“There is a consensus that in future the audit of sustainability reporting should be placed on the same qualitative level as the audit of financial reporting. Should the legislator decide to deviate from the government draft and allow other providers of assurance services in addition to auditors for the statutory assurance of sustainability reports, it must be ensured under European law that they are subject to the same requirements as auditors. This is not about a special regulation for auditors or restrictions on competition in favour of auditors. It is about ensuring the same quality requirements and competitive conditions for all.

Article 34 of the European Accounting Directive, as amended by the CSRD, sets out in detail the equivalence requirements for providers of assurance services. This means in particular:

• As with auditors, strict requirements must be set for the independence of auditors and their companies.
• As with auditors, a legally regulated supervisory system must be created that effectively monitors and sanctions all requirements, including the imposition of professional bans.
• As in the case of auditors, knowledge of auditing must be demonstrated through a state examination with written and oral examinations and, in future, CSRD knowledge must also be demonstrated through further examinations.

This is the only way to ensure the quality of the audit and compliance with EU requirements.”

Detailed information on the equivalence requirements can be found in the Chamber of Public Accountants' position paper on CSRD implementation “Ensuring the requirements of a level playing field” dated June 21, 2024 (in German).