Transparency is a fundamental pillar of corporate governance and a key tool for reducing information asymmetry between managers and stakeholders. In contemporary legal systems, managers' obligation to transparency transcends administrative or financial requirements, being recognized as a manifestation of fiduciary duty and duty of loyalty. However, in Iranian law, this obligation lacks a coherent legal framework, with regulations scattered across various laws. Conversely, French law has established a comprehensive framework through legislative reforms, judicial precedents, and EU regulations. This research examines the theoretical foundations and comparative scope of managers' transparency obligation in Iranian and French law using a descriptive-analytical and functional comparative approach. Findings reveal that while both systems emphasize information disclosure and stakeholder protection, French law demonstrates greater conceptual coherence, broader scope, and more effective enforcement mechanisms as part of managers' duty of loyalty. Iranian law faces challenges including regulatory fragmentation, ambiguous obligation boundaries, and weak supervisory mechanisms