ENGIE SA – Annual report – 31 December 2025
Industry: utilities
NOTE 17 PROVISIONS
Accounting standards
General principles related to the recognition of a provision
The Group recognizes a provision where it has a present obligation (legal or constructive) towards a third party arising from past events and where it is probable that an outflow of resources will be necessary to settle the obligation with no expected consideration in return.
A provision for restructuring costs is recognized when the general criteria for setting up a provision are met, i.e., when the Group has a detailed formal plan relating to the restructuring and has raised a valid expectation in those affected that it will carry out the restructuring by starting to implement that plan or announcing its main features to those affected by it.
Provisions with a maturity of over 12 months are discounted when the effect of discounting is material. The Group’s main long-term provisions are provisions for the back-end of the nuclear fuel cycle, provisions for dismantling facilities, provisions for site restoration costs, and provisions for post-employment and other long-term benefits. The discount rates used reflect current market assessments of the time value of money and the risks specific to the liability concerned. Expenses with respect to unwinding the discount on the provision are recognized as other financial income and expenses.
Estimates of provisions
Factors having a significant influence on the amount of provisions, and particularly, but not solely, those relating to the back-end of the nuclear fuel cycle, to the dismantling of nuclear facilities and of gas infrastructures in France, include:
- cost estimates (see Note 17.2 “Obligations relating to nuclear power generation facilities”);
- the timing of expenditure (notably the timetable for the end of gas operations regarding the main gas infrastructure businesses in France) (see Notes 17.2 “Obligations relating to nuclear power generation facilities” and 17.3 “Dismantling of non-nuclear plant and equipment and site rehabilitation”); and
- the discount rate applied to cash flows.
These factors are based on information and estimates deemed by the Group to be the most appropriate as of today.
Modifications to certain factors could lead to a significant adjustment in these provisions.
The impact of unwinding discount adjustments in respect of post-employment and other long-term benefits relates to the interest expense on the benefit obligation, net of interest income on plan assets.
The “Other” line mainly comprises actuarial gains and losses arising on post-employment benefit obligations in 2025 which are recorded in “Other comprehensive income”, as well as the effects of transferring responsibility for nuclear waste management to the Belgian State.
Additions, utilizations, reversals and the impact of unwinding discount adjustments are presented as follows in the consolidated income statement:
The different types of provisions and the calculation principles applied are described below.
17.1 Post-employment benefits and other long-term benefits
See Note 18 “Post-employment benefits and other long-term benefits”.
17.2 Obligations relating to nuclear power generation facilities
17.2.1 Closing of the agreement with the Belgian State on the ten-year extension of two reactors and on the transfer of financial responsibility for nuclear waste management to the Belgian State
On March 14, 2025, ENGIE and the Belgian government completed the transaction covering the ten-year extension of the Tihange 3 and Doel 4 nuclear reactors and the transfer of responsibility related to nuclear waste. This final step follows on from the European Commission’s approval on February 21, 2025.
The agreements signed with the Belgian State in 2023 (Phoenix agreements) provided for:
- the 10-year extension of the Doel 4 and Tihange 3 nuclear reactors as part of a 50/50 partnership between the Belgian State and the Group, contingent upon the implementation of a contract for difference protecting ENGIE against market risks; and
- the transfer of financial responsibility to the Belgian State for managing nuclear waste and spent fuel in return for the payment of a lump-sum discharge amount of €15 billion2022, within the limit of a volumetric credit covering all nuclear waste produced by the Belgian power plants during their legal operating life, from commissioning to dismantling.
As agreed, the completion of the transaction resulted in the payment of the first installment to the Belgian State in March 2025 (€12.2 billion, including the Electrabel partners’ share in certain power generation facilities) related to category B and C waste (highly radioactive waste intended for geological storage). This payment was partially settled by monetizing part of the financial assets dedicated to covering nuclear provisions (€9.5 billion).
On July 10, ENGIE restarted the Tihange 3 nuclear reactor and on October 8, reconnected Doel 4 to the grid after a major overhaul to extend their operating life by ten years. The restart of the second reactor resulted in the payment of the second and final installment to the Belgian State (€3.6 billion including the Electrabel partners’ share in certain power generation facilities) related to the transfer of responsibility for low-level radioactive category A waste for surface storage). The two extended-life reactors, Doel 4 and Tihange 3, were brought to BE-NUC, a joint venture owned equally by the Belgian state and ENGIE. The Doel 1, Tihange 1 and Doel 2 reactors were shut down on February 14, September 30 and November 30, 2025, respectively, in line with Belgium’s nuclear phase-out schedule.
At the end of this agreement, the Group essentially retains responsibility for the on-site storage of spent fuel waste until the end of the dismantling operations and until 2050 at the latest, as well as for the conditioning of all waste in accordance with the contractual agreement. The Group will also remain responsible for the final shutdown of the reactors, their dismantling and the clean-up of the site at the end of their operating life. The process of setting up and managing all these provisions, for which the Group is responsible, will continue to be reviewed by the Commission for Nuclear Provisions (CPN) every three years.
17.2.2 Three-year review by the Commission for Nuclear Provisions (CPN)
The Belgian law of April 11, 2003, partially repealed and amended by the law of July 12, 2022, granted Group subsidiary Synatom responsibility for managing provisions set aside to cover the costs of dismantling nuclear power plants and managing spent fuel. This law is supplemented by the law implementing the Phoenix Agreement of April 26, 2024, on guaranteeing security of supply in the energy sector and reforming the nuclear energy sector.
The tasks of the Commission for Nuclear Provisions (CPN), set up pursuant to the above-mentioned law, are to oversee the process of computing and managing these provisions. In accordance with the law, every three years the CPN conducts an audit of the application and adequacy of the calculation methods used to compute nuclear provisions.
To enable the Commission for Nuclear Provisions to carry out its work in accordance with the law, Synatom is required to submit a report every three years describing the core inputs used to measure these provisions.
In this context, on October 2, 2025, Synatom submitted a request to the CPN for a review of nuclear provisions, which was approved a second time by its Board of Directors after an initial decision was overturned by the Minister of Energy in a letter dated September 12, 2025, following the suspensive appeal lodged on September 2, 2025, by the Belgian government representatives on Synatom’s Board of Directors. The file submitted to the CPN proposes, in addition to various updates, a provision decrease of approximately €1 billion, resulting from technical optimizations, a downward assessment of the overall risk level, and an increase in the discount rate.
On December 23, 2025, the CPN sent Synatom a copy of the notice it had received from the National Agency for Radioactive Waste and Enriched Fissile Material (Organisme National pour Déchets Radioactifs et des matières Fissiles enrichies – ONDRAF). This notice recommends a very significant increase, approximately €2,5 billion, in the total estimated expenditure compared to the assumptions made during the last triennial review. In an exchange with the CPN on January 8, 2026, confirmed by letter dated January 9, 2026, the Group rejected these recommendations, considering them preliminary, overly conservative and, in some cases, contradictory.
The notice issued by ONDRAF is in line with the methodology to be adopted by the CPN when reviewing Synatom’s proposed provision adjustments. It is not binding on the CPN, which has 120 days from submission of the documentation to inform Synatom of its comments and invite it to submit, within 60 days, either a new proposal that takes its comments into account, or a reasoned opinion outlining the reasons why the comments cannot be acted upon. Moreover, it is common for the CPN to revise the estimates provided by ONDRAF ̶ estimates that we challenge whenever they diverge from the most recent technical, economic, or financial data, as well as from the most likely industrial scenarios. Those estimates should also include the upward trend in interest rates. The CPN then adopts its decision. In view of the significant changes proposed in the ONDRAF notice, Synatom requested and obtained a 75-day extension to the usual 120-day deadline in order to continue discussions with ONDRAF and CPN on the parameters and cost assumptions underlying the assessment of provisions.
Consequently, in light of the above and in the absence of an opinion from the CPN, the Group considers that the latest assumptions reviewed and approved by the CPN in its final opinion issued on July 7, 2023, during the last triennial review exercise, supplemented by the opinion of June 24, 2024, on the assessment of the impact of the extension of Doel 4 and Tihange 3, remain the most appropriate to date for establishing nuclear provisions as of December 31, 2025.
17.2.3 Provisions for the back-end of the nuclear fuel cycle
Under the terms of the agreement with the Belgian State, the risks associated with this liability have been considerably reduced. With regard to waste management, the Group’s responsibility is essentially limited to on-site storage of fuel elements until the end of dismantling operations, and until 2050 at the latest, as well as compliance with the contractual criteria for transferring waste to ONDRAF, with the liability estimated at €1.7 billion2022, as indicated in the draft law implementing the agreement.
Provisions not covered by the lump-sum discharge payment are calculated based on the following principles and inputs:
- storage costs primarily comprise the costs of building and operating additional dry storage facilities and operating existing facilities, along with the costs of purchasing containers;
- a discount rate of 3.0% (including inflation of 2.0%) was used by the CNP at the time of the previous triennial review, for the portion not covered by the lump-sum discharge payment.
The costs effectively incurred in the future may differ from the estimates in terms of their nature and timing of payment.
Sensitivity
As indicated in the previous section, uncertainty surrounding the finalization of the 2025 documentation submitted to the CPN led the Group to maintain the carrying amount of nuclear provisions at December 31, 2025 on the basis of the CPN’s definitive July 2023 opinion, supplemented by the opinion of June 24, 2024 on the impact assessment of the extension of Doel 4 and Tihange 3. Following the assumption by the Belgian State of all obligations relating to nuclear waste after its transfer to ONDRAF, the Group will only remain exposed to changes in future storage and conditioning costs and the corresponding discounting inputs prior to the transfer (as mentioned above, liability estimated at €1.7 billion2022):
- the costs of building dry storage facilities and purchasing fuel element containers at the Group’s sites could differ from those covered by the provisions. A 10% change in these costs, still to be incurred would represent a €60 million change in provisions;
- a 10% change in the annual operating costs of the storage facilities would result in a €30 million change in the provision;
- a 25 basis point change in the discount rate would result in a €40 million adjustment to non-transferred provisions. A fall in the discount rate would lead to an increase in outstanding provisions, while a rise in the discount rate would reduce the provisions’ amount.
It should be noted that the risk of exceeding volumetric credits is considered, at this stage, to be highly unlikely, as the volumetric credits established in the agreement have incorporated the volumetric contingencies estimated as part of the provision review in 2022.
17.2.4 Provisions for dismantling nuclear facilities
Accounting standards
A provision is recognized when the Group has a present legal or constructive obligation to dismantle facilities or to restore a site. The present value of the obligation at the time of commissioning represents the initial amount of the provision for dismantling with, as the counterpart, an asset for the same amount, which is included in the carrying amount of the facilities concerned. This asset is depreciated over the operating life of the facilities and is included in the scope of assets subject to impairment tests. Adjustments to the provision due to subsequent changes in (i) the expected outflow of resources, (ii) the timing of dismantling expenses or (iii) the discount rate, are deducted from or subject to specific conditions, added to the cost of the corresponding asset. The impacts of unwinding the discount each year are recognized in expenses for the period.
In view of the legal end-of-life of the Belgian nuclear reactors, any provision adjustments will have a direct impact on the income statement for the year (including provisions relating to the two extended-life reactors whose assets have been transferred to the joint venture equally owned with the Belgian State). A provision is also recorded for nuclear units for which the Group holds a capacity (France) right up to its share of the expected dismantling costs to be borne by the Group.
At the end of their operating life, the nuclear power plants must be shut down for the period during which spent fuel is unloaded from the plant, and until the site is dismantled and cleaned up.
The dismantling strategy is based on the facilities being dismantled (i) immediately after the reactor is shut down, (ii) on a mass basis rather than on a unit-by-unit basis, and (iii) completely, the land being subsequently returned to greenfield status.
As a result of the agreement, financial responsibility for the management of all category A and B waste conditioned in accordance with the contractual transfer criteria will henceforth lie with the State, with the Group now only liable for final shutdown and dismantling.
The Group’s remaining liability for the final shutdown and dismantling is estimated at €6.7 billion2022, as set out in the law implementing the agreement. At December 31, 2025, provisions for dismantling nuclear facilities are calculated based on the following inputs:
- the start of the technical shutdown procedures depends on the unit concerned and on the timing of operations for the whole nuclear reactor. The shutdown procedures are immediately followed by dismantling operations;
- the scenario adopted is based on a dismantling program and on timetables that must be approved by the nuclear safety authorities. The safety conditions for the shutdown phases have been defined with the Belgian Federal Agency for Nuclear Control (AFCN) for the Doel 3 and Tihange 2 units that have already been shut down. The safety conditions for the dismantling phase have not yet been determined. The costs may change depending on the outcome of these discussions and the detailed schedule for the implementation of these phases which is currently being defined;
- costs payable over the long term are calculated by reference to the estimated costs for each nuclear facility, based on a study conducted by independent experts under the assumption that the facilities will be dismantled on a mass basis. The costs effectively incurred in the future may differ from the estimates in terms of their nature and timing of payment;
- for the various phases, margins for contingencies, reviewed by ONDRAF and the Commission for Nuclear Provisions (CPN), are included during the last triennial review;
- an inflation rate of 2.0% is applied until the dismantling obligations expire in order to determine the value of the future obligation;
- the discount rate used by the CPN, during the last triennial review, was 2.5% (including inflation of 2.0%).
The costs effectively incurred in the future may differ from the estimates in terms of their nature and timing of payment.
Lastly, the Group sets aside provisions to cover the costs relating to the final shutdown phase of its drawing rights in Tricastin and Chooz B, as well as for the dismantling period leading to the dismantling and clean-up of the Chooz B site, in accordance with the respective agreements with EDF. These remain unchanged compared to 2024, and are based on provisions for Belgian assets that most closely resemble these power plants, and are updated in line with revisions by the CPN.
Sensitivity
As indicated in the previous section, uncertainty surrounding the finalization of the 2025 CPN documentation led the Group to maintain the carrying amount of nuclear provisions at December 31, 2025 on the basis of the CPN’s definitive July 2023 opinion, supplemented by the opinion of June 24, 2024 on the impact assessment of the extension of Doel 4 and Tihange 3. In light of the agreement, the Group is only responsible for shutdown and dismantling, including conditioning of the nuclear waste arising from these operations, in accordance with the contractual transfer criteria (as indicated above, liability estimated at €6.7 billion2022):
- a 10% change in shutdown costs of the units would lead to a change in the provisions of around €200 million;
- a 10% change in unit dismantling costs would lead to a change of around €400 million in nuclear provisions;
- a 25 basis point change in the discount rate would lead to an adjustment of approximately €170 million in the provisions. A fall in the discount rate would lead to an increase in outstanding provisions, while a rise in the discount rate would reduce the provisions’ amount.
17.2.5 Financial assets set aside to cover the future costs of dismantling nuclear facilities and managing radioactive fissile material
As indicated above, the Belgian law of July 12, 2022, partially repealing and amending the law of April 11, 2003, granted the Group’s wholly-owned subsidiary Synatom responsibility for managing and investing funds received from operators of nuclear power plants in Belgium and intended to cover the costs of dismantling nuclear power plants and managing spent fuel. Pursuant to the law of April 11, 2003, Synatom could lend up to 75% of these funds to nuclear power plant operators provided that certain credit quality criteria are met.
The amount of outstanding loans between Synatom and nuclear operators, representing the countervalue of provisions for spent fuel management, was repaid to Synatom as at December 31, 2025, and the amount of outstanding loans between Synatom and Electrabel, representing the countervalue of provisions for dismantling, will be repaid by September 30, 2031.
The percentage of the provisions not subject to loans to nuclear operators is invested by Synatom either in external financial assets or in loans to legal entities meeting the “credit quality” criteria imposed by law.
The Synatom Board of Directors and its Investment Committee are responsible for defining Synatom’s investment policy after consultation with the CPN, in accordance with the law of July 12, 2022. Based on a rigorous risk control policy, the Investment Committee oversees investment decisions, which are managed by a team headed by an Investment Director.
Synatom invested some €2.1 billion in such assets in 2025.
The value of financial assets dedicated to covering nuclear provisions amounted to €5,624 million at December 31, 2025, and their return was 5.4% for the year.
17.2.5.1 Valuation of financial assets in 2025
Loans to entities outside the Group and other cash investments are shown in the table below:
Loans to legal entities outside the Group and the cash held by the Undertaking for Collective Investment in Transferable Securities (UCITS) are presented in the statement of financial position under “Loans and receivables at amortized cost”. Bonds and associated hedging instruments held by Synatom through the UCITS are presented under equity or debt instruments (see Note 14.1 “Financial assets”).
The change in the period mainly includes the effects of monetizing part of the nuclear provisions hedging assets in order to settle the payment of the first and second last installments of the nuclear liabilities (see Notes 4.2.2 “Closing of the agreement with the Belgian State on the ten-year extension of two reactors and on the transfer of financial responsibility for nuclear waste management to the Belgian State” and 14.1.1.3 “Loans and receivables at amortized cost”).
The breakdown in the change in the cumulative fair value of Synatom’s assets is presented as follows:
The net gain for the period generated by these assets amounted to €283 million in 2025 (net profit of €324 million in 2024).
17.3 Dismantling of non-nuclear plant and equipment and site rehabilitation
17.3.1 Dismantling obligations arising on non-nuclear plant and equipment
Certain items of plant and equipment, including conventional power stations, transmission and distribution pipelines, storage facilities and LNG terminals, have to be dismantled at the end of their operational lives or safely shut down. These obligations are the result of prevailing environmental regulations in the countries concerned, contractual agreements, or an implicit Group commitment. The most important issue for the Group concerns gas infrastructures in France.
France’s political guidelines for the energy transition aim to achieve carbon neutrality by 2050, by reducing greenhouse gas emissions and promoting renewable energies, particularly biomethane and hydrogen. The scenarios for achieving this goal, including France’s National Low Carbon Scenario, the ADEME scenarios, and RTE’s “Energy Futures” prospective study, project a significant decline in gas consumption, while maintaining an important role for gas infrastructure, which is necessary to ensure the flexibility of the energy system and limit the rise in peak electricity demand.
The Multi-Year Energy Program (PPE 3), which was open for public consultation from November 4 to December 16, 2024, and whose implementing decree was published on February 13, 2026, confirms the growing importance of renewable gases in the future energy mix, with a target of 44 TWh injected by 2030, a target confirmed by the March 2025 report of the Court of Auditors. The roadmap also provides for increased development of hydrogen and the need to strengthen national green gas and CO2 networks. These guidelines reinforce the Group’s vision of the importance of gas infrastructure in France and its continued role in the national energy landscape.
This analysis is also shared by the CRE, which in April 2023 issued a report entitled “The future of gas infrastructure in 2030 and 2050, in the context of achieving carbon neutrality” following its work with gas infrastructure operators and various stakeholders. The CRE continued its study during 2025 with a view to publishing a new report in 2026.
In addition, the gas package published in May 2024 paves the way for the implementation of a regulatory framework for hydrogen transport to be rolled out by 2033 at the latest. To this end, in October 2025, the CRE began preparatory work, including workshops between November 2025 and May 2026, focusing in particular on the certification of network operators, transport, balancing, storage, and terminals. This work increases the visibility of the gradual conversion and future use of existing infrastructure.
Due to the projected importance of green gases in the French energy mix scheduled for 2050 and beyond, gas infrastructures will remain largely necessary. Their adaptation and reconversion to green gas, hydrogen or CO2 transport mean that they can be used in the very distant future, which means that the present value of future dismantling expenses is almost zero, except in the specific cases of LNG terminals and reduced operation and non-regulated storage sites mainly in France and Germany, for which provisions for dismantling amounted to €363 million at December 31, 2025 and €353 million at December 31, 2024.
Given its time horizon and developments in French and European public policies, the Group will continue to assess the long-term scenario that will enable it to achieve carbon neutrality by 2050 on a regular basis. These assessments will be accompanied by a review of the valuation of dismantling provisions.
A more substantial change in the regulatory framework could have an impact on the sizing, operating life and dismantling schedule of gas infrastructures in France, and could have an impact on the amount of the provision for dismantling.
17.3.2 Hazelwood Power Station & Mine (Australia)
The Group and its partner Mitsui announced in November 2016 their decision to close the coal-fired Hazelwood Power Station, and cease coal extraction operations from the adjoining mine from late March 2017. The Group holds a 72% interest in the former 1,600 MW power station and adjoining coal mine, which has been consolidated as a joint operation.
At December 31, 2025, the Group’s share (72%) of the provision covering the obligation to dismantle and rehabilitate the mine amounted to €194 million, versus €239 million at December 31, 2024.
Dismantling and site rehabilitation work commenced in 2017 and focused on: managing site contamination; planning site wide environmental clean-up; the demolition and dismantling of all of the site’s industrial facilities, including the former power station; and ongoing aquifer pumping and designated earthworks within the mine to ensure mine floor and batter stability with a view to long-term rehabilitation into a pit lake.
The ultimate regulatory obligations are likely to be revised during the life of the project and could therefore have an impact on provisions.
The amount of the provision recognized is based on the Group’s best current estimate of the demolition and rehabilitation costs that Hazelwood is expected to incur. However, the amount of this provision may be adjusted in the future to take into account any changes in the key inputs.
17.4 Other contingencies
This caption essentially includes provisions for commercial litigation, tax claims and disputes (except income tax, pursuant to IFRIC 23), provisions for restructuring and provisions for onerous contracts relating to storage and transport capacity reservation contracts.
Accounts examples 