Sustainability and compliance disclosure

Build a disclosure that links each figure to its source and calculation

• Domain: Audit & Compliance
• Moment: Before you sign
• Customer: Listed companies and their subsidiaries preparing assured sustainability disclosure

Prepare sustainability figures that can be reviewed and repeated.

The situation

Thailand's SEC announced revised principles in November 2025 for phased sustainability reporting aligned with IFRS S1 and S2. The initial climate-focused phase covers Scope 1 and Scope 2 greenhouse gas emissions and requires standardised assurance. The SEC announcement also states that related regulations were being amended, so each company should confirm the rules and effective date that apply to it.

The assurance requirement changes the operating work. Each figure needs supporting records that an independent reviewer can follow.

The disclosure must be reproducible on a timetable, with clear evidence for the source, calculation, adjustments, and approvals.

What breaks today

The data arrives from everywhere and belongs to nobody. Electricity bills from forty sites in six formats. Fuel receipts. Refrigerant top-up logs. Supplier declarations that arrive as PDFs and sometimes as photographs of paper. Travel data from an agency portal. Waste manifests. None of it was collected to be audited.

Emission factors have versions and nobody records which one was used. The factor changed, the workbook was overwritten, and the prior year is no longer reproducible. This is the same defect that causes financial restatements, arriving in a function that has never had to think about it.

Certificates and declarations expire quietly. A supplier's certification lapsed in April. Nobody noticed because expiry dates live in a column in a file that is reviewed when someone remembers.

Boundary and scope decisions live in email. Which entities are in, which joint venture is proportionally consolidated, which site was divested in August and for how many months it counts. Defensible decisions, undocumented.

The workbook is the control. One spreadsheet, one owner, formulas nobody else fully understands, and a number that has to be signed by a director who cannot check it.

And it recurs. Financial close taught finance teams thirty years ago that a number produced once by heroics cannot be produced reliably twelve times. Sustainability reporting is where that lesson has not landed yet.

What Manuel does

The mechanics are identical to a financial control, because the problem is identical.

Reads what arrives. Utility bills, fuel and refrigerant records, supplier declarations, certificates, travel and logistics exports, meter readings, waste manifests. From email, portals, shared folders, SFTP or system extracts, in whatever format each site sends.

Resolves it to your reporting structure. Sites map to entities, entities to the consolidation boundary, suppliers to categories, and cost centres to business units. Each rule has an owner and can be reused each year.

Calculates the expected value and keeps the factor version. The result records consumption, the factor version, its source, and effective date. Prior periods can be restated through a recorded change when a factor is updated.

Checks completeness before anyone reports. All sites reported. All months present. No site silently missing because its bill arrived late. Period-on-period variance outside tolerance flagged with the site named. Certificates checked against their expiry dates with the lapse surfaced in advance.

Holds every adjustment in an approved register. Each adjustment has an owner, effective date, reason, values before and after, and an approval.

Produces an evidence pack. Each figure links to the source document, mapping, factor version, calculation, adjustments, and approvals.

The same pattern works for any compliance obligation with the same shape: a required set of evidence, a standard it must satisfy, a deadline, and someone who has to sign. Regulatory returns, licence conditions, supplier codes of conduct, policy attestation.

What the customer gets

This control uses a pattern that is already running on financial data, but it is not yet in production for sustainability disclosure. There is no measured sustainability result yet.

The disclosure becomes reproducible. The assurance provider can follow each figure to its source, completeness is checked before reporting, and a later reviewer can rebuild the result.

What we measure in discovery, on your own data: how many sites and months are actually complete, how many figures can be traced to a source document today, how many adjustments have a recorded owner and reason, and how long it currently takes to answer one assurance query.

What stays with your existing systems

Your sustainability platform and ERP stay in place. Strategy, targets, and the assurance opinion remain with the responsible teams and assurance provider. Manuel controls preparation: inputs, completeness, calculations, rule versions, and supporting records.

What a first scope looks like

One reporting boundary, Scope 1 and Scope 2, one closed period you have already reported. Files only, read-only, no integration. We rebuild your last disclosure from the source evidence and show you which figures reconcile, which cannot be traced, and where the completeness gaps are.

If everything traces, that is a genuinely valuable thing to establish before an assurance provider establishes it for you.

Source for the regulatory position on this page: [Thai SEC news release No. 298/2025, 28 November 2025](https://www.sec.or.th/EN/Pages/News_Detail.aspx?SECID=12309).

Related: IT audit and control testing / Management reporting certification / Continuous audit