France

As a member of the European Union (EU), France is subject to the accounting, auditing and financial reporting requirements established in EU Regulations and Directives as transposed into national laws and regulations.

The Commercial Code of 1966 (as amended) sets basic accounting functions in all business entities and requires companies to maintain accounting books and prepare annual financial statements. French accounting standards are developed and adopted by the Accounting Standards Authority (ANC), created by the Ordinance No. 2009-79 and Decree No. 2010-56, which is the legal body responsible for accounting standard-setting.

In accordance with the EU statutory framework, Regulation EC 1606/2002, as transposed into national legislation by the ANC, listed entities are required to apply EU-endorsed IFRS Standards for consolidated financial statements. In addition, all other companies are permitted to apply IFRS for their consolidated financial statements. However, no entity is allowed to apply IFRS for the preparation of their individual financial statements and instead must use French accounting standards (French GAAP). The ANC has concluded that there is no demand for the IFRS for SMEs in France where French GAAP is considered fit for purpose.

The auditing requirements in France are transposed by the Audit Directive and Regulation (EU) No 537/2014. Auditing standards are prepared and drafted by a joint commission of the Compagnie nationale des commissaires aux comptes (CNCC) and the High Council for Statutory Audits (H3C), the audit oversight authority. The H3C will subsequently adopt the drafts as standards of professional practice, after receiving an opinion on the standards from the CNCC. The Ministry of Justice is ultimately responsible for endorsing the standards at the end of this process. The standards are based on the ISA.

A mandatory audit with a term of six years is required for all PIEs and public limited companies which exceed two of the three following thresholds: (a) EUR 4,000,000 of total assets; (b) EUR 8,000,000 of turnover or resources; and/or (c) 50 employees. In addition, a mandatory audit is required for companies which are part of a small group when they exceed two of the three following three criteria: (a) EUR 2,000,000 of total assets; (b) EUR 4,000,000 of turnover or resources; (c) 25 employees.

In 2019, the law Pacte introduced a voluntary statutory audit with a term of three years for Small and Medium Entities (SMEs)

In France, the accountancy profession is regulated at the state level and at the professional level. The Financial Security Law, written into the Commercial Code, recognizes the High Council for Statutory Audits (H3C), under the supervision of the Ministry of Justice, as an independent, non-governmental entity responsible for overseeing the audit profession. In addition the Commercial Code, recognizes two segments of the profession “Commissaire aux comptes” (statutory auditors) and “Expert-comptable” (chartered accountants)—which are both regulated at the professional level by the Compagnie nationale des commissaires aux comptes (CNCC) and the Conseil National de l’Ordre des Experts-Comptables (CNOEC), respectively.

In France, the universities, the Ministries of Higher Education, Justice and Economy, Finance and Budget have a role in implementing initial professional development (IPD) requirements for professional accountants, which are established in the Commercial Code for the “Commissaires aux comptes” and in the Decree 2012-432 of 2012 for the “Experts-comptables.” To be eligible to practice as a statutory auditor or chartered accountant, individuals must: have a university degree, have work experience of at least three years in an accounting/auditing firm, pass a final assessment, and obtain the French higher accountancy degree: “Diplôme d’Expertise Comptable” (DEC). The DEC gives access to both professions; however, auditors must obtain their practical experience in audit. In addition, there is a second pathway to become a statutory auditor through the professional certificate “Certificat d’aptitude aux fonctions de commissaire aux comptes” (CAFCAC) which permits someone without a specific university education in accounting—candidates are usually engineers—the opportunity to pass a preparatory certificate before beginning three years of practical training. Subsequently, candidates must be registered with the CNCC or CNOEC in order to practice.

The H3C, as the oversight authority for the audit profession “Commissaires aux comptes,” has the following responsibilities: (i) the registration of statutory auditors and audit firms; (ii) the adoption of standards on audit, professional ethics, and internal control, as well as professional best practices; (iii) establishing a quality assurance (QA) system; (iv) developing an investigative and disciplinary system; and (v) supervision of continuing professional development (CPD) of statutory auditors. The Ministry of Justice is ultimately responsible for endorsing standards on audit, as well as professional ethics for statutory auditors.

As part of its mandate, the H3C has delegated the following activities to the CNCC: (i) QA inspections of non-public interest entities (non-PIEs); and (ii) monitoring of CPD for statutory auditors.

Statutory auditors are also subject to regulation of the CNCC, created by the decree of August 12, 1969 (as amended May 27, 2005) and codified in the Commercial Code in August 2007, as an independent institute under the auspices and supervision of the Ministry of Justice. Statutory auditors who are authorized to practice in France, whether they are individuals or legal entities, are required to belong to the CNCC. In addition, to the responsibilities delegated by the H3C, the CNCC, along with its 17 regional arms—Compagnies régionales des commissaires aux comptes—carries out the following regulatory activities: (i) providing input into the accountancy curricula and IPD requirements for statutory auditors; (ii) giving its opinion when required by the Ministry of Justice on draft laws and decrees; and (iii) submitting to the public authorities all useful proposals relating to the professional organization and the audit assignment.

In France, chartered accountants are regulated by Ordinance No. 45-2138 of 1945, which created the CNOEC, as an independent organization, under the auspices of the Ministry of Economy and Finance. Individuals and legal entities are required to be members of the CNOEC to offer accountancy services other than statutory audit. In accordance with the law, the CNOEC responsibilities include the following: (i) maintaining the registry of chartered accountants and accounting firms; (ii) establishing CPD and professional conduct requirements; (iii) establishing and operating a quality control system; (iv) preparing and drafting professional conduct standards; (v) drafting auditing standards for contractual audits and reviews of historical financial information, and other assurance and related services engagements; (vi) providing input into the accountancy curricula and IPD requirements for chartered accountants; and (vii) representing, promoting, defending, and developing the profession of chartered accountant, both in France and abroad.

In addition, the Ordinance No. 45-2138 of 1945, supplemented by the Decree No 2012-432 of 30 March 2012 and the Order of 19 January 2022 approving the internal rules of procedure of the OEC, authorizes the Regional Disciplinary Chambers, which are legally independent from the CNOEC, to investigate and discipline chartered accountants. The Regional Disciplinary Chambers are fully integrated into the French judicial system. The Regional Disciplinary Chambers undertake discipline and investigation for CNOEC members. CNOEC members may appeal decisions before the National Disciplinary Chamber. The appeal to the decisions of the National Disciplinary chamber takes place before the Supreme Court (Conseil d’Etat).

The Financial Security Law, written into the Commercial Code, recognizes the High Council for Statutory Audits (H3C), under the supervision of the Ministry of Justice, as an independent, non-governmental entity responsible for the oversight of the audit profession. The H3C is a member of the International Forum of Independent Audit Regulators.

The H3C has the following responsibilities: (i) the approval and registration of statutory auditors and audit firms; (ii) the adoption of standards on audit, professional ethics, and internal control, as well as professional best practices; (iii) establishing a quality assurance (QA) system; (iv) developing an investigative and disciplinary system; and (v) supervision of CPD of statutory auditors. As part of its mandate, the H3C has delegated some activities to the Compagnie nationale des commissaires aux comptes (CNCC)—the professional accountancy organization for statutory auditors in France. These include: (i) registration of statutory auditors and audit firms, except for non-EU statutory auditors and audit firms; (ii) QA inspections of non-public interest entities (non-PIEs); and (iii) monitoring of CPD for statutory auditors.

To enhance the oversight of listed entities, H3C and the securities market regulator, the Autorité des Marchés Financiers (AMF), signed a cooperation agreement in 2010 setting out the procedures for the AMF to assist in performing periodic inspections of statutory auditors appointed to companies under AMF’s supervision. The agreement also covers the arrangements for sharing information held and gathered by the authorities when carrying out their respective duties. In addition, the Commercial Code provides that the AMF can assist in the periodic inspections of statutory auditors auditing the accounts of persons under AMF’s supervision.

Lastly, the Commercial Code authorizes the Regional Chambers of Discipline to investigate and discipline statutory auditors related to cases with non-PIEs. The Regional Disciplinary Chambers are fully integrated into the French judicial system. Statutory auditors may appeal to the H3C and before the National Disciplinary Chamber. The appeal to the decisions of the National Disciplinary chamber takes place before the Supreme Court (Conseil d’Etat).

The Compagnie Nationale des Commissaires aux Comptes (CNCC)

The CNCC, created by the decree of August 12, 1969 (as amended May 27, 2005) and codified in the Commercial Code in August 2007, is an independent institute under the auspices and supervision of the Ministry of Justice. Statutory auditors who are authorized to practice in France, whether they are individuals or legal entities, are required to belong to the CNCC. The CNCC, along with its 33 regional arms—Compagnies régionales des commissaires aux comptes—carries out the following regulatory activities: (i) maintaining the registry of statutory auditors and audit firms, except for non-EU statutory auditors and audit firms; (ii) preparing and drafting professional standards for auditing; (iii) establishing and operating a QA systems; (iv) administering and monitoring of the CPD program; (v) providing input into the accountancy curricula and IPD requirements for statutory auditors; (vi) giving its opinion when required by the Ministry of Justice on draft laws and decrees; and (vii) submitting to the public authorities all useful proposals relating to the professional organization and the audit assignment.

In addition to being an IFAC Member, CNCC is also a member of Accountancy Europe, the Federation Internationale des Experts-Comptables Francophone (FIDEF), and the Fédération des Experts-Comptables Mediterranéens (FCM). In addition, CNCC participates in the European “Common Content Project.”

The Conseil National de l’Ordre des Experts-Comptables (CNOEC)

The CNOEC is an independent organization, under the auspices of the Ministry of Economy and Finance, created by Ordinance No. 45-2138 of 1945. Individuals and legal entities are required to be members of CNOEC in order to offer accountancy services other than auditing. In accordance with the law, the CNOEC responsibilities include the following: (i) maintaining the registry of chartered accountants and accounting firms; (ii) establishing CPD and professional conduct requirements; (iii) establishing and operating a quality control system; (iv) preparing and drafting professional conduct standards; (v) drafting auditing standards for contractual audits and reviews of historical financial information, and other assurance and related services engagements; (vi) providing input into the accountancy curricula and IPD requirements for chartered accountants; and (vii) representing, promoting, defending, and developing the profession of chartered accountant, both in France and abroad.

In addition to being an IFAC Member, CNOEC is also a member of Accountancy Europe, FIDEF, and FCM. In addition, CNOEC participates in the Professional Accountancy Education Europe (PAEE), formerly “Common Content Project”.

In France, in compliance with the Audit Directive and Regulation (EU) No 537/2014, a mandatory quality assurance (QA) review system is required for all statutory audits. The High Council for Statutory Audits (H3C) has the ultimate responsibility for quality assurance of all statutory audit firms.

Accordingly, the H3C conducts QA reviews for all public interest entities (PIEs). PIEs include listed entities, credit institutions, insurance companies, and certain companies whose turnover exceeds a certain threshold, such as: financial holding companies, one of whose subsidiaries is a credit institution; mixed financial holding companies, one of whose subsidiaries is a PIE; insurance group companies, mutual insurance group companies, mutual grouping unions, insurance welfare groups, social protection insurance group companies. As far as non-PIEs QA reviews are concerned, the H3C has delegated the reviews to the Compagnie Nationale des Commissaires aux Comptes (CNCC). In fulfilling this responsibility, CNCC maintains a monitored peer review mechanism under the oversight of the H3C. In France, the five largest audit firms operating in the jurisdictions are inspected on an annual basis. Other PIE audit firms are inspected every three years (or six years for smaller firms), and non-PIEs audit firms are inspected every six years.

To enhance the oversight of the securities market, the Autorité des Marchés Financiers (AMF) assists H3C in performing periodic inspections of statutory auditors appointed to companies under AMF’s supervision.

Based on available information on the QA review systems being carried out by the H3C and CNCC, it seems that all systems are aligned with SMO 1 best practices. The CNCC indicates that all the firms who audit large PIEs are ISQC1 compliant (either on a voluntary basis or because of their commitment to the FOF). Nonetheless, ISQC 1 and ISA 220, which are key components of the SMO 1 best practices, are not formally adopted for application by all firms.

Current Status: Partially Adopted

In France, the universities, the Ministries of Higher Education, Justice and Economy, Finance and Budget have a role in implementing initial professional development (IPD) requirements for professional accountants, which are established in the Commercial Code for the “Commissaires aux comptes” and in the Decree 2012-432 of 2012 for the “Experts-comptables.”

To be eligible to practice as a statutory auditor or chartered accountant, individuals must: have a university degree, have work experience of at least three years in an accounting/auditing firm, pass a final assessment, and obtain the French higher accountancy degree: “Diplôme d’Expertise Comptable” (DEC). The DEC gives access to both professions. However, auditors must obtain their practical experience in audit. In addition, there is a second pathway to become a statutory auditor through the professional certificate “Certificat d’aptitude aux fonctions de commissaire aux comptes” (CAFCAC) which permits someone without a specific university education in accounting—candidates are usually engineers—the opportunity to pass a preparatory certificate before beginning three years of practical training. Subsequently, candidates must be registered with the Compagnie Nationale des Commissaires aux Comptes (CNCC) or Conseil National de l’Ordre des Experts-Comptables (CNOEC) to practice.

As reported by the CNCC and CNOEC, the accountancy education program incorporates the requirements of the 2019 IES including the learning-outcome approach to IPD requirements:

• Incorporated in the new route of validation of acquired experience (“VAE”). The “VAE” is effective for the Bachelor and Master levels (“DCG” and “DSCG”) and is effective as of 2019 for “DEC;”
• Integrated as part of the next accounting syllabus reform (2019–2020).

CNCC and CNOEC members are required to complete 120 hours of continuing professional development (CPD) over a 3-year rolling period. For statutory auditors, the High Council for Statutory Audits (H3C) defines the general guidelines and the key areas for CPD fulfillment and ensures compliance with these requirements. The H3C has delegated CPD monitoring responsibilities to the CNCC. If statutory auditors are members of both institutes, the organizations take steps to ensure there is no duplication of CPD obligations.

The CNCC and CNOEC report that the education requirements in place for all professional accountants meet the revised 2019 IES requirements.

Current Status: Adopted

National legislation in France transposes the Audit Directive and Regulation (EU) No. 537/2014. Auditing standards for statutory auditors are prepared and drafted by a joint commission of the Compagnie Nationale des Commissaires aux Comptes (CNCC) and the High Council for Statutory Audits (H3C), the audit oversight authority. The H3C subsequently adopts the drafts as standards of professional practice, after receiving an opinion on the standards from the CNCC. The Ministry of Justice is ultimately responsible for endorsing the standards at the end of this process. The standards are based on the ISA with national add-ons to include specifics of the French law. The CNCC indicates that the application of ISA for statutory audits will be subject to their direct adoption at European level by the European Commission.

The CNCC reports that it translates ISA in collaboration with the Belgian Institut des Réviseurs d’Entreprises (IRE) for transposition to the “Normes d’exercice professionel”. The 2020 IAASB Handbook is available in French.

In addition, in accordance with the Ordinance No. 45-2138 of 1945, the CNOEC has responsibility for drafting standards for contractual audits and reviews of historical financial information, and other assurance and related services engagements, with approval from the Ministry of Economy, Finance and Budget. The standard-setting framework draws on international standard-setting provisions issued by the IAASB. The CNOEC indicates that the standards for contractual audits are the translated ISAs applicable as of July 2019 and the standard for auditing financial statements in a SME applicable since July 2017.

Current Status: Partially Adopted

The Ministry of Justice (MoJ) has responsibility for adopting ethical requirements for statutory auditors. The Code of Ethics was first published in 2005 and subsequently amended in 2008, 2010, 2017 and 2020. Before its publication, the MoJ consults the oversight authority for the audit profession, High Council for Statutory Audits (H3C) and the securities market regulator, the Autorité des Marchés Financiers (AMF). As reported by the CNCC, the Code of Ethics for statutory auditors is not based on the IESBA Code of Ethics, but its requirements are considered to be as stringent as those of the IESBA Code.

The Conseil National de l’Ordre des Experts-Comptables (CNOEC) is responsible for drafting ethical requirements and the Ministry of Economy and Finance for their approval, in accordance with the Ordinance No. 45-2138 of 19 September 1945.

The Code of Ethics for chartered accountants was approved and published in the Decree 2012-432 of 30 March 2012. The Code of Ethics cannot be directly compared with the IESBA Code of Ethics, due to its different structure and inclusion of additional provisions. While the intent of the French Code of Ethics for chartered accountants and the IESBA Code are similar, a strict alignment and comparison is not easily feasible.

Current Status: Partially Adopted

The Public Sector Accounting Standards Council (Conseil de Normalisation des Comptes Publics (CNOCP), an advisory body under the authority of the Ministry of Public Accounts, is responsible for establishing public sector accounting and reporting standards in France. The CNOCP issues prerequisite recommendations on the general accounting principles applicable to the public sector in France

As reported by the Compagnie Nationale des Commissaires aux Comptes (CNCC) , IPSAS have not been adopted in France and indicated that the CNOCP has concluded that it will not adopt IPSAS after an analysis developed in 2014; however, they are considered as one of the references for establishing standards. The standards are different for central government, local governments, and social security agencies but they are all accrual-based standards.

The CNCC reports in its SMO Action Plan that it has assisted the CNOCP in the translation of the 2018 IPSAS Handbook.

Current Status: Not Adopted

In France, the Commercial Code establishes a mandatory investigative and disciplinary (I&D) system for statutory auditors. With the implementation of the EU Audit Directive 2014/56 and Audit Directive and Regulation (EU) No. 537/2014, the High Council for Statutory Audits (H3C), the audit oversight authority, is responsible for I&D processes for statutory auditors. The H3C recruited an independent prosecutor who oversees conducting investigations together with a team of five persons.

The appeal to the decisions of H3C takes place before the Supreme Court (Conseil d’Etat).

Sanctions are published once they are made anonymous or can be fully consulted at the regional disciplinary chamber. The list of the possible sanctions is limited and defined by the legal framework.

The CNCC conducted an assessment of H3C’s I&D policies and processes against the best practices of SMO 6 and identified a few areas for improvement, such as having a timeframe for disposal of all cases and an independent review of complaints.

For chartered accountants, the Conseil National de l’Ordre des Experts-Comptables’ (CNOEC) regional disciplinary chambers established by Ordinance No. 45-2138 of 19 September 1945 are fully integrated into the French judicial system and are composed of two elected accountants from the Conseil régional de l'Ordre des experts-comptables (CROEC - Regional Council of the Order of Chartered Accountants) and a magistrate from the judiciary. The Government Commissioner (or his representative) to the CROEC represents the supervision of the profession.

An appeal against a decision by a regional disciplinary chamber is made to the National Disciplinary Chamber, which is composed of two elected accountants from the CNOEC and a magistrate from the judiciary. Subsequently, any appeals against the decisions of the National Disciplinary Chamber are made to the Supreme Court (same as appeals from the H3C).

The CNOEC reports that the Regional Chambers of Discipline processes fulfill the best practices of SMO 6.

Current Status: Partially Adopted

French accounting standards are developed and adopted by the Accounting Standards Authority (ANC), created by Ordinance No. 2009-79 and Decree No. 2010-56.

In accordance with the EU statutory framework, Regulation EC 1606/2002, as transposed into national legislation by the ANC, listed entities are required to apply EU-endorsed IFRS Standards for consolidated financial statements. In addition, all other companies are permitted to apply IFRS for their consolidated financial statements. However, entities are not permitted to apply IFRS for the preparation of their individual financial statements. These must be prepared in accordance with French accounting standards (French GAAP).

The ANC has concluded that there is no demand for the IFRS for SMEs in France as French GAAP is considered fit for purpose.

Current Status: Partially Adopted

Relevant Organizations

• Accounting Standards Authority (ANC)
• Autorite des Marches Financiers (AMF)
• Compagnie Nationale des Commissaires aux Comptes (CNCC)
• Conseil de Normalisation des Comptes Publics (CNOCP)
• Haut Conseil du Commissariat aux Comptes (H3C)
• Ordre National des Experts Comptables (CNOEC)

Relevant Legislation

• Economic Modernisation Act 2008
• Commercial Code of 1964
• Ordonnance no 2016-315 du 17 mars 2016 relative au commissariat aux comptes
• European Commission (EC) Directive 2014/56/EU
• Regulation EC 1606/2002
• Accounting Directive 2013/34/EU

Relevant Publications

• Accountancy Europe, Definition of Public Interest Entities in Europe, November 2019.
• Accountancy Europe, Structure and Organization of the Profession – Key Features – 2020 Update, December 2021.
• AMF, Audit Oversight Arrangements.
• CNCC, The French Statutory Audit – Statutory Auditors Serving the Public Interest, 2014.
• CNCC, SMO Action Plan, October 2022.
• CNOEC, SMO Action Plan, January 2019.
• Jeantet, Martine Samuelian and Dr. Vinzenz bödeker, Heuking Kühn Lüer Wojtek. World Services Group, The Implementation of the 4th AML Directive and the Key Elements.
• International Forum of Independent Audit Regulators (IFIAR), IFIAR 2018 Member Profile – H3C.
• IFRS Foundation, IFRS Application Around the World?Jurisdictional Profile: France, July 2016.
• Mazars, The EU Audit Reform in France 2016.
• Moore Stephens, Doing Business in France 2016.
• Paterson, Iain and Marcel Fink, Anthony Ogus et. al. Economic Impact of Regulation in the Field of Liberal Professions in the Member States. European Network of Economic Policy Research Institutes. Working Paper No. 52. February 2007.
• RSM, A Guide to Doing Business in France, January 2016.