Cooperation with the auditor

I would like to make it clear from the outset that I am writing from two perspectives: that of an advisor who, in the reporting process, is closer to the company preparing the report and responsible for it, and that of a standard-setter, i.e., a person involved in the development of reporting standards. Certified auditors can certainly look at cooperation from a different angle and add some advice on how to improve it. I hope to hear such opinions, whether in response to this newsletter or in public discussion.

When organizing and conducting cooperation, it is worth paying attention to the following issues:

1. Certification schedule. At the beginning of the cooperation, it is worth defining it in as much detail as possible. This will allow us to arrange the work in such a way that it does not become an excessive burden in the last weeks or days before the report is approved for publication. It also allows us to reserve the time of various people and organizational units in the company in advance, whom the auditor will contact, for example, to obtain relevant evidence. If an external advisor is involved in the process of working on the report, it is best to develop the schedule with their participation as well. And let's remember that these arrangements must be adhered to by all parties involved. Unannounced deviations from the schedule must be responded to quickly and decisively, regardless of which party is responsible for them.
2. A structured approach to evidence collection. Disorganized documentation confirming source data, the existence and functioning of specific policies, or the implementation of measures causes perhaps the most problems in the entire attestation process. Order and standardization in how evidence is collected and provided to the auditor is particularly important in larger and more complex capital groups.
3. Use preliminary certification to the greatest extent possible. It should take place as early as possible and cover as wide a scope as possible. This should prevent situations where, during the actual certification, we return to discussions about the results or the process of testing significance, or to discussions about whether the scenarios for analyzing climate risks and opportunities have been properly selected. All of this (and many other elements) should be verified by the auditor in advance. It is worth ensuring that the audit team confirms which elements of the audit have already been completed, even if this has already been established in the schedule. It is difficult to consider reopening closed topics (unless new external circumstances have arisen) to be professional.
4. Efficient use of the materiality filter. Not all disclosure requirements and data points of a given standard apply when our material impact, risk, or opportunity is thematically related to that standard. The rules on materiality are set out in Chapter 3 of ESRS 1 and are worth reviewing before the next reporting cycle. It should also be remembered that it is the company that decides how to apply the materiality criteria to the metrics.

I would like to emphasize the last sentence: it is the company that decides. Not the advisor (although he usually presents his recommendations, which is what he was hired to do), not EFRAG, not the European Commission, not the auditor. The company decides. It decides on the basis of criteria, i.e., it cannot be a matter of whim, but specific criteria, while the manner of establishing and applying them is entirely at the discretion of the company.

These are four points that I believe are essential for establishing effective cooperation in the certification of the report. What do you think is important for the audit to run smoothly? If you have any ideas or suggestions, please reply to this newsletter. I am particularly interested in hearing from representatives of audit firms, but also from practitioners who have gone through (easily or with difficulty) the certification of reports for 2024 😊

P.S. I would like to draw your attention to an interesting training course: a six-day course. Sustainable development in practice, organized by UN Global Compact Network Poland in September 2025. It is a very intensive training program conducted by practitioners. One of the days (dedicated to ESRS standards) will be led by MATERIALITY experts. Anyway, read the entire course program yourself, it is available at this address. Until the end of July, you can take advantage of a discount of 10% 😊