The Future of Sustainability Assurance: Potential Challenges in an Assurance Engagement of Sustainability Reports Prepared in Accordance with the Corporate Sustainability Reporting Directive (CSRD)

Abstract

The growing awareness throughout society about environmental and social issues has led companies to embrace a more transparent approach in conducting their business. Consequently, they have progressively initiated the production of sustainability reports as a means to effectively convey their environmental, social and governance performance to stakeholders. Nevertheless, there has been an increasing apprehension over the comparability and reliability of these reports. In response, a variety of actions were adopted. On the one hand, companies began the practice of engaging the services of external, independent auditors in order to improve the reliability of the disseminated information. On the other hand, different sustainability reporting frameworks (e.g., GRI, SASB, TCFD) and regulatory measures, most notably the EU Non-Financial Reporting Directive 2014/95/EU, have been introduced to promote uniformity in sustainability reporting. These measures, however, did not provide the expected results. The independence and legitimacy of sustainability assurance engagements were compromised as a result of their largely voluntary nature. Furthermore, it has been determined that Directive 2014/95/EU is inadequate in terms of its disclosure obligations, as well as limited in terms of comparability and reliability. In response, the Corporate Sustainability Reporting Directive (EU) 2022/2464 has been implemented. This Directive includes a significantly more thorough and standardized reporting mechanism as well as an EU-wide sustainability assurance requirement. As a consequence of the emergence of this entirely new phenomenon, the objective of this Master's thesis is to identify the challenges that assurance practitioners may experience during an assurance engagement of sustainability reports produced in line with the CSRD requirements. Initially, we present an outline of the five major changes brought forth by the CSRD. The literature review then assesses the current environment in sustainability assurance engagements and identifies twelve aspects that may provide challenges in CSRD assurance engagements, laying the groundwork for the empirical investigation. In order to confirm or refute these challenges and gain further perspectives, 21 semi-structured interviews were conducted with professionals in the field of ESG reporting and assurance. The findings indicated that the challenge in providing assurance on CSRD reports is ultimately reliant on the reporting entities’ capacity to provide auditable and reliable data. Furthermore, it is critical that the reporting framework includes precise criteria to ensure consistency in reporting, particularly when it comes to corroborating information based on underlying sources. The research also found that audit firms will face heavy workloads and tight deadlines, requiring the recruitment of additional staff with appropriate competencies and skills. In addition, it was recognized that collaboration and coordination between ESG and financial auditors would be necessary to execute an efficient and successful sustainability assurance engagement. Finally, difficulties may also arise if the auditor's role and responsibility for the double materiality assessment and forward-looking statements, the workload for each ESRS, the effective assessment of the linkage between financial and non-financial information, the reporting boundaries, the implementation of the double materiality assessment, as well as the precise reporting criteria for forward-looking statements, Taxonomy-related statements, and value chain-related claims are not sufficiently clarified in the future.