Sustainability

Approval of Sustainability Assurance Service Providers (SASPs)

Approval of Sustainability Assurance Service Providers (SASPs)

Introduction


The Corporate Sustainability Reporting Directive (CSRD) provides transitional provisions for the approval of statutory auditors as Sustainability Assurance Service Providers (SASPs), for the first two years of the operation of the directive i.e., between 1 January 2024 and 31 December 2025.

During this time statutory auditors already approved or those who complete the process of approval for the purposes of statutory audit in accordance with Bye Law 13, Practice and Audit Regulations, by 1 January 2026, will not have to fulfil the training requirements (exam/test and practical experience) for the assurance of sustainability reporting which will be required when the CSRD is fully implemented. These individuals will however need to undergo continuing education relating to the assurance of sustainability reporting.

It is noted that transposition of the CSRD in Ireland is in progress, and the requisite powers to carry out approval functions are not yet provided for. However, CPA Ireland is actively preparing for the implementation of the legislation. In this regard the Registration Committee have set out their expectations and guidelines as follows;
 
  • Becoming a Sustainability Assurance Service Provider – who can apply?
    Individuals who are approved as statutory auditors by CPA Ireland before 1 January 2026, can avail of transitional provisions for authorisation as a Sustainability Assurance Service Provider (SASP) subject to undertaking appropriate CPD to acquire the necessary knowledge of sustainability reporting and the assurance of sustainability reporting.

    Such statutory auditors include members, affiliated partners and responsible individuals approved as statutory auditors in accordance with Bye Law 13, Practice and Audit Regulations. The following individuals are eligible to apply:
     
    • Member of CPA Ireland, holding a CPA practising certificate with audit qualification and approved by CPA Ireland as a statutory auditor
     
    • Member of another Recognised Accountancy Body with a practising certificate with audit qualification from this body and approved by CPA Ireland as a statutory auditor and an affiliated partner
     
    • Member of another Recognised Accountancy Body with a practising certificate with audit qualification from this body and approved by CPA Ireland as a statutory auditor and a Responsible Individual (employee in firm)
  • What are the CPD requirements for an applicant?
    An applicant is required to have completed appropriate CPD to acquire the necessary knowledge of sustainability reporting and the assurance of sustainability reporting, including the following subjects in respect of the assurance of sustainability reporting:
    • Legal requirements and standards relating to the preparation of annual and consolidated sustainability reporting;
    • Sustainability analysis;
    • Due diligence processes with regard to sustainability matters;
    • Legal requirements and assurance standards for sustainability reporting.
    The relevant CPD can consist of both structured and unstructured learning and must be achieved prior to approval as a SASP.  CPA Ireland expects a SASP applicant to have undertaken a minimum of 60 hours of study, a portion of which should be structured, during the two years prior to application.

    An applicant must provide a detailed analysis of their structured and unstructured learning in their application. Sufficient detail must be provided by the applicant sufficient to enable CPA Ireland to determine that they have acquired the necessary knowledge of sustainability reporting and assurance of sustainability reporting. Given the evolving nature of expertise in this area experiential and other sources of learning may be included in the application.
     
  • How do I make an application?
    The Registration Committee have made available a Sustainability Assurance Service Provider application form for the purposes of preparing to make an application.

    Please note that transposition of the CSRD in Ireland is in progress, and the requisite powers to carry out approval functions are not yet provided for. CPA Ireland cannot yet approve an application for a SASP, however are happy to review a proposed application.

    Queries and expressions of interest can be sent to Emer Kelly, ekelly@cpaireland.ie
     
  • What happens to a SASP authorisation if my statutory auditor status ceases?
    If an individual surrenders their approval as a statutory auditor, or if it expires, is withdrawn or suspended then the approval as a SASP is similarly ceased, expired, withdrawn or suspended.
     
  • Other considerations - maintenance of competence, ethical standards and quality management systems
    Maintenance of Competence
    It shall be a condition of a statutory auditor’s approval as a sustainability assurance service provider that he or she shall take part in appropriate programmes of continuing education in order to maintain his or her theoretical knowledge, professional skills and values, including, in particular, in relation to the assurance of sustainability reporting, at a sufficiently high level.

    Ethical Standards
    The activities of an individual as a SASP are subject to the provisions of the CPA Code of Ethics related to assurance engagements.

    Quality Management Systems
    When performing an assurance engagement as a SASP, the firm is subject to ISQM1 and any requirements in law or regulation regarding the firm’s responsibility for its system of quality management.