Who will investigate all this, and how?

According to the CSRD directive, reports will be subject to limited assurance certification. This is a level of examination similar to a review of semi-annual financial statements. After three years, the European Commission will assess whether the level of certification is sufficient. If it turns out that it is not, and if the Commission issues a standard for the audit of reports, a decision may be made to introduce so-called reasonable assurance. This, in turn, is a level similar to an annual audit of financial statements.

Sustainability reports will be audited by auditing firms, the same ones that currently audit financial statements. The directive provides member states with an additional option: each country may decide whether to allow other entities, i.e., independent certification service providers, to verify reports. Whether this will also be the case in Poland remains to be seen, as the implementation of the directive into Polish law is still pending.

Each attestation service is performed by certified auditors in accordance with specific standards and procedures. With regard to sustainability reports, there is currently KSUA 3000 (National Standard for Attestation Services other than Examination and Review 3000). An international standard should also be issued soon. ISSA 5000 (International Standard on Sustainability Assurance 5000), the draft of which was submitted for public consultation in 2023. Both standards are general in nature, i.e., they have not been adapted to ESRS standards. From my conversations with various auditors in recent weeks, it appears that it is not yet clear which of these standards will form the basis for the verification of reports for 2024. However, this should become clear in the coming months.

Apart from the choice of certification standard, there is another, even more serious problem concerning the examination of reports. It concerns the lack of a sufficient number of certified auditors who can handle all certifications. However, this is a topic to be discussed in one of the next posts.