What is the Mission of Statutory Auditors in French Companies?

The mission of statutory auditors (commissaires aux comptes or, commonly referred to as CAC) in France is clearly framed by law. Whether in the form of a classic six-year statutory certification or a shorter ALPE mission for small enterprises, the auditor’s work is aimed at providing reasonable assurance on the reliability of financial statements, while respecting the limits of independence and proportionality.

1. The Classical 6-Year Mission of the CAC: Statutory Certification of the Annual Accounts

When an SARL appoints a statutory auditor, the auditor’s primary duty is to certify that the annual accounts are:

• regular and sincere, and
• provide a true and fair view of the company’s financial performance, financial situation, and assets (Commercial Code, art. L.821-53).

This mission is an obligation of means: auditors are not expected to verify every transaction in detail, nor to guarantee the absolute absence of error (Cass. com., 23 June 2015). Instead, their responsibility is to use professional judgment, supported by audit standards, to provide reasonable assurance.

a. Permanent Oversight

Auditors carry out a permanent mission, which includes:

• verifying accounting values and documents,
• checking compliance of the company’s accounts with applicable rules,
• ensuring consistency and sincerity between financial statements and information presented in management reports or documents sent to shareholders,
• and, where relevant, validating consolidated accounts at group level.

b. The Audit Report

At the general meeting, the statutory auditor issues a report that may:

• certify the accounts without reservation,
• certify with reservations,
• refuse certification, or
• state an inability to certify.

In the last three cases, the auditor must explain the reasons. Interestingly, even if the auditor refuses certification, the shareholders may still decide to approve the accounts. Courts have also clarified that a temporary refusal is not wrongful if based on legitimate doubts about a specific operation (Cass. com., 18 Feb. 2014).

c. Consolidated Accounts

If the company prepares consolidated accounts, auditors must also certify that these accounts give a true and fair view of the group’s assets, financial situation, and results. This certification is based partly on the work of auditors within the group subsidiaries.

The auditor’s report on the annual accounts must be filed at the company’s registered office at least 15 days before the general meeting (Commercial Code, art. R.225-83).

2. The ALPE Mission: A Tailored Audit for Small Enterprises

The PACTE Law of 2019 introduced a new form of statutory audit for small enterprises: the ALPE mission (audit légal petite entreprise). This three-year mission provides a lighter audit framework, adapted to the size and complexity of small businesses.

Two professional practice standards apply:

• NEP 911: governs the ALPE mission (3 years),
• NEP 912: governs the classic audit mission for small enterprises (6 years).

Comparison Between ALPE and Classic Audit in Small Enterprises

When Does the ALPE Mission Apply?

The ALPE mission may be applied in four main scenarios:

1. Voluntary appointment of an auditor by the shareholders or the general meeting.
2. Mandatory appointment by a company that heads a “small group” (see small group rules).
3. Mandatory appointment by a company controlled by the head of a small group and exceeding the thresholds 2.5 / 5 / 25 (balance sheet / turnover / employees).
4. Appointment following a minority shareholder request representing at least one-third of the capital.

In addition, a transitional regime applied for auditors already in place at the time the PACTE law entered into force.

Note: If the company’s articles of association stipulate a six-year mandate, the ALPE mission cannot be used unless the statutes are amended accordingly (CNCC, EJ 2019-64).

Proportionate and Adapted Audit

The ALPE mission is built on proportionality: auditors adapt the nature, timing, and scope of audit procedures to the size and complexity of the company.

• For consolidated accounts, auditors rely on NEP 600 (audit of consolidated accounts), adapted to the entity’s characteristics.
• The aim is to provide reasonable assurance that the accounts are free from material misstatements.
• Auditors must document their work, proportionately to the entity’s size, and record both verbal and written communications with company bodies (NEP 911, §§ 54–56).
• Justifications of assessments may be drafted in simplified form, consistent with the principle of proportionality.

The National Company of Statutory Auditors (CNCC) has also published detailed Q&A guidance on the ALPE mission, clarifying its application to small enterprises.

Key Takeaway

Statutory auditors in SARLs can intervene under two main frameworks:

• The classic six-year mission, which provides long-term oversight and applies proportionately to larger or more complex entities.
• The ALPE three-year mission, specifically tailored for small enterprises, with reduced but proportionate requirements.

Both missions maintain the same level of assurance (“reasonable assurance”), while adapting the scope and depth of procedures to the company’s reality.

This dual framework reflects the legislator’s intention to make statutory audit both rigorous and proportionate, ensuring that companies of all sizes can benefit from reliable financial oversight without being burdened by disproportionate obligations.

3. Expanded Missions and Services of Statutory Auditors in French SARLs

The role of the statutory auditor (commissaire aux comptes, CAC) has traditionally been focused on the certification of financial statements. However, the PACTE Law of 2019 significantly broadened their scope of action, allowing auditors to provide new types of services while preserving their independence.

a. A Broader Scope Under the PACTE Law

The PACTE Law introduced two major changes:

• Statutory auditors may now provide additional services and attestations, either within or outside their legal certification mission, provided they respect the Commercial Code, European regulations, and the code of ethics.
• The law abolished several prohibitions on non-audit services for companies that are not public interest entities (non-PIEs).

This reform has opened the door for auditors to offer contractual audits, diagnostic missions, recommendations, and attestations that were previously restricted. The National Company of Statutory Auditors (CNCC) has analysed 18 new missions, confirming that many are compatible with legal certification, provided safeguards are in place to protect independence.

b. The Impact of the CSRD Directive

From 1 January 2024, the European Corporate Sustainability Reporting Directive (CSRD), part of the EU Green Deal, has introduced a new reporting obligation.

• More than 50,000 companies across Europe must now publish a sustainability report on their ESG and CSR policies.
• This report must be verified by an authorised auditor, such as a statutory auditor.
• SMEs, even if not directly in scope, will also feel the impact, as larger groups will require them to provide reliable CSR data for the supply chain.

This new mission places statutory auditors at the heart of sustainability reporting verification, extending their role beyond financial statements.

c. Services Previously Prohibited: New Flexibility for Non-PIEs

Certain services that were once strictly prohibited may now be provided in a non-PIE context, with safeguards:

• If provided directly to the audited entity, such services remain presumed incompatible with statutory certification.
• If provided to a controlled entity not audited by the same auditor, they may be allowed, provided a documented risk analysis demonstrates no compromise to independence.

For non-PIEs, the European directive considers that the implementation of appropriate safeguard measures (such as separation of teams, documentation, or conflict checks) is sufficient.

Guiding Principles

Even with this new flexibility, auditors must always comply with three core principles of the EU Directive:

1. Independence – auditors must remain objective and impartial.
2. No self-review – auditors cannot audit their own work.
3. No interference in management – auditors cannot take part in the company’s decision-making.

These principles ensure that expanded services do not undermine the trust placed in statutory audits.

Key Takeaway

The PACTE Law and the CSRD Directive have transformed the role of statutory auditors in France:

• CACs are no longer limited to certifying accounts.
• They may provide a broader range of services and attestations, as long as independence is protected.
• They now play a central role in CSR and sustainability reporting, reshaping their position in French and European corporate life.

For SARLs and SMEs, this means greater access to statutory auditors’ expertise — not just for financial certification, but also for strategic assurance on sustainability and compliance.