” … the limited assurance of these public accountant’s sustainability letters provides, in certain respects, even less assurance than detailed agreed-upon procedure letters…. [T]he limited assurance letters in these sustainability reports contain very little detailed information and only reach vague, double-negative conclusions regarding the findings.”
– Michael Kraten, “Sustainability Reports and the Limitations of ‘Limited’ Assurance.” The CPA Journal (July 2019).
A recent feature for The CPA Journal (July 2019) unmasks the most politicized area of modern accounting, sustainability accounting. 
Following are excerpts from an essay by Michael Kraten (PhD, CPA, CSVP; professor of accounting and chair of the accounting, finance, and economics department at Houston Baptist University), “Sustainability Reports and the Limitations of ‘Limited’ Assurance.”
- “How many standards can a sustainability accountant possibly follow? Three dozen comprehensive standards are published by the Global Reporting Initiative (GRI), and 77 industry-specific standards are issued by the Sustainability Accounting Standards Board (SASB).
- “In addition, 17 sets of metrics are promulgated within the Sustainability Development Goals (SDG) of the United Nations, 15 components of integrated reporting are defined by the International Integrated Reporting Council (IIRC), and the AICPA, not to be outdone, chimed in earlier this year with its new guide, Attestation Engagements on Sustainability Information.
- “Sustainability standards are growing in length and complexity; as a result, the length and complexity of corporate sustainability reports are growing as well. The 2018 sustainability report of Volkswagen (VW), for instance, runs at 108 pages. The report of its European rival Fiat Chrysler Automobiles (FCA) is much lengthier, at 148 pages.”
- “Some analysts complain that such reports are filled with “green-washed” public relations content. Others disagree, claiming that the European Union’s Directive on nonfinancial reporting ensures that the sustainability content is meaningful on an individual report basis and comparable across multiple reports.”
- “Should stakeholders worry about these facts? On the one hand, it is important to keep in mind that the sustainability movement has succeeded in compelling global corporations to issue more than 100 pages of data each year. Even if significant portions of the reports are filled with green-washed information, the remaining (and perhaps some significant) portions of the reports may contain useful data.”
- ” … the limited assurance of these public accountant’s sustainability letters provides, in certain respects, even less assurance than detailed agreed-upon procedure letters. After all, an agreed-upon procedure letter contains detailed descriptions of the procedures that are performed and the findings that are produced by the procedures. In contrast, the limited assurance letters in these sustainability reports contain very little detailed information and only reach vague, double-negative conclusions regarding the findings.”
- … the descriptions of the procedures in the letters are inconsistent from company to company, and the disclaimers regarding the use of the letters by third parties vary remarkably from firm to firm. Such inconsistencies and variations greatly reduce the value of the assurance reports, and thus of the sustainability data that are included in them.”
A Surprising Finale
Professor Kraten concluded:
Clearly, there are significant limitations to the limited assurance letters in the sustainability reports. Perhaps, in addition to lobbying for improvements in sustainability reporting standards, public interest advocates should consider lobbying for the development of more stringent sustainability assurance standards.
In what was otherwise a critique of agenda-based accounting, Kraten doubles down on failure. How would “improvements” in sustainability reporting solve the problem? Lobbying? How about not lobbying.
Perhaps this surprising finale was necessary to get the article published, one which is damning to whole idea of Sustainability Reporting. Or maybe it was a sop to a train that cannot be stopped–and one which is lucrative to the profession in an artificial way.
It is time to end the futile crusade to try to objectify what is based on a set of disputable premises (such as carbon dioxide emissions being a pollutant and CO2 mitigation being good whether or not it hurts stockholders or consumers).
Another view of Sustainable Development (such as with fossil fuels) would free the accounting profession to get back to time-honored accounting theory and practice.
 A Google search of “sustainability accounting” (SA) resulted in 143 million results. The leading organization behind SA is Ceres, dedicated to “transforming the economy to build a sustainable future for people and the planet.”