When an audit firm carries out sustainability assurance, it must designate at least one key sustainability partner who is an approved statutory auditor, meets the general conditions, and has enough resources and competent personnel to do the work.
The requirement, in our words
When an audit firm performs assurance of sustainability reporting it must name at least one key sustainability partner. That partner must meet the general statutory auditor conditions (Article 4 together with Articles 6 to 12) and be approved as a statutory auditor approved in that Member State; a key audit partner may fill the role. The firm must give the partner enough resources and competent, capable staff to carry out the engagement properly.
Why it matters
The role is the sustainability counterpart of the key audit partner. It puts a named, approved person at the centre of the engagement, rather than leaving the work to a specialist team without a statutory auditor accountable for the conclusion. The partner may also be a key audit partner, so a smaller firm does not have to create a second role where one person can carry both.
What changed
The old text referred to the key sustainability partner but did not spell out the approval condition in the same sentence. The replacement makes the approval in the Member State explicit and adds the resource and competence duty on the firm.
What to do
- Name the key sustainability partner in the engagement letter and in the planning memo.
- Keep the evidence that the partner is approved as a statutory auditor approved in that Member State.
- Record the resources and the competence of the team the firm gives the partner, including any specialist who is not a statutory auditor.
Evidence to have ready
| Category | Artefact |
|---|---|
| Engagement staffing | Engagement letter or planning memo naming the key sustainability partner |
| Engagement staffing | Approval record showing that partner is a statutory auditor in the Member State |
| Engagement staffing | Resource plan listing team members, hours and sustainability competence for the engagement |
Common failures
- Sustainability engagement led by a specialist who is not an approved statutory auditor
- No documented check that the team has the skills the engagement needs
Dates
Transposition by 19 March 2027. The Commission's limited assurance standards, which shape the engagement the partner signs, are due by 1 July 2027.
The question to test
If the sustainability work is led by a specialist who is not an approved statutory auditor, who signs and on what authority?
Cross-references
A1-1 Audit firm approval · A2-16 Limited assurance
Source
Article 1(2), replacing the second subparagraph of Article 24b(1) of Directive 2006/43/EC; OJ L 2026/470, 26 February 2026; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026L0470. Our statement of the duty, read from the Official Journal text and the held control record, not the instrument verbatim.
Not legal advice; does not certify. A reading of the duty and the evidence commonly sampled, not a substitute for the Official Journal text, the national transposing measure or your auditor's judgement.