Bookkeeper, chartered accountant or staff: who does what

Quick answer. An in-house bookkeeper keeps the accounts of their own employer. The qualified chartered accountant (expert-comptable), registered with the Ordre, is the only one able to review and attest the accounts of third parties, in their own name and under their own liability (ordonnance no. 45-2138 of 19 September 1945, article 2). Staff and managers prepare the work but do not sign.

When you entrust your accounts to a firm, several people work on your file: a staff accountant enters the data, a manager reviews it, the chartered accountant signs. This split is not a matter of internal hierarchy, it stems from a regulated profession. Understanding who does what spares you two common confusions: believing an in-house bookkeeper can do everything, and believing an attestation equals a certification.

At Hayot Expertise, a firm led by a chartered accountant registered with the Ordre des experts-comptables of Ile-de-France and a statutory auditor registered with the CNCC, we regularly meet directors surprised to learn that the "accountant" they thought they had did not hold the title to attest their accounts to their bank.

The first distinction is legal, not hierarchical. The word "accountant" covers very different realities depending on the contractual link and the title held.

• The in-house bookkeeper works within a company, under an employment contract. They keep the accounts of their employer. They are not registered with the Ordre, hold no protected title and attest nothing for third parties.
• The firm staff accountant is an employee of an accounting firm. They prepare the files of several clients under the supervision of a registered chartered accountant. "Staff" and "manager" are internal firm titles, not legal ones.
• The qualified chartered accountant holds the diploma (DEC) and is registered with the Ordre. Only they may practise in their own name, review and attest the accounts of entities to which they are not bound by an employment contract.

That last point is central. Article 2 of ordonnance no. 45-2138 defines the chartered accountant as one who habitually reviews and assesses the accounts of businesses to which they are not bound by an employment contract, and who is authorised to attest the regularity and fairness of balance sheets and income statements. The employment-contract test draws the line between the in-house accountant and the independent chartered accountant.

Chartered accountancy has been a regulated profession since 1945. This carries two concrete consequences for you.

First, a monopoly. Anyone who, without being registered with the Ordre in their own name and under their own liability, habitually keeps, verifies, assesses or corrects the accounts of third parties, or directs such work, practises the profession illegally. The basis is ordonnance no. 45-2138, whose article 20 penalises illegal practice. An unregistered person keeping the accounts of several outside clients is therefore exposed to prosecution.

Second, a protected title. Only the registered diploma holder may present themselves as "expert-comptable". The title is not a marketing label: it guarantees a training path, registration with the Ordre, mandatory professional civil-liability insurance and compliance with the Code of ethics (decret no. 2012-432 of 30 March 2012, articles 141 to 169). That decree requires independence, professional secrecy and a written engagement letter.

Our accounting engagement at the firm operates within this framework, and every file is carried by an identified signatory.

Here is the typical path of an annual file in a firm, from daily flow to signature.

1. Collection and entry. The staff accountant gathers your documents, checks the consistency of flows and posts the entries, often through an accounting tool such as Pennylane or equivalent that automates part of the reconciliation.
2. Review. The manager checks the accounts, justifies balances, prepares restatements and the tax return. They raise the substantive questions with the client.
3. Supervision and signature. The registered chartered accountant reviews, validates accounting and tax options, then signs the attestation and bears liability.

The supervision ratio is itself regulated: decret 2012-432 raised from 1 in 10 to 1 in 15 the number of staff assigned to accounting work that a chartered accountant may supervise. In other words, the staff accountant always works under a registered professional's control, never alone at signature.

Our reading. What you buy is not the data entry, largely automated today, but the signatory's professional judgement: option choices, tax security, risk alerts. It is this scrutiny, and the liability attached to it, that distinguishes a firm from mere software.

Wording matters. The chartered accountant attests, the statutory auditor certifies. They are not synonyms.

In a presentation engagement (standard NP 2300, approved by order of 1 September 2016), the chartered accountant expresses limited assurance: they attest that nothing has come to their attention that calls into question the consistency and plausibility of the annual accounts prepared under management's responsibility. It is neither an audit nor a guarantee against fraud. To go further, compare the difference between bookkeeping and the presentation engagement and the scope of a chartered accountant's attestation.

Certification, by contrast, is a statutory audit engagement with reasonable assurance, entrusted to the statutory auditor. Appointment becomes mandatory when the company exceeds two of the three following thresholds, for financial years opened on or after 1 January 2024 (decret no. 2024-152 of 28 February 2024): total balance sheet above 5,000,000 euros, net turnover above 10,000,000 euros, more than 50 employees on average. The detail is in our article on the statutory auditor's mission.

The underestimated risk. A presentation attestation reassures a bank on the formal reliability of your accounts, but it does not cover a scheme that would conceal transactions. Confusing the two assurance levels means handing a third party a document that does not say what you think it says.

It is the registered chartered accountant who signs the attestation who bears professional civil and ethical liability. The staff accountant and manager, as employees, work under supervision and do not sign. This liability chain is the counterpart of the monopoly: in exchange for the title, the registered professional answers for the quality of the accounts they attest.

What the tax authority looks at. In a tax audit, the issue is not who posted a given entry, but whether the accounts and returns are compliant. Poorly kept accounts expose you to surcharges: 10 to 40 percent for missing or late returns (CGI article 1728), 40 percent for deliberate breach (CGI article 1729), on top of late-payment interest of 0.20 percent per month (CGI article 1727). An accountable signatory secures precisely this perimeter. On the tax side, our tax support for directors extends the accounting engagement.

Recently, a director of an SME approached us after entrusting their bookkeeping to a provider not registered with the Ordre, discovered when applying for financing: the bank required a presentation attestation that this provider could not legally deliver. We took over the year, made the accounts reliable and issued the attestation, which unblocked the file.

Before signing an engagement letter, check these points.

• Is the signatory registered with the Ordre of chartered accountants? Registration is verifiable.
• Does the written engagement letter state the scope, the signatory and the fee terms?
• Does the firm perform a presentation engagement if your bank or partners require an attestation?
• Do you know who supervises your file day to day, beyond the staff accountant who enters data?
• For a particular family status, can the firm distinguish the roles? See our article on the status of collaborating spouse, employee or partner.

From 1 September 2026, all businesses subject to VAT will have to be able to receive electronic invoices in a structured format, regardless of size. Issuing them will be mandatory from that date for large companies and mid-caps, and from 1 September 2027 for SMEs and micro-businesses. This setup is typically part of a firm's support: an in-house bookkeeper or an unregistered provider will not carry the same liability over the compliance of your invoicing chain.