---
title: "Verification protocol for AI-extracted emissions data and AI-drafted sustainability disclosures"
url: "https://ailawframework.com/precedents/climate-esg-and-sustainability-reporting/ai-esg-data-verification-protocol"
type: "precedent"
site: "AI Law Framework"
id: "a48-ai-esg-data-verification-protocol"
area_id: "A48"
kind: "policy"
ai_level: "yellow"
version: 1
law_stated_as_at: "2026-10-17"
---

# 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…

Canonical page: https://ailawframework.com/precedents/climate-esg-and-sustainability-reporting/ai-esg-data-verification-protocol  
Law stated as at: 2026-10-17

Site index for agents: https://ailawframework.com/llms.txt

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.

## Key facts

- Kind: Policy. A policy or procedure for a firm or client.
- Practice area: [Climate, ESG & Sustainability Reporting](https://ailawframework.com/precedents/climate-esg-and-sustainability-reporting.md)
- Jurisdictions: Australia
- AI level: Yellow. AI can help in set ways. A lawyer checks specific points before use.
- Law stated as at: 2026-10-17
- Status: Maintained. Checked on 2026-10-17 against the 5 authorities it cites, for Australia.

## 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.

## Authorities

- [AASB S2 Climate-related Disclosures (as amended)](https://standards.aasb.gov.au/aasb-s2-dec-2025)
- [Corporations Act 2001 (Cth) ss 296A, 296D (sustainability report content; directors' declaration)](https://www.legislation.gov.au/C2004A00818/latest/text)
- [Corporations Act 2001 (Cth) s 1041H (misleading or deceptive conduct)](https://www.legislation.gov.au/C2004A00818/latest/text)
- [ASIC Regulatory Guide 280 Sustainability reporting](https://www.asic.gov.au/regulatory-resources/find-a-document/regulatory-guides/rg-280-sustainability-reporting)
- [National Greenhouse and Energy Reporting Act 2007 (Cth)](https://www.legislation.gov.au/C2007A00175/latest/text)

## Official form

[Official form](https://www.asic.gov.au/regulatory-resources/find-a-document/regulatory-guides/rg-280-sustainability-reporting)

## Full text and drafting notes

The full text and the drafting notes are not part of this public page. Signed-in firm accounts can read them at https://ailawframework.com/precedents/climate-esg-and-sustainability-reporting/ai-esg-data-verification-protocol and through the signed-in MCP connector https://ailawframework.com/mcp/firm.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*