What is GEPP, and how does it affect your operators?

The PPIM, or job and career path management, requires companies with at least 300 employees to regularly negotiate the development of their jobs and skills. Most agreements and guidelines describe it using executive-level terminology: mobility, talent, and career plans. In a factory, the issues play out on the production lines (versatility, certifications, temporary assignments, and employee departures), and GEPP is best understood by examining each position individually.

Sources: Labor Code, articles L.2242-2, L.2242-11, L.6315-1 and L.6323-13 ; Act No. 2025-989 of October 24, 2025.

Definition of GEPP

Job and Career Path Management (GEPP) is the process by which a company anticipates changes in its jobs and skills, and then organizes employee development to meet those needs. Any company can implement it, regardless of its size. For companies with 300 or more employees, it also becomes a mandatory negotiation with labor unions, governed by the Labor Code.

In a factory, this approach addresses three questions: Who is capable of performing each job today? Who will need to perform it in three years, and how can each operator be developed to be ready for that role?

When the founders of Mercateam visited dozens of French factories in 2019, the answers were stored in Excel spreadsheets and on paper schedules. Yet these are the building blocks of any GEPP initiative.

Why GPEC Became GEPP

GPEC (Forward-Looking Management of Jobs and Skills) became a mandatory topic of negotiation in 2005 under the Borloo Act for companies with at least 300 employees. The Ministry of Labor defines it as «a method for adapting, in the short and medium term, jobs, workforce levels, and skills to the requirements arising from corporate strategy and changes in the economic, technological, social, and legal environments.».

In practice, the exercise is based solely on the company’s needs, focuses primarily on technical skills, and produces a three- or five-year plan that the market renders obsolete before it expires—hence its reputation as an overly complicated process.

The term «job and career management» was introduced into the Labor Code by the Rebsamen Act of August 17, 2015, which took effect on January 1, 2016. You will often read that GEPP originated with the ordinances of September 22, 2017, which primarily reorganized its rules and allowed the negotiation period to be extended to up to four years.

The GPEC framework is still included in the Code, as the primary topic of GEPP negotiations under Article L.2242-20. The Climate and Resilience Act of August 22, 2021, assigned it an additional objective: to address the challenges of the ecological transition.

In addition to this program, GEPP takes into account employees’ career paths and prioritizes support for those who have career development plans aligned with the site’s needs.

The GEPP Objectives as Seen from the Workshop

Each objective set forth in a GEPP agreement has a direct impact on a production line.

What the Labor Code Says About GEPP

The legal framework for GEPP is set forth in the chapter of the Labor Code on mandatory collective bargaining within companies (Articles L.2242-1 et seq.).

Who is responsible for negotiating a GEPP agreement?

Article L.2242-2 applies to companies and groups with at least 300 employees, as well as companies and groups of Community-wide scope that have at least one establishment or company with 150 employees in France.

Negotiations also require that a union representation body be established at the company level. A union representative appointed for a single facility does not trigger this obligation (Court of Cassation, Labor Division, September 11, 2024, No. 23-14.333).

Every three years or every four years?

Both figures are circulating, and both are correct. Article L.2242-2 requires that negotiations take place at least once every four years.

A procedural agreement, with a maximum duration of four years, may establish the schedule, the content of the topics, and the follow-up on commitments (Article L.2242-11). In the absence of such an agreement, negotiations take place every three years on the six topics listed in Article L.2242-20.

What the agreement must include

The table lists the six themes of the'Article L.2242-20 of the Labor Code and indicates where your workshop participants are staying.

Source: article L.2242-20 of the Labor Code, as amended effective August 25, 2021.

In addition to these six topics, Article L.2242-21 allows for optional topics, including jobs threatened by economic or technological changes, mobility leave, and the integration of young people. A review is conducted upon the agreement’s expiration.

View the seven optional topics in the article L.2242-21

1. Procedures for informing and consulting the CSE in the event of collective layoffs for economic reasons (Articles L.1233-21 and L.1233-22).
2. The classification of job categories at risk due to economic or technological changes.
3. Involving subcontractors in the company's workforce planning and management (GPEC) system.
4. The company's participation in workforce planning and management initiatives carried out at the regional level where it operates.
5. The implementation of mobility leave.
6. Training and the long-term integration of young people into the workforce, including the expansion of work-study programs.
7. The procedures for organizing external retraining periods, as established by the law of October 24, 2025.

Source: article L.2242-21 of the Labor Code, as amended on October 26, 2025.

What Has Changed Under the Law of October 24, 2025

The Law No. 2025-989 of October 24, 2025, which focuses on the employment of experienced workers, amends several GEPP rules.

Seniors are being excluded from the GEPP agreement. Companies with at least 300 employees are required to conduct separate negotiations on employment and working conditions for experienced employees at least once every four years (Article L.2242-2-1). Knowledge transfer is no longer listed among the optional topics for the GEPP.

The retraining period replaces Pro-A and Collective Transitions Effective January 1, 2026. External retraining periods are organized under a GEPP agreement or a collective voluntary termination agreement.

The performance review is becoming a career development review. It takes place within one year of hiring, and then every four years, with a summary review every eight years (Article L.6315-1). Agreements that provided for a different frequency must be revised by October 1, 2026.

In companies with at least 50 employees, the review verifies that the interviews have taken place and that the employee has completed at least one non-mandatory training course. If neither of these requirements is met, the employer must contribute €3,000 to the employee’s CPF (Article L.6323-13).

What are the risks for a company that doesn't negotiate?

The law requires that GEPP negotiations be initiated but makes the signing of an agreement optional.

With regard to penalties, Article L.2243-2 imposes a one-year prison sentence and a fine of €3,750 on any employer who fails to comply with the obligations set forth in Articles L.2242-1 and L.2242-20. A union may also bring the matter before a judge once the negotiation period has expired, as reiterated in the September 2024 ruling.

For companies with fewer than 300 employees, two individual obligations remain. The employer must ensure that employees are suited to their positions and maintain their ability to hold a job (Article L.6321-1), and must conduct career development interviews.

GEPP at the Production Operator Level

In production, GEPP targets are measured using different units than those used for management.

Skills that prove themselves on the job

An operator is considered competent at a workstation when he or she can operate it independently, safely, and to the required standard. This is demonstrated through a practical evaluation at the workstation and, for certain tasks, through a dated certification that expires.

The GEPP for an industrial site is therefore based on a skills matrix maintained by position, including autonomy levels and validity dates. A authorization matrix Bringing deadlines forward helps prevent the discovery of a blocked account on the day of an audit.

Start with positions held by a single person. In my experience, they shut down a production line at the first sign of a long absence or the first resignation.

A training program focused on regulations

In 2020, 36 % private-sector workers received training, compared with 49 % technicians and 54 % managers, according to the Céreq. The industry is performing better than average, with 46 % workers trained.

Who has access to training in the private sector?

Percentage of employees who completed at least one training course in 2020.

What percentage of training is dedicated to compliance?

Percentage of training hours devoted to health and safety or on-the-job training.

Céreq notes that companies that provide the most training to their workers identify training needs, maintain a skills management plan, and communicate regularly with their OPCO—the building blocks of a GEPP approach.

In companies with a large blue-collar workforce, 38 to 40 % of training hours are devoted to health and safety or job orientation, compared to an average of 24 %.

However, training required by regulation does not count as non-mandatory training for the eight-year inspection.

Plan for the skills development plan At least one non-mandatory training course per operator over an eight-year period, such as a second position, a mentor training course, or a certificate of qualification.

Journeys That Embrace Versatility

An operator's career path progresses in successive stages, from the second shift to a new production line, then to certification, a mentoring role, and sometimes a team leader position.

The versatility It thus serves two objectives of the GEPP. It ensures production continuity in the event of absences and makes each employee’s progress visible.

In Mercateam, each training course completed for a position updates the matrix, providing a factual basis for career path reviews. Our clients find that training time is reduced by a factor of four once this tracking is automated.

Temporary Staffing and Departures Within the Organization

Temporary and seasonal workers often hold full-time positions. The fourth provision of Article L.2242-20 provides for their on-the-job training and pathways to permanent employment.

Retirements are now the subject of separate negotiations, and the workshop must always identify the critical skills possessed by employees nearing retirement in order to begin the handover process in a timely manner.

Where to Start on Your Website

An effective GEPP approach in production starts with the workstations that cause a line to stall when no one knows how to operate them.

Initiate the process when operations are stable, because a GEPP launched in the midst of a reorganization is perceived as a layoff. At Michelin, the 2023 GEPP negotiations began with exit measures, according to a CFE-CGC representative quoted by Social Mirror.

The most common pitfalls in a factory—unclear communication, team leaders being kept in the dark, and the lack of performance metrics—are detailed along with the Advantages and Disadvantages of GEPP.

Keeping the GEPP Alive Beyond the Agreement

A well-negotiated GEPP agreement provides the company with legal protection. Its value in terms of production depends on a more modest factor: knowing, each week, who is in which position and who is making progress.

Mercateam supports this monitoring at more than 300 industrial sites, using a GEPP software where the skills matrix, authorizations, and career progression interviews all share the same data.

To see how your agreement breaks down by position, request a demonstration.

Sources

• Labor Code, article L.2242-20, version effective as of August 25, 2021.
• Labor Code, Article L.2242-21 and Article L.2242-2-1, versions dated October 26, 2025.
• Law No. 2025-989 of October 24, 2025 to promote the employment of experienced workers.
• Labor Code, Article L.2242-2 and Article L.6315-1.
• Court of Cassation, Labor Chamber, September 11, 2024, No. 23-14.333.
• Inffo Center, Mandatory Negotiations within Companies Following the Rebsamen Act.
• Social Mirror, GEPP Agreement and Voluntary Separations, November 2023.
• Céreq, Training Workers: A Challenge That Companies Have Addressed to Varying Degrees, Céreq Bref No. 486, June 2026.
• Ministry of Labor, Forward-Looking Employment and Skills Planning.

Sources: Labor Code, articles L.2242-2, L.2242-11 and L.6323-13 ; Céreq, Brief No. 486, June 2026.

Definition of GEPP

Job and Career Path Management (GEPP) is the process by which a company anticipates changes in its jobs and skills, and then organizes its employees’ career development to meet those needs. Any company can implement this, regardless of its size. For companies with 300 or more employees, it also becomes a mandatory negotiation with labor unions, governed by the Labor Code.

In a factory, this approach addresses three questions: Who is currently qualified to work each position? Who will need to fill each position in three years, and how can each operator be developed to be ready for that role?

When the founders of Mercateam visited dozens of French factories in 2019, the answers were stored in Excel spreadsheets and paper schedules. Yet these are the raw materials of any GEPP initiative.

Why GPEC Became GEPP

GPEC (forward-looking management of jobs and skills) became a mandatory subject of negotiation in 2005 under the Borloo Act for companies with at least 300 employees. The Ministry of Labor defines it as «a method for adapting, in the short and medium term, jobs, workforce levels, and skills to the requirements arising from corporate strategy and changes in the economic, technological, social, and legal environments.».

In practice, the exercise is based solely on the company's needs, focuses primarily on technical skills, and produces a three- or five-year plan that the market renders obsolete before it is completed—hence its reputation as a bureaucratic nightmare.

The term «job and career path management» was introduced into the Labor Code by the Rebsamen Act of August 17, 2015, which took effect on January 1, 2016. You will often read that GEPP originated from the executive orders of September 22, 2017, which primarily reorganized its rules and allowed the negotiation period to be extended to up to four years.

The GPEC framework is still included in the Code, as the primary topic of GEPP negotiations under Article L.2242-20. The Climate and Resilience Act of August 22, 2021, assigned it an additional objective: to address the challenges of the ecological transition.

In addition to this program, GEPP takes into account employees’ career paths and prioritizes support for those who have career development plans aligned with the site’s needs.

The GEPP Objectives as Seen from the Workshop

Each objective set forth in a GEPP agreement has a direct impact on a production line.

What the Labor Code Says About GEPP

The legal framework for GEPP is set forth in the chapter of the Labor Code on mandatory collective bargaining within companies (Articles L.2242-1 et seq.).

Who is responsible for negotiating a GEPP agreement?

Article L.2242-2 applies to companies and groups with at least 300 employees, as well as companies and groups of Community-wide scope that have at least one establishment or company with 150 employees in France.

Negotiations also require that a union representation body be established at the company level. A union representative appointed for a single facility does not trigger this obligation (Court of Cassation, Labor Division, September 11, 2024, No. 23-14.333).

Every three years or every four years?

Both figures are circulating, and both are correct. Article L.2242-2 requires that negotiations take place at least once every four years.

A procedural agreement, with a maximum duration of four years, may establish the schedule, the content of the topics, and the follow-up on commitments (Article L.2242-11). In the absence of such an agreement, negotiations take place every three years on the six topics listed in Article L.2242-20.

What the agreement must include

The table lists the six themes of the'Article L.2242-20 of the Labor Code and indicates where your workshop participants are staying.

Source: article L.2242-20 of the Labor Code, as amended effective August 25, 2021.

In addition to these six topics, Article L.2242-21 allows for optional topics, including jobs threatened by economic or technological changes, mobility leave, and the integration of young people. A review is conducted upon the agreement’s expiration.

View the seven optional topics in the article L.2242-21

1. Procedures for informing and consulting the CSE in the event of collective layoffs for economic reasons (Articles L.1233-21 and L.1233-22).
2. The classification of job categories at risk due to economic or technological changes.
3. Involving subcontractors in the company's workforce planning and management (GPEC) system.
4. The company's participation in workforce planning and management initiatives carried out at the regional level where it operates.
5. The implementation of mobility leave.
6. Training and the long-term integration of young people into the workforce, including the expansion of work-study programs.
7. The procedures for organizing external retraining periods, as established by the law of October 24, 2025.

Source: article L.2242-21 of the Labor Code, as amended on October 26, 2025.

What Has Changed Under the Law of October 24, 2025

The Law No. 2025-989 of October 24, 2025, which focuses on the employment of experienced workers, amends several GEPP rules.

Seniors are being excluded from the GEPP agreement. Companies with at least 300 employees are required to conduct separate negotiations on employment and working conditions for experienced employees at least once every four years (Article L.2242-2-1). Knowledge transfer is no longer listed among the optional topics for the GEPP.

The retraining period replaces Pro-A and Collective Transitions Effective January 1, 2026. External retraining periods are organized under a GEPP agreement or a collective voluntary termination agreement.

The performance review is becoming a career development review. It takes place within one year of hiring, and then every four years, with a summary review every eight years (Article L.6315-1). Agreements that provided for a different frequency must be revised by October 1, 2026.

In companies with at least 50 employees, the review verifies that the interviews have taken place and that the employee has completed at least one non-mandatory training course. If neither of these requirements is met, the employer must contribute €3,000 to the employee’s CPF (Article L.6323-13).

What are the risks for a company that doesn't negotiate?

The law requires that GEPP negotiations be initiated but makes the signing of an agreement optional.

With regard to penalties, Article L.2243-2 imposes a one-year prison sentence and a fine of €3,750 on any employer who fails to comply with the obligations set forth in Articles L.2242-1 and L.2242-20. A union may also bring the matter before a judge once the negotiation period has expired, as reiterated in the September 2024 ruling.

For companies with fewer than 300 employees, two individual obligations remain. The employer must ensure that employees are suited to their positions and maintain their ability to hold a job (Article L.6321-1), and must conduct career development interviews.

GEPP at the Production Operator Level

In production, GEPP targets are measured using different units than those used for management.

Skills that prove themselves on the job

An operator is considered competent at a workstation when he or she can operate it independently, safely, and to the required standard. This is demonstrated through a practical evaluation at the workstation and, for certain tasks, through a dated certification that expires.

The GEPP for an industrial site is therefore based on a skills matrix maintained by position, including autonomy levels and validity dates. A authorization matrix Bringing deadlines forward helps prevent the discovery of a blocked account on the day of an audit.

Start with positions held by a single person. In my experience, they shut down a production line at the first sign of a long absence or the first resignation.

In the Mercateam panel, this phenomenon affects nearly all sites: 105 of the 108 sector-specific sites have at least one skill or authorization held by a single individual, and at 98 sites, the median proportion of positions held by fewer than three qualified employees ranges from 24.8 % in the pharmaceutical industry to 77.8 % in the automotive industry.

Positions held by fewer than three qualified incumbents

Median number of positions per site, by sector.

105 out of 108 sites

have at least one skill or authorization assigned to a single holder

3 regulars

threshold for accommodating a simultaneous absence and leave

A training program focused on regulations

In 2020, 36 % private-sector workers received training, compared with 49 % technicians and 54 % managers, according to the Céreq. The industry is performing better than average, with 46 % workers trained.

Who has access to training in the private sector?

Percentage of employees who completed at least one training course in 2020.

What percentage of training is dedicated to compliance?

Percentage of training hours devoted to health and safety or on-the-job training.

Céreq notes that companies that provide the most training to their workers identify training needs, maintain a skills management plan, and communicate regularly with their OPCO—the building blocks of a GEPP approach.

In companies with a large blue-collar workforce, 38 to 40 % of training hours are devoted to health and safety or job orientation, compared to an average of 24 %.

However, training required by regulation does not count as non-mandatory training for the eight-year inspection.

Plan for the skills development plan At least one non-mandatory training course per operator over an eight-year period, such as a second position, a mentor training course, or a certificate of qualification.

Journeys That Embrace Versatility

An operator's career path progresses in successive stages, from the second shift to a new production line, then to certification, a mentoring role, and sometimes a team leader position.

The versatility It thus serves two objectives of the GEPP. It ensures production continuity in the event of absences and makes each employee’s progress visible.

In Mercateam, each training course completed for a position updates the matrix, providing a factual basis for career path reviews. Our clients find that training time is reduced by a factor of four once this tracking is automated.

Temporary Staffing and Departures Within the Organization

Temporary and seasonal workers often hold full-time positions. The fourth provision of Article L.2242-20 provides for their on-the-job training and pathways to permanent employment.

Retirements are now the subject of separate negotiations, and the workshop must always identify the critical skills possessed by employees nearing retirement in order to begin the handover process in a timely manner.

Where to Start on Your Website

An effective GEPP approach in production starts with the workstations that cause a line to stall when no one knows how to operate them.

Initiate the process when operations are stable, because a GEPP launched in the midst of a reorganization is perceived as a layoff. At Michelin, the 2023 GEPP negotiations began with exit measures, according to a CFE-CGC representative quoted by Social Mirror.

The most common pitfalls in a factory—unclear communication, team leaders being kept in the dark, and the lack of performance metrics—are detailed along with the Advantages and Disadvantages of GEPP.

Keeping the GEPP Alive Beyond the Agreement

A well-negotiated GEPP agreement provides the company with legal protection. Its value in terms of production depends on a more modest factor: knowing, each week, who is in which position and who is making progress.

Mercateam supports this monitoring at more than 300 industrial sites, using a GEPP software where the skills matrix, authorizations, and career progression interviews all share the same data.

To see how your agreement breaks down by position, request a demonstration.

Sources

• Labor Code, article L.2242-20, version effective as of August 25, 2021.
• Labor Code, Article L.2242-21 and Article L.2242-2-1, versions dated October 26, 2025.
• Law No. 2025-989 of October 24, 2025 to promote the employment of experienced workers.
• Labor Code, Article L.2242-2 and Article L.6315-1.
• Court of Cassation, Labor Chamber, September 11, 2024, No. 23-14.333.
• Inffo Center, Mandatory Negotiations within Companies Following the Rebsamen Act.
• Social Mirror, GEPP Agreement and Voluntary Separations, November 2023.
• Céreq, Training Workers: A Challenge That Companies Have Addressed to Varying Degrees, Céreq Bref No. 486, June 2026.
• Ministry of Labor, Forward-Looking Employment and Skills Planning.