COMPAGNIE NATIONALE DES COMMISSAIRES AUX COMPTES
CNCC
La Compagnie nationale des commissaires aux comptes (CNCC) est l'instance représentative de la profession des commissaires aux comptes en France.
ID: 829786043094-93
Lobbying Activity
Response to EU taxonomy - Review of the environmental delegated act
4 Dec 2025
Please see the attached response from the Compagnie Nationale des Commissaires aux Comptes (CNCC), the French institute for statutory auditors.
Read full responseResponse to Digital package – digital omnibus
9 Oct 2025
La Compagnie nationale des Commissaires aux comptes (CNCC) would like to comment as follows: With regard to the AI Act, CNCC fully supports this important piece of legislation. Artificial intelligence, in its current guise as Large Language Models, and even more so in the future, with the potential rise of General Artificial Intelligence and its ensuing consequences is a development that is too serious for its regulation to be left to a handful of large private non-European multinationals. The stakes are too high and the possible adverse impacts of AI on our liberal democratic institutions and the lives of European citizens are too tremendous for not keeping safeguards and guardrails against the misuse and intrinsic brittleness of these new transformative technologies. Europe has been a pioneer in AI regulation, and it is interesting to note that just last week California followed the example by voting a similar law, although slightly less ambitious. It is therefore vital that this valuable acquis be preserved and protected against any onslaught, whether external or internal. We further note in the context of the current debate around simplification, that the onus of the burden regarding the AI Act rests mainly on the providers of AI systems and General Purpose AI models, much more than on the corporate deployers. Users have the obligation to abstain from models the use of which is prohibited; with respect to the high-risk categories of use, these are monitored and partially restricted only where they would infringe on the fundamental rights of citizens and, accordingly, it appears to us that such restrictions are legitimate and well founded. One important matter that we wish to emphasize - and to which we drew attention in our past interactions with the Commission, is the need, not only for AI algorithms to be fully transparent, but also for the output produced to be understandable and traceable, whenever the output generated by AI systems is information that is in the public interest, such as e.g. financial or sustainability information for which there is a legal obligation of audit. Although we are aware that having fully transparent output is a challenging issue technically speaking, it is vital in order to create an audit trail which allows independent auditors to trace information back to its sources. It is equally important to remember that for financial markets to function smoothly, investors and citizens must trust the information that corporates generate and auditors report on. Finally, in order for the AI Act to work as intended, it is crucial that the regulators speed up the pace to develop and finalize the norms referred to by the IA Act. We understand that as of today, such norms have not been developed yet, and the deadline of February 2026 is approaching. This situation could be highly detrimental to the proper implementation of the AI Act and hence jeopardize the effectiveness and credibility of the regulation.
Read full responseMeeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and PwCIL and
21 May 2025 · Developments as regards CSRD implementation and legal update
Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur)
27 Mar 2025 · Omnibus
Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur) and Association Française de la Gestion financière
27 Mar 2025 · Omnibus I
Meeting with Martin Merlin (Director Financial Stability, Financial Services and Capital Markets Union) and EURALIA
27 Mar 2025 · Exchange of views on the recent omnibus simplification proposals as regards the CSRD and the expected effect of these proposals on the audit and assurance sector
Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)
24 Feb 2025 · Omnibus
Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)
5 Feb 2025 · Introductory meeting to discuss the sustainable finance framework
Meeting with Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné)
27 Jan 2025 · Simplification of sustainability reporting
2 Oct 2023
Response from the French Institute of Statutory Auditors (Compagnie Nationale des Commissaires aux Comptes CNCC) to the Commission delegated Directive amending Directive 2013/34/UE as regards the adjustments of the size criteria for micro, small, medium-sized and large undertakings or groups See attached file for a complete answer. 1 The negative impact on the sustainable transition of the economy We as auditors understand the difficulties certain companies are facing to provide from Day 1, reliable sustainability reporting at the level of both completeness and granularity required by the CSRD and the ESRSs. Instead of simply exempting those companies by raising the thresholds, we suggest to favour a continuous improvement approach towards CSRD implementation - such as we have discussed and agreed with the French audit regulator - in order to get as many businesses as possible onboard with sustainable reporting and the transition towards ESG. Rather than expecting a big bang approach under which corporates would be expected to get every single detail of CSRD reporting right from the start, we are conscious that companies will embark on a journey and will be on a learning curve for some years. We are ready and willing to accompany and support corporates in their efforts to navigate the complexities of sustainability reporting. In this context and in order to support this effort, it would be helpful if the Commission launched a reflexion on how to introduce more proportionate requirements for such midsize companies rather than excluding them altogether from CSRD reporting. Sustainability reporting, when audited, has the potential to be a competitive advantage for the EU economy in comparison to other markets. CSRD, SFDR, CSDDD and other legislative initiatives are also meant to accrue certain benefits to companies by directing green investments towards ESG activities and help innovative and/or sustainable SMEs to get funding through the capital markets. By reducing the scope of both financial and ESG reporting, the draft delegated act would also reduce the number of companies eligible for market funding and fast growth. Finally, we would like to highlight the negative message the proposed delegated act would represent for companies, now and for the future. The delegated act would reduce the scope of the CSRD less than a year after its publication in the Official Journal and only a few weeks before the beginning of the financial year of its implementation. Many of the national transposition measures are already taken and on the verge of formal publication. 2 The risk for small and medium sized companies financial health and subsequently for the real economy The current economic situation high economic uncertainty coupled with persistent geopolitical risks and high inflation calls for strong monitoring and supervision of companies across the EU to prevent business failures and contagion risks. Moreover, inflation impacts businesses in various ways. For many of them, inflation has increased more in proportion to the costs incurred by companies rather than to their net sales turnover. The suggested size-criteria adjustment thus might exclude a certain number of companies from sharing reliable financial accounts with their stakeholders at a time where their stakeholders would need it the most. Many of the companies excluded would be large SMEs which are key components of the value chains of larger corporates whose failure to obtain reliable sustainability information from their contractors could have an adverse impact upon their own ability to report reliable sustainability information in accordance with CSRD. In this context, downgrading the criteria for determining small and medium-size companies does not appear as the pragmatic choice to ensure the resilience of the economy in the long-term, because it will remove from the radar screen, those that need it most.
Read full responseResponse to European Sustainability Reporting Standards
7 Jul 2023
The CNCC, the French Institute of Statutory Auditors, welcomes the draft delegated act on the first set (Set 1) of ESRS. We applaud the considerable work carried out since the previous public consultation on the April 2022 Exposure Drafts, first by EFRAG and then by the EC, under very tight deadlines. We believe the ESRS have now reached an appropriate level of quality to efficiently support transparency and the ambition of the Green Deal. We commend the pragmatic approach adopted in preserving the integrity of EFRAG's work while listening to companies' concerns about the difficulties of implementing the ESRS. We consider that the changes proposed to ESRS overall address many of our concerns expressed last year in our answer to EFRAGs consultation, i.e. the need to review the overall volume and complexity of the disclosure requirements and the need for further phasing-in. We therefore fully support: (a) the extension of the scope of materiality assessment, with only the disclosure requirements in ESRS 2 being mandatory. This should foster relevance of sustainability reporting; (b) the introduction of new transitional measures, considering the overall demanding first-time application calendar set by the CSRD; and (c) the efforts to ensure that ESRS are sufficiently proportionate, notably through the conversion of some mandatory datapoints into voluntary ones, especially in ESRS E4 Biodiversity and ecosystems and ESRS S1 Own workforce, which are two standards whose prior drafts were the cause of much concern. We note that the interoperability of the ESRS with IFRS Sustainability Disclosure Standards could still be improved. This is key to avoid possible dual reporting for EU and non-EU companies that want to claim compliance with both frameworks. Though we welcome the changes made to ESRS 1 General Requirements about financial materiality, we regret that the alignment with IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information is not obvious. We believe that the description of what is material financial information should be aligned. We also believe that, once the Set 1 of ESRS is finalised, other EU sustainable finance regulations should be reviewed (SFDR, EBA Pillar 3). This is because consistency between them is critical. We observe some misalignment which is a source of significant concern in the financial sector and which needs to be addressed. The ESRS now set what is the relevant information to be provided by companies for sustainability reporting under the CSRD. It would be contrary to the objective laid out for the ESRS if financial market participants were to ask companies additional information that is not required by the standards (e.g. because it is assessed to be not material), to enable them to satisfy their own reporting obligations. To ensure the consistent application of the ESRS, we also encourage the EC and EFRAG to set up an organisation to provide implementation support, with appropriate stakeholders engagement and due process. As a matter of priority, additional guidance and educational material, addressing the materiality assessment process and value chain information, should be published as soon as possible. Overall, we expect that, despite the further transitional provisions in the ESRS, many companies will face significant challenges in implementing the standards in their first years of reporting. This will likely require greater than normal work for statutory auditors in order to be able to deliver their conclusions on the assurance of the sustainability reporting. Furthermore, the EC and stakeholders should acknowledge that there will inevitably be a learning curve from all parties, and that the quality of reporting will improve over time, notably with the help of statutory auditors. Please find attached our further analysis and comments to be considered in finalising the delegated regulation.
Read full responseMeeting with Stéphanie Yon-Courtin (Member of the European Parliament, Shadow rapporteur) and Insurance Europe
29 Mar 2023 · Solvabilité II
Response to Revision of Non-Financial Reporting Directive
7 Jul 2021
Dear Commissioner,
As President of the CNCC, the French institute of statutory auditors, I wish to express the overall support of the French profession to the Commission’s proposal for a Corporate Sustainability Reporting Directive (CSRD), including the development of European sustainability reporting (SR) standards by EFRAG.
1. This is because of:
a. The importance of SR to investors but also to Society as a whole (we support information to be prepared using the double materiality concept)
b. The need for the EU to measure transition to a sustainable economy and to achieve the challenge of the Green Deal, as well as implementing the SFDR and Taxonomy regulations.
2. We believe that SR will become as important as financial reporting and that there is a need for better comparable and reliable information.
3. Therefore, we need robust SR standards to prepare the information and assurance on the information.
4. There is also the need for, and we support, the CSRD enhanced role and responsibility of the entity’s governance in the preparation of the SR.
5. We welcome the proposal to give statutory auditors a central role for assurance on SR. This is consistent with the increasing interconnectivity between financial and sustainability reporting.
6. It will not be achieved without significant investment from our profession (recruitment, education, methodology, standards, etc…) but we stand ready to take up the challenge, having experience of providing such an assurance for many years in France.
7. If Member States elect to allow other assurance providers to be accredited to provide assurance on SR, it is important to ensure the same level of quality. Accordingly, we welcome the CSRD proposals that other assurance providers be subject to the same requirements as the statutory auditors in terms of:
a. Independence (code of ethics and appropriate control by supervisor)
b. Quality (which comprises both competence and quality control systems)
c. Supervision
8. Due to the challenging timetable and efforts for both companies and auditors to adapt, we agree with requiring as a first step limited assurance, transiting to reasonable assurance at a later stage.
9. We recommend that, as long as the EC has not adopted a common assurance standard for SR, a strong coordination takes place at EU level between the local institutes, assurance standard-setters and supervisors, to ensure a level-playing field (through consistency of work effort required) and quality for SR assurance across the EU.
10. We believe the SR assurance standards in Europe should be based on recognised international standards and guidance, for instance those of the IAASB.
11. The proposed CSRD is unclear about the requirements that would apply for statutory auditors for the SR assurance, where there is joint audit for financial reporting (a requirement in France).
12. We agree with the proposed CSRD scope, and the possibility given to SMEs to provide sustainability information on a voluntary basis and in a proportionate way (i.e., the development of SME SR standards).
13. We recommend to clarify whether listed subsidiaries (that are not micro-undertakings) should benefit from the proposed exemption from publishing a SR, when part of a group that provides such a SR.
14. We agree with the digitalisation of sustainability information, but we caution about the challenge it represents. From experience, ESEF still represents a huge implementation challenge. So, we recommend a dedicated project involving the stakeholders affected.
15. Finally, it is crucial that both the yet to be formed European and international sustainability standard-setters work constructively together to avoid unnecessary divergence. We support a global baseline for SR to be used consistently throughout the world, to be complemented as appropriate to meet public policy local needs. Europe has a leading role for SR and it should share its knowledge and experience with the rest of the world.
Read full responseMeeting with Claude Bocqueraz (Cabinet of Commissioner Mairead Mcguinness)
30 Jun 2021 · CMU/Audit & Sustainable Finance