Statutory Audit 

What a Statutory Audit in France Means

The statutory auditor issues an opinion on whether a company’s financial statements give a true and fair view (image fidèle) of its assets, financial position and results, in conformity with the Plan Comptable Général (PCG). The work certifies the sincerity, reliability and fairness of the financial statement — an essential guarantee on which shareholders, banks and external stakeholders rely. This is the core role of commissariat aux comptes, and it underpins the trust placed in every published statement and the requirement that a professional reviews the accounts before they are filed.

The opinion is delivered in the rapport général presented to shareholders at the annual meeting. The auditor also has the duty to issue reports on regulated agreements, capital transactions, profit allocation, equity matters, transfer of activity, asset contribution and merger deals involving the company. Where a change threatens the going concern of the entity, the auditor must trigger the procédure d’alerte — a formal European-influenced procedure addressed to management and judicial authorities. This is a multi-stage procedure that follows successive steps and a defined timetable; the addition of any new significant fact restarts the analysis, and the regulation requires each step of the procedure to be evidenced. The auditor’s statement is filed alongside the accounts, and this requirement is one a board must comply with at every cycle close.

When a Statutory Audit Is a Legal Requirement in France

It is a mandatory legal requirement when a company exceeds two of three values defined by the Code de commerce, as amended by Décret n° 2024-152 of 28 February 2024 transposing EU Directive 2023/2775:

• Balance sheet total: €5,000,000
• Net turnover: €10,000,000
• Average headcount: 50 employees

Where the company exceeds those values for two consecutive financial years, the legal requirement is to appoint an auditor for a six-year mandate at the first AGM after the company has exceeded the threshold. Smaller controlled subsidiaries within a group face lower thresholds: balance sheet €2,500,000, turnover €5,000,000, or 25 employees. A French controlled subsidiary that exceeds two of those must appoint a CAC, even where the standalone thresholds are not met. Once a company has met those conditions, the obligation cannot be deferred and the directors must comply.

Other triggers, applicable regardless of company dimension, set the same requirement: listed status on a regulated market, certain SAS structures controlled by corporate parents (Article L. 227-9-1), associations receiving more than €153,000 in public subsidies, regulated activities in the banking, insurance and payment sector, and group consolidation obligations. Each carries the same requirement to appoint a CAC, even where the company has not exceeded the headcount-based threshold and even where its profit-and-loss has not exceeded the turnover line. Associations and foundations subject to those conditions are treated under the same regulations as commercial companies of equivalent scale. The requirement applies whenever any one trigger is met.

What Our Statutory Audit Mandates Cover

Each appointment is tailored to the company, its industry and its group context. A tailored plan is set out in the mission letter, and the work typically combines the legal certification mission with the reports and group reporting tasks expected of an experienced CAC:

• Annual certification of the company financial statements under PCG and CNCC standards
• Audit of consolidated financial statements for French-headquartered groups, in French GAAP or IFRS
• CSRD limited assurance on sustainability reporting under CSRD regulations (Ordonnance n° 2023-1142 of 6 December 2023, a European directive transposed into local law)
• Specific reports: regulated agreements (conventions réglementées), capital deals, contribution and merger transactions, profit allocation
• Procédure d’alerte when going-concern indicators trigger the formal procedure
• Group reporting to the foreign parent auditor: referral instructions, perimeter alignment, group reporting forms
• Liaison with the Conseil d’administration, Comité d’audit, the Direction Générale and the shareholders through the full mandate cycle
• Examination of internal control over the figures where relevant

Statutory Audit in France vs. Audits Internationally

It differs from a US, UK or other international audit on several material points. Understanding the differences matters whenever an international business is setting up a French subsidiary or appointing a local CAC alongside its global auditor.

For a foreign parent, the practical consequence is that the French auditor cannot simply replicate the global instruction set. They hold personal legal duties and are accountable for the conclusion, the reports and the procédure d’alerte. The relationship with the group auditor is one of professional coordination, not subordination.

Why This Matters: The French Audit Regulatory Landscape

It is governed by a precise regulatory framework involving several local and European bodies:

• The Ordre des Experts-Comptables (OEC) — regulator of the chartered accountancy profession
• The Compagnie Nationale des Commissaires aux Comptes (CNCC) — professional body of registered statutory auditors
• The Haute Autorité de l’Audit (H2A) — public oversight authority, formerly H3C, supervising quality, inspections and sanctions
• The Autorité des Marchés Financiers (AMF) — securities regulator overseeing listed-issuer audits
• The Direction Générale des Finances Publiques (DGFiP) — tax administration whose positions on revenue, deductibility and transfer pricing interact with the financial statements
• The Greffe du Tribunal de Commerce — where the year-end filings and audit report are deposited
• The Autorité des Normes Comptables (ANC) — issuer of the Plan Comptable Général

The CAC is appointed for a six-year mandate, renewable. Independence rules under CNCC NEP prohibit the CAC from providing services that would compromise objectivity for the same client in the same audit cycle — including accounting outsourcing, valuation work used in the financial statements and most forms of advisory. The standard French corporate tax rate is 25% (DGFiP, 2025), which forms the baseline for current and deferred tax positions reviewed at year-end. The CSRD directive (Ordonnance n° 2023-1142 of 6 December 2023, transposed into French law) extends the certification perimeter to sustainability reporting for in-scope companies — a European requirement that has materially expanded the audit perimeter and the related law applicable here.

How We Run an Audit Mandate

Our approach follows CNCC NEP standards and is organised around five main phases. The main phases are sequenced and documented; each mandate is tailored to the company’s scale, jurisdiction, industry and group context:

1. Acceptance and appointment: independence checks, conflict analysis, audit strategy and engagement terms confirmed with the shareholders
2. Risk planning: examination of internal control, identification of significant accounts and sustainability KPIs, money-laundering and fraud-risk indicators (anti-money-laundering procedures under CNCC standards)
3. Interim fieldwork: testing of controls, transaction-level work, transfer-pricing analysis, walk-throughs of order-to-cash, purchase-to-pay and payroll processes
4. Year-end: substantive work on balance sheet and P&L items, the consolidated audit where applicable, CSRD limited work
5. Reporting: issue of the rapport général and the legal reports on regulated agreements, capital matters and other items required by law

Throughout the cycle, the partner and engagement manager maintain direct contact with the company’s CFO, the audit committee and the group auditor. Records are kept in multilingual files to support filing with the Greffe du Tribunal de Commerce and group reporting to the foreign parent. The procedure followed at each step is documented and traceable; nothing in the procedure is left to memory, and records are retained pursuant to CNCC retention rules to ensure full traceability.

Risk, Independence and Quality Control

A statutory audit is fundamentally about risk: detecting material misstatement, fraud, money-laundering exposure and going-concern issues, and ensuring that the financial statement presents a true and fair view. CNCC standards require the CAC to maintain a documented risk assessment at each phase, to refresh the strategy where significant operations or transformation projects occur, and to apply work involving related-party deals and complex group structures involving cross-border flows. Each transformation of the perimeter is shared with the engagement quality reviewer (EQR).

Independence rules are equally precise. The auditor may not assist in accounting, payroll, valuation or most advisory tasks for the same client in the same cycle. Our firm is structured so that the audit team, the accounting team and the transaction-services team operate under separate management, with documented Chinese walls. This allows a single qualified client organization to engage Interexco for distinct service offerings without compromising the conclusion on a given mandate.

Quality control is supervised internally by the EQR and externally by H2A inspections. Each appointment is checked at acceptance and on each renewal, and every partner is a qualified, registered professional whose work is subject to peer review. Compliance with NEP standards is monitored continuously, and any compliance gap identified during the cycle is documented and remediated. Each partner must comply with continuing-education requirements set by the CNCC, which play an essential role in maintaining technical standards.

How to Choose a Statutory Auditor in France

When a company first reaches the threshold, the practical question is how to choose a CAC whose expertise and capacity match the mandate. Useful criteria to assess include:

• Registration: confirm the firm and the partner are CNCC-registered and that the partner holds the qualifications of a qualified statutory auditor
• Independence: check whether the firm holds any other paid relationship with the company (accounting, payroll, advisory) that would breach the rules
• Industry and group experience: ask for evidence of relevant mandates involving similar scale, group structure and reporting framework
• International capability: where the parent or shareholders are foreign, confirm the firm can operate in the relevant languages and align with group reporting
• Sustainability readiness: from FY 2024 / FY 2025 onwards, sustainability limited work is part of the certification perimeter for in-perimeter companies
• Fees and mandate terms: documented in a written letter pursuant to CNCC requirements, with a clear schedule of hours and partner involvement

A tender typically involves three or four candidate firms, an information memorandum on the company and its group, a meeting with the proposed partner, and a written recommendation to the shareholders. The appointment is then formalised at the AGM for the six-year mandate. Most CFOs decide on the basis of a simple combination of independence, technical expertise and partner accessibility.

What Statutory Audit Changes for the Business

A statutory audit is sometimes perceived as an external constraint. In practice, a well-run mandate provides shareholders, banks and public bodies with a trusted, independent view on the company’s financial position. Findings and recommendations from the CAC frequently enhance internal control, surface process weaknesses and provide a documentation trail that supports any subsequent deal, refinancing or capital raise. For PE-backed targets in particular, a clean history is a precondition for an effective exit, and it materially supports the trust of investors. It also delivers an essential guarantee of integrity around the figures, and a guarantee against undetected misstatement.

For a foreign parent setting up its French operating business, the work also performs a transparency function: the local CAC issues an opinion on the French financial statements which group management can rely on. The country-specific accountability provided — including the strict legal obligation to alert on going-concern issues — gives the parent a degree of regulatory comfort that is difficult to obtain from a group-only sign-off. It also plays an important role in dialogue with the banks, with the tax administration and with key suppliers.

Bottom Line: When Statutory Audit France Is the Right Choice

The practical conclusion: it is not optional once a company has crossed the legal threshold. The appointment of a CAC is a legal requirement, and the choice of firm materially affects the quality, cost and stakeholder credibility of the reporting cycle. For international groups, the right partner is one whose expertise, languages and group-reporting practice meet the parent’s needs while preserving full independence under CNCC standards.

Interexco offers a CNCC-registered commissariat aux comptes practice with over 40 years of experience, a partner team that operates routinely in five languages, and the scale to handle complex group structures involving multiple French entities, transfer pricing and sustainability limited assurance. We work on local perimeter alongside Big Four group auditors, and as group auditor for headquartered groups whose consolidated financial statements require certification.

Frequently Asked Questions

What are the current thresholds for a statutory audit in France? Under Décret n° 2024-152 of 28 February 2024, statutory audit in France is mandatory when a company exceeds two of three values: €5 million balance sheet, €10 million turnover, or 50 employees. Lower thresholds apply to controlled subsidiaries within a group: €2.5 million balance sheet, €5 million turnover, or 25 employees. These apply to financial years opened from 1 January 2024.

What is the difference between a commissaire aux comptes and an expert-comptable? An expert-comptable is a chartered accountant regulated by the Ordre des Experts-Comptables and authorised to perform accounting work for third parties. A commissaire aux comptes is registered with the CNCC, authorised to issue an independent conclusion certifying the financial statements. Many professionals hold both qualifications, but the two functions cannot be performed by the same firm on the same entity in the same cycle.

How long is the mandate of a French statutory auditor? A statutory auditor is appointed by the shareholders for a six-year mandate, renewable. For certain SAS subsidiaries under simplified regimes, a three-year term may apply. The mandate cannot be terminated unilaterally except in specific circumstances defined by law.

Can a French statutory auditor also provide accounting or due diligence services? No. Independence regulation under CNCC standards prohibits the auditor from providing work that would compromise objectivity for the same entity in the same cycle — including accounting outsourcing, payroll, certain valuations and most advisory. Interexco organises its accounting, due diligence and audit teams in separate functional structures, allowing the firm to act for the same client group across distinct service offerings without conflict on a given mandate.

Are foreign-owned subsidiaries in France subject to French statutory audit rules? Yes. A subsidiary of a foreign parent is subject to the same legal thresholds and triggers as any local entity. Group consolidation by a foreign parent under IFRS or US GAAP does not exempt the subsidiary from preparing French statutory financial statements under the PCG and, where the thresholds are met, having those statements audited by a registered statutory auditor.

Does Interexco act as group auditor or only on local perimeter? Interexco acts most often on local perimeter within a wider international group audit, coordinating with the group auditor — including Big Four group auditors — on referral instructions, materiality, group reporting deliverables and the group file. For Paris-headquartered groups, our CNCC-registered practice acts as the group auditor on the consolidated financial statements.

Does the auditor also certify CSRD sustainability reporting? Yes. Pursuant to Ordonnance n° 2023-1142 of 6 December 2023 transposing the European CSRD directive, the statutory auditor must issue a limited assurance conclusion on the sustainability reporting of in-scope companies. Interexco delivers this work as part of the audit mandate for in-scope clients.

Is a statutory audit required for associations and foundations in France? An association must appoint a statutory auditor when it receives more than €153,000 in public subsidies in a given year, or when its activity meets specific size criteria. Foundations are also subject to the requirement depending on their legal form, endowment and public-interest status. The thresholds above apply once the entity has exceeded any two for two consecutive years, even where it would not normally exceed the smallest threshold band.

What happens if a company fails to appoint a statutory auditor when required? Failure to appoint a CAC when the legal threshold is exceeded constitutes a breach of the law. The company’s directors can be held liable, and any shareholder or interested party (including the Procureur de la République) can apply to the Tribunal de Commerce for the judicial appointment of an auditor. Filings submitted to the Greffe without the required audit report may be rejected.

Speak With Our Audit Team

If you are reviewing whether your local entity has reached the threshold, preparing a tender for a new mandate, or coordinating a group audit across multiple jurisdictions, contact one of our partners about your timetable, group structure and law framework. Our team operates in English, French, Italian, Spanish,Arabic and Russian, and acts routinely alongside Big Four group auditors on local perimeter.