On 30 September 2026, CFE-CGC Groupe RATP, the management union, filed a social alarm with Jean Agulhon, the group's human resources director. The one-page letter, published on the union's website and signed by Valérie Vovk, central union delegate and vice-president of the organisation, rests on a single ground, quoted here in full: "Non-compliance with social dialogue regarding the deployment of AI in the company and non-compliance with employee representative bodies in terms of information and consultation on projects to introduce new technologies in the company."

The letter names no tool or project. It gives no figures and makes no demand, other than to meet management representatives. Its vocabulary, "information consultation", "introduction of new technologies", is that of the labour code.

Vocabulary borrowed from the labour code

Article L. 2312-8 of the labour code provides that the social and economic committee (CSE) "is informed and consulted" on matters concerning the organisation and running of the company, "in particular" on "the introduction of new technologies, any major change affecting health and safety or working conditions". These rules apply to RATP: Article L. 2311-1 declares them applicable to public industrial and commercial establishments.

For uses affecting staff, Article L. 2312-38 requires the CSE to be informed "prior to their introduction in the company" about "automated personnel management processing", and to be informed and consulted, before any decision, on techniques "enabling monitoring of employee activity". Article L. 2312-15 requires a "sufficient examination period" and "precise written information". Depending on the case, these texts therefore require prior information or consultation: the tool must be presented to elected representatives before it is implemented.

Nanterre, Créteil, Paris: CSEs before the interim judge

Committees that felt bypassed have already won. On 14 February 2025, the interim judge of the Nanterre judicial court ordered a company, whose name is redacted in the anonymised version of the order, to "suspend the deployment" of five IT tools, including Finovox and Synthesia, "until completion of the consultation" of the CSE begun on 26 September 2024, under a penalty of one thousand euros per infringement found for ninety days. The employer argued that the tools were being tested. The judge held that this phase "on the contrary constitutes an initial implementation" and that early deployment constituted "a manifestly unlawful disturbance".

On 15 July 2025, the Créteil judicial court in turn suspended the use of AI tools in the press sector until the consultation was closed, according to the commentary by Caroline Froger-Michon, partner at CMS Francis Lefebvre, and Violaine Goux, who quote this reason: "It is not seriously contestable that artificial intelligence is a new technology".

In a judgment of 21 May 2026, the Paris Court of Appeal upheld that order. The case concerned Groupe Industrie Services Info (GISI), a subsidiary of Infopro Digital, its editorial assistant DIGI and authorised access to ChatGPT. The court held it irrelevant that use of the tool was optional, or that employees had used AI before any employer decision. When a project advances through staggered decisions, the committee "must be consulted at each stage", it wrote, echoing the first judge. ActuIA had reported on this judgment in June.

Judges do not always side with elected representatives. In a note of 13 April 2026, the same authors mention an order of the Paris judicial court of 10 February 2026 according to which Copilot 365 is not a major project requiring CSE consultation. The note mainly comments on a Nanterre order of 29 January 2026, which required consultation for the replacement of HR software already incorporating AI. For its authors, analysis of uses and their effects on the organisation "takes precedence" over technical characteristics.

Nine demands set out as early as June

In a leaflet dated June 2026, CFE-CGC Groupe RATP said it had been received in a meeting by management after challenging it "on several occasions" about "the lack of social dialogue" around AI. It listed nine demands, including no job cuts linked to AI, a register of AI systems, an impact study before each deployment and sharing of productivity gains.

The same document reports that management proposed opening negotiations on a method agreement in the last quarter of 2026, and that the union replied that in the meantime, any deployment or experiment introducing AI must be subject to information and consultation. This is the union's version; management has not published its own, and no announcement of the opening of such negotiations was found as of 5 October.

Quoted by La Revue du Digital on 1 October, Fabien Renaud and Valérie Vovk, president and vice-president of CFE-CGC Groupe RATP, demand that deployment be carried out "transparently, with clear governance, a genuine assessment of its impacts and consultation with employee representatives". According to the same article, the union says it is not opposed to AI and notes that management proposes to use it notably in human resources, which it considers "antinomic" with "human resource management".

Five working days for a report

The social alarm is a procedure that RATP's collective agreement presents as an in-house creation. Article 70 of amendment no. 3 to the agreement on the quality of social dialogue, signed on 7 July 2022, recalls that RATP "was the originator of the social alarm mechanism for conflict prevention", taken up by the law of 21 August 2007 on continuity of public transport service. The transport code, at Article L. 1324-2, has since provided that a strike notice may only be given "after prior negotiation" with the unions considering filing it.

Only union delegates may trigger the alarm, with one ground per alarm. Management must then "hold a meeting with the authors of the alarm and draft the report of agreement or disagreement within 5 working days" of receipt, unless an additional period is agreed. For a letter received on 30 September, this period expires on 6 October. The alarm necessarily precedes any strike: "no strike notice may validly be filed unless this prevention procedure has been previously implemented and has resulted in a report of disagreement". The letter of 30 September mentions no action.

As of 5 October 2026, no public response from RATP management to this alarm has been found, nor any published report. The group's documents on AI mainly concern operations: predictive maintenance and graffiti detection in a press release of June 2025, and a generative AI assistant, "SEM'Alain", presented in October 2025 on the group's website as "currently deployed on metro and RER lines" to answer operational questions from station staff. These pages do not say whether the tools have been submitted to the bodies; the union letter does not target them.

Two weeks before professional elections

RATP's professional elections take place from 19 to 23 October 2026, according to the union, which is making AI a campaign theme: "For AI serving employees, and not the other way round, from 19 to 23 October, vote CFE-CGC Groupe RATP", concludes a text it published on 25 September. The alarm comes from a single union, that of management, and was filed less than three weeks before the vote. This context says nothing about the merits of the grievance, but sheds light on the choice to make it public.

The European regulation will wait until December 2027

The European AI regulation also provides for informing elected representatives. Its Article 26, paragraph 7, obliges an employer putting a high-risk AI system into service in the workplace to inform worker representatives and affected employees in advance. For systems in Annex III, point 4 of which covers employment and worker management, Article 113 as amended by Regulation (EU) 2026/1744 postpones application to 2 December 2027. The tools described in the documents cited above (maintenance, graffiti detection, operational assistant) do not concern employment decisions; the HR uses mentioned by the union are not publicly detailed. In France, the obligation to consult the CSE applies without waiting for that date.

For an employer, litigation turns on two questions: does the tool affect working conditions, and was it implemented before the CSE's opinion? A pilot extended before that opinion exposes one to an interim order, which is decided on documents: dates of information, documents transmitted, opinion given or not.

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