Can our auditor prepare our climate report?

Usually not, and it turns on whether they will also assure it. Preparing a disclosure you later assure is a self-review threat under APES 110, and for a public interest entity that threat cannot be reduced to an acceptable level, so the service is prohibited. Other entities need a case-by-case assessment.

Does APES 110 stop our audit firm from helping us?

Not entirely. APES 110 prohibits your audit firm from assuming management responsibility, and prohibits non-assurance services that create a self-review threat for a public interest entity audit client. Advice, training and review of work you prepared and own may still be possible, but preparing the disclosure itself generally is not.

What is the self-review threat and why does it apply to us?

A self-review threat arises when a firm has to evaluate its own earlier work. If the firm that built your emissions inventory then gives an assurance conclusion on it, it is checking itself. APES 110 treats that as a threat safeguards generally cannot fix for a public interest entity.

Glossary›Regulation, capture and thresholds / Regulation, capture and timing›APESB

Glossary term

Cluster B · B22

Tier 2

APESB

Definition

The Accounting Professional and Ethical Standards Board issues the ethical and professional standards binding Australian accountants, including APES 110 Code of Ethics and APES 305 Terms of Engagement. Its independence requirements determine what services an assurance firm may provide to a client whose sustainability report it assures, and are the reason preparation and assurance are usually separated.

Accounting Professional and Ethical Standards Board

· APES 110 and APES 305, plus the Amending Standard for Sustainability Assurance and Reporting and the use of External Experts issued 8 July 2025 ·

In force

On this page

In practice
What the assurer does with it
Commonly confused with
Timing and relief
Sources
Related terms
Related questions

Cluster

B · Regulation, capture and thresholds / Regulation, capture and timing, 26 terms

In practice

The APESB is not a government body and its standards are not legislation. It is established by CPA Australia, Chartered Accountants Australia and New Zealand, and the Institute of Public Accountants, and its standards bind their members. For statutory assurance work that distinction has no practical effect: compliance with APES 110 is effectively mandatory for anyone performing it.

Why a CFO cares. APES 110 is the reason your audit firm may decline to build the emissions inventory it will later assure. The self-review threat provisions prevent a firm evaluating its own prior work, and for a public interest entity the threat cannot be reduced to an acceptable level by safeguards: the service is prohibited outright. That produces the preparer and assurer split, and the referral pattern that follows from it.

The 2025 amending standard. APES 110 was extended to sustainability assurance specifically by an amending standard issued 8 July 2025, effective 1 January 2026, which imported the international ethics requirements for sustainability assurance and added requirements for the use of external experts. The external expert provisions matter to a first-time reporter, because sustainability engagements routinely involve specialists (scenario modellers, engineers, emissions practitioners) and the standard now sets expectations about how an assurance firm evaluates and uses them.

APES 305 covers terms of engagement, including the disclosure of outsourced work. It is short, it is rarely discussed, and it is the standard that requires clarity about who is actually doing the work you are paying for.

What the assurer does with it

The firm applies APES 110 at engagement acceptance and continuously thereafter, mapping every service it and its network firms provide to the entity against the independence prohibitions. The entity-facing consequence is a set of questions: who prepared the disclosures, what role any adviser played, and whether management made and owns the judgements. The answer the firm needs is that management took responsibility. An adviser described as having made the decisions creates a problem for the entity, not only for the adviser. The firm also provides a written independence declaration identifying which report it relates to, and must reassess if circumstances change mid-year: for example if the firm’s consulting arm wins work that ends up touching the emissions data.

Commonly confused with

The Corporations Act independence provisions in Part 2M.4, which are separate, narrower and also apply. Both bind the same engagement. Also confused with the AUASB, which sets what the assurer must do rather than who may do it.

Timing and relief

The Amending Standard for Sustainability Assurance and Reporting and the use of External Experts was issued 8 July 2025 and took effect 1 January 2026. Optional transitional relief is available for sustainability assurance engagements in tranches; confirm the current tranche dates with the practitioner, because they determine when the full independence provisions apply to your engagement.