Tax audit: how to react to an audit

Update April 2026 - Receiving a tax audit notice always provokes the same reflex: tension. However, a tax audit is not automatically synonymous with adjustment. In 2025, the DGFiP recorded record results in terms of tax audits, with more than a million audits carried out and adjustments notified exceeding 13 billion euros, according to the latest published data. These figures confirm an underlying trend: the tax administration is intensifying its audits, relying increasingly on the algorithmic cross-referencing of data and the automated analysis of the accounting entries file (FEC).

The correct reaction to a tax audit is neither panic nor passivity. It is a clear method, based on your rights and your supporting documents. This guide explains exactly what to expect and how to prepare.

In brief: The tax audit covers several distinct procedures (document audit, accounting audit, examination of personal tax situation). Each type of control obeys precise rules defined by the Book of Tax Procedures (LPF) and the charter of the audited taxpayer. The right to make an error (article L. 80 A of the LPF) and the regularization procedure during control (article L. 62 of the LPF) offer concrete defense levers.

The tax administration has several control tools, each governed by specific legal provisions. The official documentation of the DGFiP (BOFiP, updated January 2026) distinguishes four main procedures:

• documentary inspection (article L. 10 of the LPF): the administration examines your déclaration and the documents you have sent, without on-site intervention. This is the most common form of control;
• accounting audit (article L. 13 of the LPF): an in-depth examination of your accounts, on site at your premises or in the tax services. It concerns the overall consistency of your accounting entries;
• the accounting exam: a lighter form of verification, often used for small businesses;
• the contradictory examination of personal tax situation (ESFP) (article L. 12 of the LPF): it concerns individuals and verifies the consistency between your declared income and your lifestyle.

Each procedure triggers different guarantees for the taxpayer, as provided by the charter of rights and obligations of the audited taxpayer.

Understanding the administration's selection criteria allows you to better anticipate. In 2026, the DGFiP will massively use data mining and automatic file reconciliation. The main warning signs identified by industry professionals include:

• a significant difference between the declared turnover and the average of your sector (the sectoral ratios of the DGFiP are regularly updated);
• a sudden drop in margin or result without apparent economic justification;
• inconsistencies between the VAT collected and the turnover declared;
• operations with non-cooperative countries or complex cross-border arrangements;
• a lifestyle clearly higher than the declared income (individuals);
• repeated omissions or delays in your déclarations;
• anomalies detected by the automated processing of the FEC during the check.

According to the report of the Court of Auditors of December 2025 on the fight against tax fraud, the targeting of controls has been considerably refined thanks to artificial intelligence and the processing of massive data. This means that random checks have become marginal: each tax audit today is based on a documented presumption.

Upon receipt of the letter from the administration, do not react urgently. Take the time to read the verification notice carefully and note the following information:

• the exact nature of the control (accounting verification, documentary control, ESFP);
• the tax years concerned (the recovery period is 3 years in principle, article L. 169 of the LPF);
• the date of first intervention or the response deadline;
• the list of requested documents;
• the issuing service (SIE, control brigade, DIRCOFI for large companies);
• mention of the verified taxpayer charter, which must be attached or made available.

This initial framing is essential. It determines the scope of the tax audit and your precise obligations. An inspector cannot extend his investigation beyond the exercises mentioned in the notice, unless there is a specific enhancement procedure.

The charter of the rights and obligations of the audited taxpayer is not a simple courtesy document. It has legal value and non-compliance may result in the procedure being declared void. Here are the fundamental guarantees you have:

Right to information#

The administration must inform you of the purpose of the check, the exercises checked and your rights. The charter must be given to you at the start of the verification.

Right to legal assistance#

You can be assisted by an advisor of your choice (accountant, tax lawyer) during each interview with the auditor. This right is guaranteed by article L. 47 A of the LPF.

Right to contradiction#

Any proposed rectification must be notified to you in writing, with a response time of 30 days (article L. 57 of the LPF). You can make written comments or request an interview.

Right to regularization#

Article L. 62 of the LPF allows an error or omission to be spontaneously regularized during an inspection. Since February 2026, a single form has been created to simplify this procedure, as specified in the new doctrinal guidelines of the DGFiP (BOI-CF-IOR-20-10).

The right to make mistakes#

Included in article L. 80 A of the LPF, the right to make an error allows a good faith taxpayer who commits an irregularity for the first time to regularize his situation without suffering the full level of penalties. This system applies under certain conditions:

• it must be a first error on the same tax;
• the taxpayer must demonstrate good faith;
• regularization must occur spontaneously or within the time limit set by the administration.

The file of accounting entries (FEC) has become the central tool for any accounting audit. Mandatory for all companies required to maintain complete accounting (article L. 47 A of the LPF), this standardized file contains all of your accounting entries in standardized format.

What the auditor looks for in your FEC#

• the sequentiality of part numbers: any break in séquence is a warning signal;
• accounting dates: entries made at the end of the financial year in an unusual manner attract attention;
• third party accounts: accounts 401, 411, 455 are scrutinized to detect possible concealments;
• reconciliations with the tax package: the consistency between the FEC and the 2065/2031 déclarations is automatically checked;
• the absence of mandatory information: each entry must include the fields required by the FEC standard.

Sanctions linked to the FEC#

Failure to present a compliant FEC may result in two types of cumulative sanctions (article 1734 sexies of the CGI):

• a fine of 10% of reinstated profits or, if this amount cannot be determined, of 5% of declared turnover;
• a rejection of accounting, opening the way to automatic taxation.

Hayot Expertise Advice: What is costly in a tax audit is not only the initial error. Above all, it is the inability to explain it, document it or correct it in time. A clean, documented and consistent FEC is your first line of defense.

Step 1: Create a complete documentary file#

Systematically collect:

• tax returns for the financial years concerned (VAT, IS, tax return);
• the complete and tested FEC for each exercise;
• supporting documents for sensitive records (invoices, contracts, minutes);
• VAT/turnover/accounting reconciliation tables;
• summary notes documenting your tax decisions (provisions, depreciation, tax integration).

Step 2: Anticipate friction points#

As an accountant, we systematically identify risk areas even before the first discussion with the auditor:

• contestable déductible expenses: reception costs, executive rémunération, attendance fees;
• insufficiently justified provisions: any provision must be based on quantified and documented elements;
• VAT on personnel expenses: the deductibility of VAT on benefits in kind is a classic of control;
• transfer pricing: transactions between related companies must be documented in accordance with article 57 of the CGI.

Step 3: Structure your discussions with the auditor#

• designate a single contact person (manager or accountant);
• respond to requests on time, neither too quickly nor too late;
• provide only the requested documents, no more;
• trace in writing each important exchange;
• keep a copy of any document transmitted.

Our field experience has allowed us to identify the most costly errors:

• responding too quickly without rereading the documents: a hasty response can commit your company on inaccurate grounds;
• produce incomplete or corrupt exports: an illegible FEC is assimilated to a lack of présentation;
• improvise a posteriori justification: the verifier quickly detects arguments constructed after the fact;
• neglect response times: the absence of a response within 30 days constitutes acceptance of the proposed enhancements;
• ignore the remedies: you have free and contentious appeals (article R. 196-1 of the LPF);
• accept the first proposals without discussion: the contradictory phase is made for debate.

We intervene at three levels to secure your position:

1. Before the control: preventive audit of your FEC, consistency review of the package/comptabilité/TVA, identification of sensitive points and preparation of supporting documents.
2. During the inspection: organization of the response, preparation of documents, securing exchanges with the verifier, formulation of a well-argued technical position.
3. After the inspection: analysis of rectification proposals, exercise of appeals, negotiation of penalties, assistance with the departmental commission for direct taxes and turnover taxes if necessary.

Be accompanied during a tax audit

A tax audit is best managed when your numbers, your documents and your method are already aligned. In 2026, intensified tax audits and the growing use of automated data analysis make preparation even more strategic. The best protection remains the quality of the file even before the first letter from the administration. A documented and well-advised taxpayer transforms a test into a simple formality.

(Official sources: BOFiP - BOI-CF-IOR-20-10, Book of tax procedures - Articles L. 10, L. 12, L. 13, L. 47 A, L. 57, L. 62, L. 80 A)