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ESG: Accountants’ opportunity to lose

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The field of environmental, social and governance reporting and assurance is a natural opportunity for accountants, and one that’s ripe for the taking. But they risk losing the opportunity if they don’t move more quickly.

Incoming and evolving regulation from the European Union and in some U.S. states means more companies will be looking for attestation that their climate and other initiatives are actually effective. Accounting firms are at varying stages with ESG, with the biggest firms having invested billions in this area and smaller firms just getting started. However, there’s still hesitancy among many firms.

There are three key areas of regulations to watch: the Corporate Sustainability Reporting Directive in the EU, the proposals from the Securities and Exchange Commission in the U.S., and American state regulation, specifically from California.

ESG and environmental puzzle - concept art

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With the new presidential administration, experts anticipate that the SEC will table or even rescind its proposed regulation. But EU regulations are expected to impact as many as 3,000 private and public U.S. companies, and proposed regulation in California will impact all companies that do business in the Golden State.

“What we always talked about previously was, ‘We have this alphabet soup of standards and frameworks and nobody knows what to do,'” KPMG US sustainability leader Maura Hodge said. “But what we’re actually finding is that it’s creating a patchwork of complexity, so while it’s more organized, it is still very complicated.”

“I think that there is a desire on the preparers’ part to continue to pump the brakes on this and say, ‘We don’t want to go all in because everything keeps changing and we aren’t sure if it’s going to be required or mandated or not,'” Hodge said. “But what we have been advising and the reality is that this needs to happen. Most of these companies have been reporting voluntarily historically anyway, and I think there’s a recognition and a realization that transparency and accountability in that reporting is what is desired.”

“At a minimum, shifting what you’ve done in the past to get to this regulatory baseline is a no-regrets move that you kind of keep working forward to,” she added.

Highly transferable skills

Accountants are well-suited to performing this service as ESG reporting and assurance moves away from the marketing and investor relations side of companies and becomes a financial function with regulation and standards.

Though accountants may need upskilling in specific sustainability topics, Ami Beers, senior director of the assurance and advisory innovation team at the American Institute of CPAs, says the foundational processes and skills are highly transferable, like understanding different standards and frameworks, gathering data from multiple sources, pulling together reports, and implementing processes and controls and governance.

“We have been collectors of data and auditing of that data for millennia now. We’ve been doing it with financial data. It only makes sense that we could do it with nonfinancial data. We already have frameworks set up that we adhere to for really high-quality work and high-integrity work, which ESG is in general,” said Jennifer Harrity, ESG and sustainability leader at Top 100 Firm Sensiba.

“Accounting firms are very good with the quantifiable data, but the qualitative data is scarier for them because that’s not normally where they live,” Harrity said. “But when you look at it, this is data that you look at opportunities and risks and that’s what accountants have been really good at for a very long time — looking at the numbers and having it tell a story, being able to tell that story to the clients in order to see what is opportunities and risks for an organizations. When paired with the financial data, it’s an extremely impactful forecast, and it’ll allow you to forecast for your clients with a much longer look into the future than just financial data alone.”

Where to start with ESG

With an ongoing talent shortage, firms may feel at a loss on how to start a whole new practice when they still have their traditional compliance work to complete. Starting with a materiality assessment using the Sustainability Accounting Standards Board’s framework is a good place to start, Harrity said.

“Don’t just jump into the practice. Figure out what you want to help your clients with in the ESG space and run through it yourself as a firm,” Harrity said. “One of the things that we did is we said we’re not going to offer any services or tools to our clients that we have not put ourselves through, and I think once you start doing that, you start to really see the value of ESG from an owner standpoint and from an organizational standpoint.”

Establishing good governance practices cannot be overlooked, either. Oftentimes, standard operating procedures aren’t written down — they live in an individual employee’s or a collective’s head.

“If the person who’s responsible for collecting this data were to wake up tomorrow and not be able to come to work, would somebody else be able to know what they were doing and be able to recreate that information?” Hodge said.

After ensuring there is solid governance, then firms can layer controls on top.

“What’s really important to remember — we talk about this all the time with controls on the financial reporting side — is that the company needs to be doing that before their assurance providers come in,” said KPMG’s Hodge. “Because while we perform some of the same procedures, you don’t want the assurance provider to find those mistakes. You want to have identified them and resolved them prior to the assurance provider coming in, or else it just makes the process longer.”

As the profession moves from a compliance to an advisory model, with developing technology like artificial intelligence taking over the compliance side, ESG is an opportunity for firms to add a revenue-generating service to their consulting and advisory arsenals. But this opportunity won’t be around for long.

“There are a lot of sustainability consulting firms, not accounting firms, that are chomping at the bit for this work. If accounting does not get their butts together, it’s ours to lose,” Harrity said. “This business and this niche could be a really powerful additive to our firms, but if we linger, those sustainability firms are going to swoop in and really dominate the space, and it’s going to be hard for us to come back in.”

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Accounting

White House establishes Strategic Bitcoin Reserve

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The White House today issued an executive order formally creating a Strategic Bitcoin Reserve as well as a U.S. Digital Asset Stockpile. 

The reserve will treat bitcoin, the first and most popular blockchain-based cryptocurrency, as a reserve asset. It will be capitalized with tokens owned by the Department of Treasury that was forfeited as part of criminal or civil asset forfeiture proceedings. Other agencies, such as the FBI, will evaluate their legal authority to transfer any bitcoin owned by those agencies to the Strategic Bitcoin Reserve. The administration said that the U.S. will not actually sell these bitcoins, as they would act as a store of reserve assets. The executive order authorizes the Secretaries of Treasury and Commerce to develop budget-neutral strategies for acquiring additional bitcoin, provided that those strategies impose no incremental costs on American taxpayers.

The U.S. Digital Asset Stockpile, meanwhile, will consist of digital assets other than bitcoin owned by the Department of Treasury that was forfeited in criminal or civil asset forfeiture proceedings. Versus the bitcoin reserve, the government will not acquire additional assets for the U.S. Digital Asset Stockpile beyond those obtained through forfeiture proceedings. Also unlike the bitcoin reserve, the Secretary of the Treasury may determine strategies for responsible stewardship, including potential sales from the U.S. Digital Asset Stockpile.

The executive order also says that agencies must provide a full accounting of their digital asset holdings to the Secretary of the Treasury and the President’s Working Group on Digital Asset Markets.

The administration justified the decision by saying that, with a fixed supply of 21 million coins, there is a strategic advantage to being among the first nations to create a Strategic Bitcoin Reserve, though it did not elaborate. It also said that the government currently holds a significant amount of bitcoin but has not maximized its strategic position as a unique store of value in the global financial system. It decried $17 billion worth of what it called “premature” sales of bitcoin. It also pointed out that there has not been a centralized policy for managing digital asset reserves held by the government, so right now holdings are scattered throughout different departments. 

“Taking affirmative steps to centralize ownership, control, and management of these assets within the Federal government will ensure proper oversight, accurate tracking, and a cohesive approach to managing the government’s cryptocurrency holdings. This move harnesses the power of digital assets for national prosperity, rather than letting them languish in limbo,” said the executive order. 

Dr. Sean Stein Smith, a Lehman College accounting professor who is also chair of the Accounting Working Group in the Wall Street Blockchain Alliance, said that while the executive order only sets up a framework for now, there will be significant implications further down the road. One possibility is an increased emphasis on crypto audits, as David Sack, AI and Crypto Czar, stated multiple times that one of the first pieces of business to move the E.O. forward would be to conduct on audit of current U.S. holdings. With buy-in from the Executive branch, and the emphasis on the importance of crypto audits, said Smith, the profession has an opportunity to expand efforts to standardize the currently disparate crypto audit practices.

Another impact will be client FOMO, as people may reason “after all if it is good enough for the U.S. government it should be good enough for me?” It will be especially important for accountants to educate clients about the risk and opportunities of crypto investments as well as to provide advisory services to those clients interested in integrating crypto into operations.

“In short the E.O. establishing an SBR and digital asset stockpile are set to further propel interest in crypto investments and utilization at clients of all sizes. The emphasis on high quality crypto audits, internal control and advisory opportunities as more investors (retail and institutional) potentially move into the sector, and the inevitable tax issues that will arise as a result all present opportunities for the profession,” said Smith in an email.

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As AI rises in importance, so too does governance

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AI governance was a major theme of 2024, and as the technology continues to evolve, oversight and control—as well as ways to demonstrate it to others—will become even more important this year. 

This was the assessment of Danny Manimbo, a principal with Top 50 firm Schellman, who is primarily responsible for leading the firm’s AI and ISO practices. Speaking during the firm’s Schellmancon event today, he said that last year saw the release of a number of AI governance frameworks, including the National Institute of Standards and Technology’s AI Risk Management Framework, the International Standards Organization’s ISO 42001, and Microsoft’s revisions to its Supplier Security and Privacy Assurance Program to account for AI. Meanwhile, actual regulation is also gaining momentum, with Manimbo pointing to the EU’s AI Act, South Korea’s AI Basic Act, and a number of state-level regulations such as California’s recent AI laws. 

“That kind of set the tone for a lot of the inquiries and the interest that we saw, and for the trends on where GRC was going in 2024, maybe not so much immediately in the beginning of the year, because the frameworks were so new, but I think they were boosted by a number of things in the regulatory standpoint,” said Manimbo. 

The other panelist, Lisa Hall, chief information security officer for the trust platform SafeBase, added that, given the pace of AI advances, it is likely that last year’s measures were not the end but just the beginning, especially considering how widely used even the current generation of solutions is. 

“I think it’s only going to increase, and everyone seems to have some type of AI offering,” said Hall. “Regulations and standards will likely become more demanding, and even with the shadow IT capabilities we have now, I worry that we may be underestimating how often AI technologies are actually used by our employees. And also, on the flip side, how can we best leverage these to make our lives easier?”

Manimbo noted that, with this rise in control frameworks and regulation, this year will also see a rise in demand for ways to demonstrate that one is aligned and compliant with them. The ISO 42001 certification, for which Schellman recently became the first ANSI-accredited body allowed to audit and grant certification for compliance with the standard, is one example, but he anticipated other avenues will open this year. “For example, I sit on the [Cloud Security Alliance] AI Control Framework [board], and they are launching a program scheduled for the second half of this year which is going to be very similar to their [Security Trust Assurance and Risk] program for cloud security but specific to AI risk. That’ll be another avenue,” he said. He added that other standard setters, like the AICPA, might also decide to update their frameworks to account for AI risk. 

Such demonstrations are vital for establishing customer trust in a world that is increasingly connected. Hall noted that supply chains have grown much more complex, which has allowed attackers new opportunities to target vendors or third party software providers and compromise multiple downstream organizations at once. In such an environment, establishing trust with a customer is vital, but it can often involve lengthy and tedious audits filled with manual processes. While she has had success with some automation, such as using AI to reduce time on customer questionnaires and automate access controls, there remain many things that still need human intervention. 

“I’ve definitely struggled with that, like where an auditor is asking for data sets, you’re coming back with a sample set, you’re bouncing back and forth from a tool to gather evidence, and it becomes even more complex when you’re dealing with customer audits and you’re talking to more than one auditor, and you can only reuse evidence for so long that evidence goes stale,” she said. “And then a lot of times, auditors have competing platforms and tools that may not integrate with yours. So it’s still a manual process. There’s a ton of back and forth communication there. I’m still copying and pasting, I’m still downloading from here and uploading to here. So I’d love to see this process improve,”  

Manimbo noted AI has also been helping processes like this, noting that AI can itself help bolster an organization’s controls through automating routine processes and reducing dependence on manual processes. 

“On this front, some of the things that have plagued us in the past is the amount of context that we need as professionals to know if something is something that needs to be addressed immediately as part of a control failure that may be detected. And I think AI will help provide that context there… It may not necessarily be [about] what the controls may be, but how efficient are the models in augmenting existing automation to find those failures in a way that we can effectively address those findings in a way that we can again improve on those and so hopefully reducing additional burden on a team members,” he said. 

However, with all these different frameworks coming out, and with current ones being revised to account for AI, professionals may be challenged in keeping up with all the changes. Professionals need to not only know how to apply these frameworks but also how to scale them as time goes on. Hall said that, by maintaining a security-focused mindset and being proactive, so that the organization is more able to respond to change. 

“If we build and buy with security in mind and find ways to leverage automation and AI to enable us to quickly adjust, … we’re just going to be way better off,” said Hall.  “Instead of looking at ‘here’s the strict regulation, here’s what I have to do,’ [it is] kind of this afterthought, by being more proactive and just having these things in mind. .. I think it’s about us having that mindset of: How is the security built in? How can I be accountable and prove that I’m doing what I’m doing? And think about that before the auditors show up and before the regulations show up.”

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AICPA in discussions with IRS over tax season jitters

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The American Institute of CPAs is monitoring the situation at the Internal Revenue Service amid reports of layoffs of up to half the staff, keeping in touch with IRS officials about maintaining services during the critical tax season.

“In recent weeks, there has been a flood of information regarding the current state of the IRS, some of which has resulted in conflicting reports, creating confusion,” said AICPA president and CEO Mark Koziel in a statement Friday. “The AICPA is having active discussions with IRS officials to clarify this information and we are actively monitoring developments as the IRS continues to assess the immediate and long-term implications. With the volatility of the present environment and rapidly changing events, it is important to reconcile fact from fiction for taxpayers and their advisors. Despite inconsistent reports, we know that the IRS is making every effort to maintain this tax season’s service levels comparable with that of recent years.”

He stressed the importance of the IRS maintaining service during tax season.

“The ability of the IRS to maintain service levels for taxpayers and their preparers is critically important to the AICPA,” Koziel added. “IRS services in combination with modernization efforts, which include technology advancements, have been the bedrock of AICPA’s recommendations for many years. A modern, functioning IRS is essential for Americans to meet their tax obligations and to our country’s financial health.”

The AICPA is also offering recommendations to the embattled agency. “The AICPA continues to provide recommendations to the IRS that will offer some level of relief as we work diligently to understand the impacts to services offered to taxpayers and their practitioners,” said Koziel. “We offer our voice and support to minimize public confusion about current IRS operations.”

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