For a French NGO or CSO that appeals to public generosity, the statement of use of resources (CER) is neither an additional table in the annual accounts nor a formality to be dispatched at the end of the financial year. It is the public, enforceable and published commitment that the organisation makes to its donors: "here is the money you entrusted to us, here is precisely what we did with it". For the CFO, the head of accounting or the finance coordinator, producing a CER compliant with regulation ANC 2018-06 and the associated CROD requires a precise mechanism: identifying what does or does not fall under public generosity, structuring a coherent analytical plan, documenting an allocation method, and tracing each euro from collection to its final use, sometimes thousands of kilometres from headquarters.
This guide explains exactly what the statement of use of resources is, who it applies to, and how to build it so that it withstands scrutiny by a statutory auditor, a magistrate of the Court of Auditors, a journalist or a demanding donor. We detail the headings required by regulation ANC 2018-06, the classic pitfalls encountered by associations and foundations, and we show how Abvius, the Finance, Operations and MEAL ERP designed for NGOs, enables you to produce a CER that is reliable, auditable and reproducible each year without starting from a blank page.
NGO Statement of Use of Resources: producing a compliant and auditable CER
Reading time: ~14 min
- The CER, cornerstone of NGO financial transparency
- Legal framework: law 91-772, regulation ANC 2018-06 and the CROD
- Who must publish a CER: thresholds, scopes and organisations concerned
- Structure and headings of the CER: decoding each line
- The classic pitfalls that cause a CER to fail in audit
- Abvius: industrialising the production of the CER and the CROD
- 5 implementation steps for a compliant and auditable CER
- Mini FAQ on the statement of use of resources
1. The CER, cornerstone of NGO financial transparency
The statement of use of resources, better known by its French acronym CER, is an annual financial statement required of associations and foundations that appeal to public generosity. Its purpose is simple to state, much harder to produce: presenting, for a given financial year, the origin of the resources collected from the public and the use the organisation has made of them, clearly distinguishing between social missions, fundraising costs and operating costs.
The CER is part of a strong French tradition of accountability to individual donors. It does not replace the annual accounts (balance sheet, income statement, notes); it complements them. Where the annual accounts give an overall view of the financial situation, the CER zooms in on a specific question: what, concretely, was done with the donations received from the general public? This apparently mundane question conditions the confidence of individual donors, the public legitimacy of the NGO and, increasingly, its eligibility for certain institutional funding that requires a high level of financial transparency.
CER, CROD and annual accounts: what story are we trying to tell?
To understand the usefulness of the NGO statement of use of resources, it must be placed within the French accounting ecosystem. The annual accounts tell the asset and economic story of the organisation. The income statement by origin and destination (CROD), introduced by regulation ANC 2018-06, breaks down expenses and income by funding origin and by operational destination. The CER, finally, isolates public generosity in order to track its use from end to end. These three documents form a coherent triptych: the annual accounts provide the framework, the CROD sheds light on the year's flows, the CER traces the fate of the donations.
2. Legal framework: law 91-772, regulation ANC 2018-06 and the CROD
The obligation to produce a statement of use of resources originates in law no. 91-772 of 7 August 1991, which established the principle of financial transparency for bodies that appeal to public generosity. Thirty years later, the framework was profoundly renewed with regulation no. 2018-06 of 5 December 2018 of the French Accounting Standards Authority (ANC), which came into force for financial years opening on or after 1 January 2020, and has since been supplemented by several technical updates.
Decree no. 2019-504 of 22 May 2019 specified a structuring threshold: above 153,000 euros of resources collected through an appeal to public generosity over a financial year, the organisation must make a prior declaration to the prefectural authorities and draw up a CER. Below this threshold, the publication obligation does not apply, but many NGOs choose to publish a CER voluntarily to strengthen donor confidence.
The contribution of regulation ANC 2018-06
Regulation ANC 2018-06 did far more than tidy up the old chart of accounts for associations. It thoroughly overhauled the presentation of the annual accounts and required the joint production of a CROD and a CER for the organisations concerned. The heading "investments and disinvestments related to public generosity" was added to the CER, in order to trace the investment flows (acquisition of durable equipment, construction of infrastructure) financed by donations. The successive updates (2020, 2021, 2022) clarified the treatment of dedicated funds, legacies in progress and voluntary contributions in kind, all sensitive subjects for NGOs whose activity is partly voluntary or relies on donations in kind.
3. Who must publish a CER: thresholds, scopes and organisations concerned
The obligation to produce and publish a statement of use of resources does not concern all NGOs. It is triggered by two cumulative conditions: appealing to public generosity, and exceeding a threshold of resources collected on that basis. Understanding these two notions is an essential prerequisite, because many organisations underestimate their actual scope of "appeal to public generosity" and discover their obligation at the time of a control.
What is an "appeal to public generosity"?
An appeal to public generosity refers to any campaign conducted at the national level, by any means of communication (press, television, radio, billboards, mailing, internet, social media, door-to-door canvassing), to solicit donations from the general public for a cause. This includes appeals in cash but also in kind, and one-off campaigns as well as permanent solicitations. An NGO that publishes a donation form on its website, that sends an annual mailing to its donors, or that solicits donations by SMS during a humanitarian crisis falls within the scope. Conversely, solicitations addressed exclusively to institutional funders (AFD, ECHO, European Commission, private foundations) do not fall under appeal to public generosity.
Thresholds and organisations concerned
| Type of organisation | Triggering threshold | Associated obligations |
|---|---|---|
| Standard associations and foundations | EUR 153,000 of resources collected through appeal to public generosity | Prior declaration, CER, CROD, published annual accounts |
| Religious associations (1907 law) | EUR 50,000 of resources collected | Specific annual CER |
| Endowment funds and sheltered foundations | Variable depending on the nature of the resources and the internal regulations | Application of regulation ANC 2018-06; CER if appeal to public generosity |
| NGOs without appeal to public generosity | Not applicable | Annual accounts and, where applicable, the CROD; no mandatory CER |
Beyond the legal obligation, several labels and charters (Don en Confiance, IDEAS, CHS certification) incorporate the CER into their criteria. An NGO that wants to strengthen its credibility with the general public or with demanding institutional donors can publish a CER even below the legal threshold: it is a strong signal of accountability.
4. Structure and headings of the CER: decoding each line
The statement of use of resources is presented in two main columns: the "resources collected during the year" column and the "uses during the year" column. The logic is that of a loop: you identify what comes in under public generosity, you track what goes out to implement it, and you reconcile the two to explain the variances (carried-forward funds, dedicated funds, voluntary contributions).
The origin of resources collected from the public
The first section isolates the resources collected under public generosity: manual donations, individual patronage, legacies and gifts, other gratuitous transfers, financial income related to public generosity and reversals of provisions. Here, institutional funding (public grants, donor agreements, membership fees) must be excluded, as it is recorded in the CROD but not in the CER. The boundary between these two worlds seems obvious on paper; in practice, it requires a solid analytical plan and disciplined recording of bank journals.
The uses: social missions, fundraising, operations
On the uses side, regulation ANC 2018-06 requires a breakdown into three broad categories that structure the way the CER is read by donors and controllers.
Social missions bring together all the actions carried out in France and abroad that correspond to the organisation's statutory purpose: humanitarian programmes, development projects, advocacy, awareness-raising actions. This is the heading donors scrutinise first: a social missions / total uses ratio below 70-75% generally attracts attention and can undermine confidence.
Fundraising costs cover the costs related to collection itself: mailing campaigns, advertising, fundraising agency fees, salaries of dedicated teams, online donation platforms, fundraising events. This line must not be artificially understated: an audit will quickly identify misclassified costs.
Operating costs and other expenses bring together the structural costs (general management, accounting, human resources, IT, institutional communications) to the extent of the fraction covered by public generosity. These costs are legitimate and indispensable; the challenge is to calculate them with a traceable allocation method.
Investments related to public generosity and carried-forward funds
The major innovation of regulation ANC 2018-06 is the formalisation of "investments and disinvestments related to public generosity". When an NGO uses donations to finance the acquisition of a building, a durable vehicle or an infrastructure (borehole, school, health centre), these investments must appear in a dedicated heading. The logic is as follows: a donation allocated to an investment is not a use of the year, but an asset that will provide service for several years. Its traceability in the CER is essential to explain to donors the actual allocation of their contributions.
Carried-forward funds related to public generosity and dedicated funds make it possible to manage the classic timing gap between collection and use. An NGO that collects 2 million euros in December for an emergency will not, in most cases, be able to spend them in full before year-end. The unused funds are carried forward to the following year and earmarked for their intended allocation, which makes the CER legible over time and avoids the illusion of underspending.
5. The classic pitfalls that cause a CER to fail in audit
Producing a compliant CER is not only a matter of format; it is above all a matter of method and traceability. The controls carried out by statutory auditors, the Court of Auditors or the General Inspectorate of Social Affairs (IGAS) bring up a limited number of recurring complaints.
The first pitfall is the incorrect classification of resources. Confusing a corporate donation falling under patronage (public generosity) and an earmarked private grant (institutional funding) distorts the resources column and warps the whole social missions ratio. A poorly designed analytical plan, where the bank journals do not carry the information on the nature of the donation, is the main cause of this type of error.
The second pitfall lies in the absence of a documented allocation method. Operating costs (rents, support salaries, IT) must be broken down between the part financed by public generosity and the part financed by other resources, according to an explicit and reproducible key. If the method is not formalised in a procedure note validated by the governance body, the auditor will consider it unenforceable.
The third pitfall is insufficient end-to-end traceability. When the statutory auditor asks to reconstruct the use of a specific donation from its collection to an expense in the field, they must be able to follow the chain without interruption: bank journal, analytical allocation, commitment, purchase order, invoice, validation, archived supporting document. A break in the chain means an ineligible expense and a weakened CER.
The fourth pitfall concerns the management of dedicated and carried-forward funds. Poor maintenance of dedicated fund balances from one year to the next creates variances that are difficult to explain and gives the impression that the organisation does not have control over the use of donations. Conversely, rigorous monitoring of dedicated funds is a signal of good management that reassures donors and funders.
How to equip CER monitoring: paper, Excel, ERP
| Criterion | Excel spreadsheets | Accounting software alone | NGO ERP (Abvius) |
|---|---|---|---|
| Identification of public generosity at data entry | Manual, a source of errors | Possible but without analytical control | Native analytical dimensions, automatic controls |
| Allocation method for operating costs | Scattered formulas, untraceable | Manual breakdowns at year-end | Configured keys, automatic recalculation, history retained |
| Monitoring of dedicated and carried-forward funds | Dashboard to be recreated each year | Class 19 accounts usable but not very visual | Real-time monitoring by project and by donor |
| Digital audit trail | Non-existent, risk of overwritten files | Partial, limited to entries | Complete, from the supporting document to the CER |
| Reproducibility from one year to the next | Weak, depends on individuals | Medium | High, industrialised process |
6. Abvius: industrialising the production of the CER and the CROD
We design Abvius as the first Finance, Operations and MEAL ERP conceived for NGOs, CSOs and international solidarity organisations. Our conviction is simple: a reliable statement of use of resources is not built at year-end, with the help of reconstructed spreadsheets. It is built throughout the financial year, from entries qualified at source and an unbroken chain of traceability between headquarters and the field.
In concrete terms, Abvius enables you to identify public generosity as soon as income is recorded, relying on native analytical dimensions (source, campaign, donor, allocation). The real-time budget monitoring by project, donor and nature of resource makes the balance of dedicated funds and the pace of consumption visible at every moment. The digital audit trail links each accounting entry to its supporting document and its validation workflow, from the commitment request to the archived invoice. The configurable validation workflows incorporate your delegation of authority scheme and embody internal controls, while the electronic signature secures remote approvals, indispensable for organisations whose teams often operate across several continents.
The headquarters-field centralisation avoids re-entries between country offices and headquarters: a commitment entered in the field is automatically uploaded, with its analytical dimension and supporting document, into the consolidated accounts. Finally, the modules for automatic donor reporting and for generating the CROD and the CER rely on the same accounting and analytical data used throughout the year, which guarantees consistency between the annual statements and the financial reports submitted to donors. To go further, you can visit our Abvius website or our articles dedicated to the NGO analytical chart of accounts, the digital audit trail and the donor compliance guide.
7. 5 implementation steps for a compliant and auditable CER
Preparing the production of a statement of use of resources cannot be improvised. Here is the five-step sequence we recommend to NGOs and CSOs that wish to make their CER reliable, whether they are starting from an Excel situation or want to industrialise an existing arrangement.
Step 1 — Map the sources of public generosity. Take stock of all the campaigns, channels and formats through which your organisation collects donations from the general public: online donations, mailings, direct debits, legacies, individual patronage, donations in kind, events. For each channel, identify the source recording system (CRM, payment platform, bank). This mapping is the foundation of the future analytical plan.
Step 2 — Define a structured analytical plan. Build a multi-dimensional analytical plan that makes it possible, at data entry, to qualify each resource (public generosity vs other resources, donor, campaign, earmarking) and each use (social mission by programme and country, fundraising, operations). A solid analytical structure is the most profitable investment you can make to make the CER reliable.
Step 3 — Formalise an allocation method for operating costs. Document in writing the distribution key for indirect costs between public generosity and other resources: on what basis (relative weight of resources, dedicated payroll, time spent), at what frequency, validated by whom. This note must be approved by management and kept available to the statutory auditor.
Step 4 — Equip end-to-end traceability. Set up an information system that links the bank journal to the analytical accounting, to the commitment, to the supporting document and to the validation workflow. The digital audit trail is no longer a luxury: it is the condition for withstanding an in-depth control and for producing the CER without manual reconstruction.
Step 5 — Prepare publication and communication. The CER only makes sense if it is read. Alongside the technical version, prepare an accessible presentation aimed at donors, put the document online on your website and attach it to your follow-up campaigns. A clear and accessible publication strengthens confidence and increases, over time, your fundraising capacity.
8. Mini FAQ on the statement of use of resources
What is the difference between the CER and the CROD?
The income statement by origin and destination (CROD) is a comprehensive statement that breaks down all the year's expenses and income by funding origin (public generosity, public grants, other resources) and by operational destination (social missions, operations, etc.). The statement of use of resources (CER) is a complementary focus that isolates public generosity alone in order to track its detailed use, including investments and carried-forward funds. The two documents are produced together and feed into one another.
Is the CER mandatory for all French NGOs?
No. The obligation applies to organisations that appeal to public generosity and whose resources collected on that basis exceed 153,000 euros over a financial year (50,000 euros for religious associations). NGOs that solicit only institutional funding (AFD, European Commission, private foundations) are not required to produce a CER, but must apply the other provisions of regulation ANC 2018-06 and, where applicable, the CROD.
What are the penalties for a non-compliant or unpublished CER?
Failure to comply with the obligations related to appeal to public generosity can result in administrative penalties (formal notice, withdrawal of accreditation), the loss of tax advantages for donors, reinforced controls by the Court of Auditors and, in the event of serious breaches, criminal proceedings. Beyond the penalties, the reputational risk is often more damaging: a CER criticised by the specialist press or by a financial magistrate can durably affect fundraising.
Must the CER be audited by a statutory auditor?
Yes, in the vast majority of cases. Organisations subject to the obligation to publish a CER are also subject to the obligation to appoint a statutory auditor, whose mission includes certifying the annual accounts and checking the consistency of the CER and the CROD. The statutory auditor verifies in particular the cost allocation method, the completeness of the public generosity resources, the correct treatment of dedicated funds and the consistency of the data between the CER, the CROD and the notes.
Summary
The statement of use of resources is not a year-end exercise: it is the culmination of an analytical discipline maintained throughout the financial year. For an NGO or CSO that collects donations from the general public, producing a CER compliant with regulation ANC 2018-06 requires a structured analytical plan, a documented allocation method, end-to-end digital traceability and a governance body that validates and publishes. Beyond compliance, it is a powerful tool for dialogue with donors and for building confidence. By properly equipping the chain — from the collected donation to the field expense — you turn a regulatory obligation into a competitive advantage. To go further, discover our complete guide to donor compliance, our article on the digital audit trail, or talk to our team via the Abvius contact page.