Statutory Auditor Mandatory in France 2026: ALD Thresholds, Special Cases and Consequences

Updated 25 May 2026 — reviewed by Samuel Hayot, expert-comptable (chartered accountant)

The French statutory audit obligation — commissaire aux comptes (CAC) — underwent a major structural reform with the loi PACTE in 2019, followed by a further upward revision of the so-called ALD thresholds (audit légal des petites entreprises) that took effect for financial years opened from 1 January 2024. These revised figures are the operational reference in 2026.

Direct answer. A standard French commercial company must appoint a statutory auditor if it exceeds, for two consecutive financial years, at least two of the following three criteria: turnover excluding VAT above €12 million, balance sheet total above €6 million, headcount above 50. These thresholds are set by decree (Decree 2008-1487 as amended) within the framework of Article L823-1 of the French Commercial Code. Other entities are subject to specific regimes described below.

The loi PACTE first raised the thresholds to €4 million balance sheet, €8 million turnover, and 50 employees. The 2024 revision went further still: €6 million balance sheet and €12 million turnover. The headcount criterion remains at 50.

In practice, this change excludes a larger number of growing SMEs from the statutory obligation. A company that, under the previous framework, exceeded the €4 million balance sheet threshold may now fall below the new €6 million ceiling and avoid mandatory appointment — provided it does not simultaneously breach two criteria.

The trend is towards greater flexibility for smaller structures, but it does not remove the obligation for entities growing rapidly. Directors in hypergrowth must reassess their position at every year-end.

The thresholds for associations and CSE are revised periodically by decree. Check current figures on service-public.fr and with the CNCC before advising.

Three corporate forms require a statutory auditor from incorporation, regardless of their level of activity.

The SA (société anonyme) is the primary example. Article L225-218 of the Commercial Code requires one or two statutory auditors depending on size. A newly formed SA with zero revenue is still required to appoint a CAC at the time of incorporation.

The société en commandite par actions (SCA) follows the same regime as the SA. This structure is less common but is used in some family office and asset management contexts.

The Societas Europaea (SE) registered in France is also subject to an unconditional obligation, under the European regulation and its French implementing decree.

Our reading: directors who incorporate an SA for governance reasons — supervisory board, preference shares, an IPO in view — sometimes forget that the CAC obligation is immediate. This cost must be factored into the operational budget from the date of registration.

Animating holdings (holdings animatrices) — those that actively participate in managing their subsidiaries — are subject to the standard ALD thresholds. However, the threshold assessment differs depending on whether consolidated accounts are prepared or not.

A situation frequently seen in practice: a holding SAS does not exceed any threshold on a standalone basis (minimal own turnover, modest balance sheet). But it controls two or three operational subsidiaries. Once the group exceeds the ALD thresholds on a consolidated basis, the parent company becomes obligated to appoint a statutory auditor at group level.

The consolidated threshold assessment derives from Article L823-2 of the Commercial Code. The holding must therefore verify not only its own figures but also the aggregated data across the perimeter it controls.

The underestimated risk: a director creates a new holding to reorganise the group, does not breach any individual threshold, and incorrectly concludes that no CAC appointment is required. At the first financing round or acquisition, the bank or investor discovers the absence of a statutory auditor. The regularisation process — appointment, acceptance, taking up of duties, initial work — can delay a transaction by several weeks.

Associations Receiving Public Funding#

A French association (non-profit under the 1901 law) whose resources partly derive from public grants may be subject to a statutory audit obligation well below the thresholds applicable to commercial companies. The trigger threshold is linked to the annual amount of grants received from the State, local authorities, or public bodies. The law requires a mandatory appointment beyond a certain ceiling (à vérifier on service-public.fr, as the figure is subject to revision by decree).

Associations that also conduct a significant economic activity may additionally exceed the standard ALD thresholds and become subject to the obligation on that basis.

Comité Social et Économique (CSE)#

Works councils (CSE) whose annual resources exceed a decree-defined threshold must have their accounts certified by a statutory auditor. This threshold is distinct from the one applicable to companies. A company may not be subject to the CAC obligation at company level while its CSE is caught by the requirement if its resources — principally the operating subsidy and the contribution to social and cultural activities — exceed the regulatory ceiling.

In practice: the CSE's statutory auditor is appointed by the committee itself through a resolution of its members. The company's director is not party to this appointment, but the HR function is typically asked to provide the necessary accounting information.

Voluntary appointment of a commissaire aux comptes is permitted for any company, even below the thresholds. Several practical reasons lead directors to take this step.

Bank financing and investment. Lending institutions and venture capital funds place greater confidence in certified accounts. In LBO transactions, structured property financing, or early-stage rounds with institutional investors, the presence of a CAC can be a condition of access to funding.

Credibility with major clients. Some public-sector contracting authorities and large private-sector companies require certified accounts for the last three financial years as part of their supplier approval process.

The ALPE mission (audit légal des petites entreprises). Since the loi PACTE, small companies can opt for a lighter-touch statutory audit mission known as ALPE. The statutory auditor carries out procedures adapted to the size of the entity, without reaching the level of a full engagement. The cost is reduced and the report produced remains distinct from an unqualified certification opinion.

Trade-off: for an SME below the thresholds but planning to raise funds within 18 to 24 months, the ALPE mission represents a relevant governance signal at a controlled cost. It does not replace a full due diligence exercise, but it reduces the time investors spend on financial verification.

The statutory auditor titulaire is appointed for six financial years. This duration is set by the Commercial Code and cannot be altered by the articles of association or by a decision of the general meeting. At the end of the six years, the mandate does not renew automatically: the general meeting must deliberate on a new appointment, potentially with a new provider.

The six-year term is designed to guarantee auditor independence while allowing the CAC to build deep knowledge of the company. It also means that the CAC remains in post even if the company's figures fall back below the regulatory thresholds during the mandate.

What this means in concrete terms: a company that exceeds the thresholds in year N, appoints a CAC, and then falls below the thresholds in year N+2 remains bound to honour the mandate through to year N+6. It cannot terminate the engagement early without a court ruling on just cause.

A French software publisher produces the following figures:

• Year N: turnover (excl. VAT) €9.5 M, balance sheet €4.8 M, 38 employees — no ALD 2024 threshold exceeded
• Year N+1: turnover (excl. VAT) €13.2 M, balance sheet €7.1 M, 52 employees — all three thresholds exceeded simultaneously

The two-consecutive-year condition is met at the close of year N+1 on at least two criteria (turnover and balance sheet). The statutory appointment obligation arises from that date. The company has six months from year-end to appoint a commissaire aux comptes registered on the list of the Haute Autorité de l'Audit (H3C).

If the company fails to do so and opens a financing round in year N+2, it is in breach of Article L823-1 of the Commercial Code. Investors and their legal counsel will identify this during pre-closing due diligence.

A Paris-based director operates three restaurants through individual SAS companies, each individually below the thresholds. He creates a holding SAS to consolidate the shareholdings and simplify cash management. The holding only invoices intragroup service recharges: its own turnover amounts to €600,000.

During an annual review meeting, analysis of the group's consolidated accounts reveals the following: aggregated turnover €14.8 M, consolidated balance sheet €8.3 M, total headcount 68 employees. All three ALD thresholds are exceeded. The CAC obligation at group level had arisen two financial years earlier.

The regularisation required an extraordinary general meeting of the holding, identification of an available and willing statutory auditor, formalisation of an engagement letter, and the production of reports covering the two prior financial years. This catch-up exercise cost more than two years of ordinary engagement fees and delayed a bank refinancing by several months.

The Haute Autorité de l'Audit (H3C) supervises statutory auditors and may conduct quality-control inspections of their files. The clerks of commercial courts (greffes des tribunaux de commerce) check, at the time of annual accounts filing, whether the statutory auditor's report is present for companies subject to the obligation. Repeated absence of a CAC report in filed accounts can flag an irregularity.

In addition, during a tax audit, the tax authority may note the absence of certification and draw consequences regarding the presumption of regularity of the accounts.

• Updated ALD thresholds: the figures €12 M / €6 M / 50 employees are those resulting from the 2024 revision, applicable to financial years opened since 1 January 2024. Any company that assessed its position under the old thresholds (€8 M / €4 M) must redo the analysis.
• First year under the new thresholds: if your company exceeded the old thresholds but not the new ones, check whether a CAC mandate is still running. The mandate does not end because the thresholds have been raised.
• Groups in formation: any acquisition or creation of a subsidiary changes the perimeter and may alter the consolidated threshold assessment.
• Associations and CSE: the specific thresholds are subject to decree revision. An annual verification is required before each general meeting or renewal of the governing body.

Our firm works with directors on two distinct levels: first, the diagnostic (are you or are you not subject to the obligation?), then the organisation (appointment timetable, selection of a statutory auditor appropriate to your sector, coordination between our expert-comptable engagement and the CAC mandate).

We also assist in regularisation situations, when an irregularity is identified during a financing or disposal process. In those cases, speed of execution and coordination with the lawyer or M&A adviser are critical.

For further reading:

• Training for statutory auditors and regulatory developments
• CAC and JEI status: securing your hypergrowth
• Accounting support for SMEs and startups

The statutory auditor obligation in 2026 rests on three ALD thresholds revised in 2024: turnover excluding VAT above €12 million, balance sheet total above €6 million, headcount above 50 employees — two out of three, over two consecutive financial years.

But this threshold table does not cover the full picture. SA, SCA, and SE entities are subject without any condition. Holdings must reason at consolidated level. Associations receiving public grants and CSE bodies are governed by their own specific regimes. And a voluntary appointment — in particular through the ALPE mission — can be relevant well below the mandatory thresholds.

The absence of a CAC when one is required exposes the director to civil, criminal, and operational consequences that far outweigh the cost of the engagement.

This article presents a general framework updated as at 25 May 2026. It does not replace a case-specific analysis of your legal and accounting position. The thresholds applicable to associations and CSE are subject to revision by decree: verify current figures before making any decision.