Table 2.

Emerged themes based on the views of interviewees

ThemeFindingsSEGAP framework
Auditors’ capability
  • Regulatory delays prevent auditors from using their full capability set

Regulatory ambiguity and contractually agreed scopes constrain the depth of assurance, reinforcing the audit gap. Divergent CSRD transposition enlarges the grey ellipse and weakens cognitive legitimacy (scope misaligned with expectations) and dispositional legitimacy (trust in independence and capacity), thereby indirectly widening the perception gap
  • Audit scope remains voluntary and is predominantly confined to contractually agreed limited assurance:

  • National drafts confirm limited assurance as the structural baseline during transition, reinforcing capability constraints

Professional judgment
  • DMA is inherently judgment-intensive

Judgment remains dependent on plausibility checks and absent thresholds. Dominance of financial materiality. weakens procedural legitimacy (opaque methods) and moral legitimacy (accountability intent unrealized). symbolic legitimacy is sustained, while structural constraints contribute to the audit and perception gap
  • Under limited assurance and management-defined DMA boundaries, auditors cannot challenge methodological choices, enabling managerial capture

  • Reasonable assurance could substantiate accountability, but companies’ DMA processes and internal controls systems are not yet mature

Risk orientation
  • Sustainability audits extend risk considerations beyond financial exposure to ESG impacts; however greenwashing risks and material omissions are frequently treated as out of scope

Plausibility-based audit approach and exclusion of greenwashing and omissions enlarge the audit gap. Blurred boundaries between financial and impact materiality erode cognitive legitimacy and moral legitimacy (justice, inclusivity, sustainability left untested), reinforcing symbolic assurance
  • Auditors apply a plausibility-based rather than risk-oriented audit approach

  • Auditors recognize the need to balance epistemic (rigor, accuracy, objectivity) and nonepistemic (justice, inclusivity, sustainability) values

Stakeholder integration
  • Stakeholder engagement occurs before audits and is mediated by management; auditors receive summarized or internalized inputs

Stakeholder expectations are insufficiently embedded, with validation tied to financial logics and limited procedures. This sustains symbolic inclusion, undermines procedural and exchange legitimacy. This is reinforcing the perception gap, which in turn is reflecting auditors’ structural constraints
  • Validation of IRO base remains plausibility-based rather than risk-oriented

Assurance level
  • Limited assurance is reinforced by national CSRD transposition

A restricted audit scope reinforces the audit gap: Reliance on ISAE 3000 narrows assurance to financial materiality logics, leaving impact dimensions untested. Auditors recognize legitimacy risks, as users may assume greater scrutiny, which is indirectly widening the perception gap. While this sustains pragmatic legitimacy, it widens the perception gap and leaves moral and dispositional legitimacy fragile
  • Reasonable assurance is feasible. It functions as maturity indicator and is limited to selected quantitative metrics. Companies internal control systems and data quality are not yet mature

Regulatory ambiguity
  • Fragmentation persists during the transition to ISSA 5000, with ISAE 3000 (Revised) serving as an interim baseline

Deregulation, and variability in national transposition widen both the audit and the perception gap. Without enforceable criteria for omissions, impact materiality or greenwashing, auditors cannot navigate DMA consistently. These oscillations might destabilize expectations and erode cognitive, procedural and moral legitimacy
  • ESRS thresholds for impact materiality, greenwashing and omissions remain vague

  • The postponement of reasonable assurance constrains auditors’ ability to apply the risk-oriented audit approach, limiting their responsiveness to plausibility checks

Source(s): Created by author

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