Domain A · Area A-CA3 · Interoperability, external requirements and reporting-basis claims
A.8Maintain requirements traceability and control reporting-basis claims
Working Draft version 1.1
Purpose and scope
This unit covers the capability to maintain a version-controlled requirements-to-disclosure register and to evaluate whether proposed public statements about compliance, accordance, alignment, adoption, reference, coverage, use or endorsement in relation to a reporting instrument or reporting basis are supported by the applicable criteria, evidence and approvals. It links the reporting basis to owners, data, disclosures, omissions, evidence, review and publication.
Applied competency statement
Can maintain a version-controlled requirements-to-disclosure register and evaluate whether proposed reporting-basis claims about compliance, accordance, alignment, adoption, reference, coverage, use or endorsement are supported by the applicable criteria, evidence and approvals.
Boundary and escalation
This unit owns requirements-to-disclosure traceability and the criteria, wording and approval of reporting-basis claims. G.7 performs claim-by-claim substantiation and overall-impression review for broader sustainability claims; F.9 governs assurance, certification and accreditation wording; G.11 controls published-claim monitoring and correction. Final legal responsibility remains with authorised management and, where necessary, legal advisers.
Key quality risks
Incomplete or outdated requirements registers; missing ownership, evidence or disclosure links; unsupported compliance, accordance, alignment, adoption or endorsement claims; ambiguity between reporting-basis claims and broader sustainability claims; inconsistent claims across channels; failure to reflect omissions or transition relief; and unapproved publication or delayed correction.
A.8-K01
Understands the purpose and minimum fields of a requirements-to-disclosure register, including source, version, applicability, requirement, owner, status, disclosure location, evidence, review, omission and change history.
Knowledge Type: Requirements register · Normative Weight: Core
A.8-K02
Understands distinctions among compliance, in accordance, alignment, consistency, adoption, reference, use, coverage, endorsement, approval, assurance and certification claims.
Knowledge Type: Reporting-basis claims · Normative Weight: Core
A.8-K03
Understands that each reporting-basis claim depends on the applicable instrument, reporting basis, completeness conditions, permitted omissions, transition provisions, wording and approval.
Knowledge Type: Claim criteria · Normative Weight: Core
A.8-K04
Understands source-to-requirement-to-owner-to-evidence-to-disclosure traceability and methods for identifying gaps, duplication, unresolved status and inconsistent claims.
Knowledge Type: Traceability and completeness · Normative Weight: Core
A.8-K05
Understands claim review, legal escalation, sign-off, publication control, correction, withdrawal, restatement and version-management requirements.
Knowledge Type: Governance and correction · Normative Weight: Core
A.8-K06
Understands intellectual-property, trademark, legal, assurance, accreditation and endorsement boundaries relevant to public claims.
Knowledge Type: Professional boundary · Normative Weight: Core
A.8-S01
Design or operate a controlled requirements-to-disclosure register with clear ownership, status, evidence, disclosure and change fields.
Skill Type: Core applied capability · Observable Output or Result: Controlled requirements-to-disclosure register
A.8-S02
Trace each applicable requirement to its treatment, evidence and disclosure and identify gaps, unsupported omissions, duplication and inconsistent status.
Skill Type: Traceability and completeness · Observable Output or Result: Requirements completeness analysis
A.8-S03
Evaluate proposed reporting-basis claims against the reporting basis, applicable criteria, evidence, omissions, transition status and permitted wording.
Skill Type: Claim analysis · Observable Output or Result: Reporting-basis claim substantiation record
A.8-S04
Coordinate technical, management and legal review, record sign-off and manage changes, corrections or withdrawal of unsupported claims.
Skill Type: Approval and correction · Observable Output or Result: Reporting-basis claim approval and sign-off record
A.8-S05
Explain claim risks and limitations clearly and challenge wording that overstates compliance, equivalence, endorsement, assurance or certification.
Skill Type: Communication and challenge · Observable Output or Result: Claim-risk briefing
A.8-B01
Does not permit ambiguous or promotional wording to substitute for satisfaction of the applicable claim criteria.
Behaviour Type: Integrity of claims · Non-compensable Requirement: No
A.8-B02
Keeps gaps, omissions, transition relief, assumptions and unresolved status visible rather than masking them through completion labels.
Behaviour Type: Traceability and transparency · Non-compensable Requirement: No
A.8-B03
Escalates unsupported or legally sensitive claims before publication and supports prompt, controlled correction when necessary.
Behaviour Type: Escalation and correction · Non-compensable Requirement: No
Typical tasks · 4
A.8-T01
Establish or update the requirements register using the approved reporting basis and current authoritative sources.
Primary Output Link: A.8-O01
A.8-T02
Assign owners and trace each requirement to data, evidence, disclosure location, omission or unresolved action.
Primary Output Link: A.8-O01
A.8-T03
Assess proposed public claims and wording against the applicable criteria, evidence, transition status and limitations.
Primary Output Link: A.8-O02
A.8-T04
Obtain technical, management and legal sign-off and control publication, changes, correction or withdrawal.
Primary Output Link: A.8-O03
Level 1 · Foundation
A.8-L1-01
Can maintain assigned entries in a requirements register, link them to evidence and disclosure locations and check a predefined reporting-basis claim against an established checklist.
Indicator Dimension: Task execution
A.8-L1-02
Can identify missing ownership, evidence, disclosure treatment or approval and escalate ambiguous or unsupported claim wording under supervision.
Indicator Dimension: Quality, judgement and accountability
Level 2 · Practitioner
A.8-L2-01
Can independently operate a multi-instrument requirements register, perform completeness and traceability review and assess proposed reporting-basis claims and limitations.
Indicator Dimension: Task execution
A.8-L2-02
Can coordinate owners and reviewers, resolve routine inconsistencies, document substantiation and explain why a claim is supportable, qualified or not permitted.
Indicator Dimension: Quality, judgement and accountability
Level 3 · Advanced Practitioner
A.8-L3-01
Can design or critically review organisation-wide requirements and claim-control methods across multiple reports, entities, instruments and publication channels.
Indicator Dimension: Method design and review
A.8-L3-02
Can challenge high-risk claims, advise governance and legal functions on supportability and correction, and establish sign-off, version, monitoring and post-publication controls.
Indicator Dimension: Leadership and governance
Illustrative evidence · 6
A.8-E01
Controlled requirements-to-disclosure register with source, version, applicability, owner, evidence, disclosure and status fields.
Evidence Type: Work product
A.8-E02
Reporting-basis claim substantiation record linking proposed wording to criteria, evidence, omissions and limitations.
Evidence Type: Work product
A.8-E03
Reporting-basis claim approval and sign-off record, including legal or governance review where required.
Evidence Type: Work product
A.8-E04
Completeness, traceability and cross-channel consistency review with identified gaps and actions.
Evidence Type: Process evidence
A.8-E05
Documented challenge, correction or withdrawal of an unsupported or ambiguous claim.
Evidence Type: Review evidence
A.8-E06
Observed defence of a claim conclusion and response to a proposed overstatement.
Evidence Type: Observed performance
Assessment · 3
A.8-A-L1
Register-maintenance exercise, claim checklist and situational judgement
Traceability; completeness; correct use of status and ownership; recognition of unsupported or ambiguous claim wording.
A.8-A-L2
Integrated traceability case and professional memorandum
Requirements completeness; source-to-disclosure traceability; claim criteria; treatment of reliefs and limitations; quality of approval recommendations.
A.8-A-L3
Complex multi-channel case, portfolio and oral defence
Method and governance design; legal and assurance-boundary discipline; cross-channel control; challenge, correction and oral defence.
| From | To | Type | Rationale |
|---|---|---|---|
| A.8 | A.2 | Prerequisite | Requirements and claim controls must retain source, version and status traceability. |
| A.3 | A.8 | Operational and workflow linkage | The approved reporting basis is operationalised through requirements traceability and claim control. |
| A.5 | A.8 | Change and lifecycle linkage | Requirements registers and public claims must be updated when requirements or transition status change. |
| A.6 | A.8 | Disclosure, claims and publication linkage | Crosswalk conclusions may support traceability but must not be used for unsupported equivalence or compliance claims. |
| A.7 | A.8 | Operational and workflow linkage | Material market and counterparty requirements should be incorporated into controlled traceability and claim processes where appropriate. |
| A.8 | A.3 | Prerequisite | The approved reporting basis defines which requirements and claim criteria are controlled. |
| A.8 | A.6 | Risk and control linkage | Interoperability mappings may inform the register but cannot substitute for instrument-specific claim criteria. |
| A.8 | G.7 | Strong linkage | Claim supportability and wording must be tested for substantiation and greenwashing risk. |
| A.8 | F.4 | Evidence and traceability linkage | Requirements and claim records form part of the working-paper and evidence architecture. |
| D.2 | A.8 | Evidence and traceability linkage | The disclosure architecture should remain connected to the controlled requirements-to-disclosure register. |
| F.9 | A.8 | Disclosure, claims and publication linkage | Assurance, verification, certification and accreditation wording should be controlled as public reporting claims. |
| G.7 | A.8 | Disclosure, claims and publication linkage | Claim substantiation should align with the controlled reporting basis, criteria and approval process. |
| Role | Target level | Relevance | Evidence expectation |
|---|---|---|---|
| Corporate Sustainability Reporting Practitioner | Practitioner | Required? | A case or work sample demonstrating independent performance, documented judgement and a reviewable professional output. |
| Sustainability Reporting Manager or Lead | Advanced Practitioner | Role-defining? | A complex case or verified portfolio, supplemented by oral or observed defence, demonstrating design, challenge and governance capability. |
| Sustainability Reporting Adviser or Consultant | Advanced Practitioner | Role-defining? | A complex case or verified portfolio, supplemented by oral or observed defence, demonstrating design, challenge and governance capability. |
| Sustainability Data, Systems and Controls Specialist | Practitioner | Required? | A case or work sample demonstrating independent performance, documented judgement and a reviewable professional output. |
| Assurance Readiness and Reporting Quality Specialist | Advanced Practitioner | Role-defining? | A complex case or verified portfolio, supplemented by oral or observed defence, demonstrating design, challenge and governance capability. |
| Investor, Capital Markets and Ratings Disclosure Specialist | Advanced Practitioner | Role-defining? | A complex case or verified portfolio, supplemented by oral or observed defence, demonstrating design, challenge and governance capability. |