Submitted Comment Name Anisa Chowdhury Affiliation N/A Subject Assurance Standards and Accountability Message Dear CARB Team, To safeguard the integrity of assurance engagements under SB 253 and SB 261, it is critical that Independent Assurance Practitioners (IAPs) be required to undergo formal accreditation against internationally recognized assurance standards—specifically ISO 14065:2020 (Requirements for bodies validating and verifying environmental information) in combination with ISO/IEC 17029:2019 (General principles for validation and verification bodies). Unlike CPA firms, which are subject to AICPA/PCAOB inspections, IAPs currently lack an external oversight mechanism. Accreditation under ISO 14065 provides this accountability, as it requires IAPs to be independently audited by a recognized National Accreditation Body (NAB) such as ANAB (U.S.), UKAS (U.K.), DAkkS (Germany), or SCC (Canada). Without such oversight, IAPs may claim to follow assurance standards but fail to consistently apply independence, objectivity, or quality controls in practice. This creates material risk for companies relying on these engagements, as deficiencies may result in restated disclosures, regulatory exposure, or reputational harm. We strongly encourage CARB to embed ISO 14065/17029 accreditation requirements into its implementing rules for SB 253 and SB 261, to establish a robust and enforceable assurance framework across both CPA and non-CPA providers. File Upload (i.e., Attachments): N/A N/A
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