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23 June, 2021
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On April 21, the European Commission adopted a new Corporate Sustainability Reporting Directive (CSRD) [1]. This new non-financial reporting requirement for European companies marks the next step in the upcoming trend of sustainability reporting. In this article, you will read more about sustainability reporting in the European Union and the role that accountants play in it.
CSRD
The newly adopted CSRD is part of the European Green Deal, which represents the European Union’s (EU) strategy to become climate-neutral by 2050 and protect the well-being of both Europe’s citizens and nature. To achieve this, European companies are expected to adapt their business models to this. The new CSRD is designed to ensure that companies report reliable and comparable information on their progress towards a sustainable business. With the CSRD, greenwashing, the unjust claim of being environmentally friendly, is expected to be prevented [2].
The CSRD is not the EU’s first effort to increase transparency regarding the social and environmental impact that European companies have on their surroundings. In 2014, the European Commission took the first step by adopting a Non-financial Reporting Directive (NFRD) [3]. This directive requires large public-interest entities with more than 500 employees to report on several social and environmental themes. Examples of these themes are environmental protection, human rights, anti-corruption, and diversity. The information required by the EU’s NFRD is not subject to a mandatory audit by an independent third party. Nevertheless, in the Netherlands, such non-financial information is indirectly part of the financial audit, as the information is integrated with the annual report. An accountant is required to read the annual report and consider whether it contains information that is materially inconsistent with the financial statements.
With the CSRD, the EU takes the current directive a step further. From 2023 onwards, all companies subject to the CSRD must report on sustainability according to the European Sustainability Reporting Standards. These reporting standards can be seen as the IFRS for sustainability reporting and are expected to be published in the fall of 2022. The European Sustainability Reporting Standards will build upon existing reporting frameworks, such as the guidelines by the Global Reporting Initiative (GRI). GRI is a non-profit organization, who issued the first framework for sustainability reporting in 2001. Since then, GRI’s guidelines have grown to be the most popular reporting framework for corporate responsibility reporting [4].
“With the CSRD, greenwashing, the unjust claim of being environmentally friendly, is expected to be prevented”.
All large companies and listed companies in the EU will become subject to the CSRD1. A company qualifies as large when it meets at least two of the following three criteria: more than 250 employees, a revenue of more than €40 million, and more than €20 million in assets. Due to this new requirement, it is expected that more than 39,000 extra companies in the EU will become subject to the non-financial reporting requirement. Next to the expansion of companies due to the directive, the CSRD also poses several new reporting requirements. For example, the concept of double materiality is introduced. This means that the companies must consider the impact of sustainability risk, such as climate change, on the company itself, as well as the impact of the company on its surroundings. Moreover, companies are expected to share more forward-looking information, such as their targets and plans. All reporting must also be in line with the EU Taxonomy Regulation1. This regulation is newly introduced too and aims to indicate which economic activities may be labeled as “green” according to the EU. Another new requirement dictates a mandatory audit by an independent third party from 2023 onwards. More specifically, the CSRD requires a limited level of assurance. A limited level of assurance means that the assurance provider must indicate that nothing has come to their attention that implies that the information is materially misstated. A higher level of assurance is required for the financial statements, namely a reasonable level of assurance. Nevertheless, the EU has already expressed its desire to raise sustainability reporting to the same level as financial reporting1.
The role of accountants
Currently, assurance on sustainability reporting is generally provided by the same accountant, giving assurance on the financial statements. Since sustainability information is part of the annual report, this is the preferred method in the Netherlands. In 2019, the Big Four accounting firms provided assurance for 91% of the sustainability information at listed companies in the Netherlands. Outside of the Netherlands, it is more common than other accounting firms or verification firms to provide assurance on sustainability information [5].
Given the adoption of the CSRD and the increasing focus on sustainability of investors, it is likely that the demand for assurance services on sustainability information is going to rise further. Unsurprisingly, it seems that some Big Four companies have already responded to this trend by offering integrated accountancy traineeships, focusing on both financial and sustainability information. Such traineeships anticipate well the new developments in sustainability reporting.
Auditing standards
One of the developments that assurance providers in the sustainability field may face in the future is the uniformization of auditing standards for sustainability reports. The overall goal of auditing standards is to provide auditors with guidelines for determining which steps should be taken to reach the audit objective. Following such standards increases the quality of the audit. You may be familiar with PCAOB’s auditing standards, the International Standards on Auditing (ISA), or Nadere voorschriften controle- en overige standaarden (NV COS). These are applicable to financial audits. For sustainability audits, there seems to be a division between two sustainability assurance standards worldwide. On the one hand, ISAE 3000 is used. ISAE 3000 is developed by the organization as the ISA, namely the International Audit Assurance Board (IAASB). Unsurprisingly, the standard is largely based on the accounting principles for financial audits and most popular among accounting firms, according to academic research [6]. In the Netherlands, ISAE 3000 is integrated into NV COS 3000. On the other hand, AA1000 is available. This standard was created by a non-profit organization called AccountAbility, which specializes in standards and consulting regarding environmental, social, and governance (ESG) matters. Compared to ISAE 3000, AA1000 takes an approach that focuses on accountability to stakeholders. Academic research indicates the AA1000 standard is mainly used by consultancy firms.
With the adoption of the EU’s Corporate Sustainability Reporting Directive, interesting times are ahead. The new reporting requirements will likely pose challenges for both companies and assurance providers. Nevertheless, it is an important next step to more transparency on our progress towards a green and sustainable EU.
