Statutory auditor for training organisations: 2026 guide

Quick answer. A private-law training organisation must appoint a statutory auditor as soon as it exceeds, at year-end, two of the three following thresholds: 3 employees, €153,000 of turnover excluding tax (or resources) and €230,000 of total balance sheet (articles L.6352-8 and R.6352-19 of the French Labour Code). The term of office lasts six financial years, and failure to appoint exposes the director to criminal penalties.

A private-law training provider carries two distinct families of obligations, which many directors mix up.

The first is accounting. Article L.6352-6 of the Labour Code requires every private-law training organisation to prepare, each year, a balance sheet, a profit and loss account and notes, using a dedicated chart of accounts. To this is added the educational and financial return (BPF) of article L.6352-11. These obligations apply regardless of size, as soon as a modest activity threshold is crossed.

The second is the obligation to appoint a statutory auditor (commissaire aux comptes, CAC). It is triggered only when the organisation crosses certain thresholds. It is this second obligation, specific to the sector, that this guide covers.

The scope is broad: it concerns commercial companies (SASU, SARL, SAS, SA), 1901-law associations that deliver training, registered self-employed professionals, and private-law apprenticeship training centres (CFA). The legal form does not change the threshold principle; it only changes how the thresholds are assessed and which penalties apply.

For the full sector framework (activity declaration number, Qualiopi, VAT), see our dedicated training organisations sector and the guide on Qualiopi, NDA, BPF and VAT exemption.

The three sector-specific thresholds#

Article L.6352-8 of the Labour Code, completed by article R.6352-19, sets thresholds specific to training providers. A statutory auditor must be appointed as soon as the private-law organisation, whatever its legal form (SAS, SASU, SARL, EURL, association), exceeds two of the three following thresholds, assessed at the close of the financial year:

The rule is cumulative on two criteria: crossing only one of the three is not enough. Conversely, a small organisation generating €250,000 of turnover with 4 employees is caught, even if its balance sheet stays modest.

A far stricter regime than for companies#

This is what directors often discover too late. The general company regime, from the PACTE law and its decree, makes the statutory auditor mandatory only above two of the three following thresholds: €5,000,000 of total balance sheet, €10,000,000 of turnover excluding tax and 50 employees.

In other words, a standard consulting SASU can reach several million euros of turnover without an auditor. The same SASU, if it carries out training activity, falls into the obligation from €153,000 of turnover and 3 employees. The training sector therefore bears a markedly stricter regime, justified by the weight of public and pooled funding (CPF, OPCO, France Travail, regions) in its business model.

The case of associations and CFA#

Many training organisations are associations. An association that delivers training may be subject to two regimes in parallel: the sector regime above (3 employees, €153,000, €230,000) and the general association regime of article L.612-4 of the Commercial Code, which requires a statutory auditor from €153,000 of public subsidies received in the year. Both must be checked: the first one triggered creates the obligation.

Private-law apprenticeship training centres (CFA) fall under the same sector regime as other training organisations: 3 employees, €153,000 and €230,000, two criteria out of three. This is a frequent confusion: the high figures sometimes quoted (€1.55m, €3.1m, 50 employees) correspond to old association benchmarks or to the general regime, not to the training organisations regime.

How does the obligation end?#

The obligation ends when the organisation no longer exceeds two of the three thresholds for two consecutive financial years. Until this duration condition is met, the mandate continues. You must therefore reason on the trend, not on a one-off variation in a single year.

The statutory auditor audits accounts that follow rules specific to the sector. Before discussing the mission, it helps to understand the mandatory documents that every organisation must produce.

A dedicated chart of accounts#

Private-law training providers keep their accounts using a dedicated chart of accounts defined by the orders of 2 August 1995 and 21 July 2020. This applies from €15,244 of turnover for single-activity organisations, and regardless of turnover for multi-activity organisations. In practice, tracking relies on dedicated sub-accounts to trace the origin of each income item by funder.

The annual accounts (article L.6352-6)#

Each year, the organisation prepares a balance sheet, a profit and loss account and notes. These statements, and the accounting that underpins them, are what the statutory auditor will certify once appointed.

The educational and financial return (article L.6352-11)#

The BPF is the sector's reporting document. It is filed online on the "Mon Activité Formation" platform (form Cerfa 10443*17), for the 2026 campaign from 1 April to 31 May, on the data of the last closed financial year. It is organised around three main parts:

1. Identification of the organisation: activity declaration number, status, directors.
2. The financial return: the origin of income broken down by funder (companies, OPCO, the Caisse des dépôts for the CPF, France Travail, regions, the State, European funds, individuals, own funds) and the expenses, including training subcontracting.
3. The educational return: the number of trainees, trainee-hours, and the breakdown by type of action and audience.

Failure to file the BPF causes the lapse of the activity declaration number, with direct consequences on access to funding. The chartered accountant can be authorised by the organisation to carry out this filing.

BPF and accounting consistency: the key control#

The BPF must faithfully mirror the general accounting. The reconciliation between the income declared in the BPF and the income recorded in the accounts is the very first control a statutory auditor performs in a training organisation. An unexplained gap is a warning signal, both for the auditor and for the administration in the event of an inspection.

The mission follows the audit approach of the professional standards (NEP): understanding the entity and its environment, assessing risks, performing controls tailored to those risks, then forming an opinion. In a training organisation, several areas deserve specific attention.

Revenue recognition and deferred income#

Training sessions often span two financial years, and CPF-funded sessions are frequently collected in advance. The statutory auditor checks that income is allocated to the correct year according to the progress of the service, and that deferred income is correctly isolated. This is one of the sector's main risks of misstatement.

Subsidies and public funding#

The training model relies on external funders: the Caisse des dépôts for the CPF (with a co-payment raised to €150 since 2 April 2026), OPCO, France Travail, regions, the State, the European Social Fund. The statutory auditor checks the allocation of these funds, the reality of the funded actions, the required supporting evidence, and the risk of repayment where an action is ineligible or not delivered.

Subcontracting and trainer reclassification#

Many organisations use self-employed trainers. The auditor verifies the reality of the subcontracted services, their traceability, and assesses the risk of the relationship being reclassified as an employment contract, a source of URSSAF reassessment. The consistency between the subcontracting recorded in the accounts and that declared in the BPF is one of the control points.

VAT: a conditional exemption#

Continuing vocational training is exempt from VAT under article 261-4-4° a of the General Tax Code, provided the organisation obtains the certificate issued by the DREETS (form Cerfa 3511-SD). Without this certificate, the services are taxable at the standard rate of 20%. Where the organisation has a mixed activity (exempt and taxable services), the statutory auditor checks the deduction coefficient applied.

Qualiopi and traceability#

Qualiopi certification has been mandatory since 1 January 2022 to access public and pooled funding. It is based on the National Quality Framework (7 criteria). The statutory auditor does not audit teaching quality, but assesses the impact of any loss of certification on the going concern, since it conditions a significant share of funding.

The statutory auditor's report#

At the end of the engagement, the statutory auditor issues a report on the annual accounts: unqualified certification, qualified certification, or refusal to certify, together with observations and specific verifications. Where relevant, a special report on regulated agreements is also issued.

The appointment#

The statutory auditor is appointed by the competent body of the structure (general meeting of partners or members). Since the Sapin 2 law of 9 December 2016, appointing a deputy auditor is mandatory only where the principal auditor is an individual or a single-member firm. In other cases, the deputy is optional.

The term of office#

The term is six financial years when the appointment is mandatory. Where the organisation chooses to appoint an auditor voluntarily without reaching the thresholds, it may opt for a lighter engagement lasting three financial years.

The fees#

Fees depend on the estimated working time under professional standards, the size of the organisation and the complexity of its funding. They are set on a quote basis: there is no single regulatory scale. Our statutory auditor page sets out our pricing method, and the guide on how much a chartered accountant costs places these fees in the overall advisory budget.

The penalties#

Failing to appoint a statutory auditor where it is mandatory exposes the director to Commercial Code penalties: article L.820-4 provides for up to two years of imprisonment and a €30,000 fine for failing to procure the appointment of the auditor or to convene them to meetings. The offence of obstructing the auditor's duties carries the same penalties, and some decisions taken without an auditor may be void (article L.820-3-1).

On the sector side, the Labour Code also sanctions breaches of accounting and BPF obligations with fines (€4,500 under articles L.6355 and following), and the absence of a BPF causes the lapse of the activity declaration number.

Voluntary appointment#

Even below the thresholds, an organisation may voluntarily appoint a statutory auditor for a three-year engagement, for example to reassure public funders, a bank or a future buyer, securing the reliability of the accounts. This logic is close to that of other review engagements, such as the transformation auditor.

In our experience, difficulties rarely come from an isolated overrun, but from a lack of anticipation.

• Not tracking the thresholds over time. The obligation is assessed at each year-end: the three criteria must be monitored every year, not only when growth accelerates.
• A BPF inconsistent with the accounts. A BPF declared on a rough basis, without reconciliation to the accounts, is the leading cause of gaps found in audits and administrative inspections.
• Confusing the regimes. Applying the company thresholds (€5m, €10m, 50 employees) to a training organisation leads to missing the obligation for several years.
• Unsecured trainer subcontracting. Contracts, delivery evidence and traceability must be in place before the audit, not reconstructed afterwards.
• Waiting for the overrun to get organised. It is better to prepare the appointment in advance, building the auditor's cost into the budget as the trajectory approaches the thresholds.

To frame these obligations within a solid accounting setup, see also our guide on accounting obligations.