URSSAF Audits On-Site, Document-Based or Digital: Key Differences, Your Right to Refuse, and the Pitfalls of Paperless Audits
Not all URSSAF audits are equal: the method chosen by the inspector determines your rights — and in particular your right to refuse. Understanding the difference between on-site audits, document-based audits, and digital audits means you can avoid being subjected to a procedure you could have redirected.
This article is part of the series URSSAF Audits: The Employer’s Guide. Previous step: the audit notice.
The accounting and base audit: the common core
Whether conducted on-site or on documents, the audit aims to verify the accuracy of the declared contribution bases and rates (Articles L.243-7 and R.243-59 et seq. of the French Social Security Code — Code de la sécurité sociale, or CSS). Any reassessment must be justified in fact and in law: this is a requirement whose absence is sanctioned.
On-site audit vs. document-based audit
- On-site (sur place): the inspector visits your premises. You control the practical arrangements (a dedicated room, a single point of contact).
- Document-based (sur pièces): everything hinges on the documents you provide. The temptation to “give too much” is strong; yet every document communicated can feed a ground for reassessment.
In both cases, the contributing employer may be assisted by an advisor at any time (Article R.243-59-1 CSS).
The digital audit (contrôle dématérialisé, or CDA): an agreement you can refuse
The digital document-based audit (Article R.243-59-3 CSS) relies on the transmission of files (DSN — the French nominative social declaration — and payroll files). It requires your consent.
DAIRIA’s advice: systematically exercise your right to refuse within 15 days, and request the precise details of what is expected. This refusal does not constitute an obstruction of the audit and exposes you to no penalty surcharge — it simply gives you back control over the timeline and scope.
If you accept the CDA, request the precise list of the files consulted and the processing operations carried out (Article R.243-59-4 CSS). You can only meaningfully challenge what you are aware of.
Interviews: fertile ground for nullities
The inspector may interview paid individuals (Article R.243-59-3 CSS; Article L.8271-6-1 of the French Labour Code in matters of undeclared work). The pitfalls surrounding interviews are numerous: interviews conducted without consent, without prior information, or outside the cases provided for by law. An irregular interview can lead to the nullity of the findings that flow from it.
Frequently Asked Questions
Can you refuse a digital audit? Yes, within 15 days; this does not amount to obstruction of the audit.
Can interviews be annulled? Yes, if the required formalities (consent, prior information) are not observed.
On-site or document-based — what is the difference? The location and the degree of practical control; the adversarial process (contradictoire) remains identical.
Written and supervised by Guillemette Watine, attorney, former URSSAF litigation inspector, and head of the URSSAF practice at DAIRIA Avocats.
Next step → How URSSAF calculates the reassessment: flat-rate taxation, sampling and extrapolation