ESG Reporting

What the Framework Covers Today

The framework replaces the earlier Déclaration de Performance Extra-Financière (DPEF) for entities now in scope of CSRD, while preserving DPEF rules for smaller firms below the new thresholds. The information disclosed is prepared on a double-materiality basis: both the impact of the organization on people and the planet, and the financial materiality of relevant matters for the same organization.

The output sits in the rapport de gestion and reads as a structured summary covering climate, biodiversity, water, pollution, workforce, value-chain workers, affected communities, consumers and clients, conduct, and oversight. The text under ESRS sits alongside financial statements and is not a parallel marketing exercise: the same general ledger, payroll feeds, HR records, energy records and consolidation perimeter underpin both. Each entity in scope must publish a thorough annual write-up of its performance, the KPIs chosen, and the methodology applied.

What We Deliver: Our CSRD Service

Our scope covers the full cycle, from scoping to limited assurance:

• CSRD scoping: confirmation of wave applicability, double-materiality work, ESRS topic prioritisation, group disclosure perimeter
• Gap analysis: assessment of current records, internal controls and disclosures against ESRS specifications, with a transition plan to close gaps
• Information architecture: design of the flow from operations, HR, supply chain, energy systems and finance ledger into the published layer
• Controls design: segregation, evidence retention, audit trail aligned with ESRS expectations and CNCC professional rules
• Drafting: the relevant section of the rapport de gestion under ESRS, in the language of the engagement, with quarterly figures where the indicators require them
• KPIs and metrics: selection of the key performance indicators, ecology metrics, workforce measures and oversight signals, including a reasonable methodology for each ratio
• Limited assurance: a mandate delivered under CNCC professional rules, aligned with the IAASB International Standard on Sustainability Assurance (ISSA) 5000 as adopted in France
• Coordination with the statutory auditor: where Interexco is the commissaire aux comptes, the assurance work is joined up with the financial audit; where another firm holds the audit mandate, Interexco can act as the designated independent assurance practitioner where French law permits

France vs. Internationally

In France, the regime is built on the CSRD and the ESRS, transposed by Ordonnance n° 2023-1142 du 6 décembre 2023 into the Code de commerce, with detailed Décret n° 2023-1394 du 30 décembre 2023 implementation rules. The output sits inside the rapport de gestion, in a defined section, and is subject to limited assurance.

Internationally, the picture is fragmented. The IFRS Foundation’s International Sustainability Standards Board (ISSB) has issued IFRS S1 and IFRS S2, adopted in jurisdictions including the United Kingdom, Japan, Canada, Australia and several Asian markets. The United States Securities and Exchange Commission (SEC) disclosure rule has had a complicated implementation history and is currently in flux. Globally, an increasing range of investors and rating agencies require disclosure that is comparable across jurisdictions; the ISSB framework and ESRS are aligned on climate, with a structured interoperability bridge published by EFRAG and the ISSB in June 2024.

For French subsidiaries of foreign groups, the practical challenge is to deliver one framework that satisfies the European CSRD expectations of the local entity and the global investor publication of the parent. The combined model we apply enables a single information architecture to feed both streams, which strengthens transparency, helps reduce the cost of group-level consolidation, and lowers the operational expenses of duplicate workflows. We support groups in assessing both stacks side by side and in selecting the right framework for cross-border disclosure.

French Oversight Landscape

The French framework sits within a structured oversight context. It is anchored in:

• Code de commerce — provisions on the rapport de gestion, the disclosure, and the role of the commissaire aux comptes in limited assurance, as amended by the EU transposition
• Ordre des Experts-Comptables (OEC) — regulator of chartered accountancy practice, sets the ethical and quality framework for advisory work
• Compagnie Nationale des Commissaires aux Comptes (CNCC) — regulator and standard-setter for statutory audit and assurance in France, sets the professional rules for limited assurance work
• Autorité des Marchés Financiers (AMF) — supervises listed-issuer disclosure, publishes guidance on materiality and the reliability of green and societal data
• Autorité des Normes Comptables (ANC) — French accounting standard-setter, contributes to the technical interpretation of ESRS in the French context
• Code du travail — underpins the workforce measures (headcount, training programs, equality, health and safety) within ESRS S1 chapters
• DGFiP — confirms the tax treatment of transition expenses, green investment incentives and related profit-and-loss items linked to the green shift
• Loi Informatique et Libertés and the Commission Nationale de l’Informatique et des Libertés (CNIL) — frame the personal-information dimension of social data on employees, clients and suppliers

The statutory audit thresholds were updated in 2024: a financial audit is required where two of three thresholds are met on two consecutive financial years — bilan ≥ €5 M, CA HT ≥ €10 M, ≥ 50 employees (Décret n° 2024-152 du 28 février 2024, transposing EU Directive 2023/2775). These thresholds matter for the wider framework because audit and assurance work are commonly carried by the same firm, and the joint mandate is the most efficient response when both apply. The standard French rate of 25% (DGFiP, 2025) likewise frames the cash impact of transition investment decisions disclosed in the plan.

CSRD Wave One: First Application in France in 2025

CSRD wave one application in France covers large public-interest entities — listed companies, banks and insurance undertakings — with more than 500 employees, a balance-sheet total exceeding €25 million, or turnover exceeding €50 million (European Commission, CSRD Implementation, 2025). Wave-one issuers reported on the year 2024, with limited assurance signed off by the statutory auditor or a designated independent assurance practitioner.

In July 2025, the European Commission adopted a quick fix easing certain items for wave-one issuers for fiscal years 2025 and 2026, and the AMF signalled a pragmatic supervisory approach during the transition. Wave two extends scope to large firms not previously included; wave three covers listed SMEs and uses proportionate ESRS rules. The 2025 Omnibus package and the related EU work continue to refine the scope, content and timetable, which remain under active development.

For a French subsidiary of a foreign parent, the wave-one consolidation rules can change the obligation even when the local entity itself is small. The double-materiality analysis is the key step that confirms scope, identifies the relevant ESRS topics and provides an early read on the information architecture in scope.

Who Uses Our Service

Our typical mandate covers the following profiles:

• Listed groups and large public-interest entities subject to wave-one CSRD application — the joint assurance and audit combination is the right way to keep to the calendar
• French subsidiaries of foreign groups consolidated into a wave-one parent’s perimeter — the local entity must provide standardised feeds and contribute to the group statements
• Large unlisted firms preparing for wave two — the lead window on the information architecture and controls design is often longer than firms expect, and the extra months of preparation are critical
• Listed SMEs and growing businesses preparing for wave three application under the proportionate ESRS — scope and effort calibrated for size
• Private-equity-backed portfolio companies of in-scope sponsors — the portfolio entity must enable consolidated feeds at fund level even if it is itself below thresholds

For each profile, the work combines technical implementation on the information architecture with the assurance preparation that the audit firm needs. The role of the chartered accountancy practice is to help the entity satisfy ESRS specifications with reliable, auditable records and to bolster long-term disclosure capability.

ESRS Topics, Climate and Carbon Footprint

The first set of ESRS, adopted by Commission Delegated Regulation (EU) 2023/2772, covers two cross-cutting texts (ESRS 1 General Requirements and ESRS 2 General Disclosures) and ten topical chapters: five on the environment (E1 Climate change, E2 Pollution, E3 Water and marine resources, E4 Biodiversity and ecosystems, E5 Resource use and circular economy), four on people (S1 Own workforce, S2 Workers in the value chain, S3 Affected communities, S4 Consumers and end-users) and one on oversight (G1 Business conduct).

ESRS E1 on climate change is consistently the most demanding topic at first implementation. It requires disclosure of the transition plan, the carbon footprint covering scope 1, scope 2 and material scope 3 emissions, the strategy with quantified targets, and the financial impact of climate exposure on the entity’s operations and assets. The transition plan is one of the most scrutinised items by investors, rating agencies and supervisors. ESRS S1 on the own workforce covers headcount, equality, training, health and safety and the employee experience, providing structured measures that strengthen workforce transparency.

The methodology for the emissions inventory typically combines the GHG Protocol with the Bilan Carbone framework used in France. Where the company already publishes a voluntary CSR (responsibility) report, the prior CSR documentation is a useful starting point for the gap study, but it does not replace the structured disclosure that the company must now produce under the framework. Reducing scope 1 and scope 2 emissions, while improving accuracy on scope 3, is a multi-year shift that organisations should plan and resource accordingly.

Methodology: Our Approach

Our methodology is a structured, step-by-step process:

1. Scoping and materiality: confirmation of CSRD wave, group perimeter, double-materiality review, identification of in-scope ESRS topics
2. Gap study: assessment of current records, controls and disclosures against ESRS specifications, with a detailed gap memo and a remediation plan
3. Information architecture: design of the flow, including the joint finance and HR ledgers, the energy and emissions sources, the supply-chain inputs and the consolidation engine
4. Controls and documentation: design of internal controls, evidence retention rules, methodology notes and audit trail for each disclosed item
5. Drafting: drafting of the relevant section of the rapport de gestion under ESRS, in English and/or French, with the needed commentary and quarterly figures where applicable
6. Limited assurance: the CNCC-aligned limited assurance work on the published statements, with formal opinion delivered as required by the Code de commerce
7. Continuous improvement: post-issuance debrief, lessons-learned summary, and improvement plan ahead of the next cycle and the move to reasonable assurance in due course

The methodology is calibrated to the size and sector of the entity. The current environment includes firms still at the gap-study stage and firms already moving to reasonable assurance evaluation. The economic value of a properly structured framework is not limited to compliance with regulations; reliable information also strengthens the reputation of the firm with backers, the trust of clients, the buy-in of the workforce, the relationships with suppliers, and access to sustainable financing. Strong performance enhances visibility with the investor community and the rating agencies that assess the company.

Industries Served and Sector Specificities

Our work covers a range of industries with sector-specific implementation considerations:

• Industrial groups and manufacturing: footprint, water and pollution disclosures are typically the most material; the Bilan Carbone documentation is critical and helps measure progress year on year
• Asset management and banking: focus on financed emissions, taxonomy alignment, and the interaction with SFDR for investment products
• Retail, consumer goods and customer-facing businesses: focus on customers, value-chain workers, suppliers, product responsibility and circular economy; sales channel impact is a recurring theme
• Real estate and construction: a specific focus on building energy performance, biodiversity, and the transition plan for the property portfolio
• Technology and services: workforce, learning programs, equality, and the indirect emissions of the IT infrastructure
• PE-backed portfolio holdings and groups: information feeds to the sponsor’s portfolio-level publication, with a tailored platform for consolidated metrics

For each industry, the ESRS topic selection, the items in scope, the carbon methodology and the materiality threshold are calibrated to the sector profile and to the entity’s economic activities. An integrated approach across HR, finance and operations is critical. Industry-specific ESRS sector rules are under development and will refine the disclosure expectations.

Benefits of a Structured Framework

A well-designed framework delivers benefits beyond the compliance obligation alone:

• Quality of disclosed information: a joined-up architecture provides solid, auditable measures fit for limited assurance and useful insights for management
• Investor and rating-agency relationships: openness is increasingly a precondition for access to capital markets, green financing and a favourable rating score, with rating agencies factoring ESG criteria into their assessment
• Reputation and stakeholder trust: structured disclosure strengthens trust among employees, customers, backers and other stakeholders, and supports the responsibility commitment of the firm toward the planet
• Risk identification: the materiality work helps spot environmental and societal exposure early, supporting better strategic decision-making and responsible practices, and helping organisations to reduce avoidable losses
• Operational efficiency: building the sustainable shift into the existing cycle reduces duplication and lowers the operational burden across operations, helping management to better measure return on transition investment
• Long-term value: performance on these topics is increasingly linked to long-run economic success, durable strategies, the reduction of avoidable expenses, the protection of revenue and an improved cash position, supporting initiatives that invest in resilience
• Workforce buy-in: ESRS S1 chapters on the workforce, equality, training and satisfaction strengthen employee engagement and improve loyalty, helping the organization to increase retention
• Customer and market positioning: transparency supports the customer relationship, brand reputation, sales positioning and the marketing of products and services around responsible practices, enhancing competitive standing

The benefits range from regulatory compliance to a stronger long-run competitive position in the market. The commitment to responsible practice is no longer a marginal element but a core dimension of oversight and strategy. It is an increasingly crucial part of how stakeholders judge corporate performance, and a clear commitment to societal and environmental responsibility supports long-term success.

How to Choose a Partner

Selecting the firm that will support your mandate involves a small number of structured criteria:

• CNCC registration and assurance capability: limited assurance work is delivered under CNCC rules and can only be carried by a regulated firm
• OEC membership and accounting expertise: the integration with accounting workflows needs deep accounting and audit experience
• Sector experience: prior work in your industry, with the ESRS topics that matter for your activities
• Multilingual delivery: for international groups, the ability to deliver in English, French, Italian, Spanish and Russian
• Methodology depth: a documented, structured process covering scoping, gap analysis, information architecture, controls, disclosure and assurance
• Independence: where the firm provides both advisory and assurance, a review of the independence rules and the appropriate mandate structure
• Service continuity: the ability to support the entity across multiple cycles as the framework evolves
• Reasonable fees: a fee schedule calibrated to the scope, the perimeter and the assurance level, with no hidden cost or unjustified add-ons

These tests help identify a partner who will deliver reliable disclosure rather than a one-off project that does not bolster long-term capability.

Pitfalls and Challenges

Several recurring patterns explain why CSRD mandates miss their deadlines or deliver poor content. The list below also flags the key challenges first-cycle issuers face:

• Treating CSRD as a parallel project: separating it from the financial close cycle creates duplicate flows, extra cost and quality concerns — the most common implementation error in wave-one and wave-two clients
• Underestimating the double-materiality work: a superficial study leads to either over-disclosure (cost, complexity) or under-disclosure (compliance exposure)
• Weak controls on raw records: information must withstand limited assurance scrutiny; controls and audit trails are essential and frequently overlooked
• Late scoping: starting the gap study too late in the year compresses the architecture work and the assurance window
• Confusing voluntary CSR with regulated ESRS: prior CSR communication is a useful input but does not replace the structured disclosure, and the laws on disclosure now require a precise, audited presentation
• Methodology errors on emissions: scope 3, biogenic and avoided emissions are frequent sources of restatement
• Misaligned IT systems: the platform must integrate the energy system, the HR system, the procurement system and the finance ledger — a partial integration creates persistent reliability issues that can enhance reputational damage if left unresolved
• Inadequate workforce records: workforce measures (equality, training, health and safety, satisfaction) are often dispersed across multiple HR systems, requiring a joined-up model to enable reliable disclosure
• Insufficient regular oversight: published measures must be examined on a regular basis, not just at year-end, to ensure that anomalies are identified and corrected before the assurance work begins

A structured mandate with experienced practitioners helps the entity identify these factors early, design the appropriate controls and meet the calendar. Teams that meet weekly during the first cycle see fewer surprises. The dedicated team should bring practitioners with both accounting and sustainability backgrounds. Companies that invest in early preparation see lower restatement exposure and better insights from the first cycle, and stand to benefit from a measurable return on that effort.

Why Interexco

Interexco is a CNCC-registered audit and advisory firm with over 40 years of experience supporting French and international companies through regulatory transitions. From our Paris headquarters at 30 Boulevard Haussmann, with offices in Lille, Milan and Tunis, our team of nearly 50 professionals delivers ESG reporting france mandates in English, French, Italian, Spanish and Russian.

Our assurance practice is joined up with the financial audit team. For wave-one and wave-two issuers, that integration is the operational difference between a project run separately from the year-end close and a framework embedded in the standard cycle. We deliver under CNCC rules and coordinate with the group auditor and the AMF where applicable. Our long-standing presence in France and Italy enables a cross-border view that fits the typical perimeter of international groups serving a global investor base. Clients who download our briefing notes can access an introductory overview of CSRD obligations before scoping the work.

Bottom Line: When This Is the Right Choice

The practical conclusion: the disclosure is no longer optional for entities in scope of CSRD, and the structured ESRS write-up is now a core aspect of the rapport de gestion. Choosing an experienced, CNCC-registered firm that can integrate limited assurance with the financial audit and the wider accounting workflow is the most efficient way to satisfy the obligation and to strengthen long-term capability. The work should provide a structured platform for the information architecture, deliver dependable measures, and let the firm keep improving its performance over successive cycles. The commitment of the practice and its practitioners is what supports sustained quality and credible sustainable business conduct.

For French subsidiaries of international groups, the choice is structurally a group decision but with a French-law mandate layer. For listed issuers, the AMF supervises the publications and the rating community will scrutinise the comparability of the information.

Frequently Asked Questions

What is ESG reporting france under CSRD? The public disclosure of environmental, social and governance information by entities in scope of the Corporate Sustainability Reporting Directive (CSRD), under the European Sustainability Reporting Standards (ESRS), included in the rapport de gestion and subject to limited assurance by the statutory auditor or a designated independent assurance practitioner.

Who is subject to CSRD in France in 2025? Wave one in France covers large public-interest entities with more than 500 employees, a balance-sheet total exceeding €25 million, or turnover exceeding €50 million — applying to FY2024. Subsequent waves extend scope to large firms (wave two) and listed SMEs (wave three) on phased timetables. The 2025 Omnibus package and later EU measures continue to adjust scope.

What are the ESRS? The European Sustainability Reporting Standards are the EU-adopted rules under CSRD. The first set, adopted by Commission Delegated Regulation (EU) 2023/2772, covers cross-cutting items (general specifications, general disclosures) and ten topical chapters (environmental, social and governance). Sector-specific texts and proportionate SME texts are being developed.

Is the disclosure subject to audit in France? CSRD-scope information is subject to limited assurance in the first application waves — a level lower than the reasonable assurance applied to financial accounts. The expectation is to move to reasonable assurance later as the framework matures. The work is delivered by the commissaire aux comptes or, where French law permits, by a designated independent assurance practitioner.

Can a chartered accountancy firm handle CSRD implementation? Yes. An OEC- and CNCC-registered firm with the technical capability — like Interexco — can support CSRD work across scoping, information architecture, controls design, drafting and the limited assurance phase. Where the firm acts as both implementation adviser and assurance practitioner on the same target, independence rules apply and the mandate structure is calibrated accordingly.

How does CSRD interact with the financial close cycle in France? CSRD draws on the same general ledger, HR records, payroll and consolidation feeds that underpin the financial accounts. The most effective implementations integrate the information architecture with the existing finance close calendar, controls and IT systems. Treating CSRD as a parallel project — rather than an extension of the financial framework — is the most common implementation error and a significant source of additional cost.

Which French regulatory bodies supervise the disclosure? Several regulators are involved: the Compagnie Nationale des Commissaires aux Comptes (CNCC) for the assurance work, the Ordre des Experts-Comptables (OEC) for chartered accountancy practice, the Autorité des Marchés Financiers (AMF) for listed-issuer supervision, and the Autorité des Normes Comptables (ANC) for accounting standard interpretation. The CNIL frames the personal-information dimension of social data points.

What does a limited assurance engagement include? A limited assurance mandate includes a documented exposure read, materiality work, sample testing of selected data points, evaluation of internal controls, review of methodology and computation, and the issuance of a formal limited assurance opinion appended to the rapport de gestion. It is calibrated to the International Standard on Sustainability Assurance (ISSA) 5000 framework as adopted in France.

How long does it take to prepare for first-time CSRD application? For an entity entering scope for the first time, a structured readiness programme typically runs over 9 to 18 months ahead of the first year, depending on the complexity of the group, the maturity of the existing records and the integration with the financial close platform. Companies that compress this timeline often face restatement risk and elevated cost in the first cycle.