequent follow-up are to be entered into the information and communication system referred to in that Article (i.e. the ICSMS). In this respect, Ireland, via ComReg, has entered the objection it raised in relation to the national measure in ICSMS.
(60) During the online meeting of 14 May 2024 with the ANFR, and also by email sent on the same date, the Commission informed ANFR about the validity of the objection raised by ComReg and of the obligation for the Commission to issue an implementing decision.
4.2. Observations in relation to the corrective software
(61) Due to the concerns expressed by ANFR, and the subsequent national measure, Apple released a software update for iPhone 12 A2403 users in France to permanently activate the ‘on-body’ state of the ‘Body Detect’ function.
(62) The described modifications to the functioning of the ‘Body Detect’ function only took place on iPhone 12 A2403 devices operating in cellular networks located in France (18). According to Apple, the update would not be made available for all Union users since Apple considered that the iPhone was compliant with Directive 2014/53/EU and the national measure was groundless.
(63) The Commission observes that, following the release of the software update, and as confirmed by the additional tests carried out by ANFR, the iPhone 12 A2403’s behaviour related to SAR remained unchanged in the rest of the Union. Therefore, the potential lack of compliance would remain in the majority of the Union.
(64) Under Article 40(3) of Directive 2014/53/EU, any corrective action must be available throughout the Union. Therefore, the corrective measures taken by Apple, by making available the new software (iOS 17.1) activating permanently the ‘on-body’ state of the ‘Body Detect’ function only on devices operating in cellular networks located in France, are not in line with that Article.
(65) As the national measure in relation to the iPhone 12 A2403 operation without the software update, so that the ‘on-body’ state of the ‘Body Detect’ function is being permanently activated, was encoded in the ICSMS and has not been withdrawn by France, the Commission’s obligation to issue an implementing decision under Article 41(1) of Directive 2014/53/EU remains.
4.3. Substantive points
4.3.1. Radio Equipment Directive provisions
(66) Directive 2014/53/EU establishes a regulatory framework for the making available on the market and putting into service of radio equipment in the Union.
(67) Article 6 of Directive 2014/53/EU requires Member States to take appropriate measures to ensure that radio equipment is made available on the market only if it complies with that Directive. In addition, according to Article 9 of Directive 2014/53/EU, Member States are not to impede, for reasons relating to aspects covered by that Directive, the making available on the market in their territory of radio equipment which complies with that Directive.
(68) The obligations of manufacturers when placing on the Union market radio equipment are set out in Article 10 of Directive 2014/53/EU. Article 10 of that Directive requires, among other things, that manufacturers, when placing their radio equipment on the market, ensure that it has been designed and manufactured in accordance with the essential requirements set out in Article 3 of that Directive.
(69) Article 3 of Directive 2014/53/EU sets out essential requirements to ensure the protection of health and safety, as well as of certain other aspects of public interest protection. According to Article 3(1), point (a), of that Directive, radio equipment is to be constructed so as to ensure the protection of health and safety of persons and of domestic animals and the protection of property, including the objectives with respect to safety requirements set out in Directive 2014/35/EU of the European Parliament and of the Council (19), but with no voltage limit applying. Under point 2(b) of Annex I to Directive 2014/35/EU measures of technical nature must be taken so that radiation which would cause a danger is not produced.
(70) As provided for in Article 17(1) of Directive 2014/53/EU, a manufacturer is to perform a conformity assessment of the radio equipment with a view to meeting the essential requirements set out in Article 3 of that Directive. The conformity assessment is to take into account all intended operating conditions and, for the essential requirement set out in Article 3(1), point (a), of that Directive, i.e. the essential requirements relating to health and safety, the assessment is also to take into account the reasonably foreseeable conditions. In addition, where the radio equipment is capable of taking different configurations, the conformity assessment is to confirm whether the radio equipment meets the essential requirements set out in Article 3 of that Directive in all possible configurations.
(71) Under Article 40(1) of Directive 2014/53/EU, where the market surveillance authorities of a Member State have sufficient reason to believe that radio equipment covered by that Directive presents a risk to the health or safety of persons or to other aspects of public interest protection covered by that Directive, or following the amendments introduced by Directive (EU) 2022/2380 of the European Parliament and of the Council (20) that it does not comply with at least one of the applicable essential requirements set out in Article 3 of Directive 2014/53/EU, they are to carry out an evaluation in relation to the radio equipment concerned covering all relevant requirements laid down in Directive 2014/53/EU. If the market surveillance authorities find that the radio equipment does not comply with the requirements laid down in Directive 2014/53/EU, they are to without delay require the relevant economic operator to take all appropriate corrective actions to bring the radio equipment into compliance with those requirements, to withdraw the radio equipment from the market, or to recall it within a reasonable period, commensurate with the nature of the risk, as they may prescribe.
4.3.2. SAR limits
(72) Recommendation 1999/519/EC sets out limits for the exposure of the general public to electromagnetic fields in line with the International Commission on Non-Ionizing Radiation Protection (ICNIRP) guidelines. For radio equipment placed on the Union market and intended for use by the general public, those limits are set out in the harmonised standards drafted in support of Directive 2014/53/EU (21) and published in the Official Journal of the European Union by Commission Implementing Decision (EU) 2022/2191 (22).
(73) Pursuant to Article 16 of Directive 2014/53/EU, radio equipment which conforms with harmonised standards (or parts thereof), of which the references have been published in the Official Journal of the European Union, are presumed to be in conformity with the corresponding essential requirements set out in Article 3 of that Directive.
(74) Harmonised standard EN 50566:2017, which confers a presumption of conformity with the essential requirement that it aims to cover, sets out the limb SAR limit value at 4W/kg, reflecting the relevant limit established in Council Recommendation 1999/519/EC, for the purpose of demonstrating compliance with the essential requirement relating to human and animal health referred to in Article 3(1), point (a), of Directive 2014/53/EU, as far as the SAR limit value for limb is concerned.
(75) Apple’s EU declaration of conformity for the iPhone 12 A2403, which is drawn up pursuant to Article 18 of Directive 2014/53/EU, referred to that harmonised standard and therefore Apple had applied that harmonised standard, which confers a presumption of conformity with the essential requirement that it aims to cover, for demonstrating conformity with the essential requirement in question.
(76) The fact that a device, by meeting the limb SAR limit value set out in harmonised standard EN 50566:2017, which reflects the relevant limit established in Council Recommendation 1999/519/EC, can be in conformity with the essential requirement relating to human and animal health referred to in Article 3(1), point (a), of Directive 2014/53/EU, as far as the SAR limit value for limb is concerned, was not disputed by Member States.
(77) Moreover, during the online meetings held with Apple, mentioned above, the latter has never indicated that the limits, as set out in harmonised standard EN 50566:2017, are disputed. Additionally, Apple has not questioned the fact that that such exceedance for the limb SAR limit would imply non-compliance with the said essential requirement under Article 3(1), point (a), of Directive 2014/53/EU, as such, but focused instead on questioning the way in which the measurement protocol 2 was applied by or on behalf of ANFR.
(78) It is thus undisputed that a device, when it meets the relevant limb SAR limit set out in harmonised standard EN 50566:2017, is in compliance with the essential requirement set out in Article 3(1), point (a), of Directive 2014/53/EU regarding protection of health and safety of persons and domestic animals as far as the SAR limit value for limb is concerned.
(79) It is also unquestionable that a significant exceedance of the limb SAR limit value (over 40 %), as it results from the tests carried out by CETECOM on iPhone 12 A2403, would demonstrate that the device concerned is non-compliant with the essential requirement in question.
(80) As regards the SAR measurements to demonstrate equipment compliance, harmonised standard EN 50566:2017 provides that they are to be performed according to EN 62209-2:2010, Clauses 5 and 6. EN 62209-2:2010 does not, however, set out a measurement methodology for mobile communication devices featuring certain advanced functionalities that can be relevant as regards limb SAR measurement. Since the iPhone 12 A2403 has this kind of features, the development of a specific testing protocol was necessary.
4.3.3. Tests conducted by ANFR
(81) Firstly, the Commission agrees with the assessment and conclusion of ANFR, as described in recital 22, that protocol 1 is not an acceptable testing method.
(82) More specifically, Apple stated that SAR measurement requires the use of proprietary testing tools. Apple also indicated that the use of such tools was recommended by a manufacturer of SAR testing equipment. However, the Commission considers that the guidance issued by a testing equipment manufacturer does not have any binding value. Additionally, the Commission observes that the use of proprietary tools, especially when the algorithm governing the tools is not disclosed, is deemed inappropriate for the independent evaluation of SAR. Further, the use of proprietary engineering tools to measure the compliance of radio equipment with the relevant essential requirements not only does not ensure that the device is tested in foreseeable conditions of use, in particular when it comes to limb measurements, but also does not provide the necessary transparency and independence required in the context of market surveillance activities.
(83) Moreover, the Commission considers that the configuration suggested by Apple to ensure that the emission came only from one preselected antenna of the iPhone 12 A2403 was not duly justified.
(84) Additionally, even if harmonised standard EN 50566:2017 allows for a testing distance between 0 and 5 mm, the worst-case scenario should be considered. In other words, should the SAR level be higher at 0 mm than at 5 mm, the former testing distance should be used. Additionally, the Radio Equipment Directive Compliance Association (REDCA), formed pursuant to Article 38 of Directive 2014/53/EU, in its technical guidance note (TGN) 20, titled ‘SAR Testing and Assessment Guidance’, considers the test separation distance for head SAR, limb SAR and SAR in known accessories to be typically 0 mm or ‘contact’.
(85) Secondly, following the agreement of protocol 2 by ANFR and Apple, the Commission has evaluated the tests conducted by ANFR and the details provided by the concerned parties, in relation to iPhone 12 A2403, on the basis of extensive consultations with ANFR, ComReg and Apple.
(86) Both Apple and ANFR agreed to use protocol 2 as an alternative to the use of Apple’s proprietary testing tool.
(87) ANFR, using the services of CETECOM and carrying out measurements as set out in protocol 2, concluded that:
—
Prior to the software update, the iPhone 12 A2403 exceeded the limb SAR limit value as set out in harmonised standard EN 50566:2017.
—
After the software update, the iPhone 12 A2403 no longer exceeded the limb SAR limit value as set out in harmonised standard EN 50566:2017 when operating in cellular networks located in the French territory.
(88) Apple challenged the non-compliance result of the tests performed by CETECOM by stating that the device was set in a position that prevented the person performing the test from manually pushing the volume buttons to trigger the ‘Body Detect’ function as agreed in protocol 2. However, Apple did not substantiate this statement with any irrefutable evidence. Additionally, CETECOM, which is an accredited laboratory and thus a laboratory independently evaluated by an accreditation body, did not report any issues with pushing the volume button during the test and consequently triggering the ‘Body Detect’ function during the tests.
(89) Additionally, Apple indicated that CETECOM incorrectly added the SAR values of the 4G and 5G bands. That claim is deemed irrelevant since CETECOM confirmed to the Commission that the iPhone 12 A2403 exceeded the SAR limit in the 4G band alone.
(90) Apart from the concerns raised by Apple on the tests performed by CETECOM, no evidence has been identified to conclude that harmonised standard EN 50566:2017 or those tests had not been correctly applied by CETECOM.
(91) The Commission thus considers that iPhone 12 A2403 devices that do not operate with the software update iOS 17.1 are not compliant with the applicable limb SAR limit values. Therefore, such devices are not compliant with the health and safety essential requirement set out in Article 3(1), point (a), of Directive 2014/53/EU.
(92) The Commission further considers that iPhone 12 A2403 devices that operate with the software update iOS 17.1 are compliant with the applicable limb SAR limit values when the updated functionalities are fully operational, more specifically, when the software update modifies the functioning of the ‘Body Detect’ algorithm developed by Apple (iOS 17.1), by setting, in practice, the iPhone 12 A2403 in a permanent ‘on-body’ state. In that way, the software update reduces the device’s transmission power.
4.3.4. The national measure
(93) According to the Court in its judgment of 13 September 2023, in Case T-349/21 (23), in market surveillance investigations and national safeguard measures, the burden of proving that a product is not compliant with the law lies with the Member State. The Commission considers that France has met that burden of proof, as it has demonstrated the need to adopt the national measure, by testing the device and providing documented information and details.
(94) Moreover, in light of the principle of proportionality, the seriousness of the identified risks is to be weighed against the cost of the corrective measures to be applied to the product concerned (judgment in case T-152/19 (24), paragraph 78). In that respect, it should be noted that iPhone 12 A2403 is an old model and is no longer placed on the Union market by Apple, although some iPhones 12 A2403 devices might still be made available by retailers. In addition, Apple can avoid the cost of withdrawal by ensuring that iPhone 12 A2403 meets the SAR levels for limb according to the protocol 2, by deploying the already developed software ensuring that those limits are respected. That software was, however, made available only for iPhones 12 A2403 operating in France, and not for any iPhone 12 A2403 operating in Member States other than France.
5. CONCLUSION
(95) Concerning an area in which the Commission is required to carry out complex technical assessments, in particular in order to assess the justification of national measures taken pursuant to the Union harmonisation legislation, it is allowed a broad discretion with regard to those assessments (judgment in Case T-349/21, paragraph 65).
(96) Based on the evidence available, and following a thorough assessment of the arguments of all involved parties, the technical merits of the case and the principle of proportionality, the Commission concludes that iPhone 12 A2403, when running an operating system without the software activating permanently the ‘on-body’ state of the ‘Body Detect’ function, is not compliant with the essential requirement set out in Article 3(1), point (a), of Directive 2014/53/EU.
(97) Therefore, the Commission considers that the national measure is justified.
HAS ADOPTED THIS DECISION:
The measure taken by France, via its relevant market surveillance authority, Agence Nationale des Fréquences, notified on 5 October 2023, in accordance with Article 40(4) of Directive 2014/53/EU, via the information and communication system referred to in Article 34(1) of Regulation (EU) 2019/1020 (ICSMS) (25), to withdraw iPhone 12 A2403, manufactured by Apple Inc., from the market, is justified.
This Decision is addressed to the Member States.

Council Decision (EU) 2025/1757 of 8 July 2025 on the position to be adopted, on behalf of the European Union, within the EEA Joint Committee concerning the amendment to Annex II (Technical regulations, standards, testing and certification) and Annex IV (Energy) to the EEA Agreement (EED) (Text with EEA relevance)

January 13, 2026
Official Journalof the European Union ENL series
2025/1757 22.8.2025
(1) The Agreement on the European Economic Area(2)(the ‘EEA Agreement’) entered into force on 1 January 1994.
(2) Pursuant to Article 98 of the EEA Agreement, the EEA Joint Committee may decide to amend, inter alia, Annex II (Technical regulations, standards, testing and certification) and Annex IV (Energy) to the EEA Agreement.
(3) Directive 2012/27/EU of the European Parliament and of the Council(3)and Directive (EU) 2018/2002 of the European Parliament and of the Council(4)should be incorporated into the EEA Agreement.
(4) Several provisions of Directive 2012/27/EU as amended by Directive (EU) 2018/2002 require substantive adaptations that reflect the specificities of the EEA Agreement and of the EFTA States.
(5) Since the Union’s energy efficiency headline targets for 2020 and 2030 do not apply to the EFTA States, Article 1(1) of Directive 2012/27/EU as amended by Directive (EU) 2018/2002 and Articles 3(1)(a) and 3(5) of Directive 2012/27/EU should not apply to the EFTA States. However, the EFTA States set out in a voluntary manner their national indicative targets for energy efficiency, as set out in the Declaration of EFTA States attached to the EEA Joint Committee Decision.
(6) Article 5 of Directive 2012/27/EU refers to the minimum energy performance requirements to be complied with based on Article 4 of Directive 2010/31/EU of the European Parliament and of the Council(5). It is appropriate to allow Iceland to fulfil its obligations on the minimum energy performance requirements in central government’s buildings based on its national legislation, given that Iceland has a derogation from incorporating Directive 2010/31/EU into its national law.
(7) It is also appropriate to adapt Article 20(5) of Directive 2012/27/EU, in particular by replacing the reference to Article 5(1) with a more general reference to Article 5 in order to reflect the adaptations made under the latter provisions.
(8) New energy savings to be achieved by Iceland pursuant to Article 7(1) of Directive 2012/27/EU should be set at a level that reflects the specificities of Iceland’s energy market and energy mix.
(9) Given that the Icelandic energy system is isolated, near fossil-free, with high levels of security of supply and energy independence, and relies extensively on renewable geothermal energy with special characteristics, it is appropriate to allow a derogation for Iceland from certain requirements as regards metering set out in Articles 9a, 9b and 9c of Directive 2012/27/EU.
(10) Given that Iceland has no natural gas infrastructure and is exempt from Directive 2009/73/EC on the internal market for natural gas, Articles 9 and 10 of Directive 2012/27/EU as regards metering for natural gas and billing information should not apply to Iceland.
(11) Given that Directive 2004/8/EC of the European Parliament and of the Council(6)does not apply to geothermal cogeneration in Iceland, Article 14 and Article 15 of Directive 2012/27/EU as amended by Directive (EU) 2018/2002 which correlate to Directive 2004/8/EC should not apply to Iceland.
(12) Annex II (Technical regulations, standards, testing and certification) and Annex IV (Energy) to the EEA Agreement should therefore be amended accordingly.
(13) The position of the Union within the EEA Joint Committee should therefore be based on the attached draft decision,
(1) Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 on energy efficiency, amending Directives 2009/125/EC and 2010/30/EU and repealing Directives 2004/8/EC and 2006/32/EC(1)is to be incorporated into the EEA Agreement.
(2) Directive (EU) 2018/2002 of the European Parliament and of the Council of 11 December 2018 amending Directive 2012/27/EU on energy efficiency(2)is to be incorporated into the EEA Agreement.
(3) The EFTA States are not included in the EU energy efficiency headline target of 20 % energy savings by 2020. Article 3 of Directive 2012/27/EU should apply to the EFTA States except for the provisions in Article 3(1)(a) and 3(5).
(4) The EFTA States are not included in the EU energy efficiency 2030 headline targets of at least 32,5 %. Article 1(1) of Directive 2012/27/EU, as amended by Directive (EU) 2018/2002, should therefore not apply to the EFTA States. The EFTA States should instead set national indicative energy efficiency targets for 2030.
(5) The derogations for Iceland aim to ensure that energy efficiency measures are implemented in a cost-effective and appropriate manner to its situation with an isolated and nearly fossil-free energy system, with high levels of security of supply and energy independence. Iceland has an extensive deployment of renewable geothermal energy with special characteristics, which inter alia makes it necessary for Iceland to derogate from certain requirements as regards metering in Articles 9a, 9b and 9c.
(6) Article 5 of Directive 2012/27/EU refers to minimum energy performance standards contained in Article 4 of Directive 2010/31/EU on the energy performance of buildings. Iceland is exempt from applying Directive 2010/31/EU in accordance with Decision of the EEA Joint Committee No 135/2022. Therefore, obligations on the minimum energy performance in buildings shall follow from national legislation in Iceland.
(7) Iceland has a disproportionally high share of energy intensive industry resulting in a savings obligation that is several times higher than the EU average. 88 % of primary energy in Iceland is renewable and the cost of electricity and heat is low, implying fewer cost optimal savings. Therefore, in accordance with Article 7(1), Iceland should achieve new energy savings each year from 1 January 2021 to 31 December 2030 equivalent to 0,24 % of final energy consumption averaged over the most recent three-year period prior to 1 January 2019.
(8) Iceland has no natural gas infrastructure and is exempt from Directive 2009/73/EC on the internal market for natural gas in accordance with Decision of the EEA Joint Committee No 93/2017. Therefore, Articles 9 and 10 of Directive 2012/27/EU as regards metering for natural gas and billing information for natural gas should not apply to Iceland.
(9) Directive 2004/8/EC on the promotion of cogeneration based on a useful heat demand in the internal energy market does not apply to geothermal cogeneration as regards Iceland in accordance with Decision of the EEA Joint Committee No 151/2006. Articles 14 and 15 regarding cogeneration in Directive 2012/27/EU, as amended by Directive (EU) 2018/2002, correlate to the Articles regarding cogeneration in Directive 2004/8/EC. Iceland already covers 90 % of total heat demand with geothermal energy and continues to promote the development of geothermal cogeneration within its national legal framework wherever technically feasible. Therefore, Articles 14 and 15 should not apply to geothermal cogeneration as regards Iceland.
(10) Additional flexibility in the application of Articles 5 and 20 of Directive 2012/27/EU has been agreed. In Article 20(5), the reference to Article 5(1) should be replaced by a reference to Article 5 to allow the obligations of the whole Article 5 to be fulfilled by contributions to a fund.
(11) Directive 2012/27/EU repeals Directive 2004/8/EC(3), which is incorporated into the EEA Agreement and is consequently to be repealed under the EEA Agreement.
(12) Annexes II and IV to the EEA Agreement should therefore be amended accordingly,
— 32012 L 0027: Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 (OJ L 315, 14.11.2012, p. 1).’
1. The text of point 24 (Directive 2004/8/EC of the European Parliament and of the Council) is replaced by the following:‘32012 L 0027: Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 on energy efficiency, amending Directives 2009/125/EC and 2010/30/EU and repealing Directives 2004/8/EC and 2006/32/EC (OJ L 315, 14.11.2012, p. 1), as amended by:—32018 L 2002: Directive (EU) 2018/2002 of the European Parliament and of the Council of 11 December 2018 (OJ L 328, 21.12.2018, p. 210).The provisions of the Directive shall, for the purposes of this Agreement, be read with the following adaptations:(a)Articles 1(1) and 3(1)(a) and third subparagraph of Article 7(1) shall not apply to the EFTA States.(b)In Article 3(5), the following subparagraph shall be added:“Each EFTA State shall set a national indicative energy efficiency target for 2030, based on either primary or final energy consumption, or energy intensity, as part of its respective integrated national energy and climate plan in accordance with Articles 3 and 7 to 12 of Regulation (EU) 2018/1999.”(c)In Article 5(1), the words “, or, as regards Iceland, obligations in accordance with national legislation in Iceland” shall be inserted after the words “Article 4 of Directive 2010/31/EU”.(d)In point (b) of Article 7(1), the following sentence shall be added:“By way of derogation from the requirement in the first sentence of this point, Iceland shall achieve new savings each year from 1 January 2021 to 31 December 2030 equivalent to 0,24 % of annual final energy consumption, averaged over the most recent three-year period prior to 1 January 2019.”(e)Article 9 shall not apply to Iceland as regards metering for gas.(f)In Article 9a(1), the words “, or the equivalent energy consumption as regards Iceland” shall be inserted after the words “actual energy consumption”.(g)Articles 9a and 9c shall not apply to district heating systems in Iceland with fewer than 1 500 end-users.(h)Article 9b shall not apply to Iceland.(i)Article 10 shall not apply to Iceland as regards billing information for gas.(j)In Article 20(5), the reference to Article 5(1) shall be replaced by a reference to Article 5.(k)Articles 14 and 15 shall not apply to Iceland as regards geothermal cogeneration.’ — 32018 L 2002: Directive (EU) 2018/2002 of the European Parliament and of the Council of 11 December 2018 (OJ L 328, 21.12.2018, p. 210). (a) Articles 1(1) and 3(1)(a) and third subparagraph of Article 7(1) shall not apply to the EFTA States. (b) In Article 3(5), the following subparagraph shall be added:“Each EFTA State shall set a national indicative energy efficiency target for 2030, based on either primary or final energy consumption, or energy intensity, as part of its respective integrated national energy and climate plan in accordance with Articles 3 and 7 to 12 of Regulation (EU) 2018/1999.” (c) In Article 5(1), the words “, or, as regards Iceland, obligations in accordance with national legislation in Iceland” shall be inserted after the words “Article 4 of Directive 2010/31/EU”. (d) In point (b) of Article 7(1), the following sentence shall be added:“By way of derogation from the requirement in the first sentence of this point, Iceland shall achieve new savings each year from 1 January 2021 to 31 December 2030 equivalent to 0,24 % of annual final energy consumption, averaged over the most recent three-year period prior to 1 January 2019.” (e) Article 9 shall not apply to Iceland as regards metering for gas. (f) In Article 9a(1), the words “, or the equivalent energy consumption as regards Iceland” shall be inserted after the words “actual energy consumption”. (g) Articles 9a and 9c shall not apply to district heating systems in Iceland with fewer than 1 500 end-users. (h) Article 9b shall not apply to Iceland. (i) Article 10 shall not apply to Iceland as regards billing information for gas. (j) In Article 20(5), the reference to Article 5(1) shall be replaced by a reference to Article 5. (k) Articles 14 and 15 shall not apply to Iceland as regards geothermal cogeneration.’
— 32018 L 2002: Directive (EU) 2018/2002 of the European Parliament and of the Council of 11 December 2018 (OJ L 328, 21.12.2018, p. 210).
(a) Articles 1(1) and 3(1)(a) and third subparagraph of Article 7(1) shall not apply to the EFTA States.
(b) In Article 3(5), the following subparagraph shall be added:“Each EFTA State shall set a national indicative energy efficiency target for 2030, based on either primary or final energy consumption, or energy intensity, as part of its respective integrated national energy and climate plan in accordance with Articles 3 and 7 to 12 of Regulation (EU) 2018/1999.”
(c) In Article 5(1), the words “, or, as regards Iceland, obligations in accordance with national legislation in Iceland” shall be inserted after the words “Article 4 of Directive 2010/31/EU”.
(d) In point (b) of Article 7(1), the following sentence shall be added:“By way of derogation from the requirement in the first sentence of this point, Iceland shall achieve new savings each year from 1 January 2021 to 31 December 2030 equivalent to 0,24 % of annual final energy consumption, averaged over the most recent three-year period prior to 1 January 2019.”
(e) Article 9 shall not apply to Iceland as regards metering for gas.
(f) In Article 9a(1), the words “, or the equivalent energy consumption as regards Iceland” shall be inserted after the words “actual energy consumption”.
(g) Articles 9a and 9c shall not apply to district heating systems in Iceland with fewer than 1 500 end-users.
(h) Article 9b shall not apply to Iceland.
(i) Article 10 shall not apply to Iceland as regards billing information for gas.
(j) In Article 20(5), the reference to Article 5(1) shall be replaced by a reference to Article 5.
(k) Articles 14 and 15 shall not apply to Iceland as regards geothermal cogeneration.’
— 32018 L 2002: Directive (EU) 2018/2002 of the European Parliament and of the Council of 11 December 2018 (OJ L 328, 21.12.2018, p. 210).
(a) Articles 1(1) and 3(1)(a) and third subparagraph of Article 7(1) shall not apply to the EFTA States.
(b) In Article 3(5), the following subparagraph shall be added:“Each EFTA State shall set a national indicative energy efficiency target for 2030, based on either primary or final energy consumption, or energy intensity, as part of its respective integrated national energy and climate plan in accordance with Articles 3 and 7 to 12 of Regulation (EU) 2018/1999.”
(c) In Article 5(1), the words “, or, as regards Iceland, obligations in accordance with national legislation in Iceland” shall be inserted after the words “Article 4 of Directive 2010/31/EU”.
(d) In point (b) of Article 7(1), the following sentence shall be added:“By way of derogation from the requirement in the first sentence of this point, Iceland shall achieve new savings each year from 1 January 2021 to 31 December 2030 equivalent to 0,24 % of annual final energy consumption, averaged over the most recent three-year period prior to 1 January 2019.”
(e) Article 9 shall not apply to Iceland as regards metering for gas.
(f) In Article 9a(1), the words “, or the equivalent energy consumption as regards Iceland” shall be inserted after the words “actual energy consumption”.
(g) Articles 9a and 9c shall not apply to district heating systems in Iceland with fewer than 1 500 end-users.
(h) Article 9b shall not apply to Iceland.
(i) Article 10 shall not apply to Iceland as regards billing information for gas.
(j) In Article 20(5), the reference to Article 5(1) shall be replaced by a reference to Article 5.
(k) Articles 14 and 15 shall not apply to Iceland as regards geothermal cogeneration.’
2. The following is added in point 26 (Directive 2009/125/EC of the European Parliament and of the Council):‘, as amended by:—32012 L 0027: Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 (OJ L 315, 14.11.2012, p. 1).’ — 32012 L 0027: Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 (OJ L 315, 14.11.2012, p. 1).’
— 32012 L 0027: Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 (OJ L 315, 14.11.2012, p. 1).’
— 32012 L 0027: Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 (OJ L 315, 14.11.2012, p. 1).’
— The Icelandic Government has set a national target of 25 % more efficient energy use by 2030 than in 2015. The target is expressed as a cross-sectoral objective of reducing energy intensity i.e. the ratio of energy consumption (final) to real GDP in PPS adjusted terms. The indicator is part of the energy forecast that is published annually by the Environment and Energy Agency of Iceland.
— On 6 November 2020 the Liechtenstein Parliament (Landtag) adopted its Energy Strategy for 2030 setting a national energy efficiency target of 20 % compared to 2008. Central elements of the efficiency increase in the period up to 2030 are building renovations, highly efficient new buildings and efficiency improvements in lighting, motor drives and domestic appliances. Both electric heat pumps for heat supply and the electrification of transport will lead to a significant substitution of fossil fuels in the future. Reporting on the achievement of objectives takes place annually (as part of a monitoring report for the attention of Parliament).
— The Norwegian Parliament (Storting) has set a national target of 30 % more efficient energy use by 2030 than in 2015 (Government Bill St. 25 (2015-2016)). The target is expressed as a cross-sectoral objective of reducing energy intensity i.e. the ratio of energy input (primary) to real GDP. The Ministry of Energy provides annual reporting on the target in the Report to the Storting (white paper) on the National Budget.
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on the Functioning of the European Union, and in particular Article 194(2) in conjunction with Article 218(9) thereof,
Having regard to Council Regulation (EC) No 2894/94 of 28 November 1994 concerning arrangements for implementing the Agreement on the European Economic Area (1), and in particular Article 1(3) thereof,
Having regard to the proposal from the European Commission,
Whereas:
(1) The Agreement on the European Economic Area (2) (the ‘EEA Agreement’) entered into force on 1 January 1994.
(2) Pursuant to Article 98 of the EEA Agreement, the EEA Joint Committee may decide to amend, inter alia, Annex II (Technical regulations, standards, testing and certification) and Annex IV (Energy) to the EEA Agreement.
(3) Directive 2012/27/EU of the European Parliament and of the Council (3) and Directive (EU) 2018/2002 of the European Parliament and of the Council (4) should be incorporated into the EEA Agreement.
(4) Several provisions of Directive 2012/27/EU as amended by Directive (EU) 2018/2002 require substantive adaptations that reflect the specificities of the EEA Agreement and of the EFTA States.
(5) Since the Union’s energy efficiency headline targets for 2020 and 2030 do not apply to the EFTA States, Article 1(1) of Directive 2012/27/EU as amended by Directive (EU) 2018/2002 and Articles 3(1)(a) and 3(5) of Directive 2012/27/EU should not apply to the EFTA States. However, the EFTA States set out in a voluntary manner their national indicative targets for energy efficiency, as set out in the Declaration of EFTA States attached to the EEA Joint Committee Decision.
(6) Article 5 of Directive 2012/27/EU refers to the minimum energy performance requirements to be complied with based on Article 4 of Directive 2010/31/EU of the European Parliament and of the Council (5). It is appropriate to allow Iceland to fulfil its obligations on the minimum energy performance requirements in central government’s buildings based on its national legislation, given that Iceland has a derogation from incorporating Directive 2010/31/EU into its national law.
(7) It is also appropriate to adapt Article 20(5) of Directive 2012/27/EU, in particular by replacing the reference to Article 5(1) with a more general reference to Article 5 in order to reflect the adaptations made under the latter provisions.
(8) New energy savings to be achieved by Iceland pursuant to Article 7(1) of Directive 2012/27/EU should be set at a level that reflects the specificities of Iceland’s energy market and energy mix.
(9) Given that the Icelandic energy system is isolated, near fossil-free, with high levels of security of supply and energy independence, and relies extensively on renewable geothermal energy with special characteristics, it is appropriate to allow a derogation for Iceland from certain requirements as regards metering set out in Articles 9a, 9b and 9c of Directive 2012/27/EU.
(10) Given that Iceland has no natural gas infrastructure and is exempt from Directive 2009/73/EC on the internal market for natural gas, Articles 9 and 10 of Directive 2012/27/EU as regards metering for natural gas and billing information should not apply to Iceland.
(11) Given that Directive 2004/8/EC of the European Parliament and of the Council (6) does not apply to geothermal cogeneration in Iceland, Article 14 and Article 15 of Directive 2012/27/EU as amended by Directive (EU) 2018/2002 which correlate to Directive 2004/8/EC should not apply to Iceland.
(12) Annex II (Technical regulations, standards, testing and certification) and Annex IV (Energy) to the EEA Agreement should therefore be amended accordingly.
(13) The position of the Union within the EEA Joint Committee should therefore be based on the attached draft decision,
HAS ADOPTED THIS DECISION:
The position to be adopted, on behalf of the Union, within the EEA Joint Committee on the proposed amendment of Annex II (Technical regulations, standards, testing and certification) and Annex IV (Energy) to the EEA Agreement, shall be based on the draft decision of the EEA Joint Committee attached to this Decision.
This Decision shall enter into force on the date of its adoption.
The following is added in point 6 (Directive 2009/125/EC of the European Parliament and of the Council) of Chapter IV of Annex II to the EEA Agreement:

‘, as amended by:

—
32012 L 0027: Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 (OJ L 315, 14.11.2012, p. 1).’

Annex IV to the EEA Agreement shall be amended as follows:
1. The text of point 24 (Directive 2004/8/EC of the European Parliament and of the Council) is replaced by the following:
‘
32012 L 0027: Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 on energy efficiency, amending Directives 2009/125/EC and 2010/30/EU and repealing Directives 2004/8/EC and 2006/32/EC (OJ L 315, 14.11.2012, p. 1), as amended by:
—
32018 L 2002: Directive (EU) 2018/2002 of the European Parliament and of the Council of 11 December 2018 (OJ L 328, 21.12.2018, p. 210).
The provisions of the Directive shall, for the purposes of this Agreement, be read with the following adaptations:
(a) Articles 1(1) and 3(1)(a) and third subparagraph of Article 7(1) shall not apply to the EFTA States.
(b) In Article 3(5), the following subparagraph shall be added:
“Each EFTA State shall set a national indicative energy efficiency target for 2030, based on either primary or final energy consumption, or energy intensity, as part of its respective integrated national energy and climate plan in accordance with Articles 3 and 7 to 12 of Regulation (EU) 2018/1999.”

(c) In Article 5(1), the words “, or, as regards Iceland, obligations in accordance with national legislation in Iceland” shall be inserted after the words “Article 4 of Directive 2010/31/EU”.
(d) In point (b) of Article 7(1), the following sentence shall be added:
“By way of derogation from the requirement in the first sentence of this point, Iceland shall achieve new savings each year from 1 January 2021 to 31 December 2030 equivalent to 0,24 % of annual final energy consumption, averaged over the most recent three-year period prior to 1 January 2019.”

(e) Article 9 shall not apply to Iceland as regards metering for gas.
(f) In Article 9a(1), the words “, or the equivalent energy consumption as regards Iceland” shall be inserted after the words “actual energy consumption”.
(g) Articles 9a and 9c shall not apply to district heating systems in Iceland with fewer than 1 500 end-users.
(h) Article 9b shall not apply to Iceland.
(i) Article 10 shall not apply to Iceland as regards billing information for gas.
(j) In Article 20(5), the reference to Article 5(1) shall be replaced by a reference to Article 5. (k) Articles 14 and 15 shall not apply to Iceland as regards geothermal cogeneration.’

2. The following is added in point 26 (Directive 2009/125/EC of the European Parliament and of the Council):
‘, as amended by:
—
32012 L 0027: Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 (OJ L 315, 14.11.2012, p. 1).’

The texts of Directives 2012/27/EU and (EU) 2018/2002 in the Icelandic and Norwegian languages, to be published in the EEA Supplement to the Official Journal of the European Union, shall be authentic.
This Decision shall enter into force on, … provided that all the notifications under Article 103(1) of the EEA Agreement have been made (*1).
This Decision shall be published in the EEA Section of, and in the EEA Supplement to, the Official Journal of the European Union.