Every auditor has this client. Maybe several of them. Maybe most of them.
They’re a good business, often a very good one. Well run, profitable, sensibly managed by people who know their industry inside out. The financial audit is comfortable and familiar; you’ve done it for years and you know exactly what you’re dealing with. And now mandatory climate reporting has landed in scope, and you already know, before you even raise it, exactly how the conversation is going to go.
Because this client does not care about climate. It has never been part of how they generate value, and nothing about the new obligation changes that. When you bring it up, you won’t get enthusiasm. You’ll get a sigh, a roll of the eyes, and quite possibly some genuine anger: at the burden, at the cost, at the sheer imposition of being asked to account for something that has nothing to do with why the business exists.
You can’t fix how they feel about it. But you still have to do your job. And too many auditors underplay this: whether that job turns out clean, efficient and predictable, or a painful, margin-destroying scramble, is largely determined by what you do in the early conversations, long before any assurance work begins.
This is a piece about managing that client. Not the technical assurance methodology. You have that. This is about the human and commercial engineering that gets a disengaged, “we’re-nowhere” client to a place where the report is defensible, the audit is manageable, and the relationship survives intact.
Understand what you’re actually dealing with
Start by being honest about the starting point. This client is almost certainly nowhere. No emissions measured, no climate governance, no climate risk process, and no appetite to build any of it. That’s not a mark against them. It’s the normal baseline for the overwhelming majority of businesses now caught by these rules. Competent operators, zero climate infrastructure. If you want a fast way to show them the gap, walk them through an AASB S2 readiness checklist.
Your challenge is that you can’t build it for them. Separation of duties and independence mean the very things the client most wants to offload, the preparation, the governance drafting, the emissions calculation, are precisely the things you are not permitted to do. You cannot audit your own work. So “I’ll just sort it out for them” isn’t on the table, no matter how tempting it is when a deadline looms.
Which leaves you with a more subtle but far more valuable role: you are the person best placed to steer this client toward help, early, before the situation becomes unrecoverable. That is not overstepping. It is exactly the kind of guidance a trusted auditor should provide. Getting the client to the right independent provider, at the right time, is the most valuable move you can make to protect the engagement, and the client relationship. We’ve written more about that dynamic in why accountants are the natural ally in climate reporting.
Step one: make them name an owner
Before anything else, the client needs to decide who owns this. One person. Not “the team,” not “management”: a named individual, ideally the CFO or another senior operator who understands the business and the industry deeply.
This matters to you specifically, because an unowned climate reporting process is the leading cause of the year-end disaster you’re trying to avoid. If nobody owns it, nothing exists when you arrive to test it. When you nudge the client on this, you’re not being pushy. You’re preventing the exact scenario that blows up your audit timetable. Our guide to climate governance frameworks for Group 2 and 3 entities is a useful thing to hand a reluctant CFO.
The client’s chosen owner will resist. They’ll say they’re already stretched, that it isn’t their area, that they don’t want it. They may kick and scream. That’s fine, expected even. The message the client’s leadership needs to deliver, and that you can quietly reinforce, is simple: own it anyway, and get on with it. Clear ownership is what gives the whole process a spine, and a process with a spine is one you can actually audit.
Step two: get them to the right help, and this is your responsibility
This is where the auditor’s role becomes decisive.
The client can, and should, outsource the overwhelming majority of this work. They are not expected to build an in-house climate function. They need a good provider, and if it’s the right one, it won’t cost anywhere near what the client fears. The comparison between Big 4 and specialist consultants is worth reading before you make an introduction.
But not any provider will do. And steering the client toward the right one is, frankly, part of doing your job well. You have a direct interest in who they engage, because the quality of that provider determines the quality of what eventually lands on your desk for assurance. The right partner for this kind of client (the disengaged, starting-from-nothing client) is someone who:
- Is skilled at exactly this situation. Not a provider who needs a motivated, climate-literate client to function, but one who is comfortable walking a reluctant business from zero to a defensible report with minimal internal drama.
- Produces assurance-ready output. A clean audit trail, coherent narrative, defensible methodology, complete data. The kind of workpapers that make your engagement manageable and predictable rather than a series of unpleasant surprises.
- Keeps the client’s internal effort small, so the client stays cooperative rather than resentful, which, in turn, keeps your fieldwork smooth.
A good provider makes your audit lean, well-managed, and predictable. That protects your margin and it produces a happy client. A poor provider, or no provider until the last minute, does the opposite. So pointing your client to the right help early isn’t a favour to them. It’s how you protect your own engagement economics and your relationship with the client at the same time. It is core to the job. The eight questions to ask an AASB S2 consultant make a good filter to hand over.
What the right provider will actually do
When you’re assessing whether a client’s chosen provider is up to the task, this is the pattern a good one follows. You want to see all of it, because each element maps directly to something you’ll need to assure.
They diagnose the current state honestly. They start from “you’ve done nothing,” aren’t fazed by it, and treat it as the normal baseline.
They map existing governance: no new structures, no new hires. A good provider works out where climate governance fits into the management structures the client already has, rather than inventing a climate department. For you, this means the governance you’ll be testing is real and embedded, not a hollow shell created for show.
They assess existing risk management and set up a climate framework quickly. Most existing risk processes don’t quite fit climate, so a good provider stands up a simple, fit-for-purpose climate risk framework, a matter of minutes to establish the structure. Again, this gives you something concrete and methodical to assure.
Then they build the path forward, which typically runs several workstreams in parallel:
A sustainability committee charter built on existing people and meetings. The provider drafts a charter or terms of reference for a sustainability committee staffed by existing managers operating within an existing management meeting structure. On paper it’s proper governance; in practice it’s the client’s regular leadership forum with a standing agenda item. From your seat, it’s genuine, testable oversight, not an empty box.
A pre-scanned list of climate risks and opportunities for the client to score. Rather than making a disengaged client invent risks from scratch, the provider runs a market scan of similar businesses in their industry and hands over a ready-made list. The client’s only job is to score them using their deep business knowledge. This is one of the few genuinely internal tasks, and it produces the documented judgement you’ll want to see behind the risk disclosures.
Scenario analysis and detailed risk scoring, done by the provider. The client returns the scored list; the provider generates the scenario analysis and detailed scoring against the newly established framework. Client judgement in, structured methodology out.
A governance and risk narrative the client is comfortable with. The provider drafts the narrative that links it all together, and because this will be publicly available, the client gets to read, shape and sign off on exactly what’s said about the business before anyone else sees it. A measured, defensible account. No accidental world-saving pledges, no earth-killer tone. For you, an agreed narrative that’s settled early means no eleventh-hour rewrites during fieldwork.
Emissions measurement running alongside. The provider defines the emissions boundary (what to measure), decides what data to collect, and then the client’s financial controller or analyst collects data that usually already exists in the systems. The provider reviews it, assesses completeness, and does the carbon accounting calculation. This is the workstream you’ll scrutinise most closely, particularly around Scope 3 emissions, so a provider who builds completeness and traceability in from the start is doing half your evidence-gathering for you.
Assembly into a finished draft with a full audit trail. Everything comes together as a final report draft, complete with the audit trail and agreed narrative, structured for a smooth approval, and a smooth assurance process.
Why this makes your job manageable
Add up the client’s internal effort across all of that and it’s small: a few hours on disclosures, a few hours collecting data. The rest sits with the provider. A light internal load keeps the client cooperative and keeps the process from stalling.
For you, the payoff is the thing you actually care about: a report that arrives with defensible governance, a coherent risk framework, complete and traceable emissions data, an agreed narrative, and a clean audit trail. That is an engagement you can plan, resource and price with confidence. Lean, well-managed, predictable: exactly the audit that protects your margin and leaves the client feeling well served. ASIC is satisfied, the client’s owners are satisfied, and you’ve delivered the assurance without it becoming a fire drill.
The one thing that will wreck all of it: leaving it late
This is the point to hammer with these clients, because it’s the one that determines everything.
You cannot assure processes that didn’t exist. If the governance committee, the risk framework and the data collection are all conjured up in the final fortnight, there’s nothing real to test, and no amount of scrambling makes retrofitted governance look genuine. It won’t stand up, and you’ll be the one who has to say so. This only gets sharper as assurance requirements phase up to 2030.
Start the client early and those processes have time to actually operate, giving you real, testable subject matter. There’s a commercial dimension for the client, too: leave it late and there are fewer good providers with capacity, less room to negotiate, and a narrower choice of who they work with. Early movers get better service for less; late movers get whoever is left, at a premium, and then you inherit whatever mess that produces.
This is why the timing conversation is yours to lead. Raise it early, well before year-end, and frame it plainly: the client’s own experience of this audit will be far better if the help is in place now. You’re not nagging. You’re protecting them from a predictable and entirely avoidable disaster, and protecting your own engagement in the same move.
The bottom line for the auditor
Managing a disengaged climate reporting client isn’t hard, but it isn’t passive either. Your job is not to prepare the report; you can’t. Your job is to recognise early that the client is nowhere and doesn’t care, to push them to name an owner, and to steer them toward a provider genuinely skilled at these situations, one who will make your assurance manageable and predictable rather than chaotic.
Do that early, and the engagement becomes what you want every engagement to be: clean, efficient, defensible, and profitable, with a client who ends up better off than they expected. Some of these clients even discover the narrative wins them business, or that their staff quietly value the effort. You don’t have to promise them that. You just have to get them moving.
The clients who don’t care are exactly the clients who need you to care about the timing and the help, early, and on purpose. Get that part right and the rest of the audit takes care of itself.
Advising a client who’s nowhere on climate reporting? Refer them to CarbonHalo and we’ll get them to an assurance-ready report with minimal internal effort.
