French CPA: the equivalent of the French chartered accountant in 2026
French CPA does not exist as an official title in France. Expert-comptable, commissaire aux comptes: missions, differences from US CPA and UK Chartered Accountant.
Expert note: This article was written by our chartered accountancy firm. Information is current as of 2026. For a personalised review of your situation, contact us.
French CPA: the equivalent of the French chartered accountant in 2026
Updated April 2026 — The search for a French CPA is common among foreign companies established in France, American or Anglo-Saxon directors, and professionals looking for a French accounting counterpart to their home credential. However, in France, the title of Certified Public Accountant (CPA) simply does not exist. The French accounting profession is built on two distinct and separately regulated pillars: the expert-comptable and the commissaire aux comptes. Understanding this architecture is essential to identify the right contact and assign them the right missions.
For further reading, see also French chartered accountant diploma, Chartered accountant: code of ethics and Accounting studies in France.
The US CPA: a credential with no direct French equivalent
What is the CPA in the United States?
The Certified Public Accountant (CPA) is a professional credential awarded in the United States by State Boards of Accountancy, following successful completion of the Uniform CPA Examination and fulfilment of professional experience requirements. The CPA can perform a broad range of services: bookkeeping and accounting reviews, audit (in states that permit it), tax advice, financial attestations, and tax representation before the IRS.
This credential is versatile and covers functions that French law distributes across several separately regulated professions.
What is the Chartered Accountant (CA) in the United Kingdom?
The Chartered Accountant (ICAEW, ICAS, CA ANZ) is the reference credential in the UK and many Commonwealth countries. Its scope of practice is comparable to the US CPA. In France, international firms frequently employ Chartered Accountants in advisory or audit roles, but they cannot qualify as a "commissaire aux comptes" without being registered with the CNCC.
The French expert-comptable: the functional equivalent of the CPA for management and advisory missions
A regulated profession since 1945
The profession of expert-comptable in France is governed by Ordinance no. 45-2138 of 19 September 1945 and its implementing decree of 30 March 2012 (Decree no. 2012-432). The practice of the profession is reserved for members registered on the roll of the Ordre des Experts-Comptables (OEC), a national professional body governed by the same ordinance.
The path to becoming an expert-comptable is demanding: a three-year Diplôme de Comptabilité et Gestion (DCG), followed by a two-year Diplôme Supérieur de Comptabilité et Gestion (DSCG), then a three-year professional placement in a firm, and finally passing the Diplôme d'Expertise Comptable (DEC), a State diploma awarded by the ministry responsible for finance.
The missions of the expert-comptable
The expert-comptable can perform all of the following missions:
Accounting missions:
- ▸Bookkeeping (data entry, preparation of annual accounts)
- ▸Review and compilation of accounts
- ▸Preparation of the tax return package (liasse fiscale)
- ▸Preparation of budgets and management dashboards
Tax missions:
- ▸Tax optimisation advice
- ▸Preparation and filing of tax returns (VAT, corporate tax, income tax, local business taxes)
- ▸Assistance and representation during tax audits
Social and payroll missions:
- ▸Preparation of payslips
- ▸Monthly nominal social declarations (DSN)
- ▸Employment law and HR advice
Legal missions:
- ▸Legal secretarial work (maintaining registers, drafting general meeting minutes)
- ▸Legal advice ancillary to accounting and tax missions
Attestations and reports:
- ▸Turnover attestations for tender processes
- ▸Profitability attestations in acquisition contexts
- ▸Account presentation reports
What the expert-comptable cannot do
The expert-comptable cannot certify accounts in the context of a statutory audit. This mission is reserved for the commissaire aux comptes. Nor can they replace a lawyer for drafting complex legal instruments (share transfers, mergers, material commercial contracts).
The commissaire aux comptes: the French statutory auditor
A distinct and complementary profession
The commissaire aux comptes (CAC) is the professional authorised to certify annual accounts in the context of a statutory audit engagement. They are registered with the Compagnie Nationale des Commissaires aux Comptes (CNCC) and subject to oversight by the Haut Conseil du commissariat aux comptes (H3C), an independent supervisory authority.
French law maintains a strict incompatibility between the roles of expert-comptable and commissaire aux comptes for the same entity: a firm may practise both professions for different entities, but not for the same company at the same time. This separation is designed to guarantee the independence of the statutory auditor.
Comparative table: CPA / CA vs Expert-Comptable / CAC
| Criterion | CPA (USA) | CA (UK) | Expert-Comptable (FR) | CAC (FR) |
|---|---|---|---|---|
| Regulated title | Yes (State Board) | Yes (ICAEW/ICAS) | Yes (OEC / Decree 2012) | Yes (CNCC / H3C) |
| Founding text | State laws | Royal charters | Ordinance 1945 | Commercial Code L820-1+ |
| Bookkeeping | Yes | Yes | Yes | No |
| Statutory audit | Yes (some states) | Yes | No | Yes |
| Tax advice | Yes | Yes | Yes | Limited |
| Account certification | Yes | Yes | No | Yes |
| Payroll and social | Partial | No | Yes | No |
How to work with a French expert-comptable: guide for foreign companies
For a foreign company (American, British, German) setting up in France, the relationship with the French expert-comptable is structurally important. Key points to anticipate:
Language of accounts: annual accounts must be drawn up in French and in euros. If your internal needs require reporting in English or another currency, the expert-comptable can prepare a parallel report, but the statutory accounts remain in French.
The liasse fiscale: unlike the United States where the tax return is often separate from the accounts, in France the expert-comptable simultaneously prepares the annual accounts and the liasse fiscale (Cerfa forms constituting the corporate tax return). These two documents form an inseparable whole.
Social declarations: French payroll is highly specific (monthly DSN, applicable collective bargaining agreement, employer social charges among the highest in Europe). The expert-comptable or their social department generally handles the entire payroll process.
Tax calendar: filing deadlines for the tax return package and accounts vary by legal form and financial year-end. The expert-comptable manages these deadlines on behalf of the client.
Hayot Expertise advice: when a foreign company arrives in France and requests a "French CPA", the first question to ask is: do you need bookkeeping and advice (role of the expert-comptable), certification of accounts (role of the CAC), or both? The answer determines the right contact. For American companies or American expatriates in France, our teams are accustomed to working in English and bridging US GAAP or US Tax frameworks with French requirements.
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Frequently asked questions
What is the equivalent of a US CPA in France?
In France, the functional equivalent of the US CPA is the expert-comptable for bookkeeping, tax and social advisory missions. For statutory audit and account certification missions, it is the commissaire aux comptes (CAC), a distinct profession regulated by the Commercial Code. Both professions are separately governed and incompatible for the same client entity.
Can a US CPA practise in France?
A US CPA cannot perform the regulated missions of an expert-comptable or commissaire aux comptes in France without being registered with the OEC or CNCC respectively. Recognition procedures exist under European Directive 2006/43/EC and bilateral agreements, but they involve aptitude examinations and experience requirements.
What is the difference between an expert-comptable and a commissaire aux comptes in France?
The expert-comptable manages accounting, taxation and advisory services for their client. They are not independent from their client — on the contrary, they are the client's service provider. The commissaire aux comptes (CAC) is an independent statutory auditor who certifies the accounts. Both professions are strictly incompatible for the same entity at the same time, to guarantee the auditor's independence.
How does a French expert-comptable work with a foreign parent company?
The French expert-comptable can prepare the mandatory French statutory accounts and a parallel report in English or under IFRS or US GAAP standards as required by the parent. They liaise with the French tax authority and social bodies. Coordination with the group's accounting or tax teams abroad is a standard part of their mission for French subsidiaries of international groups.
Article written by Samuel HAYOT
Chartered Accountant, registered with the Institute of Chartered Accountants.
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