Role of Professionals in ESG
Who Does What in Sustainability Reporting

For most of the history of the accounting profession, the boundary of its work was the financial statements. Anything a company said about its environmental performance or its treatment of workers sat outside that boundary, in a separate document, prepared by a separate team, subject to no external examination and no professional standard.

That boundary has moved. Sustainability data is now published in the annual report, structured to defined criteria, filed in machine-readable form, and — for an expanding cohort of listed companies — verified by an independent party applying an assurance standard. The moment ESG information became measurable, comparable and assurable, it became professional work.

N D Savla & Associates supports companies across Mumbai, Navi Mumbai, Thane and Goa on the professional side of ESG: building the data systems, designing the controls, preparing the disclosures, running materiality assessments, supporting board and committee oversight, and getting the organisation ready for assurance. We work alongside internal sustainability teams rather than in place of them.

Because ESG reporting has acquired every characteristic that makes information a professional problem: it is quantitative, prepared to defined criteria, published to third parties who rely on it, and independently tested.

Consider what a BRSR Core disclosure actually is — a set of key performance indicators, computed from operational records, using stated methodologies and conversion factors, aggregated across a defined reporting boundary, subject to materiality judgements, reviewed by a preparer and an approver, and examined by a verifier who samples the underlying evidence. Strip out the subject matter and that is a description of financial reporting.

The difference is that the financial reporting system has had a century to develop its controls and a profession trained to operate them. ESG data has had, in most Indian companies, three or four years. The infrastructure gap is the reason professional involvement matters — not because sustainability teams lack expertise in sustainability, but because measurement discipline is a distinct skill from subject knowledge.

ESG work is genuinely multidisciplinary, and confusion about who owns which piece is a common source of failure. The division below reflects how the work actually splits in practice.

Chartered Accountants

The accounting profession contributes on measurement, controls, reporting and assurance — designing how sustainability data is captured and consolidated, establishing traceability from a reported figure back to a source document, building internal controls over the reporting process, preparing the disclosures, and preparing for or providing independent verification. ESG accounting and internal controls work is where the profession adds the most.

Company Secretaries and governance professionals

Governance is a full third of ESG and frequently the weakest documented pillar. Board composition, committee terms of reference, minuting of ESG oversight, related party disclosure, whistleblower mechanisms and policy approval all fall to the secretarial function. Evidence that the board actually considered its ESG risks usually sits in secretarial records.

Internal auditors

Internal audit provides the second line of assurance over ESG data before the external verifier arrives. A dry run performed by internal audit that samples reported figures and traces them to source is the single most effective preparation for a first assurance engagement.

Technical and environmental specialists

Engineers, environmental scientists and energy auditors generate and validate the underlying measurements — emissions monitoring, effluent testing, energy audits, waste characterisation. The accounting profession does not replace this expertise and should not attempt to.

Registered valuers and financial specialists

Climate and transition risk increasingly affects asset values, impairment assessments and useful life estimates. Where a company holds assets exposed to regulatory transition, registered valuer input feeds into both financial reporting and strategy disclosures.

Legal advisers

Environmental and labour compliance, contractual ESG obligations, greenwashing exposure from unsupported claims, and the disclosure implications of pending proceedings all require legal input. A sustainability claim that cannot be substantiated is a legal risk before it is a reporting one.

The expansion of professional responsibility into non-financial information has happened three times in modern history, and each expansion followed the same pattern: information became important, then became unreliable, then became regulated.

The first expansion produced the audit itself. Nineteenth century company legislation required accounts to be examined because shareholders separated from management could not otherwise rely on what they were told. The Indian profession was formally organised on this basis through the Chartered Accountants Act, 1949, establishing the Institute of Chartered Accountants of India.

The second expansion was internal controls. Through the twentieth century the auditor's attention moved from verifying transactions to evaluating the systems that produced them. In India this culminated in the internal financial controls reporting requirement introduced by the Companies Act, 2013. The principle established was that reliable output requires reliable process, and the process is itself auditable.

The third expansion is happening now, extending both principles to non-financial information. Sustainability disclosure moved from voluntary narrative to mandatory structured reporting, and then to verified reporting. The Institute of Chartered Accountants of India established a dedicated board to develop sustainability reporting and assurance standards.

There is a fourth force at work: the convergence of financial and sustainability reporting. The International Sustainability Standards Board was established in 2021 under the IFRS Foundation — the same body that oversees international financial reporting standards — signalling that sustainability information is being treated as a category of corporate reporting rather than a separate discipline.