The French government last week approved legislation to boost transparency in the extractives industry, forcing large mining, forestry, and other extractive companies to report payments to governments on a country by country basis as well as on a project basis.

France joined the United Kingdom in implementing the European Union directive before the July 2015 deadline. The EU law, passed last year, requires large listed and unlisted oil, gas, mining, and forestry firms to publish annually material payments to governments of countries in which they operate, beginning with January 2016 financial statements. Companies covered by the law must exceed two of the three criteria set by the EU – turnover of €40 million, assets of €20 million, or 250 employees. The U.K. passed its implementation of the directive in August.

Last year both the U.K. and France joined the Extractive Industries Transparency Initiative (EITI), a long-running effort designed to combat corruption by requiring extractives companies to disclose government payments, which in turn helps those in often poor host countries track payments for their natural resources.

The French law, which calls for payments exceeding €100,000 a year to be reported, will take effect this January. The reports must be free and publicly accessible. The debate over the legislation included whether the new rules should extend to subsidiaries.

France General Assembly member Christophe Caresche, the rapporteur for the legislation, said extending the reporting requirements to subsidiaries would create a number of problems, particularly since the proposed amendment applied to all subsidiaries and not those just engaged in actual mining activities. It also could put French-based companies at a competitive disadvantage, he indicated.

“Not only do these amendments go beyond the scope of the directive, but they induce a breach of equality because they would impose different constraints to companies of the same sector,” Caresche said during the debate, according to a translation of the legislative session transcript. “By imposing on a subsidiary acting outside the mining sector a constraint that a competing company from the same industry would not be facing, we would introduce unequal treatment that seems problematic. I do not want to impose on French companies, in an area that is strategic and hyper-competitive, constraints that would involve difficulty in terms of competition.”

Critics of the move, including Oxfam France, called the law a “missed opportunity for transparency” and a victory for the extractives lobby. In its statement released after the vote, Oxfam France pointed out that the law fell short of previous commitments by French President Francois Hollande and others that new requirements would encompass all subsidiaries, especially those located in tax havens. The concern is companies could avoid disclosure by shuffling government payments to subsidiaries based in tax havens.

However, Caresche said the fight against corruption and the fight against tax evasion are two different objectives, and noted the G20 leaders were planning to discuss the tax evasion issue at their upcoming summit.