For years, companies’ non-financial information was checked fairly lightly, through the French non-financial performance statement (déclaration de performance extra-financière, DPEF). The European Corporate Sustainability Reporting Directive, the CSRD, changed the scale: the companies concerned now publish a sustainability report structured according to European standards, and that report must be certified by a professional registered on a list kept by the French audit oversight authority (Haute Autorité de l’audit). A new profession has thus taken root in firms, between financial audit, environmental and social data and advisory work. This article explains what has changed, who can carry out this assignment, what it actually involves and how a junior can position themselves.
What the CSRD changed for audit firms
Directive (EU) 2022/2464, known as the CSRD, was transposed into French law by the ordinance of 6 December 2023. The report to the President of the Republic accompanying the ordinance sums up the change: the sustainability report replaces the non-financial performance statement and takes its place in a separate section of the management report.
Three changes matter for firms:
- a common framework: information is prepared according to the European Sustainability Reporting Standards (ESRS), which cover the environment (climate, pollution, water, biodiversity, circular economy), social matters (own workforce, workers in the value chain, communities, consumers) and governance;
- a double materiality analysis: the company identifies both the issues that affect it and those on which it has an impact, and publishes only what is material;
- mandatory certification: a statutory auditor or an independent third-party body issues an opinion, on the basis of a limited assurance engagement, in a certification report.
The timetable was staggered according to company size, then postponed by two years for some companies by a 2025 European directive known as “stop-the-clock”, transposed in France the same year. The first companies concerned are already publishing; the next ones will enter the scheme later. For a candidate, this means the profession is real today, but that its volume will depend on how the timetable develops: check the texts in force at the time you read this.
Statutory auditors and independent third-party bodies
The ordinance turned the H3C into the Haute Autorité de l’audit (H2A), responsible in particular for overseeing the professionals who certify sustainability information. According to the FAQ published by the H2A, two categories of professionals may carry out the assignment, provided they are registered on specific lists:
- statutory auditors, registered on the main list and then on the list of “statutory auditors authorised to certify sustainability information”;
- partners, directors or employees of an independent third-party body (organisme tiers indépendant, OTI), registered on the “list of sustainability auditors”, provided the OTI is accredited by the French accreditation committee (COFRAC).
Registration conditions differ according to the date. Professionals already registered or accredited before 2026 were able to benefit from a transitional regime, provided they had taken training approved by the H2A totalling at least ninety hours. For new entrants, the FAQ mentions a professional traineeship of at least eight months and a specific exam on the certification of sustainability information.
In practice, the “profession” of sustainability auditor covers two realities:
- the signatory, registered on one of the lists, who puts their liability behind the opinion issued;
- the teams, made up of financial auditors trained in sustainability, specialists in the environment, climate or social data, and sometimes engineers, who carry out the work.
A junior first joins the second category.
What a sustainability assurance engagement involves
A limited assurance engagement aims to conclude that nothing has come to the auditor’s attention that would call into question the compliance of the information with the applicable requirements. It is less extensive than an audit of financial statements, which aims at reasonable assurance, but it follows a comparable approach. Pending a European limited assurance standard, the H2A has published guidelines describing the work expected.
In practice, the work covers several points:
- the double materiality process: how the company identified its impacts, risks and opportunities, with which stakeholders, and whether the approach is documented;
- compliance with the ESRS: the presence of the required information for issues deemed material, and its consistency with the standards;
- the indicators: greenhouse gas emissions, energy and water consumption, headcount, workplace accidents, pay gaps; tests on source data, reconciliations, review of calculation methods;
- the EU taxonomy disclosures: the share of revenue, capital expenditure and operating expenditure that is aligned;
- consistency with the financial statements: environmental provisions, climate-related impairments, information on transition plans.
The difficulty lies in the nature of the data: it often comes from systems outside accounting (energy management, human resources, purchasing), with internal controls that are less mature than those of the accounting chain.
Skills expected: audit, non-financial data, ESRS
Firms are looking for profiles able to combine three sets of skills.
The audit approach. Risk-based approach, sampling, documentation of work, professional scepticism: this is what distinguishes a sustainability auditor from a CSR consultant. Financial auditors who train in sustainability are therefore in high demand.
Knowledge of non-financial data. Greenhouse gas inventories and their three scopes, social indicators, supply-chain data: knowing where a figure comes from and how it is calculated is essential to test it.
Command of the frameworks. The ESRS, the EU taxonomy and the H2A guidelines form the framework of the engagement; familiarity with international frameworks (GHG Protocol, ISSB standards) is a plus.
Add to that transferable skills: ease with spreadsheets and data-analysis tools, the ability to talk with non-financial contacts (plant managers, HR managers, buyers), and clear writing.
Training and paths to specialise
Several paths lead to this profession.
From financial audit. This is the most natural path: an auditor with a few years’ experience takes their firm’s in-house sustainability training, joins certification engagements and gradually specialises. Firms often organise mixed teams, which makes the transition easier.
From a specialised degree. Master’s degrees in sustainable development, sustainable finance or environmental engineering, supplemented by a solid grounding in accounting and audit, give access to the sustainability teams of firms or independent third-party bodies.
From the chartered accountancy track. Future statutory auditors can include sustainability from their traineeship onwards, by joining certification engagements, and aim eventually for registration on the list of authorised statutory auditors. Our article on what sets a chartered accountant apart from a statutory auditor recalls the path to signing.
From consulting. Consultants who help companies with their first sustainability report sometimes move over to assurance; the reverse is common too. The two professions coexist in large firms, and the article on advisory work in a Big Four firm, its assignments and career paths 🔗 describes the advisory side of these organisations. Beware, however, of independence rules: a firm cannot certify a report it helped to build.
Our overview of audit firms beyond the Big Four helps identify the firms that are developing this activity, often in the regions too.
Showcasing CSR experience on an audit CV
For a candidate, the challenge is to show both an auditor’s rigour and an understanding of sustainability data.
In the summary, name the target role and your dual skill set:
- Before: “Junior auditor passionate about sustainable development.”
- After: “Financial auditor (two years, industrial groups), trained in the ESRS and the EU taxonomy, looking for a position in a sustainability information assurance team.”
In your experience, describe sustainability work as audit work: which indicator, which scope, which tests. For example: “Tested scope one and two greenhouse gas emissions data for 6 industrial sites: reconciliation with energy invoices, review of emission factors, documentation of differences.”
In your skills, separate frameworks (ESRS, taxonomy, GHG Protocol), techniques (double materiality, limited assurance, tests on non-financial data) and tools.
A volunteer role or an internship in a CSR department can count, if described with the same precision. The statutory audit partner CV example shows how a sustainability offering appears on a senior profile, and the IT auditor CV example illustrates another specialism built on financial audit. To build your own, the CV editor handles the layout and produces a PDF readable by firms’ screening software, which often filters on terms such as ESRS or double materiality.
Sources
- European Union, Directive (EU) 2022/2464 on corporate sustainability reporting (CSRD) 🔗.
- Légifrance, ordinance no. 2023-1142 of 6 December 2023 on the publication and certification of sustainability information 🔗.
- Haute Autorité de l’audit, FAQ on the certification of sustainability information 🔗.
Frequently asked questions
Do you need to be a statutory auditor to become a sustainability auditor?
To sign, you must be an authorised statutory auditor or belong to an accredited independent third-party body and be registered on the list of sustainability auditors. To work in the teams, no registration is required.
Can someone without an accounting background enter this profession?
Yes, especially with an engineering background or as an environmental specialist, in the expert teams. A grounding in audit and accounting nevertheless remains an asset for progressing.
Is a sustainability assurance engagement an audit?
It is a limited assurance engagement, less extensive than an audit of financial statements, but it follows a comparable approach: risk analysis, tests, documentation and a report.
Will the profession last despite the timetable postponements?
The postponements delay the entry of some companies into the scheme, but the first companies concerned are publishing and having their information certified. The profession exists; its volume will depend on how the texts evolve.