Statutory auditor (CAC) for the French Works Council (CSE): when is it required (EUR 3.1M threshold), how to appoint one, articulation with the chartered accountant

Updated 21 May 2026 — Appointing a statutory auditor (Commissaire aux Comptes — CAC) for the CSE (Comité Social et Économique — French Works Council) is mandatory as soon as the committee exceeds certain financial or structural thresholds — typically EUR 3.1M of annual resources, or 2 out of 3 thresholds defined by articles D2315-1 et seq. of the French Labour Code and the ANC 2015-01 regulation. Too often overlooked by growing CSEs (notably those expanding their ASC programmes or integrating an additional site), this obligation engages the treasurer's personal liability in case of non-compliance. This guide details the 2026 thresholds, the appointment procedure, the articulation with the CSE's chartered accountant, ethical incompatibilities and typical fees.

<div class="featured-snippet"> A <strong>statutory auditor (CAC)</strong> must be appointed by the CSE as soon as it exceeds at year-end <strong>2 of the 3 following thresholds</strong> ([articles D2315-1 et seq.](https://www.legifrance.gouv.fr/codes/section_lc/LEGITEXT000006072050/LEGISCTA000035642790/)): <strong>50 employees employed by the CSE</strong>, <strong>EUR 3.1M total balance sheet</strong>, or <strong>EUR 1.55M annual resources</strong>. Above <strong>EUR 3.1M of annual resources alone</strong>, the CSE moves to full accounting regime and the CAC is mandatory. Appointment is by <strong>majority vote of the titular CSE members</strong> for a term of <strong>6 financial years</strong>. The CSE's CAC must be <strong>distinct</strong> from the company's CAC (ethical incompatibility). </div>

The obligation to appoint a statutory auditor for the CSE depends on the accounting regime applicable to the CSE, defined by articles D2315-1 et seq. of the French Labour Code and the ANC 2015-01 regulation:

Detail of "2 of 3 thresholds"#

The CSE moves to full regime (and therefore mandatory CAC) as soon as it exceeds at the close of two consecutive financial years at least 2 of the 3 following criteria:

1. 50 employees employed by the CSE (ASC coordinators, secretaries, ticketing managers, etc.).
2. EUR 3.1 million total balance sheet.
3. EUR 1.55 million annual resources (sum of employer subsidies AEP + ASC + other revenues).

Important: the notion of "annual resources" integrates both budgets AEP and ASC. A CSE with EUR 200,000 of AEP + EUR 1,500,000 of ASC = EUR 1.7M of resources, threshold therefore crossed on this criterion.

Case of EUR 3.1M threshold "alone"#

If a CSE receives more than EUR 3.1M of annual resources (adding AEP + ASC), it moves directly to full regime and mandatory CAC, regardless of the other thresholds. This is the case for large central CSEs of groups (Auchan, Carrefour, Renault, La Poste, etc.).

Article L2315-73 of the French Labour Code frames the appointment of the CSE's CAC. Here is the step-by-step procedure:

Step 1 — Threshold crossing identification#

At each annual closing, the CSE's chartered accountant must check the thresholds and signal to the treasurer any crossing. Our firm systematically anticipates this point in the A-Z fixed fee: we signal the crossing from the 1st financial year and at the latest at the close of the 2nd consecutive financial year above the thresholds — to prepare the appointment before the approval AGM.

Step 2 — CAC firm selection#

The CSE is sovereign in its choice of CAC. The firm must be:

• Registered with a CRCC (Regional Chamber of Statutory Auditors) — verifiable on the CNCC website.
• Independent from the company: strong independence rule under the French statutory auditor Code of Ethics (H3C / CNCC) — the CSE's CAC should not be the same firm as the company employer's CAC (see incompatibility section below).
• Competent in CSE accounting: not all CAC firms are familiar with the specifics of ANC 2015-01 regulation and the AEP/ASC double accounting.

Step 3 — Appointment vote at plenary meeting#

• Inscription of the subject on the agenda of the plenary meeting by the secretary.
• Deliberation and vote by a majority of titulars present.
• For each CSE: 1 titular CAC + 1 alternate CAC (the alternate intervenes in case of the titular's impediment). Designation of the alternate is no longer mandatory in all configurations since the PACTE law (2019), but remains recommended.

Step 4 — Term length#

The CSE's CAC term is 6 financial years (article L823-3 of the French Commercial Code applicable by analogy). At the end, the mandate may be renewed or a new CAC may be designated — always by CSE vote.

Step 5 — Notification to the employer#

The CSE notifies the employer of the CAC's appointment by recorded delivery. The employer has no right of refusal; it takes note of the appointment and welcomes the CAC during on-site interventions if necessary.

Many CSEs confuse chartered accountant and statutory auditor. Here are the essential distinctions:

The principle: non-cumulation of missions#

The same firm may not be both chartered accountant and statutory auditor of the same CSE — this is an ethical incompatibility posed by French accounting regulation (separation between bookkeeping and certification functions). In practice, the CSE chooses:

• Firm A (chartered accountant): keeps the books, produces the accounts, drafts the L2315-69 report.
• Firm B (statutory auditor): audits and certifies the accounts produced by firm A.

The CAC's role: certification and alert#

The CAC produces each year:

• A general certification report on the annual accounts (with or without reserves).
• A special report on regulated agreements where applicable.
• An observations letter in case of irregularities or difficulties.
• An alert procedure if facts compromising the CSE's going concern are observed (rare but possible for large CSEs).

The independence of the CSE's CAC is an absolute rule, framed by the French Code of Ethics of the profession. Several incompatibilities apply:

1. Independence from the employer's CAC#

Strong ethical rule: in practice, the CSE's CAC should not be the same firm as the employer's CAC. The French statutory auditor Code of Ethics (H3C / CNCC) and French case law require every statutory auditor to be independent both in spirit and in appearance from the entities they certify, which makes such a cumulation a clear conflict-of-interest risk. Concretely, the employer transmits confidential information to the CSE via the BDESE, and the CSE's CAC must be able to control this information without bias — this is why we systematically recommend two distinct firms.

2. Incompatibility with the CSE's chartered accountant#

As seen above, the same firm cannot accumulate both missions on the same CSE.

3. Incompatibility with ancillary services#

The CAC cannot, in addition to its certification mission, provide the CSE with accounting, tax or legal services — it must remain an independent auditor. Occasional consulting services remain possible within strict limits.

4. Family and financial incompatibility#

The CAC must have no family link with the CSE's elected members, nor direct or indirect financial interest in the CSE or its main suppliers.

Funding: entirely on the AEP (operating) budget of the CSE — it is an operating expense, not a social and cultural activity.

Our firm is registered with CRCC Paris and intervenes as CSE CAC for several large French committees — strictly observing the incompatibility rule: we are never simultaneously chartered accountant and CAC of the same CSE, nor CAC of the CSE and the employer company.

Our CAC audit methodology relies on:

• Risk audit at the start of the mandate (CSE-specific mapping).
• Internal control tests on AEP / ASC separation, securing 10% transfers, compliance with URSSAF caps.
• Substantive tests on revenues (employer subsidies, ticketing) and expenses (expense claims, trips, gifts).
• ANC 2015-01 compliance tests on accounts presentation.
• Annual observations letter to the treasurer and CSE bureau with improvement recommendations.

Context: a central CSE of a French retail group (5,200 employees, 12 sites in France) sees its annual resources evolve as follows:

• 2023: EUR 2.85M — below threshold, simplified regime, no CAC.
• 2024: EUR 3.42M — threshold crossing of EUR 3.1M.
• 2025: EUR 3.68M — confirmation of the crossing.

Action taken by our firm (CSE chartered accountant):

• Crossing detected at 2024 closing (April 2025).
• Formal information to the CSE bureau at the plenary meeting of May 2025.
• Selection of an independent CAC (third-party firm, registered CRCC Paris) — tender between 3 firms.
• CAC appointment vote at the plenary meeting of June 2025 (mandate 2025-2030, 6 financial years).
• 1st financial year 2025 audit by the CAC in March-May 2026, certification without reserves.
• Move to full regime from financial year 2025: shift from streamlined balance sheet/income statement to standardised, complete notes, more analytical granularity.

CAC fees: EUR 9,500 HT/year, over 6 years = EUR 57,000 HT cumulated.

• CSE accounts approval 2026: management report, AGM, employee communication — The CAC presents its report at the AGM; read the complete procedure.
• Outsourcing CSE bookkeeping at 100%: why delegate A-Z rather than have the treasurer post entries — The A-Z chartered accountant prepares the accounts the CAC certifies.
• CSE bookkeeping in 2026: digitalisation with Pennylane and ANC 2015-01 compliance — ANC 2015-01 compliance is the bedrock of CAC certification.
• Our dedicated offering: specialist CSE chartered accountant — 50+ active mandates, including Auchan Retail France. Dedicated CAC, 24-hour quote.

Article written and reviewed by Samuel Hayot, chartered accountant registered with the Ordre des Experts-Comptables of Paris Île-de-France and statutory auditor registered with CRCC Paris. Hayot Expertise intervenes as CSE CAC for several large French committees, in strict compliance with ethical independence rules.

Sources: L2315-64, L2315-73, D2315-1 et seq., ANC 2015-01 Regulation, CNCC, French Ministry of Labour — CSE. This analysis is up to date as of 21 May 2026. For the appointment of a CAC for your CSE, book an appointment on 06 51 47 43 92.