Mission of the auditor: what does it cover?
Certification of accounts, specific verifications, alerts, independence and limits: understanding the mission of the CAC in 2026.
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.
Quick answer: what does the statutory auditor's mission cover in France?#
The mission of the commissaire aux comptes, France's statutory auditor, covers four areas: certifying the annual and consolidated accounts (article L. 821-53 of the Commercial Code), carrying out the specific verifications required by law, triggering the alert procedure when going concern is compromised, and reporting criminal offences to the public prosecutor. The mandate runs six financial years.
The mission of the auditor is not limited to "verifying accounts". It is part of a precise legal and normative framework, with an opinion on the accounts, specific due diligence and strong independence requirements.
What is the mission of the auditor?#
The mission of the auditor (CAC) is a mandatory legal audit for certain companies. The CAC examines the annual accounts and, where applicable, the consolidated accounts, in order to certify that they are regular, fair and give a true and fair image of the assets, financial situation and results of the entity.
Who the report is for: the auditor's opinion is set out in a report addressed to the partners and shareholders, its legal recipients.
This scope is defined by the French Commercial Code and by the professional practice standards (NEP). Since 1 January 2024, those standards have been adopted by the H2A, the French audit regulator, approved by order of the Minister of Justice and codified in the Commercial Code: they are no longer issued by the national body of auditors (CNCC). The appointment thresholds were raised a first time by the PACTE law of 22 May 2019, then a second time by decree no. 2024-152 of 28 February 2024, for financial years beginning on or after 1 January 2024. The nature of the mission itself remains unchanged.
The heart of the mission: certification of accounts#
Certification constitutes the raison d'être of the auditor. It is based on NEP 700, which governs the formulation of the opinion in the audit report.
The key phases of the audit#
The CAC carries out its mission according to a methodology structured in several stages:
- Getting to know the entity: analysis of the sector of activity, the economic model, the organization and the internal control environment
- Risk assessment: identification of sensitive areas likely to contain significant anomalies, whether due to fraud or errors
- Definition of the audit approach: selection of appropriate procedures (consistency tests, surveys, external confirmations, physical observations)
- Collection of evidence: gathering of sufficient and appropriate evidence to support the opinion
- Review of audit assertions: verification of existence, valuation, completeness, rights and obligations, and appropriate presentation of each accounting item
- Formalization of the opinion: drafting of the report, with a conclusion that may be an unqualified certification, a certification with reservations, a refusal to certify or an impossibility to certify
The four types of opinion#
At the end of its mission, the CAC formulates one of the following four opinions:
- Unqualified certification: the accounts are regular and fair, free from material misstatement
- Certification with reservations: misstatements exist but are not serious enough to invalidate the accounts as a whole
- Refusal to certify: the anomalies are so significant that the accounts do not give a true picture
- Impossibility to certify: the auditor was unable to carry out the necessary audit procedures, or the uncertainties are too numerous for an opinion to be expressed (NEP 700, paragraph 14)
A word of caution on wording: the standard says "impossibility to certify". The word "abstention", common in everyday language, appears nowhere in NEP 700. Unqualified certification remains the normal outcome and reservations the exception: in practice, they most often concern the valuation of intangible assets, risk provisions or going concern.
The exact wording of each opinion and its NEP 700 reference#
| Opinion (wording used by the standard) | Criterion set by NEP 700 | Reference |
|---|---|---|
| Unqualified certification | The audit provides reasonable assurance that the accounts, taken as a whole, are free from material misstatement | paragraph 8 |
| Certification with reservations | Two cases: disagreement (uncorrected material misstatements whose effects are clearly circumscribed) or limitation (audit procedures that could not be performed, with circumscribed effects) | paragraphs 9 and 11 |
| Refusal to certify | The effects of the misstatements cannot be clearly circumscribed, or a reservation would not be enough to inform the reader | paragraph 12 |
| Impossibility to certify | The necessary procedures could not be performed, or multiple uncertainties prevent an opinion from being expressed | paragraph 14 |
Two points that avoid misunderstandings: the assurance provided is high but not absolute, conventionally called reasonable assurance (NEP 700, paragraph 8); and the report on the consolidated accounts, where one exists, is separate from the report on the annual accounts (NEP 700, paragraph 4). The version of NEP 700 in force was approved by order of 28 December 2023 and codified in article A. 821-92 of the Commercial Code.
What are the specific CAC checks?#
Beyond the certification itself, the auditor carries out verifications required by law. These procedures are not part of the opinion on the accounts: they are presented in a separate part of the report, only regulated agreements being covered by a special report.
Verifications on regulated agreements#
The CAC examines the agreements concluded between the company and its managers, partners holding more than 10% of the voting rights, or other related parties. In public limited companies, these agreements must first be authorised by the board of directors (article L. 225-38 of the Commercial Code) or, where the company has a management board and a supervisory board, by the supervisory board (article L. 225-86 of the same code), and then approved by the general meeting. The regime varies with the corporate form: the auditor issues a special report on the agreements disclosed to it.
Verifications on governance and remuneration#
The auditor controls:
- the sincerity of the information given on the remuneration of executive corporate officers
- compliance of the management report with the annual accounts
- the consistency of information relating to the environmental and social situation (for the companies concerned)
- the regularity of capital operations (increases, reductions, share buybacks)
Observations on the corporate governance report#
A persistent misconception: the auditor no longer issues a report on internal control. The chairman's report on internal control, and the auditor's report that came with it, were abolished by ordinance no. 2017-1162 of 12 July 2017, for financial years beginning on or after 1 January 2017. The auditor now presents observations on the corporate governance report drawn up by the board of directors or the supervisory board (article L. 225-235 of the Commercial Code). Internal control itself is neither audited nor certified: it is assessed only to calibrate the audit approach.
The auditor's legal duties beyond certification#
Two duties often go unnoticed, and they are not of the same nature: the first is a specific verification, the second an autonomous legal obligation, independent of the opinion on the accounts.
| Duty | What the auditor does | Legal basis |
|---|---|---|
| Equal treatment of shareholders (specific verification) | The auditor makes sure that equal treatment has been respected between shareholders, partners or members of the competent body | art. L. 821-56 Commercial Code |
| Reporting criminal offences (autonomous duty) | The auditor reports to the public prosecutor the criminal offences of which it became aware, without incurring liability for that report | art. L. 821-10 Commercial Code |
Beware of the outdated references still widely quoted online: ordinance no. 2023-1142 of 6 December 2023 renumbered the whole body of French statutory audit law on 1 January 2024. Article L. 821-53 became L. 821-53, L. 823-10 became L. 821-54 and L. 823-12 became L. 821-10.
How does the CAC alert procedure work?#
Where facts are likely to jeopardise the going concern of the company, the auditor triggers the alert procedure set out in articles L. 234-1 to L. 234-4 of the Commercial Code. The sequence is always the same: a written request for explanations sent to the manager, a reply expected within fifteen days, referral to the collegiate body with a copy to the president of the commercial court, and then, if the situation persists, a special report presented to the general meeting.
It is not a sanction but a preventive mechanism: in practice, most situations are settled at the first request for explanations.
What is the duration and independence of the mandate?#
The auditor is appointed by the general meeting of shareholders for a term of six financial years: the appointment ends after the meeting that approves the accounts of the sixth financial year (article L. 821-44 of the Commercial Code). The term may be limited to three financial years where the appointment is voluntary, or where it is made at group level. It is the method of appointment that triggers the shorter term, never the size of the company. The mandate is renewable.
The rules of independence#
Independence is the cornerstone of the mission. The CAC must respect strict rules:
- prohibition on holding financial interests in the audited company
- prohibition to exercise incompatible management or advisory functions
- rotation of the signing partner in public interest entities: no more than six consecutive financial years, within a limit of seven years, followed by a three-year cooling-off period before taking part in the engagement again (article L. 821-34 of the Commercial Code). Outside public interest entities, there is no general rotation requirement
- an annual written confirmation of independence addressed to the audit committee of the audited entity (article 6 of Regulation (EU) no. 537/2014), and not to the CNCC or to the H2A. The H2A is the French High Authority for Audit, the independent public authority that replaced the H3C on 1 January 2024: it has nothing to do with the High Authority for Transparency in Public Life
These rules ensure that the CAC's opinion is objective and free from any conflict of interest. They are regularly reinforced by the European legislator, notably since Regulation (EU) no. 537/2014 of 16 April 2014 on the statutory audit of public interest entities.
To find out more about the legal framework, consult obligation of auditor and the PACTE law and auditors.
Does mandatory rotation apply to every company?+
No, and it is not limited to the individual signing partner. At firm level, and for public interest entities only, article 17 of Regulation (EU) no. 537/2014 caps the total duration of the engagement at ten years, extended to twenty years where a public tender has been organised and to twenty-four years in a joint audit issuing a joint report, with a four-year cooling-off period before any new appointment. Outside public interest entities, no firm rotation is imposed.
What the CAC mission does not cover#
It is essential to understand the limits of the mission to avoid any misunderstanding between management and the auditor. The law says so itself: certifying the accounts "does not consist in guaranteeing the viability or the quality of the management" of the audited entity (article L. 821-55 of the Commercial Code).
The mission of the CAC does not replace:
- the responsibility of managers in drawing up the accounts: it is the management which prepares the accounts, not the CAC
- operational internal control on a daily basis: the CAC observes and assesses the systems, but does not put them in place
- company strategy: the CAC does not participate in strategic decisions, it notes the accounting consequences
- permanent financial management: the audit is a periodic mission, not ongoing management support
- detection of all fraud: the CAC implements procedures to identify significant anomalies, but an audit does not guarantee the discovery of all irregularities, especially if they are concealed in a sophisticated manner
Hayot Expertise Advice: the mission of the CAC must be understood as a framework of trust. To derive value, you must carefully prepare the accounts, the closing, the documentation and the dialogue with the teams. A well-prepared audit runs more smoothly and leads to fewer reservations.
How to prepare effectively for your CAC mission#
Experience shows that companies that anticipate the mission of their auditor benefit from a smoother audit and a more constructive relationship. Here are the best practices that we recommend to our clients:
- Prepare a complete closing file: balances, journals, justifications for regularization accounts, reconciliation tables
- Document accounting estimates: impairment tests, provisions for risks, evaluation of intangible assets
- Anticipate CAC questions: identify sensitive points upstream (turnover ahead of schedule, accrued liabilities, off-balance sheet commitments)
- Organize a shared calendar: plan exchanges with the CAC from the month preceding the closing to avoid last minute emergencies
- Maintain a register of conventions: list all conventions likely to be regulated to facilitate specific verifications
Do you want to better prepare your company for CAC work?#
We can help you make the closing process, documentation and sensitive points of the audit more reliable.
Discover our accounting and finance support
Conclusion#
In 2026, the mission of the auditor remains a key financial confidence system. It covers the certification of accounts, specific verifications, a preventive alert procedure and governance controls. Its scope is broad but precise, and it benefits from being anticipated on the management and finance side.
Frequently asked questions
What is the difference between a statutory auditor and a chartered accountant in France?
The commissaire aux comptes is an independent auditor appointed to certify the accounts. He does not prepare them. The expert-comptable draws up the accounts, advises management and handles bookkeeping. The two engagements are complementary but strictly separate, so that the independence of the audit is preserved.
When must a company appoint a statutory auditor?
Since the PACTE law of 22 May 2019, as updated by decree no. 2024-152 of 28 February 2024, a SAS or a SARL must appoint an auditor as soon as it exceeds two of the three following thresholds at the closing date: 5,000,000 euros of total assets, 10,000,000 euros of turnover excluding tax, 50 employees. The obligation then applies from the following financial year. Lower thresholds (2,500,000 euros of total assets, 5,000,000 euros of turnover, 25 employees) apply to a company controlled within a small group. Some companies, such as SA and SCA, are subject to the obligation whatever their turnover.
How long does a statutory audit engagement last?
The auditor's mandate runs for six financial years: the appointment ends after the meeting that approves the accounts of the sixth financial year (article L. 821-44 of the Commercial Code). It may be limited to three financial years where the appointment is voluntary or made at group level, which depends on the method of appointment, not on the size of the company. The annual audit work itself, in our experience, spreads over two to four months, from the preparation of the closing to the delivery of the report.
What happens if the auditor refuses to certify the accounts?
A refusal to certify is a strong signal. It means the accounts contain material and pervasive misstatements. The shareholders are alerted and must take corrective measures. In the most serious cases, the auditor can trigger the alert procedure and, where the going concern of the company is at stake, inform the president of the commercial court.
Can the statutory auditor be held liable for an error in the accounts?
Yes. The auditor incurs civil and criminal liability if he fails to meet his obligations. If he omits to report irregularities or offences of which he became aware, or certifies accounts containing inaccuracies he should have detected, he may be sued by the company, the shareholders or third parties. This is why the professional standards (NEP) require a rigorous and documented approach.
Must the statutory auditor detect every fraud?
No, and this is a key limit of the engagement. The auditor performs procedures designed to identify material misstatements, whether they arise from fraud or from error, but an audit only provides high and not absolute assurance, conventionally called reasonable assurance (NEP 700, paragraph 8). A sophisticated, concealed fraud may therefore escape the audit work. The auditor is, however, required to report to the public prosecutor the criminal offences of which he became aware (article L. 821-10 of the Commercial Code).
Article written by Samuel HAYOT
Chartered Accountant, registered with the Institute of Chartered Accountants. Certified Pennylane trainer.
Regulated French accounting and audit firm based in Paris 8, built to support companies across France with a digital and decision-oriented approach.
Sources
Official and operational sources cited for this page.
This topic is part of our service Fractional CFO Paris for startups and SMEs
Need a quote or personalised advice?
Our accountancy firm supports you through all your steps. Get a free quote to review your situation and receive a bespoke fee proposal, or contact us directly.