Service 01 · SRI audit & French SRI label

SRI audit and French SRI label preparation

Assessing the robustness of an SRI framework, and understanding how it actually fits into the investment strategy, management processes and organisation. From strategy to evidence.

Discuss your framework The six pillars of the standard
Independent auditorfor AFNOR Certification, on the French SRI label
6 pillarsof the standard, reviewed one by one
Chain of evidencefrom commitment to data, decision and supporting document
The framework

The French SRI label in brief

The Label ISR is a public label backed by the French Ministry of the Economy. It is awarded to funds by independent certification bodies after an audit, then checked through follow-up audits.

The current standard came into force on 1 March 2024 for new applications. Funds that were already labelled had until 1 January 2025 to comply. It is significantly more demanding than the previous version: higher selectivity, stronger exclusions and new attention to companies’ climate transition plans.

For an asset manager, the challenge is no longer just to have an ESG methodology. You need to be able to demonstrate that this methodology genuinely drives management decisions, and that every commitment made to investors rests on data, controls and evidence.

  • 30% selectivity: the ESG analysis must reduce the investment universe by at least 30%.
  • Sector-based and norms-based exclusions, notably on fossil fuels.
  • Climate transition plans examined, in line with the Paris Agreement.
  • Adverse impact indicators: at least two indicators better than the initial universe.
The standard

The six pillars of the French SRI label

The standard is organised into six pillars. For each one, I look at what is written, what is done, and what can be demonstrated.

  1. Pillar I

    The fund’s ESG objectives

    The financial and non-financial objectives pursued across environmental, social and governance issues, and how they are presented to investors.

    What I checkClear, measurable objectives, consistent with the investment strategy.
  2. Pillar II

    The analysis and rating methodology

    The ESG assessment method for issuers, data sources, controversy management and the human resources dedicated to it.

    What I checkThe robustness, traceability and acknowledged limits of the method.
  3. Pillar III

    ESG in portfolio construction

    How the analysis translates into decisions: E, S and G weightings, selectivity, exclusions, thresholds, transition plans and the treatment of derivatives.

    What I checkThat ESG genuinely changes the composition of the portfolio.
  4. Pillar IV

    Voting and engagement

    The voting policy, voting rates, dialogue with issuers and escalation rules. For real estate: engagement with tenants, users and suppliers.

    What I checkEngagement that is tracked, documented and followed up.
  5. Pillar V

    Enhanced transparency

    Information provided to investors and distributors, publication of the portfolio inventory, and internal control of the ESG framework.

    What I checkThat what is said matches what is done, and is controlled.
  6. Pillar VI

    Monitoring ESG performance

    Measuring the portfolio’s ESG performance over time and reporting on principal adverse impacts, compared with the initial universe.

    What I checkReliable indicators, calculated in a stable and explainable way.

The pillars above are those of the standard for securities funds; real estate funds follow the same pillars, with a pillar IV devoted to engagement with stakeholders. Source: French SRI label standard in force since 1 March 2024.

The approach

An assignment in six stages

The work is adapted to the maturity of the fund or asset manager. It can cover an existing framework, preparation for an audit or a change in SRI strategy.

  1. Scoping the framework

    Fund objectives, investment strategy, SRI and ESG commitments, applicable standard, internal organisation.

  2. Document and methodology review

    Policies, ESG methodologies, procedures, tools, data, controls, reporting and documentation for investors.

  3. Review of operational practices

    How ESG criteria actually feed into analysis, security selection, portfolio construction, controversies, engagement and voting.

  4. Testing the chain of evidence

    Linking a commitment or requirement to a piece of data, a management decision, a control and a supporting document.

  5. Gaps and weak points

    Methodological inconsistencies, insufficient data, weak traceability, unclear responsibilities, practices that are hard to demonstrate.

  6. Improvement plan

    Prioritised actions to secure the framework, improve its auditability and, where needed, adjust the strategy or processes.

Depending on the assignment

Deliverables

  • Maturity assessment of the SRI/ESG framework
  • Map of requirements, processes, responsibilities and evidence
  • Gap analysis between documentation, methodology and practice
  • Review of the ESG methodology and selection criteria
  • Analysis of ESG data quality and traceability
  • Control grid or mock audit, pillar by pillar
  • Risk matrix and points of attention
  • Prioritised recommendations and operational action plan
  • Updates to procedures, controls or reporting
  • Preparing teams for a certification audit or external review
Who it is for

Who the assignment is for

Asset managerspreparing a first labelling or a renewal.

Equity, bond and multi-asset fundswhose framework must hold up against the current standard.

Real estate fundswith their own indicators: energy, emissions, occupants, supply chain.

Institutional investorswho want to understand what a labelled fund guarantees before selecting it.

Independence

I work as an independent auditor for AFNOR Certification on the French SRI label. This auditing practice informs FINéCOS assignments: I know what an auditor expects, and where frameworks are most often fragile.

The two activities remain separate: I do not act as a certification auditor for a fund or asset manager I have advised.

Preparing for an audit, securing a framework?

Tell me about your fund, your timetable and your concerns. I will get back to you quickly to set up a first conversation.

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Further reading

See also

ProfileAlexandre Van OoteghemMore than fifteen years in responsible investment, SRI auditing, ESG and foresight. ServicesAll FINéCOS servicesResponsible investment policy, interim support, strategic monitoring. FrançaisAudit ISR et label ISRCette page en français.