The auditor or assurance provider must give a limited assurance opinion on whether the sustainability reporting complies with the directive and the ESRS, on the process used to identify the information, on the mark-up requirement and on the Article 8 Taxonomy disclosures, while respecting the right of protected value chain undertakings to decline.
The requirement, in our words
The statutory auditor or other assurance provider must give an opinion, based on limited assurance, on whether the sustainability reporting complies with the Directive and the ESRS, on the process used to identify the information reported, on the mark-up requirement of Article 29d and on the Taxonomy Article 8 disclosures; the reference to SME standards is removed. Member States must ensure the opinion is formed in a way that fully respects the right of value chain undertakings with up to 1 000 employees to refuse data beyond the voluntary standards, so the absence of such data cannot by itself ground a qualified conclusion.
Why it matters
The opinion is the assurance product the market has been waiting for, and the scope is wider than a check of the numbers. It covers the materiality process and the Taxonomy disclosures, which are the two areas most likely to be undocumented. The new paragraph 2a adds a boundary: the assurance work must respect the value chain right to decline information beyond the voluntary standards.
What changed
The old Article 34(1)(aa) required an opinion on compliance with the sustainability reporting requirements. The replacement adds the standards, the process, the mark-up and the Taxonomy disclosures, and inserts the value chain boundary.
What to do
- Agree the assurance scope in writing with the provider, covering the ESRS, the process, the mark-up and the Taxonomy disclosures.
- Prepare the evidence for the materiality process, not only the datapoints.
- Show how the engagement respected a protected supplier's right to decline.
Evidence to have ready
| Category | Artefact |
|---|---|
| Sustainability assurance | Limited assurance report covering ESRS compliance, the materiality process, mark-up and Article 8 disclosures |
| Sustainability assurance | Assurance working paper documenting how value chain gaps from protected undertakings were treated |
| Sustainability assurance | Engagement letter scoping the four subject matters of the opinion |
Common failures
- Assurance conclusion modified solely because small suppliers declined data beyond the voluntary standards
- Opinion silent on the identification process
Dates
Applies to financial years starting on or after 1 January 2027. The Commission's limited assurance standards are due by 1 July 2027.
The question to test
Does the engagement letter cover the process and the Taxonomy disclosures, or only the reported datapoints?
Cross-references
A1-2 Key sustainability partner · A2-4 Value chain cap · A2-15 Collective responsibility
Source
Article 2(12)(a) and (b), amending Article 34(1)(aa) and inserting Article 34(2a) of Directive 2013/34/EU; 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.