Article 1 changes who may be approved as an audit firm, who may sign a sustainability assurance engagement, when the assurance standards arrive and how a third-country auditor is registered for sustainability work.
The article makes five changes to the Statutory Audit Directive. The first rewrites the approval conditions in Article 3(4): the natural persons who carry out statutory audits on the firm's behalf must meet the statutory auditor conditions in Articles 4, 6(1), 7(1), 8(1) and (2), 9, 10(1) first subparagraph, 11 and 12, and must be approved in the Member State concerned. A majority of the voting rights must sit with approved firms or with natural persons who meet those conditions. A majority, capped at 75 percent, of the members of the administrative or management body must be approved firms or qualifying natural persons. Where the body has two members or fewer, one must qualify. Member States may add conditions only on the management-body point, and only where proportionate.
The second change concerns the key sustainability partner. When an audit firm carries out assurance of sustainability reporting, it must designate at least one key sustainability partner. That person must satisfy Article 4 and Articles 6 to 12 and be approved as a statutory auditor in the Member State. The partner may also be a key audit partner. The firm must give the partner sufficient resources and personnel with the competence and capabilities the role needs.
The third change sets a deadline for limited assurance standards. The Commission must adopt delegated acts by 1 July 2027 that set out the procedures for the assurance engagement, including planning, risk consideration, the response to risks and the type of conclusion. The standards must have been developed with due process, public oversight and transparency, must contribute to credibility and quality, and must be conducive to the Union public good.
The fourth change inserts a transitional registration route for third-country auditors and audit entities. For assurance reports on annual or consolidated sustainability reporting issued for financial years starting between 1 January 2025 and 31 December 2030, a third-country auditor may be registered under a lighter regime by giving the competent authority six items: identity and legal structure, a declaration of sustainability knowledge, a description of any network, the assurance standards and independence requirements applied, a description of the internal quality control system for sustainability assurance, and the date and outcome of the last quality assurance review. If any item is missing, the authority must not register the auditor. The fifth change extends the delegated power in Article 48a(2) for the assurance standards.
Why it matters
The audit market is the delivery route for the limited assurance opinion that every in-scope company needs. If the firm cannot name a qualified key sustainability partner, the engagement cannot be signed in the form the directive requires. The third-country route matters to groups whose parent is outside the Union and whose assurance provider is not established in a Member State.
Dates
Transposition for Article 1 is due by 19 March 2027 (Article 5(1)). The Commission's limited assurance standards are due by 1 July 2027 (Article 26a(3) as amended). The third-country transitional registration covers financial years starting from 1 January 2025 to 31 December 2030.
What to do
- Check the firm's approval file against the three tests in the new Article 3(4): who signs, who holds the voting majority, and who sits on the management body.
- Name the key sustainability partner in the engagement letter and keep the approval record with the engagement file.
- For a third-country provider, assemble the six registration items before the first assurance report is issued.
The duty records in Article 1
| Code | Duty | Citation |
|---|---|---|
A1-1 | Audit firm approval | Article 1(1), replacing Article 3(4) of Directive 2006/43/EC |
A1-2 | Key sustainability partner | Article 1(2), replacing the second subparagraph of Article 24b(1) of Directive 2006/43/EC |
A1-4 | Third-country auditor registration | Article 1(4)(b), inserting Article 45(5b) of Directive 2006/43/EC |
Source
Article 1, amending Directive 2006/43/EC, Directive (EU) 2026/470, OJ L 2026/470, 26 February 2026. Our statement, not the instrument verbatim.
Not legal advice; does not certify. A reading of the article and the duties inside it, not a substitute for the Official Journal text or the national transposing measure.