The CAQ is pleased to share our views related to the California Air Resources Board (CARB) Information Solicitation to Inform Implementation of California Climate-Disclosure Legislation: Senate Bills 253 and 261, as amended by SB 219.
Given our role, our comments are focused on the assurance-related aspects of the solicitation. Our response highlights the benefits of assurance, the benefits of assurance engagements performed by professional accountants, and provides insights into key considerations for CARB in drafting the assurance-related aspects of the upcoming regulation. Our letter provides insight into the following key elements that the CARB should incorporate into the regulation as the assurance requirements are drafted:
- Recognized reporting standards should be specified to enable assurance
- Acceptable assurance standards should be specified
- Levels of assurance should be specified
- Minimum requirements for assurance providers should be specified
- The importance of oversight of assurance providers
We are pleased that certain key elements are already included in SB 253 (i.e., specifying use of a recognized reporting standard and specifying the levels of assurance required). To promote consistent, comparable, and reliable assurance, we encourage the CARB to incorporate the remaining elements, leveraging the existing assurance ecosystem, to help maximize the benefits that can be derived from assurance engagements.
Read the full comment letter here.