As the summer season comes to end, there’s not only a shift in the weather but also a renewed focus on strategic planning and forward-thinking.
The demand for more and reliable ESG reporting is increasing, driven by user demands and upcoming new regulations, such as the Corporate Sustainability Reporting Directive (“CSRD”). As a result, more ESG metrics and disclosures are being assured and, when CSRD becomes applicable from 2024, an increasing number of companies will obtain assurance over their entire sustainability report (“sustainability statement”). This assurance is also increasingly being provided by the companies’ financial statement auditors. Therefore, it is vital that companies plan ahead, to ensure they have the right assurance strategy to keep pace with the level of change in the market.

Context

We continue to see an uptick increase in the amount of ESG reporting that FTSE100 companies obtain assurance over. Investors, suppliers, customers, and employees all want to understand the purpose and values of the businesses they work with or for. Therefore, it is important for Boards and management teams to monitor and assess the breadth and level of assurance that is being obtained, in light of the trends we’ve identified below.

In this article, we present the key trends in ESG assurance for the UK’s largest listed companies. Our analysis is based on a review of all FTSE 100 companies’ 2023 Annual Reports, ESG reports, company websites, and, where publicly available, ESG assurance reports. The data was obtained using the latest Annual Reports published as of May 2024 (see Appendix 1). For comparative purposes, we have used our December 2022 article “All icing. No cake” which collated similar data on the FTSE 100 for the 2021 year-end.

Key Findings

In 2023, 79% of companies obtained assurance1, marking a 4% increase from 2021. This means the vast majority of the FTSE 100 have at least some experience of the requirements of an assurance process, such as understanding the importance of providing accurate information to the assurance practitioner.

Collaboration across different teams within a company is vital to support a smooth reporting and assurance process and we expect this to become more important as companies begin to report under the CSRD.

Our data shows that 47% of companies that obtained ESG assurance in 2023 used the same practitioner for both ESG assurance and financial statement auditing. This is a significant 14% increase from 2021, reflecting a trend we expect to continue in the next few years as the CSRD comes into force. This is due to the level of detail and disclosures required for the European Sustainability Reporting Standards (ESRS) that is likely to have overlap with the auditor knowledge and processes. For example, ESRS Topical Standard G1 requires disclosures related to an entity's risk assessment and control environment, which, in providing assurance over, may have some overlap with work performed during a financial statements audit.

63% of companies that obtained assurance in 2023 received it from a “Big 4” accounting firm, representing an 8% increase from 2021.

As the reporting and assurance requirements increase for the largest UK companies, more companies may seek alignment between their assurance and audit practitioner.

In 2023, 52% of the assurance reports were signed on the same day as the financial statements audit report. Currently, some companies publish separate sustainability reports and metrics that are assured after the Annual Report is issued. However, under CSRD, the sustainability statement, which is subject to assurance, must be presented within the Annual Report itself. Companies that do not currently receive assurance at the time of publishing their Annual Report need to plan ahead to meet this requirement.

As expected, the majority of the ESG assurance reports in 2023 were for limited assurance. 94% of the reports signed provided limited assurance, 5% were hybrid2 and just one company obtained reasonable assurance for all its assured KPIs.

For context, reasonable assurance work follows a similar methodology to an audit, involving understanding of the company and its culture, identifying risks, undertaking detailed testing, evaluating the evidence obtained and forming an assurance opinion. This type of assurance report is positively phrased, such as “in our opinion, the report is properly prepared, in all material respects, in accordance with..

Limited assurance follows the same methods as reasonable assurance but with a lower level of assurance, meaning the procedures performed are less extensive. This type of assurance report is negatively phrased, such as "nothing has come to our attention..."

For guidance and support on your ESG assurance journey, contact our ESG assurance team.

Article written by: Andy Kierney and Phil Bennett.

We obtained the data using the latest Annual Reports published of the FTSE 100 companies as at May 2024. The data covers mostly December 2023 year/period ends, but ranges from April 2023 until March 2024 year/period ends.

List of companies included:

3i Group plc

Admiral Group plc

Airtel Africa plc

Anglo American plc

Antofagasta plc

Ashtead Group plc

Associated British Foods plc

AstraZeneca plc

Auto Trader Group plc

Aviva plc

B&M European Value Retail S.A

BAE Systems plc

Barclays plc

Barratt Developments plc

Beazley plc

BP plc

British American Tobacco plc

BT Group plc

Bunzl plc

Burberry Group plc

Centrica plc

Coca-Cola HBC AG

Compass Group plc

Convatec Group plc

Croda International plc

DCC plc

Diageo plc

Diploma plc

DS Smith plc

EasyJet plc

Entain plc

Experian plc

F&C investment Trust plc

Flutter Entertainment plc

Frasers Group plc

Fresnillo plc

Glencore plc

GSK plc

Haleon plc

Halma plc

Hikma Pharmaceuticals plc

Howden Joinery Group plc

HSBC Holdings plc

IMI plc

Imperial Brands plc

Informa plc

InterContinental Hotels Group plc

Intermediate Capital Group plc

International Consolidated Airlines Group, S.A.

Intertek Group plc

J Sainsbury plc

JD Sports Fashion plc

Kingfisher plc

Land Securities Group plc

Legal & General Brands plc

Lloyds Banking Group plc

London Stock Exchange Group plc

M&G plc

Marks & Spencer Group plc

Melrose Industries plc

Mondi plc

National Grid plc

NatWest Group plc

Next plc

Ocado Group plc

Pearson plc

Pershing Square Holdings Ltd

Persimmon plc

Phoenix Group Holdings plc

Prudential plc

Reckitt Benckiser Group plc

RELX plc

Rentokil Initial plc

Rightmove plc

Rio Tinto plc

Rolls-Royce Holdings plc

RS Group plc

Schroders plc

Scottish Mortgage Investment Trust plc

Segro plc

Severn Trent plc

Shell plc

Smith & Nephew plc

Smiths Group plc

Smurfit Kappa Group plc

Spirax-Sarco Engineering plc

SSE plc

St James Place plc

Standard Chartered plc

Taylor Wimpey plc

Tesco plc

The Berkeley Group Holdings plc

The Sage Group plc

Unilever plc

Unite Group plc

United Utilities Group plc

Vodafone Group plc

Weir Group plc

Whitbread plc

WPP Group UK Limited

  1. For context the assurance being provided is under a range of standards, primarily ISAE 3000 or 3410 (84%), but also under other standards such as ISO 14064, so the external assurance is not always comparable.
  2. Hybrid Assurance is when assurance has been obtained on specific KPIs, where some KPIs have been assured to a limited a reasonable level.