CNCC: NEP 600R group-audit rules apply to voluntary consolidations

The Compagnie nationale des commissaires aux comptes has published CNP 2026-03Cncc, an October 2026 frequently-asked-questions documentCncc on applying the revised group-audit standard NEP 600R — Audit des comptes de groupe – aspects particuliersCncc, applicable to group-account certifications for financial years opened from 4 November 2025Cncc. The FAQ answers auditors' first questions following the phases of a group audit; the CNCC says the list will grow.

NEP 600R applies to voluntarily prepared consolidated accounts whether published or notCncc. Published voluntary accounts fall fully under the standardCncc, because article L. 233-28 of the code de commerce requires their certification under article L. 821-53 once a merchant publishes them. Unpublished voluntary accounts under a contractual audit are also coveredCncc: under CNCC doctrine (CNP 2021-12), the auditor follows all audit normes except NEP 700, 701 and 702, so NEP 600R applies.

Small groups within article L. 230-2 that voluntarily produce consolidated accounts cannot set NEP 600R aside for NEP 912 aloneCncc: NEP 912 (§13) itself refers the auditor to the group-audit approach, and NEP 600R (§09) covers all group audits regardless of size. The auditor applies NEP 600R with proportionality, adapted to the small group's size and complexity.

For a single legal entity across several establishments, scope turns on how the accounts are prepared. It is in scope where distinct units — separate locations, management or systems producing their own general ledger, such as bank branches whose ledgers are aggregated at head office — feed a consolidation-like aggregation (ISA 600 revised §A4)Cncc, and out of scope where one system records everything centrally with no aggregation, such as a retail chain booking all shops in the same ledgerCncc; analytical accounting per establishment alone does not bring it into scope. A holding company preparing no consolidated, combined or aggregated accounts is outside NEP 600RCncc; if it prepares such accounts subject to legal certification, the standard appliesCncc. Consolidation tiers (paliers de consolidation) meeting the §02 definition of group accounts are coveredCncc: the tier auditor then acts both as component auditor and sub-group auditor where the group auditor treats the sub-group as one component, though certifying the group accounts — including checking the tier auditor's work is sufficient — remains the group auditor's responsibility.

On risk, the starting point changes: the group auditor identifies and assesses the risk of material misstatement and designs the response from the group accounts first — significant transaction classes, balances and disclosures under NEP 315, then procedures under NEP 330 and NEP 600R §§31, 35 — rather than from the contributing entities. Work may cover all components or only some, provided no residual risk of material misstatement remains for each significant item. Responsibilities are unchanged: the group auditor decides on which components work is done; management determines the consolidation scope.

Instructions to component auditors must contain the NEP 600R list — related parties and going concern (§29), group-risk matters (§30), thresholds (§34), matters supporting the group opinion such as work identification, ethics and independence, breaches of law, misstatements above threshold, bias indicators, internal-control weaknesses and communications to the article L. 821-63 bodies (§43), and subsequent events (§48)Cncc. Beyond that the content is for the group auditor's judgment, calibrated to component risks, prior experience, geographic and regulatory distance, and access to working papers. The CNCC provides a template set to adapt; where group and component teams share members, instructions may be less developed.

Legal basis: NEP 600 révisée, homologated 29 October 2025Cncc, applicable to financial years opened from 4 November 2025Cncc; code de commerce articles L. 233-28, L. 230-2, L. 233-16 and L. 821-53; CNCC FAQ CNP 2026-03 of October 2026.