Paris · Situation
Sustainability and CBAM reporting in Paris
Almost nobody in this region starts this work voluntarily. It arrives as a procurement questionnaire from a European customer, a contract clause, or a listing rule with a date attached. Then it becomes finance’s problem, because it is a disclosure, controls and assurance problem wearing an environmental coat.
Two separate pressures are worth telling apart. Local listing rules — Singapore and Malaysia from FY2025, Australia’s first group from January 2025, Taiwan from FY2026, Japan’s largest issuers for years ending March 2027 — put ISSB-based climate disclosure on a published timetable. Quite separately, exporters of steel, aluminium, cement, fertiliser, hydrogen or electricity into the EU now sit inside CBAM, whose definitive regime began on 1 January 2026 and which needs embedded emissions calculated at installation level, per production route. That is a plant-level measurement job, not a corporate reporting one, and the two are routinely confused.
On the CSRD question specifically: the 2026 Omnibus package cut the scope sharply, to EU companies above 1,000 employees and €450m turnover, with first reports in 2028. It also capped what those companies may demand from suppliers under 1,000 employees. If you are below that line, the honest answer is that you owe far less than the questionnaire in your inbox implies — and knowing that is worth money.
What this calls for
- A greenhouse gas inventory that would survive an audit — Scope 1 and 2 built properly, Scope 3 screened rather than guessed
- Data architecture: metering, utility and fuel records, ERP tagging, and a controls layer, because assurance is coming
- A supplier data programme focused on the top fifth of spend, not a questionnaire sent to everyone
- For CBAM exporters, a separate workstream: installation-level measurement, process-route allocation, an accredited verifier
- Governance wiring — board mandate, committee charter, who signs what
- Someone who can read the rule and tell you what you genuinely do not have to do
What is specific to France
- Employer contributions are largely uncapped above the plafond, so on-costs scale with executive pay rather than flattening out — the opposite of Thailand, where they are effectively nil at CFO level.
- Exiting a French executive is expensive by design: a 30% employer contribution on rupture conventionnelle indemnities, and up to twenty months of salary at the prud’hommes if it goes wrong. A prestation de services ends on notice.
- The subsidiary audit thresholds — EUR 5m revenue, EUR 2.5m balance sheet, 25 employees — pull small French entities of foreign groups into a real reporting obligation years before they have the finance team to meet it.
- The expert-comptable is the incumbent adviser and is deeply embedded — often the only external financial voice the patron has heard for a decade. A fractional DAF who arrives positioned against the expert-comptable loses. One who arrives as the person who turns the expert-comptable’s output into decisions gets in the door.