Policy · Climate, ESG & Sustainability Reporting
Verification protocol for AI-extracted emissions data and AI-drafted sustainability disclosures
Internal protocol requiring source tracing and human verification whenever AI extracts emissions or ESG data, summarises supplier questionnaires or drafts sustainability report narrative, so AI errors do not become misleading statements or undermine the directors' declaration.
- Kind
- Policy. A policy or procedure for a firm or client.
- Where it applies
- Australia
- AI use
- Yellow AI can help in set ways. A lawyer checks specific points before use.
- Law stated as at
- 17 October 2026
- Status
- Maintained. Checked on 17 October 2026 against the 5 authorities it cites, for Australia.
- Version
- 1
- Source
- Written for this library
When to use it
Use when a reporting entity, or its advisers, will use AI in preparing a sustainability report, modern slavery statement or ESG disclosures. Do not use as the entity's whole sustainability reporting control framework; it covers the AI-specific controls.
How AI may be used
This protocol is AI-specific. AI may extract, reconcile and draft, but every figure is traced to source and checked, every narrative sentence is linked to evidence, and people own the judgments.
AI may
- Extract activity data and emissions figures from invoices, meter data and supplier responses into data templates with source links.
- Reconcile disclosed figures to NGER reports and flag differences.
- Draft first-pass narrative against AASB S2 headings, marking every sentence without a source.
AI must not
- Must not estimate, impute or fill missing data unless a documented method approved by the data owner is used and disclosed.
- Must not decide materiality, select scenarios or set targets.
- Must not receive supplier personal information or confidential pricing in a tool not approved for that data.
The lawyer checks
- Sample and full checks in section 5 are completed and recorded before figures go to the auditor.
- Every narrative sentence in the final draft has a source and an owner.
- The board paper tells directors where AI was used and what was verified.
Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.
Official form
Open the official form. Always use the current version from the issuer.
Read the full text
The full text is for signed-in accounts. It is free. When you sign in you can:
- read the whole precedent, with its drafting notes beside it;
- copy it, or download it as a Word file or Markdown;
- add it to your firm’s knowledge base, so colleagues can find it;
- let the AI tools you connect read it from that knowledge base.
The summary, the law it rests on and the AI-use guidance above stay public. Privacy.
More in Climate, ESG & Sustainability Reporting
- Mandatory climate reporting readiness memo (Group 1, 2 or 3 entity)
- Greenwashing review checklist for environmental and sustainability claims
- Modern slavery and human rights supplier clause with audit rights
- Board paper: directors' declaration on the sustainability report
- Prompt template: climate disclosure gap list and first-draft narrative (with guardrails)
All precedents for Climate, ESG & Sustainability Reporting · Tasks and AI use in this area