A third-country auditor or audit entity may be registered under a transitional regime for sustainability assurance reports covering financial years from 2025 to 2030, but only if it gives the competent authority all six listed items.
The requirement, in our words
For assurance reports on yearly or group sustainability reporting for financial years beginning for the years 2025 through 2030, a third-country auditor or audit entity is registered under a lighter regime if it gives the competent authority: its name, address and legal structure; a declaration that the signing auditor has acquired sustainability reporting and assurance knowledge, with its level; a description of any network it belongs to; the assurance standards and independence rules applied; a description of its internal quality control system for sustainability assurance; and whether and when its last quality assurance review for such engagements took place and its outcome. Missing any item means no registration. The board-equivalence test in Article 45(5) now excludes the sustainability-specific qualification articles.
Why it matters
The route keeps assurance available during the first years of the new regime without opening the full third-country equivalence process. It is a registration, not an equivalence decision, and the authority must make clear that the registration is under the transitional regime. The six items give the authority enough information to identify the auditor, understand the network and see the quality control behind the opinion.
What changed
Article 45 gains a new paragraph 5b. It sits alongside the existing third-country paragraphs 1 to 5a and disapplies them for sustainability assurance in the stated period, on condition of registration.
What to do
- Assemble the six items as one registration file, with the date of each submission.
- Obtain the signed declaration on the signing auditor's sustainability knowledge and the level of that knowledge.
- Do not issue the assurance report until the authority confirms the registration.
Evidence to have ready
| Category | Artefact |
|---|---|
| Third-country auditor registration | Registration application file containing all six information items with dates of submission |
| Third-country auditor registration | Signed declaration on the signing auditor's sustainability knowledge and its level |
| Third-country auditor registration | Copy of the last quality assurance review report for sustainability engagements, or a statement that none has taken place |
Common failures
- Assurance report issued before the registration was confirmed by the competent authority
- Quality control description that covers financial audits only and is silent on sustainability assurance
Dates
The transitional regime covers financial years starting between 1 January 2025 and 31 December 2030. The national measure is due by 19 March 2027.
The question to test
Which of the six items is missing from the file, and has the authority confirmed the registration in writing?
Cross-references
A1-2 Key sustainability partner · A2-16 Limited assurance
Source
Article 1(4)(b), inserting Article 45(5b) 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.