France – CSRD Sustainability Certifier Disclosure Requirements Take Effect

France has introduced a new filing requirement for companies subject to the Corporate Sustainability Reporting Directive (CSRD), requiring the identity of the individual or organisation responsible for certifying sustainability information to be formally registered. The information must be recorded with the Trade and Companies Registry (RCS) and the National Register of Enterprises (RNE), further strengthening transparency around sustainability reporting and assurance.

The requirement forms part of France’s implementation of the CSRD framework and is intended to improve the traceability and accountability of sustainability reporting by ensuring that the assurance provider responsible for reviewing sustainability disclosures is formally identified within public registration records.

Regulatory Background

As sustainability reporting requirements continue to expand across Europe, companies within the scope of the CSRD must appoint an approved assurance provider to review and certify their sustainability information.

The new French filing requirement obliges affected companies to formally disclose the identity of that assurance provider as part of their corporate registration information.

The measure took effect on the 6^th of May 2026 and applies whenever a relevant filing or declaration is made with the RCS and RNE.

By requiring the identity of the certifier to be formally recorded, the regulation aims to enhance transparency and provide greater visibility over who is responsible for the assurance of sustainability disclosures.

Applicability and Scope

The filing requirement applies to companies that are subject to mandatory sustainability assurance obligations under the CSRD.

These entities must appoint either:

• A Statutory Auditor; or
• An independent assurance provider

to perform sustainability assurance engagements and certify the company’s sustainability information.

Companies currently within the scope of the CSRD in France include:

• Large listed companies with more than 500 employees (since 2024)
• Large non-listed companies exceeding at least two of the following thresholds: 250 employees, €50 million turnover or €25 million balance sheet total (since 2025)
• Listed SMEs (from 2026)

Companies within scope should review their sustainability reporting arrangements and ensure the required assurance provider information is accurately reflected in future filings.

Filing Requirements and Compliance Process

Entities that fall within the scope of the requirement should undertake a review of their sustainability reporting obligations and identify the individual or organisation responsible for providing assurance.

The process will typically involve:

• Determining whether the company falls within the applicable CSRD thresholds
• Confirming the identity of the Statutory Auditor or independent assurance provider responsible for sustainability assurance
• Collecting the relevant registration information
• Ensuring the required information is included in filings submitted to the RCS and RNE

The decree does not introduce a separate filing deadline. Instead, the requirement applies whenever the relevant company filing or declaration is submitted to the registries.

Practical Considerations

Companies may wish to review their sustainability governance processes to ensure responsibility for sustainability assurance is clearly documented and aligned across legal, compliance and reporting teams.

As sustainability reporting obligations continue to evolve, maintaining accurate registry information will become increasingly important in demonstrating compliance with CSRD requirements.

Companies should also ensure any future changes to their appointed assurance provider are reflected in subsequent corporate filings where required.

Risks of Non-Compliance

The decree does not introduce new standalone financial penalties relating specifically to the certifier disclosure requirement.

However, incomplete, inaccurate or missing information may result in administrative complications relating to registry filings and could lead to filing delays, deficiencies or rejection of submissions under the existing rules that govern RCS and RNE registrations.

How Mercator® by Citco (Mercator) Can Help

Mercator can assist with:

• Assessing whether a company falls within the scope of the CSRD assurance requirements
• Reviewing sustainability reporting obligations
• Identifying the appropriate assurance provider information required for filing
• Coordinating updates to corporate registration records
• Preparing and supporting RCS and RNE filings
• Assisting with ongoing compliance obligations as reporting requirements evolve

For assistance, please contact [email protected]