First performance audit reporting deadline confirmed for batteries, EEE and HSP

RPRA has confirmed the first performance audit reporting deadlines for batteries, ITT/AV and lighting (EEE) and hazardous and special products (HSP), following feedback from PROs on implementation timing:

RPRA has shifted the first performance audit reporting deadline for batteries, ITT/AV and lighting from what’s outlined in the regulations (i.e., the same deadline as annual performance reporting, April 30) to allow registrants more time to understand their requirements and gather the appropriate data.

Transition approach for 2027 audit reporting

RPRA recognizes that data limitations for past performance years may affect the ability of PROs and processors to obtain an unmodified CSAE 3000 reasonable assurance opinion for the first filing. The transition framework provides the following treatment:

• • For the 2027 reporting year only: RPRA will accept audit reports containing qualified, adverse or disclaimer of opinion conclusions without making immediate adjustments to reported recovered resources.
    • Registrants submitting modified audit opinions in 2027 may be subject to additional reporting obligations in 2027 and 2028 to demonstrate progress toward achieving full CSAE 3000 compliance.
  • Beginning with the 2030 performance reporting cycle: Any qualified, adverse or disclaimer of opinion may result in retroactive adjustments to recovered resource figures, reducing reported totals to only those amounts independently verified to the CSAE 3000 reasonable assurance report. In other words, a PRO who submits a modified report could see a decrease in their management performance.

Next steps

Most producers have retained the services of a PRO to complete this reporting on their behalf. However, it remains the responsibility of a producer to ensure their reports are submitted by the deadline to avoid compliance action.

PROs and producers reporting on their own activities should review the applicable verification and audit procedure(s) and plan their audit with their third-party auditor ahead of the 2027 reporting deadline:

• Batteries Registry Procedure – Verification and Audit
• EEE Verification and Audit Procedure
• Hazardous and Special Products Verification and Audit Procedure

For reporting questions, contact RPRA’s Compliance and Registry Team.