Samuel RUTIL, graduate of Sciences Po Grenoble - UGA (2025), financial auditor
SébastienGAND, lecturer at Sciences Po Grenoble - UGA and researcher at CERAG, UGA
On January 5, 2023, the French State Audit Office (Cour des Comptes) published the final report on the experiment to certify the accounts of local authorities that has been underway since 2016. Provided for under Article 110 of the NOTRé law, this experiment involved 25 volunteer local authorities of varying sizes and status, in a certification process inspired by practices already in force for the State, public health establishments and universities. The aim was to assess the possibility of opening up the certification of local public accounts to the private sector, in this case to statutory auditors. The verdict was clear: although technically feasible, the generalization of this approach was ruled out. As a result, France remains one of the few European Union countries not to have established a system of local certification by private auditors.
This French exception raises questions. Not because the reform is materially unfeasible - on the contrary, reports by the Cour des Comptes and feedback from experience show that it can make a real contribution to structuring the financial function, improving internal control and making accounting entries more reliable. But because neither institutional nor political dynamics seem to be in a position to make it an object of transformation for local governance. A comparison with Italy, where local auditing was entrusted to private professionals in the 1990s within a stabilized legislative framework, sheds light on the reasons for this divergence.
Methodology: qualitative research was carried out to shed light on the French exception in a comparative way. It is based on fifteen semi-structured interviews with French and Italian players involved in the certification of local public accounts, supplemented by a documentary analysis of public reports, scientific articles and legal texts in both countries.
The results are derived from a thematic analysis inspired by Braun and Clarke (2014) mobilizing Kingdon's (1984) Multiple Streams Framework (MSF) conceptual framework. Codes were identified inductively from verbatim and documents, then organized according to the three MSF streams. This approach enabled the structuring dynamics of each national context to emerge.
A reform absent from the French political agenda
In France, the issue of certification of local accounts remains largely confined to a debate between experts. Neither local elected representatives, nor the media, nor public opinion have taken up the issue. A magistrate at the Cour des Comptes admitted to the survey: "It's not a big political issue at national level. It remains a specialist debate specific to the local world". The subject is technically complex, has little political value and is difficult for citizens to understand.
This marginalization is also due to an administrative culture in which the budget, and not the annual accounts, remains the cornerstone of local management. As one finance director explains, "the accounting sphere is often considered the poor relation". However, "if the accounting is not good, any financial analysis becomes a sandcastle". In this world, external certification is often misunderstood, confused with legality control, grading or even validation by the public accountant, who provides no assurance as to the accuracy of the accounts.
IT tools and professional standards unsuited to widespread use
The experiment took place in an unstable normative and technical environment. The compendium of certification standards, drawn up by the Conseil de normalisation des comptes publics (CNoCP), was not published until 2021, five years after the launch of the experiment. As a former head of department, now a member of the CNoCP, points out: "It was quite complicated, because the compendium of standards didn't exist at the start of certification".
IT tools are also inadequate. The HELIOS national information system, used by the DGFIP (Direction Générale des Finances Publiques), does not allow automated extraction of entries. The absence of accounting entry files, which are required in the private sector, severely limits analysis possibilities. The local accounts quality indicator (IQCL), developed to objectivize the reliability of accounts, was abandoned after showing its limitations: some local authorities rated very favorably had their certification refused, revealing a systemic bias. "The DGFIP may have used the systems to make people believe that everything was working well," says a magistrate at the Cour des Comptes.
Statutory auditors, for their part, face a twofold difficulty: on the one hand, professional standards designed for the private sector are difficult to transpose to the local context, particularly when it comes to certifying tax receipts, and on the other hand, there is a lack of Education specific to public accounting, which is still absent from public accounting curricula.
A reform rooted in Italy's crisis
In contrast to the situation in France, Italy introduced a system of mandatory auditing for local authorities in 1995. This turning point came at a time of systemic crisis: exploding local debts, currency crisis, corruption scandals and political restructuring. The creation of a college of auditors - drawn by lot from among certified professionals - was part of a process to modernize the State. Auditors are trained by the Ministry of the Interior, paid according to national scales and supervised by the Italian Court of Audit.
Italy has thus built a hybrid model: external auditing entrusted to private professionals, strong public supervision, and measures to standardize practices (standardized questionnaires, homogeneous reports). Above all, this reform was accepted locally. Associations of elected representatives did not oppose it, and local authorities saw the auditors as providing technical support, not as a political threat.
A missed window of opportunity in France
John Kingdon's multi-flow model (1984) - that of problems, solutions and politics - sheds light on the absence of a window of opportunity for the development of certification of local authority accounts in France. In the French case, there appears to be no alignment of flows. The problem is not sufficiently salient to call for a collective framework. Solutions, still only partially operational, are gradually improving, but their institutional consolidation remains fragile. Finally, the political flow is non-existent: the government has abandoned the subject, Parliament has not taken it up, and associations of elected representatives have defended the status quo. Even the private sector has remained rather passive: "the industry has failed to build a convincing sales pitch", notes one consultant.
Some initiatives are calling for a revival. The Association Finances, Gestion, Évaluation des collectivités territoriales (AFIGESE) is proposing compulsory certification for large local authorities (regions, départements, metropolises, towns with more than 100,000 inhabitants), accompanied by a lighter certificate for smaller structures. It points out that "the return on investment exists and is recognized" (reliability, security, identification of new revenues), but that it has not yet been measured. However, without clear political impetus, this proposal will remain a dead letter.
A lasting exception?
Certification does not guarantee good management - as the example of Birmingham, bankrupt despite its certified accounts, shows - but it does provide an essential technical foundation for transparency and accountability. The absence of a reliable system weakens financial analysis capabilities, prevents strategic steering and limits comparability between local authorities.
The French exception is not simply the result of technical delays. It is the result of an institutional model where control is an exclusive public function, and where opening up to private players remains culturally suspect. As long as certification is not seen as a lever for modernizing and securing local public management, it will remain confined to an unfinished reform - experimented with but never taken on board.
References
Braun, V., & Clarke, V. (2014). What can "thematic analysis" offer health and wellbeing researchers? International Journal Of Qualitative Studies On Health And Well-Being, 9(1), 26152. https://doi.org/10.3402/qhw.v9.26152
Kingdon, J. (1984), Agendas, Alternatives and Public Policies. Harper Collins.
Pour aller plus loin :
Rutil, S. (2025). Quand le privé audite le public: l'exception française dans le
contexte européen. https://doi.org/10.13140/RG.2.2.21827.26404