Heatwaves: complying with the July 2026 decree with HelloSpot

The register of vulnerable people changed in nature this summer. Decree no. 2026-590 of July 3, 2026, published in the Journal officiel (France’s official gazette) on July 4 and in force since July 5, turns it into a tool kept all year round, partly fed by the département and the pension fund, and subject to more precise data rules.

The short answer: the register is no longer used only for alerts. It is also used to inform people of their rights and to combat isolation. Recipients of the APA and the PCH will be registered automatically from 2027, unless they object. And every registration must be traced, confirmed and restricted to staff designated by the mayor.

What follows summarizes the text published on Légifrance, then how HelloSpot lets you apply it.

What the decree of July 3, 2026 changes

The decree implements article L. 121-6-1 of the Code de l’action sociale et des familles (CASF, France’s social action and families code), as amended by law no. 2024-317 of April 8, 2024, known as the “ageing well” law. It creates three articles, R. 121-1-1 to R. 121-1-3, and largely rewrites articles R. 121-2 to R. 121-11 of the same code.

A register kept all year round, with three purposes

Until now, the register was “exclusively limited” to implementing the alert and emergency plan. That wording has been removed. Article R. 121-1-1 now gives it three purposes:

1. organizing regular contact with registered people when the alert and emergency plan is triggered;
2. informing these people and their relatives of their rights, of the benefits they may be entitled to and of support and assistance schemes;
3. offering actions against social isolation and identifying situations of loss of autonomy.

Any reuse of the data for electoral or commercial purposes is prohibited. Each person can object at any time to the processing of their data, for all or some of these purposes.

Heatwaves, cold spells: the same register

The decree mentions neither heat nor cold. It refers to the alert and emergency plan of article L. 116-3 of the CASF, set up in each département (France’s administrative county) “in the event of exceptional risks”. A cold spell therefore falls under the same register and the same rules as a heatwave.

Two ways onto the register

On request (article R. 121-1-2). The following people may be registered, at their own request or that of a third party, unless they or the person in charge of their legal protection object:

• people aged 65 and over living at home;
• people over 60 recognized as unfit for work, living at home;
• disabled adults receiving a disability-related benefit (allocation aux adultes handicapés, carte mobilité inclusion…) or an invalidity pension, living at home.

The person themselves, or the person in charge of their legal protection, can make the request by any means provided by the mayor. A third party, however, must make it in writing. The mayor acknowledges receipt of the request, and this acknowledgment serves as confirmation of the person’s consent. It reminds them that they can be removed at any time.

Automatically, unless they object (article R. 121-1-3). The following people are registered without having to take any step, unless they object within two months of the notice received with their award decision:

• recipients of the personal autonomy allowance (APA, a benefit for elderly people losing autonomy) living at home;
• adult recipients of the disability compensation benefit (PCH);
• recipients of social action benefits paid by pension funds for loss of autonomy.

Once a year, the president of the departmental council and the CARSAT (the regional pension and occupational health fund) send the mayor the data of new recipients: identity and contact details, type of benefit and, where applicable, the legal protection arrangement with the contact details of the person in charge of it. These files contain no data on medical conditions or on the level of loss of autonomy.

On receipt, the mayor sends each person, or the person in charge of their protection, a letter confirming their registration and informing them that they can be removed at any time.

The timeline for automatic registration

The département and the CARSAT must inform current recipients by January 31, 2027 at the latest. Each recipient then has two months to object to the transfer. The decree sets no date for the transfer that follows: the first files will reach town halls at the earliest two months after that notice, most likely in spring 2027 for most municipalities, just before the hot season. After that, the transfer becomes annual, for new recipients.

What the register may contain

Article R. 121-4 sets out the list of data that may be recorded:

• identity and contact details: last name, first name, date of birth, sex, address, e-mail address, telephone;
• where applicable, the legal protection arrangement and the identity and contact details of the person in charge of it;
• the capacity in which the person is registered, and the type of benefit received;
• living conditions at home;
• housing: its type and how the air can be cooled;
• dates of prolonged absence and the people to notify in an emergency;
• where applicable, the contact details of the home care service;
• the date of registration and, if the request comes from a third party, their name and capacity.

At any time, the mayor may ask registered people to complete this information.

Who has access, and for how long

The mayor ensures the data is accurate and updates it regularly. Every five years, the mayor checks that registered people do not object to remaining on the register. A person admitted to a social or medico-social facility is removed from it.

Only the mayor and the staff of the municipal social services, the CCAS (municipal social action center) or the CIAS (its intermunicipal equivalent) individually designated and authorized by the mayor may consult, enter or modify the data, on a need-to-know basis. These staff members are bound by professional secrecy.

When the alert plan is triggered, the mayor gives the prefect (the State’s representative in the département), on request, the data needed to contact the people concerned. Health services, social and medico-social facilities and services supporting older or disabled people and, where applicable, the CIAS may also receive some data, according to their remit and the purpose pursued. Outside an alert, for information on rights or combating isolation, they ask for it in writing.

The data is kept until the person’s death or until their removal from the register. Technical traces of use of the register are kept for one year.

How HelloSpot applies the decree

HelloSpot builds these rules into the “Heatwave” (« Canicule ») folder of the one-stop shop procedure catalog, ready to use in the template account for CCAS. The municipality has no form to build: it reviews the procedures, adjusts them if needed and publishes them.

Online procedures for residents and their relatives

Residents find the procedures they need on the municipality’s website:

• register themselves on the register;
• register a relative or a third party, including a person under guardianship or curatorship. The applicant states their relationship with the person and, where applicable, the contact details of the person in charge of the protection measure. The online form is an electronic written document: it meets the requirement of a written request for a third party;
• unregister, at any time.

Each procedure records the reason for registration among those provided for by the text: 65 and over, over 60 and recognized as unfit for work, disabled adult, recipient of the APA or the PCH. The acknowledgment of receipt is sent automatically. A person who cannot complete the procedure online, or the person in charge of their legal protection, goes through the front desk or the telephone: a staff member enters their request in the same register.

Automatic registration from the département and CARSAT files

When the annual file from the département or the CARSAT arrives, the municipality imports it into HelloSpot. Beneficiaries join the register with the data from the file. The municipality then sends them the confirmation letter required by the decree. Duplicates with registrations already received are flagged, and the staff member keeps the final decision.

A register you can use during the alert

On the day the prefect triggers the alert plan, for a heatwave as for a cold spell, the register becomes the municipality’s action list:

• the contact details of each person and of the relatives to notify, close at hand;
• alert reminders and SMS messages, according to the contact method each person has chosen (see email and SMS reminders and citizen communication);
• organizing home visits.

The rest of the year, the municipality can use it for the other two purposes: informing people of their rights and identifying those who are becoming isolated.

Access restricted to designated staff

The decree restricts access to staff members individually designated and authorized by the mayor. In HelloSpot, each staff member has their own account and their own permissions: front desk staff can enter a registration without seeing the whole register, while the CCAS works on the complete list. The data is hosted in France (see privacy, GDPR and data sovereignty).

What remains to be done at the town hall

The decree and the GDPR leave the municipality a few decisions that the tool does not make for it:

• designate and individually authorize the staff who consult and modify the register (a written decision keeps a record of that choice);
• update the information given to residents: the three purposes, the possible recipients, the right to object at any time;
• prepare the confirmation letter sent to people registered automatically, before the first file arrives;
• schedule the five-yearly check that registered people do not object to remaining on the register;
• record the register in the municipality’s record of processing activities, with its new purposes and its retention period.

For keeping the register day to day and managing a heat episode, see also our article on the register of vulnerable people. The complete system is presented on the heatwave help and prevention page.