SAE 3410 — ICAI Standard on Assurance Engagements on Greenhouse Gas Statements
SAE 3410 — ICAI's standard on assurance engagements over greenhouse gas statements; the Indian analogue of IAASB's ISAE 3410.
Definition
SAE 3410 is the Indian assurance standard governing engagements on greenhouse gas (GHG) statements, issued by the Auditing and Assurance Standards Board (AASB) of the Institute of Chartered Accountants of India (ICAI). It is the Indian analogue of the IAASB’s ISAE 3410, with which it is substantively aligned.
The standard provides ICAI-member CA firms with the methodology, procedural requirements, and reporting framework for assurance engagements over a quantitative GHG inventory — typically structured under the GHG Protocol Corporate Standard using the Scope 1 / Scope 2 / Scope 3 classification.
SAE 3410 supports both reasonable assurance (high but not absolute level, expressed positively) and limited assurance (a moderate level, expressed negatively). The engagement letter specifies which level is being provided.
What an SAE 3410 engagement covers
A typical SAE 3410 engagement comprises the following procedural elements:
| Phase | What the assurance practitioner performs |
|---|---|
| Acceptance + scoping | Confirms management’s responsibility for the GHG statement; agrees on applicable criteria (e.g., GHG Protocol), the boundary (organisational + operational), the assurance level (reasonable / limited), and the reporting framework |
| Understanding | Obtains an understanding of the entity, its operations, internal controls over GHG data, and the methodology used to estimate emissions for each emission source / Scope category |
| Risk assessment | Identifies risks of material misstatement at the GHG-statement level and at the assertion level for each significant emission source — quantification errors, double counting, omitted sources, wrong emission factors |
| Procedures | Tests source documentation (utility bills, fuel-card logs, refrigerant top-up records, business-travel records, supplier-spend data), recalculates emissions using applied emission factors, performs analytical procedures over year-on-year movements, sample-tests significant Scope 3 categories |
| Reporting | Issues an assurance report stating the level of assurance, the criteria used, the scope of work, and the conclusion |
The standard does NOT prescribe specific emission factors, boundary conventions, or accounting choices — those come from the applicable criteria (typically GHG Protocol). SAE 3410 governs how the assurance practitioner verifies the entity’s adherence to those criteria.
SAE 3410 vs ISAE 3410
| Aspect | SAE 3410 (ICAI) | ISAE 3410 (IAASB) |
|---|---|---|
| Issuer | Auditing and Assurance Standards Board (AASB) of ICAI | International Auditing and Assurance Standards Board |
| Application | Indian CA firms providing GHG assurance to entities operating in India | Globally — applied by audit / assurance firms in jurisdictions that have adopted the IAASB framework |
| Substantive content | Aligned with ISAE 3410 (procedural requirements, definitions, reporting templates are largely common) | The reference IAASB standard issued in 2012 |
| Practitioner eligibility | Member of ICAI in good standing; firm must have appropriate Quality Control under ICAI Quality Standards | Member of an IFAC-member body; firm under IAASB-aligned QC framework |
| Assurance opinion | Issued on Indian CA firm letterhead under signing partner’s DSC | Issued per IAASB reporting templates |
In practice, an Indian listed entity preparing a GHG inventory for BRSR Core or voluntary disclosure typically receives an assurance opinion under SAE 3410 from an ICAI-firm partner. If the same entity also requires a globally-recognised opinion (for ESG ratings, EU customer due diligence, or overseas-investor reporting), the engagement may dual-reference SAE 3410 and ISAE 3410, or be issued under both.
SAE 3410 in the Indian BRSR context
SEBI’s BRSR Core circular (July 2023) introduced mandatory reasonable assurance on the BRSR Core attributes for India’s largest listed entities — phased in by market-capitalisation rank. The SEBI text does not name a single mandatory assurance standard for all BRSR Core attributes; the standard applied is determined by the engagement letter between the entity and the assurance practitioner.
For GHG-specific BRSR Core attributes (e.g., GHG emission intensity per rupee of turnover, Scope 1 + 2 + 3 emissions disclosures), SAE 3410 is the directly applicable ICAI standard. The assurance partner cites SAE 3410 (or both SAE 3410 and ISAE 3410 if a dual citation is appropriate) in the assurance report.
For non-GHG BRSR Core attributes (water withdrawal intensity, female-wages percentage, POSH complaints, job creation in smaller towns, etc.), SAE 3410 does not apply — those engagements are typically governed by SAE 3000 (Revised) / ISAE 3000 (Revised), the broader assurance standards for non-financial information.
When is SAE 3410 applied vs SAE 3000
A common point of confusion for listed entities is which standard applies to which BRSR Core attribute:
- GHG-related BRSR Core attribute (any quantitative emissions disclosure — Scope 1, Scope 2 location-based, Scope 2 market-based, Scope 3 categories, GHG intensity per revenue, GHG intensity per FTE): SAE 3410 applies.
- Non-GHG BRSR Core attributes (water, female wages, POSH, openness of business, job creation, complaint disclosures, training, etc.): SAE 3000 (Revised) applies.
The assurance partner segments the engagement accordingly and may issue one combined assurance report that internally references both standards for the appropriate scope.
Reasonable vs limited assurance under SAE 3410
SAE 3410 explicitly supports both assurance levels:
- Reasonable assurance: higher level of confidence. The practitioner performs more extensive procedures — substantive testing, recalculation, vouching, sample-based detailed testing. The assurance opinion is expressed positively (“in our opinion, the GHG statement is, in all material respects, fairly stated in accordance with the applicable criteria”). This is the level mandated by SEBI for BRSR Core attributes.
- Limited assurance: moderate level. Procedures are primarily analytical and inquiry-based; less detailed substantive testing. The opinion is expressed negatively (“nothing has come to our attention that causes us to believe the GHG statement is not, in all material respects, fairly stated”). Common in voluntary disclosures, smaller entities, or year-1 engagements before scaling to reasonable assurance.
Related terms
- ISAE 3410 — the IAASB analogue; substantively aligned
- GHG Protocol — the typical applicable criteria
- Scope 1 Emissions / Scope 2 Emissions / Scope 3 Emissions — the categories audited
- BRSR Core — the SEBI mandate that drives demand for SAE 3410 engagements
- Reasonable Assurance — the assurance level SEBI mandates for BRSR Core