Jean-Jacques Pluchart
The research workshop organized on June 27, 2025 by the Institute of Psychoanalysis and Management (IPM), an academic association member of the FNEGE, gave rise to several communications on the theme of “gray areas of the management of organizations”. Professor J-J. Pluchart (Scientific Director of the IPM) presented research on the gray areas of financial and extra-financial communication, the results of which are likely to interest the readers of clubturgot.com.
Since its inception, financial accounting has given rise to various frauds contrary to the regulations and standards in force, to which have recently been added so-called “creative” practices apparently aligned with an accounting framework, but in fact not in accordance with the ethics of the company. These behaviors are part of the “gray areas” of management, located on the border between the regulatory and non-regulatory domains. These practices have diversified with the obligation to publish sustainability reports, which requires the reporting of several hundred extra-financial indicators, both accounting and statistical, as part of ESG (Environment, Social, Governance) reporting. The accounting gray area has thus extended to practices relating to green and social washing, nudging, faking, etc. These deviations have been facilitated by certain applications – so-called projective – of Artificial Intelligence.
The research, based on a questionnaire survey of a population of statutory auditors and trusted third parties, identified common practices observed in the grey areas covering accounting and sustainability reporting, as well as analyzing the motivations of their authors. The panel surveyed distinguishes between fraudulent manipulations contrary to regulations, which are a priori in “black areas”, and non-fraudulent manipulations contrary to professional ethics or company ethics, which constitute “gray areas”. The discriminating criterion that dominates the auditors’ responses is compliance or non-compliance with laws, regulations, and professional standards.
Accounting and Extra-Accounting Practices
The respondents distinguish:
– Accounting fraud (“black areas”), such as the recording of fictitious transactions (sales, purchases, movements of stocks, receipts or disbursements…) and the issuance of false invoices; the non-recognition or recording of actual transactions that do not comply with IFRS standards (such as the activation of advertising or training costs); the falsification of accounting documents (invoices, contracts, certificates, labels…), the deconsolidation of subsidiaries in debt and/or in deficit; the failure to publish the company’s accounts or the publication of only pro-forma accounts; the early recording of income or delayed expenses from one year to the next…
– Non-fraudulent accounting manipulations, such as the adjustment of discretionary accruals (optional allocations or reinstatements of depreciation and provisions) and/or the need for working capital; the application of the big bath technique during a change of management, by exceptional allocations of provisions that can be reinstated in the following years; the smoothing of results over several years in order to maintain a regular distribution of dividends, and/or to display results in line with forecasts; the change in the inventory valuation method in order to generate capital gains or losses; the activation of certain expenses (R & D, interest …) and their amortization over several years; the revaluation of certain assets (real estate, goodwill …) using models generating capital gains or losses (also cited by Chiapello, 2005); the unusual use of factoring or discounting to improve cash flow; the non-publication or partial publication of accounting results despite the risk of legal proceedings; the publication of “oriented” pro-forma results, in order to influence the course of the action; the manipulation of segmented information to guide comparisons between competitors in the same industry …
– “Real accounting manipulations” (creative accounting), such as the artificial increase in sales through excessive year-end discounts and/or exceptionally favorable invoice payment terms; the deferral of expenses from one year to the next (including research and development and/or training expenses); the realization of lease back operations of various assets (headquarters, stores, warehouses, factories, equipment, etc.); the abnormal disposal of non-operating and/or investment assets…
– Extra-financial manipulations, such as in black areas, non-compliant practices of disinformation, qualified as environmental (green washing) and social or societal (social washing) laundering, covering erroneous, imprecise or truncated data; in gray areas, non-information (some key data are omitted) or non-monitored information (companies display objectives but not results), and the biased framing of the company’s projects or operations:
– over time, with simulations and projections (facilitated by AI) to present the most favorable or most credible data (such as net-zero or very long-term gender parity objectives without regular monitoring of achievements);
– in space, with data (also processed using AI) not representative of a field, due to intentional targeting errors and/or biased parameters, ambiguities or textual inconsistencies, which lead to errors in data interpretation.
Factors favorable to gray areas
Overall, the auditors interviewed believe that it is increasingly difficult to isolate the types of more or less fraudulent manipulations, insofar as a growing number of them (misappropriation of assets, fraud in purchases or overheads, etc.) are internal or external while benefiting from internal complicity, and are the subject of increasingly difficult to detect hedging manipulations. Manipulations that are deemed to be in gray areas by auditors and ICOs (Informative Commissionner Officers), are generally observed when:
– the company is over-indebted, its results are declining, its stock price is volatile and/or the continuity of its operations is threatened;
– conflicts of interest between the company’s stakeholders (in particular between investors, partners, staff, the State, etc.);
– the company’s shareholding is open and fragmented; the smoothing of the company’s results reassures its stakeholders about the company’s resilience;
– the company’s image is less likely to be degraded if it complies with accounting rules but not or little with ESG standards, which are more recent and uncertain.
According to the respondents, some managers therefore justify their intentions and behaviors by:
– “good reasons”: the difficult or particular situation of the company justifies a “certain interpretation” of the rules and standards;
– “professional routines”: “accountants have always practiced accounting and tax optimization, the new standard is inapplicable…”
– “beliefs”: “non-information makes it possible to avoid green or social bashings; the superiority of the shareholder model, innovation takes precedence over ESG alignment, etc.”
Several auditors believe that AI techniques stimulate the creativity of manipulators, but conversely reinforce the barriers to manipulation by reducing information asymmetries between managers and company stakeholders. They also promote digital attacks through better knowledge of companies and their leaders, but they allow a wider and faster dissemination of accounts and allow earlier detection of risks.
Gray area management systems
Auditors and ICOs are very divided on the mechanisms to be implemented to better regulate practices in gray areas. They distinguish between internal and external structures and procedures, coercive and incentive. Among the internal mechanisms for the prevention and detection of fraudulent and non-fraudulent but risky practices, they cite in order of frequency of citations:
– the example given by the company’s leaders opposed to “compromises” with regulatory frameworks and ethical principles,
– the speeches and behaviors of operational managers, compliance managers, quality managers, and risk managers;
– the organization of actions and training for the prevention, detection and correction of manipulations;
– the development of an ethical culture of the company;
– the implementation of AI systems for detecting accounting fraud (complitech) and cyber security…
Among the external bodies and devices, auditors and ICOs cite the strengthening of the roles of trusted third parties, classified according to three lines:
– statutory auditors and consulting auditors, responsible for systematic or random checks;
– stock market regulators, tax and social administrations, responsible in particular for monitoring tax packages in order to detect fraud in tax and social security codes, financial and extra-financial rating agencies and financial analysts;
– leaders and experts of associations defending environmental, social and societal causes, etc.
In conclusion, the majority of respondents point out that the gray areas in financial and extra-financial communication are rather favored by insufficient coordination or cooperation between the multiple trusted third parties and by the frequent revisions of the regulatory, accounting, and extra-accounting frameworks. The respondents’ answers make it possible to go beyond the classical approaches in management sciences, according to which the manipulations in the gray areas are explained by the “Cressay triangle” (or its derivatives) or result from different psychological biases. These theoretical constructions do not explain why the accounting and statistical manipulations practiced by the managers of the company are multiplying. The exploration of the gray areas of management restored in the research, underlines the interest of their “situationist, socio-dynamic and psycho-analytical approaches”. It shows the importance of accounting reviews, compliance checks and auditing of digital protection systems. It is an invitation for business leaders to empower staff and raise awareness of ethics, as well as an incentive to secure procedures, systems and data, but it shows above all that the still imprecise or uncertain notions of gray area or sensitive terrain cannot be precisely defined and applied without resorting to concepts and heuristics that are not only accounting or statistics, but also sociology, psychology and psychoanalysis.
