CNCC details accounts-auditor work when reports carry ESG data

The CNCC has updated its October 2026 frequently-asked-questions document on what publishing sustainability information in the rapport de gestion means for the commissaire aux comptes certifying the accountsCncc. The FAQ covers entities that must publish sustainability information in a separate section of their management report for years opened from 1 January 2024, certified with limited assurance by the accounts auditor, another auditor, or an organisme tiers indépendantCncc — and distinguishes three situations depending on who verifiesCncc.

Even where the audited entity has no sustainability-publication duty, sustainability matters can affect the accounts — asset measurement, useful lives and residual values, provisions, financial instruments, going concern and notesCncc — and the audit work under the normesCncc. Where the entity does publish, the accounts auditor uses that information when gaining knowledge of the entity under NEP 315Cncc, tracks the verifier's progressCncc, and at sign-off reads both the sustainability information and the verifier's conclusions to catch manifest inconsistencies signalling a material misstatement or stale risk assessmentCncc, coordinating with a separate verifier within professional secrecy (articles L. 821-35 and L. 822-2)Cncc.

On timing, the accounts auditor cannot sign a report lacking its conclusion on specific verifications while the issuance deadline has not passedCncc: it waits for the complete management report including sustainability information as approvedCncc. If the complete report arrives too late for the procedures it deems necessary, it draws the consequences on its specific-verifications conclusion and possibly its opinion — for example an observation that late communication prevented verification. A listed company's accounts count as audited or certified only from the report signature date. The sustainability verifier's report is an "other document" outside NEP 9510 control, but connectivity means the accounts auditor should preferably have it before signingCncc; the engagement letter may usefully require it in compatible timeCncc. Where communication with the verifier works and the auditor understands its intended conclusions including subsequent events, judgment may allow signing firstCncc, with any later failure to issue the verifier's report in time reported to the deliberating body, the article L. 821-63 bodies and possibly the AMFCncc. One auditor holding both mandates need not sign both reports the same dayCncc, though simultaneous signature helps for subsequent events: H2A durability guidelines end the verifier's work at its report dateCncc, while NEP 560 §18 governs events the accounts auditor learns of between signature and approval.

For specific verifications, a CSRD-scope entity that appoints a verifier but ultimately publishes no état de durabilité draws a carence report from the verifierCncc, and the accounts auditor flags the irregularity in the specific-verifications part of its reportCncc. Voluntary ESG information from an entity outside CSRD falls under NEP 9510 §§7–10 — sincerity-and-consistency checks for items drawn from or reconcilable to the accounts, plausibility reading for the restCncc — not §11, which covers only information published under articles L. 232-6-3 and L. 233-28-4 or voluntarily under that frameworkCncc. On the meaning of "directly reconcilable" in revised NEP 9510 §11, the update poses the question whether it equals "extracted from the accounts" in §07Cncc, pointing to NI XVIII §4.32.2 — but the answer breaks off mid-sentence in the published text, so no concluded equivalence is statedCncc. What is settled, under revised NEP 9510 (homologated 20 April 2026, Journal officiel 26 April 2026), is that the accounts auditor checks that each significant directly-reconcilable sustainability item agrees with the accountsCncc.

Legal basis: code de commerce articles L. 232-6-3, L. 233-28-4, L. 22-10-36, L. 821-54, L. 822-24 and L. 821-63; NEP 9510 révisée (20 April 2026) §§7–11; NEP 315 §15; NEP 560 §18; CNCC FAQ mise à jour octobre 2026.