CA ANZ is broadly supportive of the proposals to amend Sections 390, 290 and apply to proposed Section 5390 (sustainability assurance), subject to some practical considerations. We support the use of a principles-based approach to developing the proposals.

CA ANZ raised concerns regarding the following proposals:

• The exclusion of "experience" in the proposed definition of expertise
• The applicability of the CCO framework regardless of the scope, importance or materiality of the work the expert is engaged to complete
• The practicality of assessing independence of the experts' team where non Professional Accountant experts may not have systems in place to support the scope, extent and continuous reporting requirements
• The need for a prohibition where CCO requirements cannot be met rather than a requirement to apply the conceptual framework.  CA ANZ does not support the proposed prohibition
• The impact on the availability of experts due to the application and extent of the CCO framework coupled with independence requirements akin to what is required for the audit and engagement team.
• Whether the independence requirements placed on experts achieve the right balance for their contribution to an audit or assurance engagement.
• The impact that the availability of experts may have on SMPs and SMEs to provide either expert services or audit and assurance engagements.
• The period for which objectivity requirements apply to the expert.