IMAGINE this: after months of work, a company is ready to publish its sustainability report. The targets are approved, the disclosures are polished, and the board wants the assurance report signed. There is only one uncomfortable question left.
The firm being asked to provide that assurance had earlier helped the company develop parts of the sustainability reporting process.
The practitioner knows the business, the people, and the work. That familiarity is precisely what makes the appointment attractive. But now, with the assurance report waiting for a signature, the practitioner has to pause and ask: Can we independently assure what we helped build?
The better question, of course, should have been asked much earlier.
This dilemma may become increasingly relevant as sustainability moves into formal reporting and assurance. Companies need expertise; practitioners want to help, and executives want credible information. Today’s roles can determine tomorrow’s options.
Ethics and independence therefore belong in the conversation long before the assurance report reaches anyone’s desk.
A timely change in the code
The 2026 edition of the International Code of Ethics for Professional Accountants brings sustainability reporting and assurance more clearly into the ethical and independence framework. The sustainability reporting-related revisions become effective on December 15, 2026, while the sustainability assurance provisions generally apply to engagements on sustainability information for periods beginning on or after that date.
This is more than a technical update. Sustainability information now shapes strategy, risk, investment decisions, and corporate reporting. As it becomes more consequential, expectations around how it is prepared and assured will rise.
For executives, that creates a governance question. For preparers, it creates an ownership question. For practitioners, it creates an independence question.
When useful advice becomes too much help
Many organizations are still building their sustainability reporting capabilities. Data comes from different functions, processes and controls are developing, and management reasonably seeks outside expertise.
The tension is not about whether advisers should help. It is about where that help stops.
A practitioner can understand existing processes, identify gaps, discuss industry practices, present recommendations, and undertake assurance-readiness work. Depending on the circumstances, these services may be permissible.
Independence does not require advisers to stop advising. It requires clarity about who evaluates the advice, makes the decision, and takes responsibility for it.
Good independence planning does not restrict access to expertise. Done early, it helps management obtain needed advice while preserving credible future assurance options. Independence concerns become much more serious when practitioners make management decisions, design processes or controls whose outputs may be assured, or prepare sustainability information the same firm may later assure.
But capability is not the same as permissibility.
Practitioners must ask whether today’s advisory role may compromise tomorrow’s assurance role. Preparers must ask whether management retains ownership of its judgments, methodologies, and reported information.
Independence is an early design decision
Who designed the process and methodology? Who developed the information and selected the recommendations? What other services did the prospective assurance firm provide?
Those questions are best raised before a reporting deadline. If independent assurance is part of the plan, executives should consider it when appointing advisers.
Procurement, scope, and management responsibilities can shape future assurance options. That does not mean using fewer advisers or receiving less advice. It means designing the relationship deliberately. That is why independence planning matters. Independence works best when treated not as a final compliance gate, but as part of the engagement architecture.
Commercial pressure does not make the dilemma disappear
Executives want progress, preparers have deadlines, boards want credible information, and firms want to solve important client problems. The adviser who knows the organization may seem the obvious choice.
Ethics does not require professionals to ignore these commercial realities. It requires us to navigate them without allowing commercial considerations to override professional judgment.
Sometimes, a service must be structured differently, responsibilities separated, or management required to make and document its own decision. In some circumstances, the appropriate conclusion may ultimately be that a firm should not undertake a particular role.
These conversations are rarely easy, but they are easier before the work is done than when an assurance report awaits signature.
That gives executives a useful question to ask whenever advisory and assurance needs may intersect: If you help us with this today, will it affect what you can independently assure us tomorrow?
The decision before the signature
Return to the practitioner with the assurance report waiting for a signature.
The practitioner does not sign. The firm first considers the services provided and their independence implications.
The firm first examines what it actually did. Did it merely assess readiness and present observations for management to consider? Or did it design the reporting process, determine methodologies, prepare information, or make decisions that belong to management?
In our hypothetical case, the review confirms that the firm went beyond advice and assumed responsibilities incompatible with the independence required for the assurance engagement. The firm therefore concludes that it should not provide the assurance, and another assurance provider is appointed.
The outcome is inconvenient. It may disrupt the timetable, increase cost, and require another firm to learn about the business. But signing despite a compromised role would solve a deadline problem by creating a credibility problem, undermining the very trust that assurance is intended to strengthen.
This does not mean every prior service prevents a later assurance engagement. The nature and extent of the work matter. The point is to assess independence before roles become difficult to unwind.
What 15 December should make us ask
December 15, 2026 should not be treated merely as an effective date to add to a technical calendar. It should prompt earlier conversations among accountants, executives, and preparers about who owns the judgments, who builds the process, and who may later be asked to assure the result.
For executives, the question is no longer only, “Who can help us build this?” It is also, “Who might we want to assure it later, and how do we preserve that option now?” That conversation is worth having before scopes are finalized, systems are designed, and responsibilities are assigned.
For accountants, the challenge is equally direct. We should not wait until the assurance report is ready before asking where advice ends, management responsibility begins, and independence could be lost.
The signature in our story was stopped at the last moment, but the dilemma was created months earlier. As sustainability moves to the forefront of reporting, perhaps that is the conversation accountants should be having now: not only what we are prepared to sign, but also what we are prepared to question before the pen ever reaches the page.
Mannel Hernandez is a director for the Audit & Assurance practice area at P&A Grant Thornton. One of the leading audit, tax, advisory, and outsourcing firms in the Philippines, P&A Grant Thornton is composed of 29 Partners and 1,300 staff members. We’d like to hear from you! Connect with us on LinkedIn and like us on Facebook: P&A Grant Thornton and email your comments to business.development@ph.gt.com. For more information, visit our website: www.grantthornton.com.ph.
