ACCA has been actively promoting transparency and best practice in sustainability reporting since 1990. We are very pleased, therefore, to have the opportunity to respond to the consultation paper Assurance on a Greenhouse Gas Statement issued by the International Auditing and Assurance Standards Board (IAASB) of the International Federation of Accountants.
We found the appendix to the consultation paper to be particularly helpful in focussing our comments. It is a well-crafted working draft, drawing on existing pronouncements to illustrate how a possible International Standard on Assurance Engagements could emerge. The IAASB is currently also considering revision of ISAE 3000 Assurance Engagements Other than Audits or Reviews of Historical Financial Information, which acts as an umbrella standard for the ISAE series and we recognise that changes to it could affect the form of any specific standard.
The consultation paper contains 30 questions, which we have used to structure our detailed response. From our answers and the general comments that precede them, we highlight the following:
- We strongly suggest that this project should not result in a highly detailed standard that is only suitable where a large reasonable assurance engagement is carried out by auditors of public interest entities.
- In our view, to meet the demands of the market, the eventual standard must deal with both reasonable and limited assurance engagements.
- We consider that the IAASB needs to explain how its standards can be applied alongside the standards and guidance that are already in use for greenhouse gas assurance.
- We do not agree with a requirement in the working draft that the engagement partner must be a professional accountant, as multidisciplinary teams may be led by those with other qualifications.