CSRD reporting requires external assurance
The CSRD requires assurance for companies in scope. Accountancy Europe explains that the directive introduced an EU-wide requirement for limited assurance over sustainability reporting, beginning with 2024 ESRS reports published in 2025. The later stop-the-clock Directive postponed application for large companies that had not yet started reporting and for listed SMEs, but it did not remove assurance for companies in scope for a reporting year.
An external practitioner examines the sustainability statement and issues a conclusion. Sorena AI ESG compliance helps teams keep the underlying data and evidence traceable.
Assurance tests evidence, not presentation
An assurance engagement tests the reported information. Accountancy Europe describes a risk-based process across planning, execution, and reporting. The practitioner understands the company's environment and internal controls, then gathers and evaluates evidence by asking management, testing controls, analysing transactions and documents, and obtaining third-party confirmations.
KPMG explains that reasonable assurance follows a methodology similar to an audit: understand the company, review its controls, identify risks, and perform detailed testing before forming a conclusion. Limited assurance is less extensive but still tests whether reported figures have support.
Limited and reasonable assurance require different work
The current requirement is limited assurance, while EU law allows a later move to reasonable assurance. The Commission may adopt reasonable assurance standards by 1 October 2028 after assessing whether the transition is feasible for companies and practitioners.
Accountancy Europe explains that a limited engagement uses fewer procedures and gathers less evidence. KPMG compares reasonable assurance with a full audit opinion and limited assurance with a lighter review. Both require evidence, but reasonable assurance involves more extensive testing. Build a traceable process that can support deeper testing if the standard changes.
Build the assurance file behind one ESG number
Pick one reported ESG metric and test its evidence trail. The file should show the source record, reporting period, calculation method, owner, reviewer, version history, assumptions, control performed, exception handling, and final sign-off. If the disclosure is an Article 8 KPI, connect it to the EU Taxonomy eligibility and alignment evidence too.
The process must show where the number came from, who changed or reviewed it, and why the company considers it complete.
No trail, no sign-off
Missing or untestable data can affect the assurance conclusion. KPMG expects modified opinions to be relatively common in the early years when key data is missing or lacks sufficient quality or granularity. KPMG compares this with a qualified audit opinion while noting that it may not be as serious.
A reported number must be traceable to a source. ESG data often lives in spreadsheets, email threads, and one-off extracts that are difficult to reconstruct months later. If the practitioner cannot test a figure, the assurance conclusion may reflect that limitation.
Give ESG data the trail finance already has
Treat ESG data like financial data from the start. Every reported figure should trace to a source, carry an owner, and record how it was produced. An external practitioner can then retrieve and test the evidence instead of stopping at missing data.
Sorena AI Assessment Autopilot builds obligations from authoritative source texts, assigns clear owners, and tracks evidence as work progresses. Humans decide what the company reports; the system keeps every figure traceable to its source and ready for assurance review. When assurance season arrives, the materials should already exist.
EU assurance standards are still developing
The EU's common limited-assurance standard is still being developed. Directive (EU) 2026/470 moved the Commission's adoption deadline from 1 October 2026 to 1 July 2027. Until the EU standard is adopted, Member States may use national assurance standards, procedures, or requirements. The IAASB has also adopted ISSA 5000 as a global sustainability-assurance standard.
Companies cannot choose every standard that may govern an engagement, but they can keep their data sourced, owned, and traceable. That evidence trail supports review under the current rules and reduces rework if the standards change.
Build the report for assurance
For in-scope companies, the sustainability statement is subject to assurance. A practitioner tests evidence, traces figures, and publishes a conclusion. Keep the underlying data sourced, owned, and traceable so each reported figure can be reviewed.
Frequently asked questions
Is sustainability assurance mandatory under the CSRD?+
Yes, for companies in scope for the relevant reporting year. Accountancy Europe explains the [CSRD](/artifacts/eu/corporate-sustainability-reporting-directive) introduced an EU-wide requirement to obtain limited assurance over sustainability reporting from 2025 on 2024 ESRS reports, with the statutory auditor expressing a conclusion. The later stop-the-clock Directive postponed application by two years for large companies that had not yet started reporting and for listed SMEs, but it did not remove the assurance model.
What is the difference between limited and reasonable assurance?+
Accountancy Europe describes limited assurance as involving fewer procedures and less evidence before the practitioner concludes. KPMG compares reasonable assurance with a full financial audit opinion, using a similar methodology of understanding the company, testing controls, and evaluating evidence in detail. EU law allows the Commission to adopt reasonable assurance standards by 1 October 2028 after assessing whether the transition is feasible.
Why does ESG data now need an audit trail?+
Because assurance tests evidence, not narrative. A practitioner gathers evidence, tests internal controls, and traces reported figures to their sources. KPMG expects modified opinions where data is missing or cannot be tested. A sourced, owned, traceable trail, the kind Sorena Assessment Autopilot builds continuously, is what lets a figure survive that examination.
Sources
- Accountancy Europe, FAQs: fundamentals to assurance on sustainability reportinghttps://accountancyeurope.eu/publications/faqs-fundamentals-to-assurance-on-sustainability-reporting/?ref=sorena.io
- KPMG, Limited vs reasonable assurance over ESGhttps://kpmg.com/xx/en/our-insights/esg/limited-vs-reasonable-assurance-over-esg.html?ref=sorena.io
- EUR-Lex, Directive (EU) 2025/794 stop-the-clock amendmentshttps://eur-lex.europa.eu/eli/dir/2025/794/oj/eng?ref=sorena.io
- IAASB, Understanding International Standard on Sustainability Assurance 5000https://www.iaasb.org/focus-areas/understanding-international-standard-sustainability-assurance-5000?ref=sorena.io
- European Commission, Corporate sustainability reportinghttps://finance.ec.europa.eu/financial-markets/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en?ref=sorena.io
- EUR-Lex, Directive (EU) 2026/470 amending corporate sustainability reporting and due diligence requirementshttps://eur-lex.europa.eu/eli/dir/2026/470/oj/eng?ref=sorena.io


