CCRcorp Sites  

The CCRcorp Network unlocks access to a world of insights, research, guides and information in a range of specialty areas.

Our Sites


A basis for research and practical guidance focusing on federal securities laws, compliance & corporate governance.


An educational service that provides practical guidance on legal issues involving public and private mergers & acquisitions, joint ventures, private equity – and much more.


The “one stop” resource for information about responsible executive compensation practices & disclosure.

Widely recognized as the premier online research platform providing practical guidance on issues involving Section 16 of the Securities Exchange Act of 1934 and all of its related rules.


Keeping you in-the-know on environmental, social and governance developments

Yesterday I wrote about how one French pension is putting pressure on their financial auditors. Here in the US, non-financial ESG/sustainability auditors – at least those auditing in certain environmental regulatory compliance contexts may soon have to make big changes in their audit practices. Our friend Chris McClure from Crowe posted a reminder last week that companies subject to EPA’s rules on hydroflouorocarbon (HFC) reduction under The American Innovation and Manufacturing (AIM) Act must file a third party audit by May 31, 2024. This is notable because under the regulation (40 CFR 84.33):

An auditor must meet the following requirements: 

(1) The auditor must be a certified public accountant, or firm of such accountants, that is independent of the regulated person. Such an auditor must comply with the requirements for professional conduct, including the independence requirements, and the quality control requirements in 40 CFR 1090.1800(b)(1)(ii), as well as applicable rules of state boards of public accountancy. Such an auditor must also meet the requirements to perform an attestation engagement in 40 CFR 1090.1800(b)(1)(ii)

(2) The auditor must meet the independence requirements in paragraph (f) of this section.

The regulation goes into detail about independence and reporting requirements. EPA also provided a guide specifically for CPAs performing these audits, which states:

“The EPA has determined that attestation engagements, specifically agreed-upon procedures (AUP) engagements, performed in accordance with the AICPA Attestation Standards, specifically AT-C section 215 Agreed-Upon Procedures Engagements, by an independent certified public accountant (CPA), meet the audit requirement established in the Hydrofluorocarbon (HFC) Allocation Framework Rule…”

This isn’t the only EPA regulation mandating the use of CPAs. The regulations referenced in the AIM rule are attestation requirements under the Agency’s Fuels, Additives and Regulated Blendstock regulations for motor fuels. Piling on, non-financial ESG, sustainability and CSR auditors looking to conduct assurance engagements under SEC’s climate rule (once it is settled) will have to align with/adopt financial audit standards as I blogged about earlier. These firms face difficult choices if they want to stay in the game – at least in the US.

If you aren’t already subscribed to our complimentary ESG blog, sign up here: for daily updates delivered right to you.

Back to all blogs

The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile