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ESG and CSRD Reporting Support in France

CSRD reporting and ESG advisory in Paris: materiality assessment, Scope 1-2-3 carbon footprint, ESRS report for SMEs and mid-caps. Hayot Expertise.

13 min readUpdated 12 July 2026
Scope 1-2-3
Full carbon footprint built to the ADEME and GHG Protocol method
70 to 90%
Share of total emissions sitting in Scope 3 for a services firm
From €4,500
ESG diagnostic and double-materiality matrix, excl. VAT
> €450M
Revenue threshold (with > 1,000 employees) set by Omnibus I, to be transposed in France by 19 March 2027

Business performance is no longer measured by EBITDA alone. Integrating ESG (Environmental, Social and Governance) criteria and the European CSRD directive is becoming vital to access preferential bank financing, retain employer attractiveness and win strategic tender processes.

The CSRD: are you in scope?

The CSRD (Corporate Sustainability Reporting Directive) imposes standardised non-financial reporting under the ESRS (European Sustainability Reporting Standards).

Implementation schedule:

Companies in scopeFirst applicable financial year
Large companies > 500 employees (already under NFRD)FY2024 (report in 2025)
Large companies (current French law; Omnibus I thresholds of 1,000 employees and €450M once transposed)FY2027 (report in 2028)
Listed SMEs on regulated marketsFY2028 (report in 2029), removal from scope under Omnibus I once transposed
Non-listed SMEsNo direct legal obligation (but value chain pressure)

The Omnibus directive (2025-2026): the two-year postponement is in force in France (Act No. 2025-391 of 30 April 2025), and Directive (EU) 2026/470, in force since 18 March 2026, must be transposed by 19 March 2027 at the latest. We keep you informed in real time.

Even if your SME is not directly required to report under CSRD, your major clients (CAC 40 companies, listed ETIs) need your Scope 3 carbon data to complete their own reporting. If you cannot provide this data, you risk being excluded from tender processes and supplier panels from 2026/2027 onwards.

What is double materiality?

The CSRD introduces the concept of double materiality:

  1. Financial materiality (outside-in): impact of ESG issues on the company's financial performance (physical climate risks, transition risks, human capital...)
  2. Impact materiality (inside-out): impact of the company's activities on the environment and society (CO₂ emissions, working conditions, governance...)

Our ESG diagnostic identifies the "doubly material" issues: those that are both important for your performance and for your impact on the world.

Our ESG service for SMEs and mid-sized companies

Step 1: ESG maturity assessment and double materiality

We carry out an initial 360° diagnostic (Environmental, Social, Governance). Deliverable: ESG maturity report with prioritised issues mapping and actionable recommendations. Duration: 5 to 10 days. Fee: on quote.

Step 2: Carbon footprint measurement (Scope 1, 2, 3)

In partnership with specialist engineers, we help you collect the necessary data (purchases, transport, energy, waste) and consolidate your GHG inventory (BEGES) in accordance with the ADEME and GHG Protocol methodology.

The 3 scopes:

  • Scope 1: Direct emissions (boilers, company vehicles, industrial processes)
  • Scope 2: Indirect energy-related emissions (electricity, purchased heat)
  • Scope 3: Other indirect emissions (supplier purchases, business travel, products sold, end-of-life)

Scope 3 typically represents 70 to 90% of total emissions for a services company.

Step 3: Building measurable non-financial KPIs

This is where our accounting expertise adds real value: just as we audit your accounts, we build and validate your non-financial indicators (ESG KPIs) so they are reliable, auditable and compliant with ESRS standards.

Examples of KPIs we build:

  • CO₂ emissions per euro of value added
  • Gender parity at management level
  • Absenteeism and staff turnover rates
  • Percentage of local or certified supplier purchases
  • Governance score (ESG committee, anti-corruption policy...)

Step 4: ESG report and communication

Drafting of the ESG report compliant with CSRD/ESRS requirements, communicable to stakeholders (investors, banks, clients, employees). Adapted format: dedicated report or section integrated into the annual management report.

Who is this service for?

Companies in CSRD scope after Omnibus I. The Omnibus I directive (Directive (EU) 2026/470, in force 18 March 2026) raised the reporting threshold to large companies with more than 1,000 employees and over €450M in net turnover; France must transpose it by 19 March 2027 at the latest, and current French law still covers large companies for financial years beginning on or after 1 January 2027. Mid-sized companies of 250 to 500 employees, previously expected to report from FY2025, should largely fall outside the mandatory scope. We guide the companies that remain in scope, and those opting for voluntary reporting, through producing a full ESRS report and preparing for verification by an OTI (independent third-party body).

SMEs supplying large groups. Even with no direct legal obligation, SMEs supplying CAC 40 companies or listed mid-caps are routinely asked for their Scope 3 data and ESG questionnaires (EcoVadis, bespoke supplier surveys). We help them respond in a quantified, credible way rather than with vague statements of intent.

Companies listed on regulated markets. Directly subject to the CSRD since FY2024 when they are large companies with more than 500 employees and, under current French law, from FY2027 for other large listed companies and from FY2028 for listed SMEs, listed companies need integrated support combining accounting expertise and ESG advisory.

Businesses seeking green financing. Bpifrance, green bonds, preferential-rate loans: ESG criteria now feed directly into credit conditions. A solid ESG file opens the door to more advantageous financing.

Start-ups and scale-ups. A growing number of investment funds, impact and ESG funds in particular, require non-financial reporting from the earliest funding rounds. Tech founders can read more on our tech start-ups sector page.

Our method and client process

We run the engagement in four sequenced stages, each with a clear deliverable, so the work stays auditable from the first interview to the final report.

Stage 1: ESG maturity assessment (weeks 1 to 4). An initial documentary review and interviews with internal stakeholders (management, HR, procurement, finance). Deliverable: a maturity report with a double-materiality matrix. This is the foundation of the whole project: without this mapping it is impossible to know which ESRS indicators are genuinely relevant to your activity.

Stage 2: Greenhouse-gas measurement (weeks 4 to 12). Systematic collection of activity data and calculation of Scope 1, 2 and 3 emissions under the GHG Protocol. We identify the dominant emission items and build the carbon-reduction plan around them.

Stage 3: Building and securing non-financial KPIs (weeks 8 to 16). Definition of the key indicators per ESG pillar (emissions per euro of revenue, gender parity, absenteeism rate, governance score). We set up a reproducible, auditable collection system and train your teams to run it.

Stage 4: ESRS report and verification readiness (weeks 14 to 20). Drafting of the non-financial management report or DPEF, integrating the results of the previous stages. We assemble the file for the OTI and prepare your communication to stakeholders: investors, banks, clients and employees.

Concrete benefits of an ESG approach

  • Access to green financing: preferential-rate loans, green bonds, Bpifrance ESG financing
  • Commercial differentiation: public tenders increasingly require ESG criteria
  • Employer attractiveness: 67% of recent graduates refuse to work for a company with no ESG policy (2025 survey)
  • Cost reduction: lower energy consumption, resource efficiency, less waste

Common mistakes to avoid

1. Waiting until the law forces your hand. Value-chain pressure usually arrives before the legal obligation does. Your largest clients are already asking for ESG information in 2026. Starting now gives you a head start and spares you producing a rushed, sub-standard report under pressure.

2. Ignoring or underestimating Scope 3. Scope 3 is often the bulk of total emissions, yet it is also the hardest data to collect. Without reliable Scope 3 figures you are exposed to guesswork, or to being rejected from your clients' ESG audits.

3. Using KPIs that cannot be verified or reproduced. An ESG report is only worth as much as its indicators are traceable and verifiable. Declaring an "employee satisfaction rate" with no documented collection methodology invites criticism and accusations of greenwashing.

4. Confusing marketing CSR with CSRD reporting. Publishing a glossy CSR brochure is not the same as an ESRS report. The ESRS standards impose precise disclosure thresholds, standardised calculation methods and external verification.

5. Neglecting internal ESG governance. A CSRD report is an annual process that needs data collected continuously throughout the year. Without a trained internal ESG lead and a structured collection system, next year's report will be impossible to produce on time.

Worked example: an industrial SME with 80 employees

Profile. A metal-fabrication SME (Île-de-France), 80 employees, revenue of €12M, supplying an industrial group in the SBF 120 index.

Situation. The client group has asked its suppliers to report their Scope 1, 2 and 3 carbon footprint by the end of 2026 so it can consolidate its own CSRD reporting.

Carbon-footprint results:

ScopeSourceEmissions
Scope 1Natural gas, vehicles180 t CO₂eq/year
Scope 2Electricity consumed95 t CO₂eq/year
Scope 3Steel purchased, transport, travel2,850 t CO₂eq/year (91% of the total)

Reduction plan identified:

  • Replacing combustion-engine vehicles with electric ones: −40 t CO₂eq/year
  • Switching steel sourcing to certified low-carbon steel: −620 t CO₂eq/year of potential savings
  • Optimising logistics (consolidated deliveries): −120 t CO₂eq/year

Business impact. The client kept the supplier in its panel, avoiding an estimated loss of revenue of €1.8M. The carbon footprint was delivered for €6,500 excl. VAT: a demonstrable, immediate return on investment.

Our ESG and CSRD fees

ServiceEstimated durationFee excl. VAT
ESG diagnostic & double-materiality matrix4 to 8 weeksFrom €4,500
Carbon footprint Scope 1-2-3 (SME < 50 employees)6 to 10 weeks€4,500 to €7,000
Carbon footprint Scope 1-2-3 (mid-cap 50 to 250 employees)8 to 14 weeks€7,000 to €15,000
Full ESRS report (diagnostic + footprint + report)16 to 24 weeksOn quote (from €15,000)
ESG team training (half-day)4h€1,200
Annual support (KPI updates, report)SubscriptionFrom €3,600/year

Indicative fees. A tailored quote is issued after an initial scoping meeting, which is free of charge. See our full pricing page for how we structure engagements.

Why choose Hayot Expertise?

Accounting rigour applied to non-financial data. Our DNA as a chartered-accountancy firm makes the difference: we build ESG indicators with the same demand for traceability, verifiability and reproducibility as a set of financial accounts. Your ESG data will stand up in front of an OTI.

Integrated expertise. Beyond ESG, our firm masters taxation, legal structuring and financial management. We fold your ESG approach into your wider strategy: financing, valuation and governance. Where a holding structure is relevant, we coordinate with our holding tax team in Paris.

A Paris base with a national reach. Based at 58 rue de Monceau, Paris 8th, we support SMEs and mid-caps across every sector. Our digital tools (Pennylane, Silae, Dext) make data collection for your reporting far smoother. See also our Paris 8 accountancy practice.

Real-time regulatory watch. The Omnibus directive, ESRS updates, new bank ESG requirements: we keep you informed and adapt your strategy without waiting for the dust to settle. For the wider context, read our note on the 2026 Finance Act: key measures for SMEs and our review of business financing solutions for 2026.

Frequently asked questions

Does my company have to publish CSRD reporting?

Since Omnibus Directive (EU) 2026/470, EU law limits the obligation to companies above 1,000 employees and €450M turnover. Until France transposes it (deadline: 19 March 2027), French law covers large companies within the meaning of the French Commercial Code, since FY2024 for public-interest entities with more than 500 employees and from FY2027 for the others. Most SMEs are therefore not in scope, but they may be asked by customers or banks and can opt for voluntary reporting.

What is double materiality?

Double materiality means analysing both the company's impact on the environment and society (impact materiality) and the effect of sustainability issues on its financial performance (financial materiality). It is the starting point of an ESRS report, as it determines which topics to disclose.

Can I report Scope 3 emissions without perfect supplier data?

Yes: Scope 3 allows the use of estimates and emission factors, with an obligation to be transparent about the method. You start with the best available data, then progressively improve collection from suppliers.

How much does CSRD/ESRS reporting cost and how long does it take?

It depends on size, number of sites and data maturity; the engagement is quote-based after scoping. The project usually spans several months, most of the time spent collecting and validating indicators, ahead of verification by an independent third-party body (OTI).

Is ESG really mandatory for a non-listed SME?

Not directly in legal terms. But indirect regulatory pressure (through the value chain) and the expectations of clients and banks make an ESG approach virtually unavoidable for any SME that supplies large groups or is seeking financing.

Our banks are already asking us for an ESG questionnaire. How do we respond?

Banks typically use standardised questionnaires (EcoVadis, internal questionnaires). Our team helps you structure your responses with verified quantitative data, maximising your score and access to preferential credit terms.

What is the difference between ESG, CSR and CSRD?

CSR (Corporate Social Responsibility) is the voluntary or mandatory approach to integrating social and environmental issues. ESG (Environmental, Social, Governance) refers to the three pillars for measuring non-financial performance. CSRD is the European directive imposing standardised reporting on ESG issues according to ESRS standards.

What is the Omnibus directive and what does it mean for my company?

The Omnibus directive, proposed by the European Commission in 2025, became Directive (EU) 2026/470 of 24 February 2026, in force since 18 March 2026: it limits the obligation to companies with more than 1,000 employees and more than €450M in net turnover, and the two-year postponement of waves 2 and 3 is already in force in France (Act No. 2025-391 of 30 April 2025). France must transpose the directive by 19 March 2027 at the latest. We track the progress of the texts in real time and adjust your roadmap accordingly.

What is an OTI and when is verification mandatory?

An OTI (independent third-party body) is a statutory auditor or accredited organisation tasked with verifying the information in the ESRS report. Verification is mandatory for every company subject to the CSRD. In the first phase a "limited" assurance is required; in time a "reasonable" assurance, comparable to a financial audit, will be expected.

Does an ESG approach affect company valuation?

Increasingly, yes. Acquirers (investment funds and industrial buyers alike) now build ESG criteria into their due-diligence analysis. A company with a solid ESG report, a certified carbon footprint and reliable KPIs benefits from a valuation premium and a smoother disposal process.

Can the ESG approach be combined with other certifications (ISO 14001, B Corp)?

Yes. An ADEME carbon footprint and an ESRS report form a solid base for obtaining ISO 14001 certification or the B Corp label. We coordinate your overall approach to avoid duplication and to maximise the value of every ESG effort.

Is the CSRD mandatory for SMEs?

No, the CSRD does not apply directly to non-listed SMEs. Value-chain pressure is nonetheless very real: your large clients, who are themselves subject to the CSRD, need your Scope 3 data to consolidate their own reporting. SMEs listed on regulated markets are covered by current French law from the FY2028 financial year; once transposed, Omnibus Directive (EU) 2026/470 takes them out of scope.

How much does a carbon footprint cost for an SME?

For an SME of 10 to 50 employees, a full Scope 1, 2 and 3 carbon footprint generally costs between €4,500 and €7,000 excl. VAT. For a mid-cap of 50 to 250 employees the cost ranges from €7,000 to €15,000 excl. VAT depending on the complexity of the value chain and the quality of the data available. Scope 3 supplier-data collection is usually the most time-consuming part of the exercise.

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Samuel Hayot, Chartered Accountant registered with the French Order (OEC Paris-IDF)

Article written by Samuel Hayot

Chartered Accountant, registered with the Institute of Chartered Accountants. Certified Pennylane trainer.

Regulated French firmUpdated 12 July 2026

Regulated French accounting firm based in Paris 8, whose founder is also a statutory auditor, built to support companies across France with a digital and decision-oriented approach.

Your guarantees

A regulated firm, in Paris 8 and remote

The firm is in Paris 8. It can also work remotely with a business located elsewhere in France that wants a direct, digital accounting partner that helps it decide.

Regulated firm

Samuel Hayot is a French chartered accountant registered with the Ordre of Paris Île-de-France, and a statutory auditor on the list drawn up by the H2A, member of the CRCC de Paris.

National reach

The firm is in Paris 8. It works remotely and can support a business located anywhere in France.

Modern tools

Pennylane, Dext and Silae, with as many tasks automated as possible, so your figures stay visible and the work moves quickly.

Direct contact

The phone number is at the bottom of every page, getting in touch is simple, the engagement letter comes quickly and the mandate is scoped without detours.