Can we run an automated vishing simulation from a normal French number?

No. The regulator has forbidden ordinary geographic and mobile numbers from being presented as the caller identity for calls sent by automated systems, and operators must interrupt routing for calls that breach it. Automated outbound runs on a derogated category such as verified polyvalent numbers instead.

Does it help that our calls are not marketing?

Not in France, and this is where France parts company with the United Kingdom. The Conseil d'Etat held in June 2024 that the legislature did not intend to limit the power to calls sent in the context of telephone cold calling. It is a single-chamber decision and unreported, but it is directly on the point.

Can the works council block the programme?

No, but it must be consulted before means or techniques permitting control of employees' activity are introduced, in undertakings of at least fifty employees. The committee issues an opinion and the employer reports back with reasons, which is a consultation duty rather than the German-style veto.

Can we present our client's own number on a French campaign?

Not for automated calls. The regulator has said a principal lending its number to a call centre for automated calling cannot be allocated a polyvalent or mobile number for it, and operators must verify that the caller is the assignee or has the assignee's agreement and drop what cannot be authenticated.

Compliance

Voice phishing simulations in France

Phone numbers in FranceProvisioned by Callstrike after approval

France regulates this more directly than anywhere else in Europe, and it reaches a different answer from its neighbours: the argument that a voice phishing simulation is not marketing, which carries most of this portal, does not rescue you here. The decision that shapes a French campaign is which category of number it originates from, and it belongs at the start rather than the end.

Phone numbers

Supplied by Callstrike

Local numbers in France, after a one-time approval.

Running a simulation

Permitted, and the number decides how

Ordinary geographic and mobile numbers are barred as the identity for automated calls.

Consent

The committee, not the individual

The works council must be consulted before you introduce this. It cannot veto it.

Getting a phone number in France

One approval per country, completed in the console.

Provisioned by Callstrike after approval

Your company files its regulatory details once for this country. Local rules require the order to be placed by the provider of record, so Callstrike provisions the number on your behalf once the filing is approved. Approval is a one-time, per-country step and usually takes 3 to 5 business days. We only ask for what the regulator requires.

France is one of the countries where local rules put the order in the provider's hands, so your company files its details once and Callstrike places the order against the approval. Expect the filing to be documentary rather than declaratory: an extract from the commercial register establishes who you are, and a second piece of evidence showing a French address establishes where. A post box is not accepted, and the address has to be genuinely in France.

The harder question is not the filing at all. French numbering rules forbid ordinary territorialised numbers, meaning the geographic and mobile ones a pretext would reach for first, from being presented as the caller identity for calls sent by automated systems, and operators are required to interrupt the routing of calls that break that rule. What permits automated outbound instead is a derogated category. Settle with your account team which category your campaign will run on before you design the scenario, because it constrains what the number can look like to the person answering.

01Complete the regulatory clearance formYour administrator, in the Callstrike console. The form asks only for what the regulator requires.
02Approval is granted against your workspaceTypically three to five business days, and once only for as long as you operate here.
03A dedicated number in France is assigned to youCallstrike
04Build and launch the campaignYour team

What you provide	Accepted evidence, any one of
Proof of business identity	Excerpt from the commercial register
Proof of business addressMust be within France; a PO Box is not acceptable.	Excerpt from the commercial register showing french address, Utility bill, Tax notice, Rent receipt, Title deed

These requirements are set by the carrier and can change. The form in the console is generated from their current rules, so treat it as authoritative and this table as a summary of what to have ready. Checked 2026-09-07.

Is it lawful to run a simulation in France?

The position in short, before your counsel reads the detail below.

Yes, and France is the country on this page where that answer needs the most care, because the constraint is a numbering rule rather than a consent rule and it does not care what your purpose is. The cold-calling prohibition everyone reaches for is scoped to direct prospecting and does not reach an internal exercise. The rule that does reach you is the regulator's power to forbid categories of number from being presented as the caller identity for automated calls, and it has used that power.

Then the finding that makes France genuinely different. In June 2024 the highest administrative court held that the legislature did not intend to limit that power to calls sent in the context of telephone cold calling. Pollsters challenging the rule got nothing. So the sentence that works in the United Kingdom, in Germany and in the Netherlands, that your calls are not marketing, does not do the same work here. Two honest qualifications: it is a single-chamber decision and it is not reported in the official collection, so it is authoritative rather than a leading case.

The employee side is a real step and it is not a gate. The works council must be informed and consulted before you introduce means or techniques permitting control of employees' activity, and that duty belongs to the fifty-employee regime even though the committee itself exists from eleven. It issues an opinion, and you report back on what you did and why. Somebody who must give reasons for departing from an opinion is somebody who may depart from it, so budget the consultation as a real cost and not as an approval you might not get.

On recording, France leaves you with a gap rather than a rule, and we would rather name it. The criminal provision punishes capturing or recording words spoken in private without the consent of the person concerned. The data protection authority's page on recording telephone calls is dated 2009 and is labelled obsolete on its own site, and we found no current replacement worth building advice on. The workable French design is therefore to capture what happened rather than the audio, and to take any appetite for recordings to French counsel.

What your company needs to do

6 items, in the order you will need them.

Choose the category of number before anything elseFrance-specificThis is the French decision and everything else waits on it. Ordinary geographic and mobile numbers cannot carry an automated campaign, the derogated categories can, and the exceptions for very low volumes are switched off entirely for mobile. Ask your account team which category is available to you before you write a scenario around a number that will never be permitted to carry it.
Do not plan to present a customer's or a client's numberFrance-specificThe regulator has addressed this exact arrangement: a principal lending its number to a call centre for automated calls cannot be allocated a polyvalent or a mobile number for that purpose. Operators must also verify that the caller is the number's assignee or holds its agreement, and drop what cannot be authenticated. Since January 2026 that has been a technical whitelist rather than a policy.
Consult the works council, and write down what you did with itFrance-specificInform and consult before the technique is introduced, not before the first campaign of the second year. The output is an opinion and your reasoned reply, and the reply is the artefact worth keeping, because it is the evidence that the consultation was real rather than announced.
Document the basis and the impact assessmentLegitimate interests, with the assessment and an impact assessment behind it. Be aware of the sourcing when you write it: there is no French regulator statement we could hand you saying that employee agreement fails in the context of call-based testing, so the argument rests on the Regulation's own definition and on European-level guidance.
Capture the outcome rather than the conversationWhether the call was answered, whether a credential was disclosed and where in the script the person disengaged are all recordable as structured data. That design does not have to resolve a criminal provision against a regulator page that says of itself that it is out of date.
Plan for the AI transparency duty rather than around itThe European duty to tell a person they are dealing with an AI system, and to disclose artificially generated audio, has applied since August 2026 and reaches France directly. The exception on the face of the text is for use authorised by law to detect or prosecute criminal offences, and management's own sign-off is not that. Take the timing question to counsel rather than assuming a covert design answers it.

The controls that do the work

How Callstrike is configured, and which provision in France each choice answers.

Auto-hangup before disclosure

The bot ends the call at the moment an employee starts to give up a credential or a piece of personal data, so the thing the pretext asked for is never spoken into the system and never stored.

In France the works council consultation and the impact assessment are where the programme is actually argued, and both turn on proportionality. The call ends the moment an employee begins to give up a credential, so the exercise measures susceptibility without the credential ever entering the system. That is the strongest single fact to put in front of a committee, because it converts an argument about how carefully sensitive data is handled into a statement that the sensitive data does not exist.

In-call debrief and follow-up

A second voice breaks character as soon as the call ends, explains what just happened and why it worked, and a follow-up email repeats it in writing while the moment is still sharp.

The employment code frames the consultation around means of controlling employees' activity, and the committee's opinion is written by people who will ask what the exercise does to their colleagues. A second voice that breaks character the instant the call ends, and vishing training that follows in writing the same day, is a different proposition from a monitoring technique. It is also the part of the design that survives being described accurately in the reasoned reply.

Consent Management

Two modes: collect consent now, over email, Slack or Teams with a full audit trail per employee; or record that your organisation already has this covered, by uploading the policy, handbook clause or agreement and confirming the scope it applies to. The document is hashed, the attestation is signed and timestamped, and an audit email is issued. Included on every plan.

France's employee instrument is a collective one, so this does not replace the consultation and nothing here pretends it does. What it produces is the individual layer underneath: a dated record of what staff were told about the programme, or the hashed policy and signed scope attestation where your organisation already covers this in its own rules. That is the evidence the impact assessment refers to and cannot itself create.

SCORM module

An interactive web presentation on voice-phishing risk, delivered through your own LMS, which then invites the learner to opt into a web call with the bot. A call the person starts themselves in a browser is not a telephone call, so telephony rules do not reach it.

This is worth more in France than almost anywhere, because the numbering rule is the binding constraint and this route does not touch it. Callstrike's vishing simulator can deliver the same deepfake voice through a web call the learner starts themselves after working through the module, and a call a person opens in their own browser is not a telephone call sent by an automated system, so the caller identity rules that decide everything above have nothing to attach to.

Consent Management is included on every plan. See AI voice phishing simulation and human-in-the-loop voice phishing for how each is delivered.

The sourced position

Everything above, with the instruments behind it. Every claim cites the statute or the regulator it comes from, so your counsel can verify it rather than rely on our summary.

The basis, and a consultation that is real but not a veto

The basis is legitimate interests under Article 6(1)(f) with a documented assessment, supported by an impact assessment. Consent is the wrong instrument here as elsewhere, because it cannot be freely given by an employee and asking ends the exercise. We should be straight about the sourcing on that last point: we could not find a sentence from the French data protection authority saying so in terms about call-based testing, so the proposition rests on the Regulation's own definition of consent and on European-level guidance rather than on a French regulator quotation we can hand you.

The consultation instrument is the social and economic committee. The Labour Code requires the committee to be informed and consulted before the introduction of means or techniques permitting control of employees' activity, and that duty sits in the part of the code applying to undertakings of at least fifty employees. Note the two thresholds and keep them apart: a committee itself exists from eleven employees, but this particular duty belongs to the fifty-employee regime.

It is a consultation duty and not a veto, and the code says so in the way it describes the output. The committee issues opinions, and the employer reports back on the action taken, giving reasons. An employer who must give reasons for departing from an opinion is an employer who may depart from it. So plan the consultation into the timeline as a real step with a real cost, and do not plan for it as an approval you might not get.

Recording, and a regulator page that says it is out of date

The criminal provision is article 226-1 of the Penal Code, which punishes intentionally infringing the privacy of another by capturing, recording or transmitting, without the consent of the person concerned, words spoken in private or confidentially. It sits in the chapter on offences against the person and carries imprisonment and a fine, so this is criminal exposure rather than an administrative risk.

We are going to be honest about a gap rather than paper over it. The French data protection authority's page on recording telephone calls is dated 2009 and is labelled on the authority's own site as obsolete. That is not a source we are willing to build a recommendation on, and we did not find a current replacement meeting our standard. So on the specific question of what the regulator expects of an employer recording an employee's simulated call today, we have nothing to give you.

What we can say is that the criminal provision turns on the consent of the person concerned and on the private character of the words, and that the safest French design is therefore the same one we recommend in Germany: capture the outcome rather than the audio. A programme that records whether the call was answered, whether a credential was disclosed and where in the script the person disengaged does not need to resolve this question at all. Where you do want audio, take it to French counsel rather than to a regulator page that tells you itself it is out of date.

The cold-calling rule, and the two status caveats on it

The provision people reach for is the electronic communications code's rule on unsolicited approaches, which prohibits direct prospecting by automated calling systems and similar means without prior consent. Its scope words are prospection directe, and the surrounding definition is about promoting goods, services or the image of a person selling them. An authorised internal security test promotes nothing, so that rule is not the obstacle here.

Two status caveats on it, published rather than hidden, because both would mislead someone checking for themselves. Its internal cross-reference to a definition elsewhere in the code is stale, because the definition it points at has been renumbered, so a reader following the reference lands somewhere unhelpful. And in June 2026 the Constitutional Council censured three of its paragraphs, on cumulative enforcement, with the abrogation deferred to the end of October 2027. The prohibition itself is untouched by that decision, but if you are reading the article you should know parts of it are living on borrowed time.

The rule that actually bites an AI voice in France is not that one, and it is dealt with in the numbering section below, because in France it is a numbering rule rather than a consent rule. That is the single most important structural difference between France and the rest of this cluster.

On top of it sits Article 50 of the EU AI Act, applicable since 2 August 2026. It requires a system built to interact directly with people to be designed so the person is informed they are interacting with an AI system, and requires whoever deploys a system generating or manipulating audio constituting a deep fake to disclose that the content is artificially generated, both at the latest at the first interaction or exposure. The two exceptions on the face of the text are use authorised by law to detect, prevent, investigate or prosecute criminal offence, and evidently artistic or fictional works, where the duty is narrowed rather than removed. An employer's own authorisation is not authorisation by law.

One element the AI Act leaves genuinely open, and we will not close it: whether a synthetic voice resembling no identifiable individual meets a definition requiring resemblance to existing persons, objects, places, entities or events. Where the voice imitates a specific real person it is inside on any reading.

A word on the live operator question, because France has drawn a line here that nobody else has. The regulator has said that machine-assisted dialling may not be considered an automated system if the assistance emits calls only individually, without any possibility of parallelisation, and on the explicit command of a human for each call. Read the hedging: may not be considered, and three cumulative conditions. It is a definitional boundary rather than an exemption, and it plainly does not reach an autonomous AI caller. Any copy telling you a human in the loop puts you outside French rules is overstating a hedged sentence.

It is worth separating what that Regulation leaves alone from what it argues about, because a second article of it prohibits rather than regulates. Inferring emotions of a natural person in the workplace by an AI system is a prohibited practice, applicable since 2 February 2025 and carrying up to thirty-five million euros or seven per cent of worldwide turnover, with an exception for medical or safety reasons. Recording who answered, who disclosed a credential and who reported the call is untouched by it: those are facts about conduct, not inferences about feeling. A product that scores how stressed or how deceived a named employee sounded is on the other side of the line, and it argues about the definition of an emotion recognition system at the highest penalty tier the Regulation has.

Why the panel shows local as both sellable and restricted

The panel beside this section will look self-contradictory unless you read this first, and France is the only country in our matrix where it does. It shows that French local numbers are sellable and, immediately beneath, that local, mobile and national numbers are restricted for automated outbound. Both are true, because they answer different questions: one is about what a carrier can sell you in France, and the other is about which numbers may lawfully be presented as the caller identity for a call sent by an automated system. In every other country in this tranche those two questions have the same answer, and in France they do not.

The rule sits in the electronic communications code. It empowers the regulator to specify the categories of numbers in the national numbering plan that it is forbidden to use as the identifier of the caller presented to the called party, for calls sent by automated calling and messaging systems, and to specify the conditions under which that prohibition applies. It also empowers the regulator to specify the measures operators implement to interrupt the routing of calls that do not respect the prohibition. So the enforcement is at the network, not only at the caller.

The regulator has used the power. Its numbering plan provides that territorialised numbers, which is to say ordinary geographic and mobile numbers, may not be used as the caller identity presented to the called party for calls sent by automated systems. What permits automated outbound instead is a derogated category, the verified polyvalent numbers, and note that the commonly quoted range is incomplete: alongside the 0948 and 0949 roots there are several other metropolitan roots in the same category. There are narrow low-volume exceptions, switched off entirely for mobile numbers, and other derogated categories exist too, so the accurate framing is that ordinary numbers are prohibited and verified polyvalent numbers are one route out, rather than that they are the only conceivable one.

Now the finding that makes France genuinely different from the United Kingdom, and the reason the marketing-scope argument that carries our other European pages does not work here. In June 2024 the Conseil d'Etat held that the legislature did not intend to limit the regulator's power to calls or messages sent in the context of telephone cold calling. Pollsters challenging the rule got no exemption. So in France, unlike almost everywhere else in this cluster, the fact that your calls are not marketing does not take you outside the rule. Two honest qualifications: it is a single-chamber decision and it is not reported in the official collection, so treat it as authoritative rather than as a leading case.

The regulator has also addressed our exact commercial shape. It has said that a principal lending its number to a call centre for automated calls cannot be allocated a polyvalent or a mobile number for that purpose. If you were planning to present the client's own number for an automated French campaign, that is the sentence to read before you plan any further.

Separately, and not scoped to cold calling despite the name of the law that introduced it, operators must verify that the caller is the number's assignee or has the assignee's prior agreement, and must drop what cannot be authenticated. From January 2026 that hardened from a recommendation into an obligation to technically whitelist each customer's presentable numbers. So the practical French sequence is: settle which category of number your campaign will originate from before you settle anything else.

One currency note we would rather give you than withhold. The numbering plan in force replaced the earlier one from 1 January 2026, and we verified that the relevant paragraphs survived that replacement by comparing both texts rather than assuming continuity, which was the right call because the surrounding paragraphs were renumbered around them. What we could not establish is whether the current plan has itself been amended since. Treat this section as verified as at September 2026 and check the regulator's decisions before relying on it later.

What the country matrix holds for France

Number types:: Local
Restricted for automated outbound:: Local, Mobile, National

Generated from the same country matrix the platform enforces at dispatch, so it cannot drift from what you can actually buy.

A presence test, not a company registration

France does publish an end-user requirement, and it is worth stating precisely because it is easy to overstate in either direction.

The numbering plan applies a territoriality condition to territorialised numbers: the end user must habitually or temporarily reside in the relevant area, or justify stable links implying a frequent and significant presence there. That is a presence test rather than a documentary one. It is policed by the operator, which carries a duty to withdraw the number where the condition is no longer met.

What it is not is a company-registration requirement or a registered-office requirement, and we cut that claim rather than softening it when we could not source it. So if you are told that a French number requires a French company, ask which provision says so, because the provision we found asks about presence and links rather than about incorporation.

That is a statement about the numbering plan and not about your supplier's onboarding. The table above the seam does ask for an extract from the commercial register, and there is no conflict between the two: one is the carrier establishing who you are before it hands over a number, the other is the regulator's condition on who may hold one. Only the second is French law, and it asks about presence.

Given the numbering section above, the more consequential question for a French campaign is not what documents you assemble. It is which category of number you will be originating from, and whether your supplier can obtain one in that category at all.

NIS2 is not transposed here yet, and one framework binds nobody

France has not transposed NIS2 as at September 2026. The resilience bill passed the Senate in March 2025 and cleared a special committee in the National Assembly that September, but it has not reached a plenary vote and has not been promulgated, and the national cybersecurity agency's own site still describes it as a bill. So if a supplier is justifying your French programme by reference to NIS2 obligations, those obligations are not in French law yet. Plan for them, do not cite them.

For financial entities DORA applies directly, with compulsory security awareness and digital operational resilience training as modules in staff training schemes for all employees and senior management, a testing programme, and threat-led penetration testing for entities meeting the criteria.

One thing worth knowing about the threat-led testing framework, because it is routinely presented as a mandate: its own documentation states that it does not create any legally binding obligations. It is a framework for how such testing is conducted when it is conducted, not an instrument requiring it. And as everywhere in this cluster, social engineering is a standard technique within that testing and is not named in the Regulation, so treat a claim that European financial law requires vishing as a sales line rather than a citation.

Take this further

Research prompt for your own AI assistant

Paste into Claude, Harvey or your firm's tool to pressure-test the position above.

You are advising on an authorised internal security exercise in FRANCE. Our own employees receive a simulated voice-phishing call, placed by our vendor on our instruction, to measure susceptibility. No credential is captured or stored. The workforce is informed in advance and the CSE has been consulted.

Verify or correct each proposition below against primary French sources:

1. CPCE art. L. 34-5 is scoped to prospection directe and does not reach an internal security test. ⚠ Note its stale internal cross-reference and the Conseil constitutionnel's June 2026 censure of three paragraphs, deferred to end-October 2027.
2. CPCE art. L. 44 VI (cited as I quater in ARCEP's 2022 decision) empowers ARCEP to forbid categories of number as the presented caller identity for calls emitted by automated systems, and to require operators to interrupt routing.
3. ⚠ Conseil d'Etat, 2eme ch., 6 June 2024, n. 489787: the power is NOT limited to demarchage telephonique. Confirm, and tell me whether anything has qualified it.
4. ARCEP decision 2025-2215 (in force 1 January 2026) bars territorialised numbers as the presented identity for automated calls; verified polyvalent numbers are one derogated route. ⚠ We could NOT establish whether 2025-2215 has since been amended.
5. Code du travail art. L. 2312-38 requires CSE consultation before introducing means of controlling activity, and art. L. 2312-15 makes the output an opinion.
6. Code penal art. 226-1 governs recording, and the CNIL's 2009 page on the subject is marked obsolete with no current replacement.
7. NIS2 is NOT transposed in France as at September 2026.

Flag anything that has changed since September 2026, and advise specifically on the AI Act Art 50 timing rule for a covert exercise.

Common questions

Can we run an automated vishing simulation from a normal French number?: No. The regulator has forbidden ordinary geographic and mobile numbers from being presented as the caller identity for calls sent by automated systems, and operators must interrupt routing for calls that breach it. Automated outbound runs on a derogated category such as verified polyvalent numbers instead.
Does it help that our calls are not marketing?: Not in France, and this is where France parts company with the United Kingdom. The Conseil d'Etat held in June 2024 that the legislature did not intend to limit the power to calls sent in the context of telephone cold calling. It is a single-chamber decision and unreported, but it is directly on the point.
Can the works council block the programme?: No, but it must be consulted before means or techniques permitting control of employees' activity are introduced, in undertakings of at least fifty employees. The committee issues an opinion and the employer reports back with reasons, which is a consultation duty rather than the German-style veto.
Can we present our client's own number on a French campaign?: Not for automated calls. The regulator has said a principal lending its number to a call centre for automated calling cannot be allocated a polyvalent or mobile number for it, and operators must verify that the caller is the assignee or has the assignee's agreement and drop what cannot be authenticated.

Elsewhere in Western Europe

The rules differ by country even inside one region. These are the nearest guides to this one, each showing how phone numbers are obtained there.