The APESB exposure draft (ED 01/25) proposes amendments to APES 110 Code of Ethics for Professional Accountants (including Independence Standards) (the Code) to:

• Introduce a new standalone Part 5 – Australian Ethics Standards for Sustainability Assurance (Including International Independence Standards) (AESSA) – applicable to any practitioner undertaking a sustainability assurance engagement. 
• Revise Parts 1 to 3 of the Code to reflect sustainability reporting considerations for professional accountants.
• Make consequential and conforming amendments to Parts 1 to 4B of the Code.

We support the APESB’s proposal to incorporate the recent revisions made by the International Ethics Standards Board for Accountants (IESBA) to the International Code of Ethics for Professional Accountants (including International Independence Standards) (the International Code) into the Code. Against this backdrop of support, in our submission we raise the following concerns:

• The challenging nature of the value chain component independence provisions – we recommend aligning the operative date with the equivalent provisions in the International Code and conducting a pre-implementation review.
• The public disclosure of fee information for PIEs by the sustainability assurance practitioner.
• Operationalising the transitional provisions for long association.
• The definition of “sustainability information” differs to that in ASSA 5000.
• What constitutes a “general purpose framework” in the Australian context, and therefore what in is scope of the Independence Standards in Part 5.
• For voluntary sustainability assurance engagements, whether the requirements will be consistently applied by assurance practitioners from different professional backgrounds, and disparity in monitoring and enforcement processes for non-professional accountant practitioners compared to professional accountants.