The IESBA exposure draft (ED) proposes amendments to the Code to:

• Introduce a new standalone Part 5 applicable to any practitioner undertaking a sustainability assurance engagement (IESSA).
• Revise Parts 1 to 3 of the extant Code to reflect sustainability reporting considerations for professional accountants.
• Make consequential amendments arising from IESSA, including the Glossary.

We support, in principle, the direction that the IESBA has taken in developing ethics and independence requirements that will set the global baseline for sustainability assurance initially. Against this backdrop of support, in our submission we raise the following concerns:

• The ED is long and complex. The IESBA will likely need to produce application guidance on a scale not seen before.
• Monitoring and enforcement of non-professional accountant practitioners will be critical to prevent regulatory arbitrage.
• There are some potential gaps in requirements for group sustainability assurance engagements.
• The practicalities of obtaining statements of independence from sustainability assurance practitioners who perform assurance work at value chain entities.
• The absence of a transitional provision for non-assurance services.
• The treatment of sustainability assurance engagements as non-assurance services in the context of fees.
• The requirement for the sustainability assurance practitioner to publicly disclose fee information for PIEs.