Glossary›Assurance, audit evidence and working papers›Preparer / assurer separation
Glossary term
Cluster A · A21
Tier 1 · differentiator
Preparer / assurer separation
Definition
Preparer and assurer separation means the party that builds the climate disclosure is not the party that gives assurance over it. It is the operating consequence of the APES 110 independence rules. The preparer can be internal staff or an independent third party, provided that party has no assurance role for the same entity.
On this page
In practice
The separation is structural, not a preference, and it produces a specific set of workable arrangements.
Workable: internal team prepares, external firm assures. Independent third party prepares, the entity’s audit firm assures. Independent third party prepares, a different firm assures.
Not workable for a public interest entity: the assurance firm builds the emissions model or drafts the disclosures, then assures them.
The boundary that matters is decision ownership, not keystrokes. A preparer can build the model, run the calculations and draft the text, and the disclosures remain management’s, provided management understands the judgements, has the information to evaluate them, makes the decisions and takes responsibility for the result. A preparer who makes the judgements without management’s informed involvement creates a problem regardless of who they are.
What the assurer does with it
The assurer asks directly who prepared the report, what the preparer decided, and what management decided. They look for evidence that management engaged with the significant judgements: a judgement register with named approvers, minutes showing the boundary decision was taken by management, review sign-offs. Where the preparer is a third party, the assurer also wants to know whether that party has any other relationship with the entity that could affect the assurance. A significant judgement register with management sign-off is the cheapest way to answer all of this.
Commonly confused with
Outsourcing. Separation is about independence, not about whether the work is done in-house.
Sources
1
APES 110 Code of Ethics for Professional Accountants (including Independence Standards)
APESB
2
Review status
Review required
Last reviewed
15 September 2026
Editorial pass, unsigned
Reviewer required
Registered company auditor with APES 110 expertise
Next scheduled review
1 July 2027
Part of
Cluster A, Assurance, audit evidence and working papers
47 terms on what an assurance provider tests, what they accept as evidence, and what a preparer has to be able to produce.
Related terms
The principle the separation implements
The threat separation is designed to avoid
Who can sit on the assurance side of the line
Related questions
Does our preparer need to be independent of our auditor?
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No rule requires your preparer to be independent. The rule runs the other way: your assurance provider must be independent of what they assure. In practice that means the preparer and the assurer cannot be the same firm or network, so the preparer must sit outside your assurance provider.
Will our auditor accept a report prepared by a third party?
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Yes. Who drafted the report is not an assurance issue, because the disclosure belongs to management whoever prepared it and the directors sign the declaration. What the practitioner tests is the evidence behind the numbers, so a third-party preparer removes the independence problem without creating a new one.
Our auditor said they cannot do this. Who should we use instead?
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Because your auditor cannot prepare a disclosure they will later assure, the work goes to someone independent of them. Your realistic options are another audit firm outside your auditor’s network, a specialist disclosure preparer, or an in-house build. Independence from your assurance provider is the binding constraint, not size or brand.
Where this sits commercially
Carbonhalo sits on the preparer side of the line, permanently.
Other terms in this cluster
Preparer / assurer separation