MASE Scope in 2026: Autonomy, Sites and Sampling

A SIRET locates an establishment, not its autonomy under MASE

Who makes operational decisions locally? Who is responsible for the teams? Who leads the studies, approves the bids and organises the services or worksites? The new definitions published by MASE define autonomy through that combination of operational responsibilities. Having a separate SSE system is no longer the determining factor. A centralised SSE function does not, on its own, make every branch non-autonomous. Conversely, a separate address and a local manager do not prove that a unit genuinely controls its own activity.

A non-autonomous entity operates under the responsibility of an autonomous entity and cannot be certified on its own. If it has its own SIRET, the company still has to demonstrate that it lacks decision-making autonomy. The administrative identifier helps expose the trap. A SIRET number has 14 digits: the 9 digits of the SIREN followed by the 5 digits of the NIC. Insee specifies that the NIC encodes neither activity nor location. The SIRET identifies an establishment. It does not answer the MASE question of where operational decisions are taken.

On a single page, map the people responsible for bids, the teams assigned, worksite managers and the authority that allocates resources. Only then compare that map with the SIRET records. For every unit whose status is debated, retain a document that shows a real decision: approval of a bid, allocation of resources or a ruling on how a service is to be delivered. Add the date, the person who made the decision and the entity that carries responsibility for it. The reporting line alone is a poor map of operational autonomy.

Two establishments with separate SIRET numbers are not necessarily two autonomous entities under MASE. The answer lies in where bids, resources and operations are decided.

At the initial audit, the full scope comes before the sample

For the organisation classique shown in the official diagram, the initial audit covers 100% of the activities and 100% of the sites in scope, whether autonomous or non-autonomous. Define that scope before applying either percentage. The example shows one autonomous entity plus five non-autonomous entities, making six sites, all audited at the initial stage. It illustrates the published table; it does not create a general formula for groups of every size. The diagram applies explicitly to companies with an organisation classique. A holding company, an international network or a structure with several autonomous decision centres requires specific scoping with the local MASE administration. Prepare that discussion by linking every activity to the sites where it is performed and to the autonomous entity that bears operational responsibility for it.

In the 2026 diagram, a chantier, or worksite, counts neither as a non-autonomous entity nor as a site for the audit-duration rule. Its workforce still contributes to audit representativeness. The worksite therefore belongs in fieldwork and headcount preparation, but it must not be turned into a site under a rule MASE has not published. No public formula converts that workforce into an audit duration.

Covering activities and sites at renewal

At renewal, every activity remains covered. Every site opened since the previous audit is covered as well. For sites that were already present, full coverage is checked across no more than two consecutive audits. The preparation register therefore needs four separate populations: activities, new sites, sites from the previous scope and worksites. Record each site's opening date so that those subject to the new-site rule can be identified without ambiguity. Keep the snapshot of the scope used at the previous audit too, since it provides the reference population to be covered across the two visits. That snapshot should name each site, its status and the activities performed there.

The public diagram does not impose a 50% quota at each renewal. It requires 100% of new sites and coverage of every site in the previous scope over no more than two consecutive audits. How that coverage is scheduled in practice still needs confirmation from the local MASE administration. Use the register to verify coverage across those two audits, starting from the scope agreed with that administration. For each visit, record the sites covered and retain the local decision approving the programme.

Around 1 June 2026: four cases, with no invented date

MASE published the page on 2 July 2026 and announced that the new definitions and rules took effect on 1 June 2026. For an entreprise engagée whose membership was effective before 1 June, the initial audit remains under the old rules, with the new rules applying at the following audit. If membership took effect on or after 1 June 2026, the new rules apply from the initial audit. Keep the effective date and the publication date separate in the file.

For a company that is already certified and whose renewal is described in the source as prévu within the nine months following 1 June, one final renewal uses the old arrangements. The new rules begin with the next cycle. This transitional case determines the audit regime; it does not pre-empt the decision of the Comité de Pilotage.

If the renewal is prévu beyond that window, the new provisions apply directly. The source neither states whether the calendar boundary is inclusive nor defines what prévu means for administrative purposes. Calculating a terminal date from 1 June would add precision that the publication does not contain. Record the date adopted by the local administration, the document from which it draws that date and its written reply. When a renewal falls close to the nine-month boundary, obtain written confirmation of the applicable regime and scope before freezing the audit plan.

The update of scopes when cases come before the Comité de Pilotage is described as progressive, over about three years. That indication creates neither a universal changeover on 1 June 2029 nor a certification term. For an organisation with several decision centres, obtain written approval of the proposed structure before finalising the sites and activities to be audited.