Click here
AIRS
TRUST + AIRS Framework : Boardroom Governance for Sustainability Reporting in the Age of AI
Explore TRUST + AIRS, a practical governance framework designed to empower boards with effective oversight of sustainability reporting and the strategic use of AI in disclosures, bridging traditional oversight with today's complex reporting landscape.
Boards gain assurance over sustainability and AI-powered reporting
Executive Summary: The Dual-Lens Imperative
Boards face unprecedented pressure as sustainability disclosures become regulated, investor-scrutinized, and shaped by customer expectations. Simultaneously, AI is transforming how these disclosures are generated—estimating emissions, creating sustainability narratives, and automating reporting pipelines.
The governance challenge is clear: Directors are approving disclosures shaped by complex systems they don't govern, with data they haven't seen, and logic they cannot fully explain. Compliance may be checked, but confidence remains fragile.
TRUST + AIRS provides a structured response to this governance gap:
  • TRUST gives boards visibility across end-to-end sustainability reporting processes
  • AIRS governs the use of AI in corporate reporting
  • Together, they transform oversight from reactive to strategic
The outcome is measurable: oversight that matches complexity, disclosures that withstand scrutiny, and boardrooms capable of challenging intelligently and approving with confidence.
Solving Reporting & AI Risks
Our two core frameworks, TRUST and AIRS, address distinct but interconnected challenges in modern corporate governance.
The TRUST Framework
TRUST provides a robust system for end-to-end oversight of sustainability reporting. It ensures data integrity, process transparency, and stakeholder alignment, giving boards confidence in their non-financial disclosures. Mitigate compliance and reputation risks effectively.
The AIRS Framework
AIRS establishes clear governance protocols for the responsible use of AI in corporate reporting. It addresses data privacy, algorithmic bias, and ethical deployment, safeguarding against emerging AI-related risks and ensuring accurate, trustworthy disclosures.
Today's Complexity Has Outgrown Traditional Oversight
The Governance Gap
Boards are being asked to approve disclosures built on processes they no longer fully understand. As regulated sustainability reporting intersects with advanced AI tooling, traditional oversight models are straining under complexity.
Critical Questions Falling Through Cracks
  • Who owns the AI that drafts our ESG narratives?
  • How do we validate emissions data generated by opaque algorithms?
  • Where is the bridge between compliance checklists and real oversight?
The Solution
This is not about adding layers of compliance. It is about restoring sustainability data integrity and governance control over disclosures shaped by automation and AI.
While many organizations comply with reporting standards, few boards have structured visibility into how those disclosures are assembled, who owns the process, or how automation shapes the outcome.
The Director's Dilemma: Approving the Unseen
Directors are increasingly asked to approve sustainability disclosures generated by complex, opaque AI systems. This leaves them vulnerable to reputational damage and legal liabilities due to a lack of genuine oversight.
Traditional governance models are not equipped to handle this new reality, where data sources are fragmented and AI processes often lack transparency. Boards need a clear framework to bridge this knowledge gap and ensure robust, confident reporting.
The TRUST Framework
TRUST is built on five core governance pillars that help shift sustainability from a compliance task to a governance responsibility:
Transparency
Sustainability data, assumptions, and methodologies must be traceable, explainable, and well-documented. Boards must ensure that disclosures can withstand external scrutiny, reducing the risk of greenwashing or selective reporting.
Responsibility
Clear governance roles are essential. Boards must have visibility into who owns each part of the reporting chain, from data capture to disclosure sign-off, and what internal controls support that accountability.
Understanding
Boards and management must invest in their own sustainability literacy. This includes understanding key regulatory developments, Sustainability related risks, data limitations, and the evolving role of technology in reporting. Without this, oversight remains shallow.
Security & Sustainability
Information systems must be secure, resilient, and appropriately governed. This includes cyber integrity, data governance, and long-term sustainability of the processes themselves. These risks are board-relevant and audit-visible.
Trustworthiness
The reporting output must be capable of independent validation. This means embedding internal controls, enabling auditability, and maintaining consistency across time and disclosures. Boards must be confident that what they approve is fair, accurate, and ethically produced.
The TRUST Framework: Implementation & Assurance
The TRUST framework moves beyond conceptual pillars, offering a practical methodology for boards to gain demonstrable assurance over sustainability reporting. It focuses on processes, controls, and transparent evidence.
Process Mapping
Define and map the entire sustainability reporting workflow, from data collection and calculation to review and final disclosure. Identify key decision points and data handoffs.
Control Implementation
Integrate robust internal controls at each stage, verifying data accuracy, consistency, and compliance with chosen standards. This includes automated checks and manual validations.
Evidence Generation
Document all evidence supporting disclosures, including data sources, calculation methodologies, approvals, and changes. This audit trail is critical for internal assurance and external scrutiny.
Board Approval Point
Boards approve disclosures with a clear understanding of the underlying processes and the integrity of the data. Approval is supported by comprehensive evidence packs and management attestations.
Frequently Asked Questions
Q: Is TRUST a new reporting standard.
A: No. TRUST is a governance framework. It helps you report to standards like GRI, SASB, and ESRS by tightening ownership, controls, and evidence around non financial data. It does not replace standards, it makes reporting to them reliable.
Q: How does TRUST align with COSO and CSRD.
A: TRUST maps to COSO principles on control environment, risk assessment, control activities, information, and monitoring. It supports CSRD by making processes traceable, controls testable, and evidence ready for assurance.
Q: Will TRUST duplicate our SOX controls.
A: There is some overlap, which is good. SOX focuses on financial reporting. TRUST extends discipline to non financial metrics and AI influenced disclosures. Use a simple overlap map to avoid duplicate effort and to show what is unique to sustainability reporting.
Q: Can TRUST work with our current systems.
A: Yes. Start with what you have. Document lineage, name control owners, set evidence locations, and turn on logs. Add automation later if needed. The value comes from governance and repeatability, not from a specific tool.
Q: What results should the board expect in Year 1.
A: Named owners for decision critical metrics. Faster evidence retrieval. Fewer control exceptions. Higher assurance coverage on priority metrics. A quarterly dashboard that shows risk, progress, and readiness for external assurance.
Gain Confidence in Your ESG Disclosures
Empower your board with the TRUST framework to navigate the complexities of modern sustainability reporting. Achieve true data integrity and make approvals with unwavering confidence.
The AIRS Framework
AIRS brings visibility and discipline to areas that are often opaque or rapidly changing through four pillars of AI governance:
Accountability
Clear ownership of AI systems, including vendor-supplied tools. Oversight, ethical use, and risk escalation must be explicitly assigned.
Integrity
AI models must be bias-tested, ethically aligned, and consistently applied. When used for material disclosures, they must meet assurance standards.
Reporting
AI-generated insights must be explainable, traceable, and audit-ready.
Stewardship
AI systems must be governed across their lifecycle from deployment to retirement.
The AIRS Framework: Implementation & Assurance
The AIRS framework provides a practical roadmap for boards to implement robust AI governance, ensuring responsible deployment and confident oversight of AI-driven processes, particularly those impacting sustainability disclosures.
AI System Mapping
Identify and map all AI systems and models used in sustainability data collection, analysis, and reporting. Understand their purpose, data dependencies, and output reliability.
Bias & Integrity Testing
Implement continuous testing for AI model bias, accuracy, and ethical alignment. Ensure AI outputs for material disclosures meet stringent data integrity and assurance standards.
Explainability & Traceability
Establish clear mechanisms for explaining AI-generated insights. All AI outputs must be traceable back to their original data sources and model logic, enabling full auditability.
Lifecycle Governance & Oversight
Define and enforce governance across the entire AI lifecycle, from deployment to retirement. Boards must review regular AI assurance reports, confidently approving systems and disclosures.
Frequently Asked Questions
Q: Does AIRS replace our AI governance policy.
A: No. AIRS operationalises your AI policy for reporting. It adds concrete controls for ownership, validation, logging, explainability, and approvals where AI touches disclosures.
Q: How does AIRS align with ISO 42001 and other guidance.
A: AIRS aligns with ISO 42001 on roles, lifecycle, risk, and monitoring. It also reflects common principles from NIST AI guidance and similar frameworks, applied specifically to sustainability and other non financial reporting.
Q: What counts as an AI influenced disclosure.
A: Any metric or narrative that AI generates, edits, classifies, estimates, or ranks. Examples include generated text in the sustainability report, estimated supplier emissions, automated data quality flags, or AI selected charts.
Q: What evidence is required for AI influenced content.
A: Keep a lightweight package, model or tool ID, data inputs, prompts or configuration, versioned outputs, bias and accuracy tests, owner approvals, and immutable logs. This makes the item explainable and auditable.
Q: Can AIRS work with vendor or black box models, and what about privacy.
A: Yes. Use contract clauses for logging, transparency on updates, and access to model cards or equivalent. Set a gateway control that blocks use without named owners and required evidence. Apply data minimisation and a privacy impact assessment when personal data could be processed.
Accelerate Your AI Governance Journey
Equip your board with the essential tools to oversee AI technologies effectively. Embrace the AIRS framework to ensure integrity, accountability, and robust governance across all AI applications, securing future readiness.
Boards Must Lead With Structure
Most boards still operate on the assumption that if a disclosure has been reviewed and is technically compliant, it is also trustworthy. That assumption is outdated and risky.
The truth is that many sustainability and AI-influenced disclosures are assembled through systems that boards rarely see and processes they don't fully understand.
What is reported often meets external expectations. But the internal backbone—the systems, controls, and validations behind those numbers—are frequently underdeveloped or opaque.
"Models are summarised without scrutiny. Metrics are published without context. And when scrutiny arrives, boards may find themselves exposed. Not because they failed to ask, but because they didn't know what to ask."
Today's reporting landscape demands more. With overlapping regulations and expanding use of AI, boards are accountable for information that is technical, regulated, and often machine-generated.
The TRUST + AIRS Framework: Unified Governance
The complexity of today's reporting environment demands a step change in board governance. As AI-powered disclosures and sustainability regulation converge, boards must strengthen their line of sight across systems, challenge assumptions, and lead with confidence.
Complementing Existing Standards
The TRUST + AIRS Framework enhances, rather than replaces, existing guidelines like COSO, TCFD, ISO, CSRD ISSB etc. It equips boards with practical governance tools for robust oversight, especially in AI-influenced reporting environments.
TRUST & Established Guidelines
  • Aligns with COSO principles and CSRD/ ISSB expectations.
  • Creates clear accountability for non-financial data ownership.
  • Supports risk-informed oversight of sustainability metrics.
  • Helps boards assess disclosures for compliance and credibility.
AIRS & Responsible AI Practices
  • Aligns with ISO 42001 and recognised AI governance principles.
  • Establishes ownership for AI models, data, and outputs in reporting.
  • Ensures AI-influenced disclosures are explainable, logged, and approved.
  • Reduces bias and drift risk through ongoing validation and lifecycle control.
Together, TRUST + AIRS Elevate Oversight
  • Make AI-influenced sustainability disclosures traceable and auditable.
  • Enable structured, cross-functional conversations on high-risk metrics.
  • Give boards confidence grounded in process integrity, not just format.
Organisations Benefitting from the Framework
The TRUST + AIRS Framework is designed to be adaptable and valuable across a spectrum of organisations, particularly those navigating complex sustainability reporting requirements and increasing AI integration.
Publicly Traded Companies
Essential for meeting evolving ESG regulations (e.g., CSRD, SEC climate rules) and building investor trust in AI-influenced disclosures. Enhances reporting integrity and reduces compliance risks.
Large Private Enterprises
Ideal for maturing internal governance, preparing for future public offerings, or managing complex supply chain sustainability. Provides structured oversight for growth and risk.
AI-Driven Businesses
Crucial for companies extensively deploying AI, ensuring ethical considerations, data integrity, and accountability are embedded in their reporting and operational practices.
Organisations with Complex Supply Chains
Benefits those needing to track and report on ESG performance across extended networks, ensuring transparency and verifiable data from diverse sources.
This framework offers a structured approach for boards to gain the necessary insights and confidence in their organisation's non-financial reporting.
Organisations Benefitting from the Framework
The TRUST + AIRS Framework is built to be adaptable, scalable, and board-focused, delivering governance value across organisations facing complex sustainability reporting and growing AI integration.
1
Publicly Traded Companies
  • Meet evolving ESG disclosure regulations (e.g., CSRD, SEC climate rules, ISSB standards).
  • Build investor confidence in both the accuracy of ESG data and the governance of AI-influenced disclosures.
  • Reduce compliance risk through structured oversight and traceable audit trails.
Board value add: Enables directors to sign off disclosures with evidence-backed confidence, mitigating liability.
2
Large Private Enterprises
  • Strengthen governance maturity ahead of IPO readiness or private equity investment scrutiny.
  • Manage ESG performance across multiple business units and geographies.
  • Embed AI governance principles before regulatory requirements catch up.
Board value add: Supports strategic growth while maintaining transparency and investor readiness.
3
AI-Driven Businesses
  • Govern AI models used in reporting, customer engagement, or operational decision-making.
  • Ensure AI outputs meet ethical, explainability, and validation standards.
  • Reduce reputational risk by demonstrating responsible AI oversight to stakeholders.
Board value add: Offers a governance lens that bridges AI innovation with assurance-grade reporting.
4
Organisations with Complex Supply Chains
  • Monitor ESG performance across extended, multi-tier supply networks.
  • Validate supplier-reported data for traceability, auditability, and compliance.
  • Integrate AI-driven monitoring tools under a defined governance framework.
Board value add: Increases confidence in supply chain disclosures, reduces exposure to greenwashing claims, and meets due diligence obligations.
The TRUST + AIRS Framework gives boards a clear line of sight into both the content of disclosures and the processes behind them — enabling informed oversight, regulatory resilience, and long-term stakeholder trust.
About the Author
Deepa Rao
Deepa Rao is a sustainability and governance practitioner with decades of experience in sustainability reporting, internal controls, assurance and risk oversight. She currently leads Global Sustainability Governance and Climate Change at a Fortune 200 technology company.
A Chartered Accountant by training, Deepa has held key roles at leading consulting firms and serves on boards and audit committees across higher education institutions globally. Her work has been recognized through awards for advancing innovation in ESG oversight and reporting.
Deepa also advises technology companies on governance strategy and responsible AI deployment, and serves as a committee member at British Standards Institution (BSI) for ISO Standards.
deeparao@trustairs.uk
What's Next & Call to Action
Future Development
This white paper introduces Version 1.0 of the TRUST + AIRS Framework. Future versions will expand through:
  • Diagnostic tools, governance maturity models, and oversight benchmarks
  • Board-ready checklists, briefing templates, and assurance artifacts
  • Real-world pilot insights and implementation examples
  • Tools and practices to advance responsible AI in corporate reporting
Join the Dialogue
"Governance isn't keeping pace with innovation - that ends here." — Deepa Rao
This framework has been developed independently, based on professional experience. Feedback from peers and board leaders navigating similar governance challenges is welcome.
Key Insights for Your Board
Distil the core principles of the TRUST + AIRS Framework into a concise, board-ready summary. This one-pager provides a high-level overview, empowering directors to understand and champion integrated governance for sustainability and AI within your organization.
Coming Soon
Expanding the TRUST + AIRS Framework
We are continuously developing new resources to empower boards in navigating the evolving landscape of sustainability reporting and AI governance. Look forward to enhanced diagnostic tools, comprehensive guides, and real-world case studies designed for immediate board applicability.