In recent months the Institute has approved certain Institute Registered Auditors (audit firms), and responsible individuals (RIs) at those firms, to carry out sustainability assurance engagements in Ireland, pursuant to the EU Corporate Sustainability Reporting Directive (CSRD) as transposed into Irish law. These are referred to as ‘approved firms’ and sustainability assurance service providers (SASPs) respectively.
The recent Omnibus proposals from the EU Commission have created uncertainty over the scope of the CSRD going forward. Audit firms should be alert to these emerging developments when considering whether and/or when to seek approval to carry out sustainability assurance engagements.
Transitional (‘grandfathering’) arrangements for SASP approval
The EU Omnibus package does not include proposals to directly change the transitional (‘grandfathering’) arrangements for SASP approval. Therefore, it remains the case that an individual approved as a RI in Ireland before 1 January 2026 can avail of transitional arrangements when applying for approval as a SASP. Under those transitional arrangements a RI is eligible for SASP status if he/she undertakes a minimum of 60 hours of CPD in the relevant subjects. Note that a RI who is approved as RI in Ireland before 1 January 2026 does not have to apply for SASP status before 1 January 2026 to be eligible to avail of the transitional arrangements described above.
A person approved as RI on/after 1 January 2026 who applies for SASP status will be required, by law, to complete an examination and 8 months relevant practical experience to gain the sustainability assurance qualification.
Eligibility for approval to carry out sustainability assurance engagements
The eligibility criteria for SASP and firm approval are set out in the Institute’s Audit Regulations (incorporating assurance under CSRD) and Guidance, Ireland (the Audit Regulations). The Institute has prepared FAQs to provide information for audit firms and RIs considering applying for approval to carry out sustainability assurance engagements.
For audit firms who do wish to apply for approval at this time, the audit compliance principal can start the application process by contacting sasp-applications@charteredaccountants.ie to request the relevant application forms. When an audit firm first applies for approval to carry out sustainability assurance engagements at least one RI at the firm must also submit an application for approval as a SASP.
Ongoing obligations of approved firms and SASPs
Once approved to carry out sustainability assurance engagements, an approved firm and SASP have ongoing obligations in relation to SASP CPD, compliance with relevant provisions of the Audit Regulations and annual regulatory fees relating to sustainability assurance approved status.
Regulatory Fees
It is necessary for the Institute to collect regulatory fees to fund the Institute’s work in providing a robust regulatory framework for approved firms and SASPs. Each application for SASP status is subject to an approval fee. From 2026, ongoing annual regulatory fees will also be payable by approved firms.
Applications for RI status in 2025
An applicant for SASP status must be a RI in Ireland. As outlined above, an applicant who is approved as RI before 1 January 2026 can avail of transitional arrangements when applying for SASP status (even where that SASP application is made at a date after 1 January 2026).
If an audit firm wishes to designate new RI(s) during 2025 with the intention of ensuring that the RI status of that person is approved by the Institute before 1 January 2026, the firm is advised to submit application(s) for RI status to the Institute as soon as possible, and at the latest by 1 August 2025.
Early application allows time, in most cases, for assessment of the application by the Institute, including where necessary, consideration by the Quality Assurance Committee, before the end of 2025. The Professional Standards Department cannot provide guaranteed timelines for consideration and approval of RI applications as time required depends on the nature of the application. Complex or incomplete applications for RI status may take longer to process than well-presented, detailed applications which clearly demonstrate an applicant’s competence and experience.
While the transitional arrangements for SASP status may encourage some firms to consider appointing more RIs during 2025 than might otherwise have been intended by the firm, firms are reminded that only appropriately qualified and experienced individuals can be granted RI status in accordance with the Institute’s Audit Regulations.
Application forms for RI status are available on the Institute’s website. Queries regarding RI applications can be directed to authorisations@charteredaccountants.ie.
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