SPASER: managing responsible purchasing when you are not required to

An obligation that changes scale

Since late August 2026, all new public contracts in France must include at least one environmental award criterion and one environmental performance clause. Price as the sole criterion disappears, as Service-public.fr reminds us. This is the culmination of Article 35 of the Climate and Resilience Act.

There was still a long way to go. According to the review of the National Sustainable Procurement Plan 2022-2025, published in May 2026 by the Commissariat général au développement durable, 39% of public contracts (by value) included an environmental consideration in 2024, and 25% a social consideration. The targets were 100% and 30%.

For a public institution, the question is no longer whether to buy responsibly, but how to manage it and prove it.

The SPASER (a plan to promote socially and environmentally responsible public purchasing) is the tool designed for this. Here is how to build one in practice: who is concerned, which indicators to track, where to find the data and which pitfalls to avoid.

Who is required to have one?

Article L. 2111-3 of the French Public Procurement Code requires a SPASER from local authorities and buyers whose annual purchasing exceeds a threshold. Decree No. 2022-767 lowered it from 100 to 50 million euros excluding VAT, from 1 January 2023.

The threshold is calculated on expenditure during the calendar year, from the first euro, including small purchases made without competitive tendering. Below it, the plan is optional.

Most schools and many public institutions are therefore below the threshold. Why adopt one anyway?

to prepare for the 2026 obligations, which apply to everyone, with no threshold;
for the DD&RS label: responsible purchasing is part of the Strategy and Governance axis of the 2026 framework, and a formalised, adopted and monitored plan is strong evidence;
to give a common framework to the people who buy, often spread across several departments or entities.

Which indicators to track?

The SPASER technical sheet from the Directorate of Legal Affairs (April 2024) lists four minimum mandatory indicators for buyers subject to the plan:

the share of contracts including an environmental consideration;
the share of contracts including a social consideration;
the share of contracts awarded to social-utility solidarity enterprises (ESUS);
the share of contracts awarded to organisations employing disadvantaged or vulnerable people (sheltered workshops, ESAT, work-integration organisations).

Each share can be calculated by number or by value, awarded or spent. Even without an obligation, we recommend using these four indicators: they are recognised, comparable, and the data is available.

Better five indicators actually calculated every year than thirty indicators nobody fills in.

A three-level organisation generally works well: a few steering indicators monitored by management, a milestone to tick off for each action in the plan, and “going further” indicators kept for the teams.

Where to find the data?

This is often the sticking point. Yet much of the calculation can be done with data you already have, cross-referenced with free public sources.

Your own data

The accounting extract of expenditure, with each supplier’s SIRET number. This is the key to everything else: without SIRET, names have to be matched by hand.
The list of current contracts, with their award date and criteria. It lets you calculate indicators 1 and 2.
The documents for each contract (rules of consultation, specifications) to check that a criterion or clause is actually there.

Public sources

The Recherche d’entreprises API, free and without registration. From a SIREN number, it shows whether the organisation belongs to the social and solidarity economy (est_ess) and whether it is an inclusive organisation (est_siae), with its type (type_siae: work-integration enterprise, sheltered company, ESAT…). Indicator 4 can thus be calculated automatically.
The national list of ESUS accreditations, published each year by the French Treasury as an Excel file, with SIREN numbers. It is explicitly intended for calculating purchases from ESUS in SPASERs.

Be careful: belonging to the social and solidarity economy does not mean being ESUS-accredited. For indicator 3, only the Treasury list counts, and you need to check that the accreditation was valid on the date of purchase.

Measure the starting point: purchasing volume, share under contract, share outside contracts, the four indicators calculated over the last full year.
Clarify the scope. If several legal entities buy (school, foundation, laboratory), each has its own budget and teams. Decide whether the plan covers them all and how data will be collected.
Align the period and targets with the institution’s overall strategy (DD&RS master plan, decarbonisation plan). The SPASER implements the strategy; it does not replace it.
Choose a limited number of concrete actions: buyer training, a guide for everyday purchases, standard clauses, reserved contracts, identifying inclusive suppliers.
Have the plan adopted by the competent body. A document that has not been adopted remains a project.
Plan the monitoring: who calculates the indicators, from which data, and by when. The Code requires indicators to be published every two years for buyers subject to the plan; annual monitoring is more useful in practice.

Pitfalls to avoid

Copying a template. SPASERs published by other buyers are good sources of inspiration, but a plan taken over without adaptation keeps targets, thresholds or priorities designed for another context.
Forgetting purchases outside contracts. In a small institution, a large share of spending happens outside formal contracts. A guide for everyday purchases helps cover it.
Aiming for 100% without a baseline. A target only makes sense if the current value is known and the data exists to track it.
Neglecting the social dimension. Cleaning, catering or printing contracts lend themselves well to integration clauses and reserved contracts, but you need to act before they are renewed.
Leaving a single owner. Without a relay in each purchasing department, the plan remains just a document.

In conclusion

A SPASER is not only for large local authorities. For a medium-sized institution, it is a simple way to comply with the 2026 rules, structure buyers’ work and produce evidence for the DD&RS label. Most of the data needed is already available: it just needs to be cross-referenced.

Building or revising your responsible purchasing policy? Let’s talk for 30 minutes about your data and priorities.