France: Commissaires aux Comptes CPD, 120 Hours Over Three Years

France is the cleanest example in Europe of a Member State taking the unquantified obligation in the EU Statutory Audit Directive and attaching hard numbers to it. For commissaires aux comptes — statutory auditors — the requirement is 120 hours over three consecutive years with at least 20 hours in any one year, and it sits in the Code de commerce rather than in professional guidance. For general professional accountants the position is entirely different, and we cover that separately.

The numbers, and where they come from

The statutory hook is article L. 821-24 of the Code de commerce, in force from 1 January 2024 and formerly numbered L. 822-4. The figures themselves sit lower down, in the arrêté-level articles — article A. 821-45, which states:

La durée de la formation professionnelle continue est de cent vingt heures au cours de trois années consécutives.

Vingt heures au moins sont accomplies au cours d’une même année.

So: 120 hours across three consecutive years, with a floor of 20 hours in any single year. The three-year period is rolling, and the regulator refers to it as a période triennale — 2021 to 2023, for instance.

The originating instrument is the Arrêté du 19 décembre 2008 relatif à la formation professionnelle des commissaires aux comptes. It was amended by the Arrêté du 20 février 2018, applicable from 1 March 2018, and then renumbered and recast by the Arrêté du 28 décembre 2023, published in the Journal officiel of 31 December 2023. That recast is why older references cite articles in the A. 822-28 series: the same provisions now live in the A. 821 series.

Who supervises it, and a naming trap

The regulator is the Haute autorité de l’audit (H2A), which until recently was the Haut conseil du commissariat aux comptes (H3C). The renaming was effected by Ordonnance n° 2023-1142 du 6 décembre 2023. Material written before 2024 will refer to the H3C throughout; it is the same body.

Day-to-day monitoring is delegated to the Compagnie nationale des commissaires aux comptes (CNCC) under an agreement signed in April 2017 and approved by the garde des Sceaux the following month. One point worth flagging because it circulates in error: it is the Compagnie nationale, not the Conseil national. At least one widely-read secondary source renders it as “Conseil national”, and that is wrong.

Declaring it: 31 March, on Aglaé

Auditors declare the previous calendar year’s training to the CNCC by 31 March, with supporting documents, through the CNCC’s Aglaé platform. The regulator’s decision on declaration modalities requires the filing by 31 March of year N for training completed during calendar year N-1.

What gets declared for each action is granular: the auditor’s name, the activity type, the completion date, the duration as shown on the attendance record, the title, the organising body, any technical-committee or regional-compagnie office held, and a classification against one of the regulator’s general orientations plus a subject domain.

Supporting documents must be kept for six years. The regulator’s decision states it plainly — Leur durée de conservation est fixée à six années — and the Code de commerce carries the same rule at article A. 821-52.

Newly registered auditors: a separate 40 hours

A newly registered commissaire aux comptes owes a formation continue particulière of 40 hours. The regulation is explicit: La formation continue particulière prévue à l’article L. 822-4 est de quarante heures.

The sequencing is relieved in the first year. According to the Ordre’s regional guidance, the 20-hour annual minimum is relaxed in the year of registration, the annual obligation begins the following calendar year, the triennial obligation the year after that, and first-year training is excluded from the triennial count.

There is no ethics minimum — and that surprises people

France sets no mandatory hours for ethics, or for any other single subject. Article 7 of the Code de déontologie requires competence to be maintained but attaches no figure. The regulator publishes priority themes — for 2024 and 2025, two professional standards on securing the auditor’s engagements — without attaching hours to them.

One figure to handle carefully: the regulator reported that ethics, independence and organisation made up 9.66% of declared training activity in 2023. That is a statistic describing what auditors chose to do, not a requirement. It is occasionally repeated as though it were a quota, and it is not.

Activity caps instead of a verifiable/unverifiable split

France does not use the verifiable-versus-unverifiable distinction familiar from English-speaking jurisdictions. Instead, article A. 821-46 enumerates the permitted categories of activity and attaches a separate cap to each, and every declared action must be supported by a justificatif.

We are not reproducing the cap table here, and the reason is worth stating. Three different vintages of that list are in circulation. The CNCC’s own 2023 guide, written under the old numbering, gives colloquia and conferences at 40 hours, designing or leading training at 40, publications at 30 and participation in technical work at 32. One of the Ordre’s regional sites gives conferences at 45, course design at 20, publications at 30 and technical work at 20 per year. Against the current Légifrance text we could confirm only two figures: 45 hours over three years for colloquia and conferences, and 30 hours over three years for publications. If you need the full list, read A. 821-46 directly rather than relying on any secondary table, including ours.

Sustainability auditors: a separate, annual obligation

France has created a third category, the auditeur des informations en matière de durabilité — sustainability information auditor. The requirement is 20 hours per calendar year under Code de commerce article A. 822-18, declared to H2A directly rather than to the CNCC. Note that this one is annual, not triennial.

There is also a transitional initial-competence requirement of at least 90 hours of regulator-approved training, which also counts toward the ordinary annual and triennial minimums. Both figures come from the regulator’s own 2024 decision on orientations; we did not read them in a codified article, so treat them as regulator-attested rather than gazette-verified.

The same decision notes that the EU limited-assurance standard for sustainability was to be adopted by 1 October 2026 at the latest, and that the reporting standards themselves remain incomplete — so sustainability training content in France is a moving target rather than a settled syllabus.

How this compares

France chose to put a number where the directive sets none, and to back it with a declaration deadline, a retention rule and a sanctions route. That is at one end of the European range. At the other sits Germany, whose statutory transposition is a single sentence with no figure at all. The EU directive behind all of these national regimes explains why the spread is so wide, and our guide to statutory auditor CPD in Ireland covers a neighbouring regime with its own approach. For the international framework these national rules sit above, see where accountant CPD requirements come from.

Frequently asked questions

How many CPD hours does a French commissaire aux comptes need? 120 hours over three consecutive years, with at least 20 hours in any one year, under Code de commerce article A. 821-45.

When is the declaration due? 31 March each year, to the CNCC via the Aglaé platform, covering the previous calendar year.

How long must records be kept? Six years.

Is there an ethics quota? No. France sets no mandatory hours for ethics or any other single subject.

Do the same rules apply to experts-comptables? No — and the difference is substantial. There is no hours figure in French law for experts-comptables at all.

Meet your French CPD obligations with Learnsignal

Practitioners holding both a French audit registration and an international qualification are managing more than one rulebook, and the declaration mechanics differ as much as the hours do. Our CPD courses are built for finance professionals working across jurisdictions. The Code de commerce articles cited here are published on Légifrance.