A few examples of ESG attestation reports in SEC filings

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– So far, only a handful of companies have provided ESG attestation reports in their SEC filings.
– It’s too early to tell if this will be a real trend.

Recently, the AICPA and CAQ jointly issued this 28-page paper with an overview of ESG reporting and the related risk and legal considerations for reporting ESG information in SEC filings – and engage an independent auditor to perform an attestation engagement related to such information (here’s a subsequent paper from the CAQ with a deeper dive). This is a hot topic. Could be big bucks for the auditors.

On pages 5-6, the paper notes that so far, two US registrants and several Foreign Private Issuers have included – or referred to – an attestation report in a SEC filing. Start of a trend? Probably too early to tell.

The paper notes that nearly 30% of the companies reporting provided some sort of external assurance for some or all of their E&S disclosures in 2019, slightly over half being engineering firms providing the assurance and then independent auditors and consulting firms splitting the remaining half. By the way, you may want to check out the appendices of the report:

– Appendix 1 includes an overview of the SASB, GRI, TCFD and Integrated Reporting Framework standards
– Appendix 2 lists the various AICPA sustainability attestation resources
– Appendix 3 recommends governance processes in the attestation context