Glossary›Assurance, audit evidence and working papers›Third-party data provider oversight

Glossary term

Cluster A · A47

Tier 1 · differentiator

Third-party data provider oversight

Definition

Third-party data provider oversight is the reporting entity’s responsibility for emissions numbers produced by an outside platform, consultant or data vendor. Outsourcing the calculation does not outsource the accountability. The entity remains responsible for the disclosed figure, and the assurance provider tests the entity’s controls over that provider, not just the output.

· requirements on evidence from external sources and the work of experts ·

In force

In practice

Almost every Australian reporter uses a third party somewhere: a carbon accounting platform, an ESG consultancy, a travel agency dashboard, an energy retailer’s reporting portal. The mistake is treating the provider’s output as an answer rather than as an input that has to be understood, tested and owned.

The practical test is whether the entity can explain the number without the provider in the room. Which factor set did the platform apply, in which edition. What did it do with a missing month. How did it map a supplier to a sector. What did it assume where activity data was absent. If the answer to any of those is that the platform does it automatically, the entity has not understood its own disclosure, and it is the directors who sign the report, not the vendor.

There is a second, sharper issue specific to consultants. If the same firm builds your emissions model and also assures your report, that is a self-review threat and, for a public interest entity, it is prohibited under APES 110 rather than manageable. Entities sometimes discover this late, after a platform relationship has become entangled with an assurance relationship through a common parent or network firm.

A written agreement helps disproportionately here. What it needs to cover: which factor sets and editions are used and when they are updated; what happens to underlying data and calculation files when the contract ends; the provider’s obligation to support an assurance engagement, including responding directly to the assurer; and whether the provider will make its own methodology documentation available.

What the assurer does with it

The assurer treats the provider as an external information source and tests two separate things. First, the output: they recalculate a sample of the provider’s figures independently, using their own factor lookup, and agree the inputs back to the entity’s own source documents. Second, and less expected, the entity’s oversight: what review did management perform on the provider’s output, who performed it, when, and what did they do about the exceptions they found. A platform figure accepted without review is a control failure even where the figure is correct. They accept a provider’s output supported by documented methodology, a stated factor set and evidence of the entity’s own review. They reject a number the entity cannot explain, a provider that will not release the underlying calculation, a factor set the entity cannot name, and any arrangement where the entity’s only record of its own emissions lives in a system it does not control. Expect a direct question about whether the provider has any relationship with the assurance firm.

Commonly confused with

Assurance. A platform calculating your emissions is not assuring them, and a vendor’s internal “verification” badge is not an assurance conclusion under ASSA 5000. And with an outsourced preparer, which is a different arrangement with the same accountability rule: management makes the judgements.

Timing and relief

None specific. The oversight obligation attaches from the first reporting period, for Scope 1 and Scope 2 figures produced by a platform, and extends to the Scope 3 categories as they come into scope from the second.

Sources

1

ASSA 5000 General Requirements for Sustainability Assurance Engagements

AUASB

2

APES 110 Code of Ethics for Professional Accountants (including Independence Standards)

APESB

Review status

Review required

Last reviewed

15 September 2026

Editorial pass, unsigned

Reviewer required

Registered company auditor

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.

Where this sits commercially

Carbonhalo hands over the calculation files and the methodology, not just a number.