In France, audits aren't limited to public companies. They're mainly triggered by size thresholds. The statutory auditor is called a Commissaire aux Comptes (CAC).
A CAC appointment is generally required when the company exceeds two of the three thresholds below at year-end. These thresholds apply to financial years opened on or after January 1, 2024.
If your French subsidiary exceeds any two of these three criteria, appointing a CAC becomes mandatory. The auditor is appointed for a fixed term of six consecutive financial years.
1. Special rules for controlled subsidiaries (groups)
One point that often surprises US companies is that being part of a group can trigger the audit requirement earlier than the standalone thresholds.
Even if the French subsidiary doesn't meet the general thresholds above, a CAC must be appointed if the subsidiary is controlled by a parent company (for example, your US entity) and the subsidiary exceeds two of the following lower thresholds:
In practice, this means an audit can become mandatory sooner than expected once the French entity sits inside a larger group.
2. Best practice: voluntary audit for governance
Many US-backed scale-ups choose to appoint a CAC voluntarily, even before they hit the legal thresholds, for a few strategic reasons.
Investor confidence
First, investor confidence. An independent French statutory auditor can add credibility and rigor, which often helps with US investor (VC/PE) or lender diligence.
Reporting assurance
Second, reporting assurance. A CAC validates the French statutory accounts (PCG), which typically feed into your US GAAP consolidation process, making group reporting smoother and easier to defend.
3. Conclusion
The best approach is to track these thresholds early, especially in a controlled-group setup, so the audit requirement doesn't catch you off guard.