Environmental Auditing, Public Finance, and Risk: Evidence from Moldova and Bulgaria

Abstract

The recent expansion of sustainability studies has reshaped corporate governance and public oversight with direct implications for financial exposure and risk management. In particular, environmental auditing generates decision-useful signals on environmental liabilities, remediation and compliance costs, and budgetary/fiscal risks that affect both corporate financing conditions (e.g., cost of capital) and public finance resilience. This study conducts a comparative examination of environmental auditing practices in Moldova and Bulgaria over 2020–2025, asking how audit mandates, coverage, and disclosure practices inform banks, insurers, investors, and budget holders. Using documents from national legal databases and supervisory portals, we apply descriptive content analysis across structural, substantive, and procedural dimensions, with special attention to financial-risk channels (contingent liabilities, sanction risk, value-for-money and procurement risks). We find that Bulgaria exhibits stronger institutional implementation capacity, while Moldova shows legislative innovation; in both cases, stronger transparency, public participation, and digital audit analytics are needed to quantify fiscal and enterprise-level ESG risks. Overall, this paper positions environmental auditing as a governance lever linking sustainability oversight to finance- and risk-related outcomes, aligning with focus on sustainable finance, ESG disclosure, and governance.

1. Introduction

Environmental auditing has become a pivotal instrument in advancing sustainable development, linking corporate governance with ecological accountability. In response to increasing stakeholder demands for demonstrable sustainability practices, such audits offer a systematic framework for assessing compliance, reducing environmental risks, and improving transparency. Beyond ensuring conformity with legal standards, environmental audits function as a strategic mechanism for building confidence among investors, consumers, and society at large (IAASB, 2024; INTOSAI WGEA, 2025).

Bulgaria and Moldova, two nations with distinct socio-economic landscapes and environmental challenges, offer unique perspectives on the role of environmental auditing in strengthening sustainability within corporate governance frameworks. Bulgaria’s integration of climate adaptation priorities into national planning highlights its commitment to sustainable practices (MoEW, 2019; UNFCCC, 2025a). Meanwhile, Moldova’s efforts to modernize its environmental compliance assurance system underscore the importance of institutional capacity and stakeholder engagement in achieving ecological goals (OECD & EU4Environment, 2022).

There is a growing body of literature on environmental audits; however, limited comparative evidence exists on how the structural (legal–institutional), substantive (thematic), and procedural (methodological) components of audit systems function as governance mechanisms under different regulatory pressures (e.g., Farooq & de Villiers, 2017; Power & Gendron, 2015). Notably, no prior study systematically contrasts an EU-member state with an EU-aligned transition economy using a standardized analytical framework.

Despite extensive research on environmental audits and management systems, a critical gap persists in understanding the architectural link between specific audit implementation features and their potential to drive performance improvements (Boiral, 2012). While the literature acknowledges the importance of audits, there is a scarcity of structured, comparative analyses that dissect how specific structural (e.g., mandates, digital infrastructure) and procedural (e.g., follow-up mechanisms, transparency) components of audit systems are designed to enable or hinder measurable environmental and governance outcomes (Knechel & Salterio, 2016; Sierra-García et al., 2015). Our study addresses this gap by systematically mapping and comparing these very architectural components in Bulgaria and Moldova, providing a foundational analysis of the audit systems that are a prerequisite for achieving future performance gains. In addition, inconsistencies in definitions and measurement scales across studies further hinder comparative analyses (Farooq & de Villiers, 2017). Future research should focus on developing standardized metrics and on digital, machine-readable disclosures that can improve comparability and auditability under the EU sustainability reporting framework (European Commission, 2023; EFRAG, 2024; IAASB, 2024).

This paper aims to explore the comparative dynamics of environmental auditing in Bulgaria and Moldova, focusing on its impact on corporate governance and sustainability. By analyzing the regulatory frameworks, institutional mechanisms, and practical outcomes in these countries, this study seeks to provide valuable insights into how environmental audits can drive sustainable development while enhancing corporate accountability. The findings will contribute to the broader discourse on Environmental, Social, and Governance (ESG) practices, offering actionable recommendations for policymakers and businesses alike.

This comparative study is deliberately designed to examine environmental auditing practices in two distinct governance contexts: Bulgaria as a full European Union (EU) member state, and Moldova as a country engaged in a sustained process of EU approximation and reform. This contrast allows for an analysis of how audit mandates, institutional capacities, and procedural mechanisms adapt to and function within different levels of regulatory pressure, international anchoring, and administrative resources. The comparison illuminates the pathways through which environmental auditing can strengthen sustainability governance, whether within a mature, multi-level EU system or a context of capacity-building and legal alignment. It specifically investigates how these different starting points influence the structural design, substantive focus, and procedural rigor of environmental audits, and what this reveals about the potential for audits to act as a lever for governance improvement under varied conditions.

2. Literature Review

The conceptual framework and literature research prepared for corporate governance, sustainability and environmental auditing, based on the purpose of the research, have been explained above. When the literature studies are examined, it has been concluded that the studies that bring an integrated perspective on the subject remain relatively limited and fragmented. In addition, it has been determined that a significant portion of the studies are at the national level. This comparative design contributes to the literature by providing cross-jurisdictional evidence on audit-driven governance mechanisms, an area where existing studies remain largely fragmented. Especially, the bridge to be established between the sustainable corporate governance approach and environmental auditing can create an international awareness on the subject. In this respect, this research can be an important guide for researchers to make rich analyses in theory and practice. Based on the explanations provided, the method of research, the findings achieved and the results obtained are explained in detail in the following headings.

A comprehensive understanding of this triad requires grounding in both the broader theoretical landscape and the specific national contexts. A recent systematic literature review underscores the critical role of sustainable finance and robust ESG frameworks as enablers of the transition to a greener economy, highlighting the growing demand for reliable, audited sustainability information (Zairis et al., 2024). The practical manifestation of these global trends, however, varies significantly across national contexts. For instance, empirical research on the most liquid companies in Bulgaria indicates that while the diffusion of non-financial reporting is high, it is often driven by EU compliance mandates, with significant gaps remaining in the quality and strategic integration of this information (Bozhinova & Nikolov, 2021). Conversely, in Moldova, the focus has been on foundational capacity-building, with policy diagnostics highlighting the ongoing modernization of the environmental compliance assurance system as a prerequisite for advanced sustainability governance (OECD & EU4Environment, 2022). This contrast is significant: Bulgaria, as an EU member state, is refining implementation quality, while Moldova is still building core capacities. This distinction provides the justification for our comparative analysis of environmental auditing practices.

Environmental auditing is increasingly positioned as a core instrument of sustainability governance that links corporate decision-making with transparent environmental performance and stakeholder accountability. Recent syntheses of the literature (Pizzi et al., 2024) show a marked shift from narrow compliance checks toward evidence-based assurance that supports investor decision usefulness and public trust. Within organizations, Environmental Management Systems (EMS) and the EU’s Eco-Management and Audit Scheme (EMAS) routinize audits and verified environmental statements; empirical EU evidence finds EMAS can deliver benefits beyond ISO 14001 (International Organization for Standardization, 2015) by hard-wiring disclosure, legal compliance reviews, and continuous improvement loops (Matuszak-Flejszman & Paliwoda, 2022). At the field level, bibliometric reviews map a rapid expansion of ESG and environmental audit scholarship around themes of governance accountability, disclosure quality, and market outcomes, but also flag fragmentation across frameworks and methods—underscoring the need for convergence in assurance practice (Au et al., 2023; Bosi et al., 2022).

On the public-sector side, Government Environmental Auditing (GEA) has been theorized as a lever that tightens the policy cycle—linking design, enforcement, and outcomes. Empirical studies (Chai et al., 2022; Li et al., 2023; Wang et al., 2023) associate GEA with greener development trajectories and pollutant reductions, albeit with context-specific and sometimes lagged effects. These findings are highly relevant to transition economies like Bulgaria and Moldova, where audit capacity, digital data infrastructures, and multilevel coordination mediate whether audit insights translate into regulatory refinement and investment signals.

Standard-setting has moved decisively to strengthen credibility and comparability. In 2024, the International Auditing and Assurance Standards Board issued ISSA 5000, a principles-based global benchmark for sustainability assurance designed to interoperate with jurisdictional regimes (IAASB, 2024). In Europe, the Corporate Sustainability Reporting Directive (CSRD) mandates assurance of sustainability information, while the European Sustainability Reporting Standards (ESRS) specify granular climate, pollution, and biodiversity disclosures (European Commission, 2023). ESRS XBRL digital taxonomies operationalize machine-readable reporting and facilitate “audit-ready” data flows (EFRAG, 2024). Together, these developments signal an ecosystem shift: policy creates demand for reliable environmental information; assurance standards and digital taxonomies supply the tools for credible verification—conditions that favor the maturation of environmental auditing in both corporate and public domains.

Despite this progress, methodological hurdles remain. The most persistent is Scope 3 greenhouse-gas accounting: evidence from value-chain analyses (Nguyen et al., 2023) highlights data scarcity, supplier heterogeneity, double-counting risks, and reliance on model-based estimates across value chains. These issues complicate assurance and often limit it to “limited” (rather than “reasonable”) conclusions. Beyond climate metrics, auditors frequently face uneven criteria for biodiversity or circularity claims, forward-looking statements, and qualitative assertions—areas where ESRS/ISSA guidance is still being operationalized in practice. Reviews therefore call for sector-specific protocols, primary data pipelines, and digital traceability (e.g., tagged disclosures, provenance and audit trails) to lift assurance quality (EFRAG, 2024; IAASB, 2024; Pizzi et al., 2024).

For Bulgaria, EU membership has anchored environmental auditing in a dense regime of directives, inspectorate practices, and performance audits by public bodies, while policy work on climate adaptation has intensified since 2019 (Atanasova & Naydenov, 2025). Corporate-side audits (EMS/EMAS, compliance audits under the Industrial Emissions Directive) benefit from shared EU methods and benchmarks; public-sector audits (including Supreme Audit Institution work and EU oversight) add a second line of accountability. Remaining gaps flagged in national assessments (Atanasova & Naydenov, 2025) include uneven sub-national implementation capacity and the need to embed audit findings systematically into policy iteration. For Moldova, an OECD/EU4Environment diagnostic documents progress in modernizing the environmental compliance-assurance system—risk-based planning, coordination, transparency—while noting constraints in inspection resources, monitoring fragmentation, and limited use of ex-post audits beyond permitting (OECD & EU4Environment, 2022). International cooperative audits and UNECE reviews have catalyzed reforms, but sustained capacity-building and digitization are still pivotal for scaling audit coverage and impact.

The literature also clarifies how audits influence corporate governance. External assurance and verified environmental statements strengthen board oversight, internal control over sustainability reporting, and stakeholder trust (Pizzi et al., 2024), particularly when aligned with enterprise risk management and strategy (ISSA 5000; ESRS governance disclosures). For transition economies, alignment with CSRD/ESRS and ISSA 5000 offers a practical bridge: (i) common concepts of materiality and metrics; (ii) explicit internal-control requirements; (iii) digital tagging that eases supervisory analytics. Empirical work on GEA suggests that when public audit institutions publish clear criteria and follow-up procedures, audit recommendations are more likely to trigger enforcement and programmatic change (Chai et al., 2022; Li et al., 2023).

Bringing these strands together, the comparative implications for Bulgaria and Moldova are threefold. First, standard convergence (ISSA 5000 with ESRS/CSRD) can compress variance in audit quality and enable cross-country benchmarking—useful for investors and regulators. Second, methodological upgrades are most urgent in hard-to-audit areas (Scope 3, biodiversity, circularity), where sector guidance, supplier engagement, and data technologies can unlock reasonable-assurance pathways. Third, capacity and digitization—risk-based planning, interoperable registries, XBRL-tagged reports, and open data—are decisive in converting audit evidence into governance improvements, with EU anchoring (Bulgaria) and EU-supported reforms (Moldova) representing different but complementary routes to impact.

To provide a concise foundation for the comparative analysis,

Table 1. Evidence map of environmental auditing research.

Strand of Literature	Representative Sources *	Core Finding	Identified Gap/Research Implication
Assurance & sustainability reporting	(Pizzi et al., 2024)	External assurance improves credibility and decision usefulness of sustainability reports.	Converge assurance scope and criteria; integrate with internal control and risk management.
EMS/EMAS and organizational performance	(Matuszak-Flejszman & Paliwoda, 2022)	EMAS delivers benefits beyond ISO 14001 via verified statements and compliance reviews.	Scale EMAS-style verified disclosure cycles; evaluate causal links to outcomes.
Government environmental auditing (GEA)	(Chai et al., 2022; Li et al., 2023; Wang et al., 2023)	GEA correlates with greener development and pollutant reductions, with context-dependent effects.	Strengthen criteria publication, follow-up mechanisms, and performance focus.
Scope 3 and value-chain data quality	(Nguyen et al., 2023)	Data scarcity and supplier heterogeneity undermine comparability and assurance.	Develop sector protocols and primary data pipelines; enable digital traceability.
Standards & policy architecture (ISSA 5000; ESRS/XBRL)	(IAASB, 2024; European Commission, 2023; EFRAG, 2024)	Global assurance benchmark + EU digital reporting enable comparable, auditable data.	Operationalize interoperability; build capacity for digital tagging and analytics.
Digitalization & ESG analytics	(Au et al., 2023; EFRAG, 2024)	Bibliometric evidence of rapid ESG expansion; taxonomies support machine-readable data.	Harmonize datasets and metrics; align analytics with assurance assertations.
Transition & capacity in post-socialist contexts	(Atanasova & Naydenov, 2025; OECD & EU4Environment, 2022)	Institutional capacity and supranational anchoring condition audit impact.	Invest in risk-based planning, interoperable registries, and transparency portals.

* Source: Authors’ synthesis based on sources cited in the References.

summarizes open-access studies by theme, distilling key findings and unresolved issues that frame our research questions.

Taken together, the evidence map indicates three cross-cutting priorities for the comparative setting: (i) convergence of standards and digital auditability (ISSA 5000; ESRS/XBRL); (ii) methodological depth for hard-to-assure domains—especially Scope 3 and biodiversity—via sector guidance, primary data pipelines, and traceability; and (iii) institutional capacity—risk-based planning, interoperable data systems, and systematic follow-up—to turn audit findings into policy and managerial change. These priorities frame the subsequent Bulgaria–Moldova analysis: EU anchoring enables faster implementation and benchmarking in Bulgaria, while capacity-building and digitalization are pivotal levers for convergence in Moldova.

A review of the extant literature reveals several relevant strands of research, yet highlights a significant gap that this study aims to address. First, studies on government environmental auditing (GEA) have primarily focused on single-country contexts, particularly China, demonstrating its correlation with environmental quality improvements (Li et al., 2023) and greener development trajectories. Second, a substantial body of research examines ESG performance and disclosure at the corporate level, investigating factors such as green finance policies (Sun et al., 2023), audit committee characteristics (Fayad et al., 2024), and the theoretical foundations of sustainable finance (Morgan, 2023). Third, systematic reviews have mapped the expanding landscape of sustainable finance and ESG research (Zairis et al., 2024), identifying fragmentation across frameworks and calling for more integrated approaches.

However, these research streams remain largely siloed. There is a conspicuous absence of comparative studies that analyze environmental auditing as a governance mechanism bridging public finance and corporate sustainability, particularly within the European context with its distinct regulatory dynamics. Existing research has not systematically contrasted how audit systems function under different governance conditions—specifically, between full EU integration and EU-aligned reform processes. This study fills this critical gap by employing a structured S-B-P (Structural, Substantive, Procedural) comparative analysis of Bulgaria and Moldova. Our approach moves beyond single-country case studies to examine how environmental auditing adapts to different levels of institutional capacity, regulatory pressure, and international anchoring. This not only provides novel insights into audit-driven governance pathways but also contributes to bridging the theoretical and practical divide between public sector auditing literature and corporate sustainability research.

3. Methodology

Building upon prior conceptual explorations of environmental control and auditing methods in Bulgaria and Moldova (EEA, 2024a; UNECE, 2011, 2017), the present study advances the analysis by adopting a structured, comparative qualitative design. Earlier approaches have emphasized the role of environmental audits as control mechanisms verifying compliance with ecological and economic plans, including examination of financial documentation, authorizations, and operational procedures. While such frameworks provided valuable descriptive insights, this research extends them through a systematic methodological architecture grounded in qualitative content analysis and digital coding.

3.1. Research Design and Objectives

The study is grounded in an interpretative research paradigm. This approach is appropriate as we seek to understand, compare, and interpret the meanings, intentions, and contextual implementations of environmental auditing frameworks within two distinct national settings. The qualitative content analysis and the S-B-P coding scheme are tools that enable this structured interpretation of documentary evidence, allowing us to derive nuanced insights into how audit systems are conceived and operationalized in practice.

To ensure full methodological transparency and reproducibility, we have substantially elaborated the description of our analytical workflow. First, the process of data selection followed a structured four-step protocol: (i) identification of all potentially relevant EU, Bulgarian and Moldovan regulatory, strategic and audit documents; (ii) title- and abstract-level screening; (iii) full-text assessment based on predefined inclusion criteria (presence of environmental auditing content, institutional provisions, or sustainability-related procedures); and (iv) exclusion of documents lacking audit relevance, duplicating content, or having unverifiable provenance. Second, all analytical categories within the S–B–P framework were operationalized as qualitative variables with explicit inclusion/exclusion rules, boundary conditions, and illustrative examples, as presented in the expanded codebook (Appendix A). Third, all documents were imported into QDAcity and coded in three iterative passes—deductive coding using predefined variables, inductive refinement based on emergent patterns, and harmonization across sources. Coding outputs were exported and processed through a standardized RStudio pipeline (version 4.3.1) that generated normalized (0–3 scale) frequency matrices for cross-country comparison. Fourth, several robustness checks were performed, including intra-coder reliability assessment (92% agreement), triangulation across legal, strategic, and audit sources, sensitivity tests of normalization thresholds, and evaluation of the stability of results under single-document removal. Finally, indicators were excluded or collapsed only when they appeared in draft or incomplete documents, were duplicated across versions, or lacked the minimum specificity required for comparable coding. All coding decisions, intermediate files, and scripts are archived in the OSF repository to support full replicability of the study.

The study adopts a qualitative, comparative research design based on descriptive content analysis to explore how environmental auditing contributes to sustainability governance in Bulgaria and Moldova during the period 2020–2025. The design is guided by well-established methodological foundations which provide specific guidance for our analytical approach: the framework by Hsieh and Shannon (2005) informs our thematic content analysis; Krippendorff (2004) underpins our approach to reliability and validity; Weber (1990) offers principles for codebook development and categorization; and Zhang and Wildemuth (2009) provide best practices for the qualitative analysis process. This approach seeks to identify the regulatory, thematic, and procedural dimensions of environmental auditing in the two national contexts.

Corporate governance refers to the structures and processes through which organizations create long-term value while protecting the interests of stakeholders. Within this logic, sustainable governance requires the integration of environmental considerations alongside economic and social goals. Environmental auditing plays a pivotal role in this integration: it supplies transparent, systematic assessments of policies and practices, links performance indicators to decision-making, and supports accountability and learning. Against this backdrop, Bulgaria and Moldova offer instructive contrasts. Bulgaria—embedded in the EU governance ecosystem—illustrates how audits inform program updates (waste, water, climate) and feed into broader reporting architectures. Moldova—operating with tighter capacity constraints—uses audits more diagnostically to surface infrastructure and enforcement gaps and to steer incremental reforms. This framing motivates our comparative analysis and underpins the S-B-P coding framework applied in this study:

• Structural Dimension: This dimension focuses on the foundational elements of the audit system, including the legal and institutional framework (e.g., laws, mandates, institutional setup) and the digital foundations (e.g., data availability, IT systems used for auditing).
• Substantive Dimension: This dimension captures the core content and focus of the audits, categorizing priority themes (e.g., climate change, water pollution, biodiversity) and the outcomes that the audits aimed to achieve (e.g., compliance, performance improvement, policy change).
• Procedural Dimension: This dimension analyzes the processes and methodologies employed, including the methods of audit execution, the types of evidence gathered and utilized, demands for transparency, and mechanisms for follow-up and implementation of audit recommendations.

The research pursues three central questions designed to systematically address the core pillars of the study:

• RQ1 investigates the corporate and public governance structures that enable and mandate environmental auditing: What are the structural features of the regulatory and institutional frameworks for environmental auditing in the two countries?
• RQ2 explores the sustainability themes and outcomes that form the substantive focus of audit practices: What substantive themes and audit topics dominate reported practice?
• RQ3 examines the environmental auditing procedures themselves, including methods and mechanisms for ensuring accountability: What procedural mechanisms (methods, follow-up, transparency) are used, and how do they differ across contexts?

Collectively, they facilitate an interpretative understanding of how environmental audits shape and reflect governance quality in the sustainability domain.

3.2. Scope and Data Sources

The scope of the study encompasses national regulations, audit reports, strategies, and professional guidelines addressing environmental auditing, sustainability assurance, or environmental management systems (EMS/EMAS) in Bulgaria and Moldova. The temporal boundary (2020–2025) was selected to capture the post-COVID-19 regulatory evolution and the period of active harmonization with European Union environmental policies.

The data consist exclusively of secondary sources drawn from official and publicly accessible repositories:

• National legal databases;
• Ministerial and agency portals (environment, finance, energy);
• Websites of the Supreme Audit Institutions; and
• Professional or academic publications.

Documents outside the defined period or lacking explicit relevance to environmental auditing were excluded following a two-step screening of titles and full texts. The unit of analysis is the document (law, strategy, audit report, guideline, or policy paper).

The minimal verification dataset for this study is registered in the Open Science Framework (OSF) (Krasteva-Hristova et al., 2025) and is publicly accessible under DOI 10.17605/OSF.IO/AW5DZ (https://osf.io/aw5dz; accessed on 24 October 2025).

3.3. Coding Framework and Analytical Dimensions

To structure the qualitative analysis, a codebook was iteratively developed and organized around three analytical dimensions corresponding to the research questions:

• Structural Dimension—encompassing legal frameworks, institutional mandates, and digital infrastructures supporting environmental auditing;
• Substantive Dimension—capturing audit objectives, topics, and findings related to sustainability outcomes;
• Procedural Dimension—addressing audit methods, data collection, transparency, follow-up mechanisms, and reporting practices.

All coding and data management were performed in QDAcity, enabling systematic tagging, visualization, and cross-referencing of analytic categories. We used a three-family codebook aligned with the S–B–P scheme—S (Structural), B (Substantive), and P (Procedural)—and color-coded the families for consistency (blue, orange, green). The coding strategy combined deductive codes derived from prior literature and audit frameworks with inductive themes emerging from country-specific documents. As coding progressed, we refined code definitions to maintain conceptual coherence across both national datasets. Individual codes are numbered sequentially (e.g., S1–S5, B1–B5, P1–P5). “Representative codes” in the tables denote the most frequent and/or salient codes per theme identified in QDAcity. Following the completion of the coding process, all coded data were exported from QDAcity and subsequently processed and visualized using RStudio (version 4.3.1). This step enabled the creation of comparative heatmaps and descriptive frequency matrices to illustrate the relative intensity and maturity of themes across the supranational, Bulgarian, and Moldovan document corpora. Document IDs (e.g., SU01–SU14) correspond to the supra-level sources listed in the Document Inventory (Appendix B,

Table A2. SUPRA (EU/Europe) Document Inventory (SU01–SU14).

ID	Description	Type	Tags
SU01	Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 supplementing Directive (EU) 2013/34 as regards sustainability reporting standards (ESRS) (European Commission, 2023)	EU Law/Legal Framework	S1 Regulatory Framework
SU02	EFRAG ESRS Set 1 XBRL Taxonomy (EFRAG, 2024)	Taxonomy/Digital Reporting Framework	S4 Resources and Capacity P2 Data Collection and Evidence
SU03	EFRAG ESRS XBRL Taxonomy—Project page (Concluded) (EFRAG, n.d.)	Web Summary/EU Project	S2 Institutional Arrangements
SU04	International Standard on Sustainability Assurance (ISSA) 5000—General Requirements for Sustainability Assurance Engagements (IAASB, 2024)	Assurance Standard	P1 Audit Methodology
SU05	ISSA 5000 Implementation Guide (IAASB, 2025)	Guidance/Implementation Manual	P2 Data Collection and Evidence
SU06	INTOSAI WGEA—Guidance on Environmental Auditing (INTOSAI WGEA, 2025)	Guidance/Audit Manual	P1 Audit Methodology
SU07	INTOSAI WGEA—Publications: Studies & Guidelines Portal (WGS.co.id, n.d.)	Web Portal/Reference Source	P4 Transparency and Disclosure
SU08	ETC/HE Report 2024-5: Status Report of Air Quality in Europe for Year 2023 (EEA/ETC-HE, 2024)	EEA/ETC Report	B3 Key Indicators and Metrics
SU09	EEA Briefing: Europe’s Air Quality Status 2023 (EEA, 2023b)	Briefing/Policy Summary	B4 Risk and Impact Areas
SU10	EEA Bathing Water Country Fact Sheets 2024 (EEA, 2025a)	Country Factsheets/Data Publication	B1 Audit Topics
SU11	EEA Report 02/2023—Tracking Waste Prevention Progress (EEA, 2023c)	EEA Report/Circular Economy	B2 Objectives and Findings
SU12	EEA Waste Prevention Country Fact Sheets 2023 (EEA, 2023a)	Country Factsheets	B3 Key Indicators and Metrics
SU13	EEA Briefing: Water Savings for a Water-Resilient Europe, 2025 (EEA, 2025b)	Briefing/Policy	B5 Good Practices and Innovations
SU14	EEA Environmental Statement 2023 (EMAS) (EEA, 2024b)	EMAS Statement/Verified Disclosure	P5 Quality Assurance

); full code definitions appear in the Codebook (Appendix A,

Table A1. S–B–P Codebook (Categories, Codes, and Definitions).

Category	Code	Name	Definition
Structural	S1	Regulatory Framework	Covers all binding or semi-binding regulatory instruments—laws, directives, regulations, and policy decisions—that establish the mandate, scope, and institutional responsibilities of environmental auditing and reporting. It reflects the structural governance layer underpinning sustainability assurance systems.
	S2	Institutional Arrangements	Covers organizational arrangements and governance mechanisms that define roles, mandates, and cooperation models between institutions responsible for environmental auditing, sustainability assurance, and reporting supervision.
	S3	Mandate and Scope	Covers provisions that establish the authority, scope, and subject matter of environmental audits, including who conducts them, what domains are examined, and the degree of autonomy granted to auditors or assurance providers.
	S4	Resources and Capacity	Refers to the availability and quality of institutional resources—financial, human, and technological—required to conduct and sustain environmental auditing, monitoring, and assurance activities.
	S5	Cross-border or Regional Cooperation	Refers to institutionalized cooperation, partnerships, and joint audit initiatives across borders or within regional frameworks.
Substantive	B1	Audit Topics	Focuses on the environmental themes and issues addressed by audit institutions or sustainability assurance bodies.
	B2	Objectives and Findings	Refers to the purpose, evaluation criteria, and key results or conclusions of environmental audit activities.
	B3	Key Indicators and Metrics	Focuses on the metrics, indicators, and data tools applied to monitor environmental or sustainability outcomes within audit processes.
	B4	Risk and Impact Areas	Covers environmental and sustainability risks, as well as the actual or potential impacts identified through audits, inspections, or reporting mechanisms.
	B5	Good Practices and Innovations	Focuses on identified good practices, innovative approaches, and lessons learned that enhance the effectiveness and impact of environmental audits and sustainability policies.
Procedural	P1	Audit Methodology	Refers to the design, techniques, and analytical tools used in conducting environmental audits and sustainability assurance engagements.
	P2	Data Collection and Evidence	Refers to methods of obtaining, validating, and managing information and empirical evidence used in environmental or sustainability audits.
	P3	Follow-up and Recommendations	Refers to actions taken after audit completion to ensure that recommendations are addressed and improvements are achieved.
	P4	Transparency and Disclosure	Refers to the disclosure and communication of audit results and related information to external audiences.
	P5	Quality Assurance	Refers to procedures and institutional mechanisms that safeguard the reliability, validity, and professional integrity of environmental audits.

).

3.4. Reliability and Validity

To enhance reliability and transparency, all coded documents were subjected to multiple review cycles. Cross-checks between codes and original texts ensured internal consistency and minimized subjectivity. Coding decisions, revisions, and analytical memos were documented within QDAcity, forming a complete audit trail of the research process.

Methodological triangulation was achieved by integrating legal, strategic, and audit-based sources, thereby reinforcing interpretative validity. The approach aligns with recommendations by Krippendorff (2004) and Zhang and Wildemuth (2009) for maintaining analytic rigor in qualitative content analysis (Krippendorff, 2004; Zhang & Wildemuth, 2009).

3.5. Analytical Procedure

The coded data were synthesized into comparative country profiles and tabular summaries illustrating the three analytical dimensions. This synthesis enabled the identification of key similarities and divergences in audit scope, institutional design, and methodological practices between Bulgaria and Moldova.

Findings were interpreted in light of existing frameworks for environmental governance and sustainability auditing, linking national audit practices to broader international standards such as the EU Green Deal and the UN Sustainable Development Goals (SDGs). To ensure analytical transparency and reproducibility, the coded data were processed through RStudio using a customized script that transformed QDAcity exports into normalized code matrices. These matrices supported both tabular summaries and graphical visualizations (heatmaps), which are presented in Section 4. The integration of RStudio as a visualization tool complements the qualitative interpretation by offering an additional layer of pattern recognition and comparative depth.

3.6. Ethical Considerations and Limitations

Ethical approval was not required, as the study relies exclusively on publicly available documents and does not involve human participants.

The main limitation concerns the dependence on reported rather than raw data. Differences in reporting depth and document consistency across sources may constrain direct comparability. These limitations were mitigated through transparent coding, cross-validation of sources, and reliance on clearly defined analytical categories.

3.7. Contribution of the Methodological Approach

By integrating the traditional understanding of environmental auditing as a state control mechanism with a modern, comparative content-analytic methodology, this research bridges descriptive and analytical paradigms. The incorporation of QDAcity software ensured methodological traceability and replicability, while the focus on structural, substantive, and procedural dimensions allows for a nuanced assessment of how environmental auditing supports sustainability governance in Bulgaria and Moldova. The finalized coding framework thus provides a solid foundation for the subsequent analysis of results and thematic patterns. The combined use of QDAcity for qualitative data management and RStudio for quantitative visualization enhances the methodological novelty of the study by linking transparent coding workflows with replicable, data-driven representation of environmental auditing patterns.

4. Environmental Auditing and Corporate Governance: A Comparative Analysis of Moldova and Bulgaria in Strengthening Sustainability

Corporate governance encompasses the structures and processes through which organizations create long-term value and protect the interests of stakeholders. Within this logic, sustainable governance integrates environmental objectives alongside economic and social ones, supported by international standards and good practices (OECD, 2023). The expansion of ESG has strengthened the role of verifiable environmental and sustainability information as a bridge between policy intentions and measurable outcomes—both in capital markets and in the public sector (Friede et al., 2015; Kotsantonis et al., 2016). In Europe, this agenda is framed by the EU Green Deal and the 2030 Agenda for Sustainable Development, which require transparency, comparable indicators, and evidence-based policy adjustment (European Commission, 2019; United Nations, 2015).

This section presents the findings from the qualitative content analysis, structured according to the S-B-P (Structural, Substantive, Procedural) framework defined in the Methodology (Section 3.3). The results are organized across three levels to enable a transparent comparison: first, the supranational (SUPRA) European context, which serves as a common benchmark; followed by the national-level analyses for Moldova and Bulgaria. These patterns support an initial descriptive comparison of how each country’s audit system aligns or diverges from European norms.

Against this backdrop, environmental auditing functions both as a compliance mechanism and as a tool for strategic learning: it verifies legal obligations, identifies implementation gaps, and channels insights into program updates and investment prioritization. Bulgaria—embedded in the EU’s regulatory and reporting architectures—demonstrates more institutionalized audit cycles that feed sectoral strategies and digital disclosure. Moldova—working with more limited resources—uses audits more diagnostically to address enforcement and infrastructure gaps and to steer incremental reforms. The remainder of Section 4 presents results at three levels—SUPRA (EU/Europe), Moldova, and Bulgaria—across structural, substantive, and procedural dimensions to enable transparent comparison.

4.1. Results (SUPRA Level): European Framework for Environmental Auditing and Assurance

As a result of the qualitative content analysis in QDAcity and the application of the S–B–P scheme (Structural–Substantive–Procedural), the three analytical dimensions and the scope of the document corpus at the supranational (SUPRA) level were delineated.

Table 2. Coding Framework for Environmental Auditing (SUPRA level).

Dimension	Description	Example Documents 1
Structural	Legal and institutional frameworks defining scope, mandates, and digital infrastructures.	SU01, SU02, SU03, SU13
Substantive	Thematic focus of environmental audits: air, water, waste, biodiversity, GHG emissions.	SU08–SU13
Procedural	Methods, evidence collection, stakeholder engagement, and follow-up mechanisms.	SU04–SU07, SU14

¹ Document identifiers (e.g., SU01–SU14) refer to items in the supranational corpus compiled for this study in Appendix B, Table A2; a full mapping is provided in Appendix A, Table A1.

presents the coding framework and illustrative sources.

Based on this framework,

Table 3. Summary of Coded Themes and Document Distribution (SUPRA level).

Dimension	Key Themes	Representative Codes 1	Illustrative Documents
Structural	EU regulatory alignment, ESRS integration, XBRL taxonomy, digital auditability.	S1–S5	SU01–SU03, SU13
Substantive	Air quality, waste prevention, water resilience, national progress reports.	B1–B5	SU08–SU13
Procedural	Audit design, ISSA 5000 assurance principles, follow-up and transparency.	P1–P5	SU04–SU07, SU14

¹ Representative codes refer to the S–B–P codebook defined in Section 3.3; full definitions are provided in Appendix A, Table A1. Document IDs SU01–SU14 are listed in Appendix B, Table A2.

lists the leading themes and their representative, together with the documents distributed at the SUPRA level in which they are most prominently observed.

The supra-level analysis integrates fourteen documents (SU01–SU14) spanning EU regulations, EFRAG guidance, IAASB assurance standards, and EEA reports. Structural: EU instruments such as Regulation (EU) 2023/2772 (SU01) and EFRAG’s XBRL taxonomy (SU02–SU03) embed sustainability assurance within the corporate reporting ecosystem, defining mandatory disclosure principles and a digital infrastructure interoperable with ESMA’s Single Electronic Format; water-resilience guidance (SU13) further links environmental and financial datasets. Substantive: EEA thematic and country reports (SU08–SU12) prioritize domains like air, water, and waste prevention, emphasizing indicators, comparability, and longitudinal progress (e.g., Tracking Waste Prevention Progress, SU11), signalling a move from pure compliance checks toward effectiveness evaluation. Procedural: IAASB ISSA 5000 (SU04) and its implementation guide (SU05), together with INTOSAI WGEA materials (SU06–SU07) and the EEA EMAS statement (SU14), codify planning, evidence collection, stakeholder engagement, and follow-up.

4.2. Results (Moldova Level): National Architecture of Environmental Auditing and Assurance

As a result of the qualitative content analysis in QDAcity and the application of the S–B–P scheme (Structural–Substantive–Procedural), the analytical dimensions and the scope of the Moldova-level corpus (MD01–MD10) were delineated.

Table 4. Coding Framework for Environmental Auditing (Moldova level).

Dimension	Description	Example Documents 1
Structural	National laws, strategies, and institutional arrangements defining the framework for environmental governance and audit mandates.	MD01, MD03, MD06, MD10
Substantive	Thematic focus areas such as waste management, water, climate adaptation, and sustainability performance indicators.	MD04, MD05, MD07, MD10
Procedural	Audit methodologies, follow-up mechanisms, data reporting, and transparency practices.	MD02, MD08, MD09

¹ Document identifiers (e.g., MD01–MD10) refer to items in the Moldova corpus compiled for this study in Appendix B, Table A3; full mappings are provided in Appendix A, Table A1.

presents the coding framework and illustrative sources.

Based on this framework,

Table 5. Summary of Coded Themes and Document Distribution for Moldova.

Dimension	Key Themes	Representative Codes 1	Illustrative Documents
Structural	Legal foundations (Environmental Protection Law), institutional coordination (Moldova 2030 Strategy), and low-emission policy integration.	S1–S5	MD01, MD03, MD06, MD10
Substantive	Waste management, environmental indicators, climate resilience, and circular-economy transition.	B1–B5	MD04, MD05, MD07, MD10
Procedural	National audit standards, evidence-based reporting, UNFCCC transparency mechanisms, and follow-up reviews.	P1–P5	MD02, MD08, MD09

¹ Representative codes refer to the S–B–P codebook defined in Section 3.3; full definitions are provided in Appendix A, Table A1. Document IDs MD01–MD10 are listed in Appendix B, Table A3.

summarizes the leading themes, their representative codes, and the Moldovan documents in which these themes are most prominent.

The Moldova set (MD01–MD10) evidences a consolidating governance architecture. Structurally, the Environmental Protection Law, the “Moldova 2030” strategy, and the Low-Emission Development Programme to 2030 establish the policy backbone, while newer tools (e.g., Environmental Certificates 2026) aim to hard-wire responsibility and improve compliance transparency. Substantively, national assessments and sector studies prioritize measurable indicators in waste, water, and environmental health; feasibility analyses highlight infrastructure and capacity gaps that shape implementation pathways. Procedurally, the Court of Accounts’ INTOSAI-aligned methodology, applied audits in water/sanitation, and UNFCCC BTR1 reporting mark progress toward evidence-based assurance and international transparency.

4.3. Results (Bulgaria Level): National Architecture of Environmental Auditing and Assurance

As a result of the qualitative content analysis in QDAcity and the application of the S–B–P scheme (Structural–Substantive–Procedural), the analytical dimensions and the scope of the Bulgaria corpus (BG01–BG10) were delineated.

Table 6. Coding Framework for Environmental Auditing (Bulgaria level).

Dimension	Description	Example Documents 1
Structural	National laws, institutional arrangements, and strategic frameworks shaping the regulatory environment for environmental governance.	BG01, BG03, BG05, BG06
Substantive	Thematic focus areas of environmental policy—waste, water, climate, biodiversity, and air quality.	BG04, BG07, BG08, BG10
Procedural	Mechanisms of audit practice, data verification, reporting systems, and registry-based transparency.	BG02, BG09, BG10

¹ Document identifiers (e.g., BG01–BG10) refer to items in the Bulgaria corpus compiled for this study in Appendix B, Table A4; full mappings are provided in Appendix A, Table A1.

presents the coding framework and illustrative sources.

Based on this framework,

Table 7. Summary of Coded Themes and Document Distribution for Bulgaria.

Dimension	Key Themes	Representative Codes 1	Illustrative Documents
Structural	Legal mandates, governance structures, strategic planning, and EU cohesion alignment.	S1–S5	BG01, BG03, BG05, BG06
Substantive	Sectoral sustainability (air, water, waste, climate adaptation), policy evaluation, and risk indicators.	B1–B5	BG04, BG07, BG08, BG10
Procedural	Audit methods, follow-up evaluation, data registries, and EMAS-based transparency.	P1–P5	BG02, BG09, BG10

¹ Representative codes refer to the S–B–P codebook defined in Section 3.3; full definitions are provided in Appendix A, Table A1. Document IDs MD01–MD10 are listed in Appendix B, Table A4.

summarizes the leading themes, their representative codes, and the Bulgaria documents in which these themes are most prominent.

The Bulgaria set (BG01–BG10) points to a mature, EU-anchored governance architecture. Structurally, the Accounting Act and Public Enterprises Act establish the link between financial and non-financial accountability, while the OP “Environment” Annual Implementation Report and the Aarhus Convention Implementation Report operationalize transparency and acquis alignment—though coordination frictions across implementing bodies persist. Substantively, sector strategies and audits span waste, water, air, biodiversity, and climate: the National Climate Change Adaptation Strategy 2023–2030 operationalizes resilience planning; the EUROSAI Cooperative Audit on Plastic Waste surfaces circular-economy challenges; and EMAS/ISO adoption signals enterprise-level environmental management with verifiable outputs. Procedurally, NAO manuals and the performance audit on water resources management evidence risk-based planning, structured evidence collection, and documented follow-up, while the EMAS registry provides verification, traceability, and EU-level data interoperability. Overall, Bulgaria’s ecosystem is transitioning from compliance-centered controls to performance-oriented assurance and integrated reporting—largely aligned with European practice, with ongoing work on cross-sector harmonization and fuller linkage to core financial accountability systems.

4.4. Cross-Country Synthesis (BG vs. MD)

The cross-country synthesis highlights both convergence and divergence in how Bulgaria and Moldova deploy environmental auditing to strengthen sustainability governance. Structurally, Bulgaria operates within an EU-anchored legal–institutional framework that couples environmental and non-financial reporting and enables multi-level oversight; Moldova’s architecture is consolidating, sequencing approximation to EU standards while piloting tools that hard-wire accountability. Substantively, both prioritize waste, water and air, but Bulgaria reports more outcome-oriented objectives (e.g., adaptation, resource efficiency), whereas Moldova’s outputs remain diagnostic, targeting enforcement and infrastructure gaps. Procedurally, Bulgaria’s SAI and inspectorates document standardized planning, follow-up and public disclosure, complemented by EMAS/ISO practices; Moldova records progress via INTOSAI-aligned methods and UNFCCC BTR1 transparency, with capacity building still pivotal.

A brief temporal scan (2020–2025) confirms these trajectories: in Bulgaria, audit insights steadily informed waste and water program updates, supported wider EMS/EMAS uptake, and underpinned climate-policy roll-out—yielding measurable gains in compliance and reporting by 2025. In Moldova, audits sequenced reforms from water/waste bottlenecks to pilot climate actions and stronger follow-up under sustained international support. Across both countries, three conditions consistently raise impact: continuity of audit cycles, integrated/high-quality data, and formal tracking of recommendations. Overall, environmental auditing acts as compliance-plus in Bulgaria and a diagnostic-to-standardization pathway in Moldova, with digital auditability and stakeholder engagement as shared levers for future gains.

Figure 1 presents a comparative visualization that consolidates the results of the QDAcity-coded corpus (SU01–SU14; BG01–BG10; MD01–MD10) across the three analytical dimensions—Structural (S1–S5), Substantive (B1–B5), and Procedural (P1–P5). The heatmaps were generated in R (version 4.3.1) using processed QDAcity export files, which enabled systematic comparison of coding frequencies and thematic intensities across countries. Scores ranging from 0 to 3 reflect the relative prominence and maturity of each theme within the supranational and national frameworks. The supranational (EU-level) layer illustrates regulatory convergence and methodological standardization, integrating ISSA 5000, ESRS, and INTOSAI WGEA guidance. Bulgaria demonstrates strong procedural alignment, well-developed follow-up mechanisms, and performance-oriented assurance practices, positioning it close to the European compliance benchmark. Moldova, in contrast, shows structural innovation and ongoing legislative modernization, though implementation maturity remains limited. The visual contrast thus highlights differentiated yet converging trajectories toward integrated, digitalized, and evidence-based environmental governance.

5. Discussion: Audit-Driven Governance in Bulgaria and Moldova

This section interprets the empirical findings by situating them within broader governance, institutional, and sustainability frameworks. While the results identify systematic patterns, the interpretations here aim to contextualize these patterns rather than generalize beyond the evidence or assign causal relationships.

A recent regulatory development of particular relevance is the 2025 EU “top-the-clock” directive, which introduces new timing, reporting, and compliance obligations across financial and sustainability reporting domains. The directive affects market behaviour and investor expectations by tightening disclosure cycles, accelerating supervisory timelines, and aligning climate-finance mechanisms under a unified EU framework. Its provisions also interact directly with key variables analysed in this study, including institutional alignment, digital reporting infrastructures, and the integration of sustainability assurance into financial oversight.

These developments reinforce several of the patterns identified in our findings, particularly the importance of interoperable digital systems, cross-border comparability, and strengthened audit-based governance pathways in both countries.

5.1. Audit-Driven Governance Pathways: Bulgaria, Moldova, and Cross-Cutting Implications

Bulgaria’s EU membership hard-wires environmental auditing into a multi-level governance system where directives, funding programmes, and reporting duties reinforce one another. Audit cycles run by the Supreme Audit Institution and the environmental inspectorates feed directly into programme adjustments (waste, water) and into the rollout of climate policy (e.g., the 2024–2030 mitigation and adaptation instruments). EMAS/ISO practices in enterprises add a verified management layer that improves data quality and auditability. In practice, this has produced: (i) clearer performance targets and indicators; (ii) stronger follow-up with time-bound recommendations; and (iii) more systematic disclosure (Aarhus/SEA/EIA channels), inviting stakeholder scrutiny and improving policy coherence across ministries and the EU level. In summary, auditing functions as compliance-plus—a proactive steering tool aligning regulatory refinement, investment prioritisation, and measurable outcomes.

Compliance-plus refers to the use of audit mechanisms not only for verifying legal obligations but for steering programmatic and budgetary adjustments.

Moldova follows a more incremental trajectory typical of a transition administration with constrained resources. Diagnostic-to-standardisation describes audit systems where early-stage capacity-building and diagnosis gradually evolve into harmonised, repeatable audit cycles. Audits—by line agencies and the Court of Accounts—have exposed gaps in waste infrastructure, water governance, and enforcement, progressively informing the National Environmental Action Programme (2020–2025), subsequent sector plans, and the Environmental Strategy 2024–2030. INTOSAI-aligned methodologies and UNFCCC BTR1 reporting add credibility and connect domestic assurance to international transparency regimes. UNECE- and EU-supported initiatives provide methodological guidance, benchmarking, and access to finance, translating findings into pilot actions (e.g., circular-economy measures, risk-based inspections) and legal approximation. The observed pattern suggests diagnostic-to-standardisation—audits catalyse capacity building, the sequencing of reforms, and the gradual tightening of follow-up and disclosure.

Overall, Moldova’s ecosystem is evolving from a predominantly diagnostic, capacity-building focus toward more standardized follow-up and reporting—mirroring European practice while adapting to domestic resource constraints.

Across both countries, three conditions consistently magnify audit impact: (1) continuity of audit cycles with formal tracking of recommendations; (2) integrated, digital data systems enabling comparable indicators and machine-readable reporting (EMAS/ISO linkages; readiness for EU-style XBRL/ESRS in BG; PRTR and e-register upgrades in MD); and (3) stakeholder participation and transparency that convert findings into social accountability. Where these are mature (Bulgaria), audits inform strategy updates, EU programme management, and targeted spending. Where they are emerging (Moldova), audits remain the key lever for institutional learning, international cooperation, and convergence with European standards.

Building on these findings, we distil targeted recommendations for each country and cross-cutting actions (Section 5.2).

Overall, the coding shows convergence toward a harmonized European assurance landscape where legal frameworks (Structural), thematic content (Substantive), and assurance methodologies (Procedural) interact to strengthen environmental governance. These results serve as a benchmark for the national-level comparisons of Bulgaria and Moldova.

5.2. Policy Recommendations

5.2.1. Bulgaria: Targeted Actions for “Compliance-Plus” Policy Steering

To translate the Bulgarian diagnosis into concrete governance gains, we outline pragmatic actions that embed audit findings into day-to-day management, strengthen risk targeting, and make data and coordination work for outcomes.

• Institutionalise follow-up tracking. Establish a public, regularly updated dashboard that lists every audit recommendation with the responsible institution, a clear deadline, current implementation status, and an explicit link to the relevant budget programme or project so that citizens and decision-makers can track delivery end-to-end.
• Deepen risk-based oversight. Align annual inspection plans with national climate- and water-risk maps and prioritise facilities using combined criteria—such as reported emissions, incident history, citizen complaints, and past non-compliance—so that supervisory resources are concentrated where environmental and health risks are greatest.
• Tighten data pipelines. Interlink electronic permitting systems, the national Pollutant Release and Transfer Register, and water/waste registries with enterprise data from the Eco-Management and Audit Scheme (EMAS) and the International Organization for Standardization environmental management standard (International Organization for Standardization, 2015), and require machine-readable exports to enable analysis, comparison, and reuse across agencies.
• Address hard-to-assure areas. Develop sector-specific protocols for value-chain (Scope 3) emissions, circular-economy performance, and biodiversity impacts, and pilot external “reasonable assurance” engagements on a small set of priority indicators to build methods, confidence, and replicable practice.
• Close coordination gaps. Create an interministerial “Audit-to-Policy” forum—bringing together the Ministry of Environment, the Ministry of Finance, the Ministry of Regional Development, and the Supreme Audit Institution—that meets annually to convert audit findings into updated programmes, targeted investment choices, and concrete milestones aligned with European Union and cohesion-funding requirements.

5.2.2. Moldova: From Diagnostic Audits to Standardised Assurance

To convert Moldova’s audit-driven diagnostics into durable governance improvements, the actions below focus on locking in a full audit cycle, strengthening digital evidence, building technical capacity, leveraging international transparency regimes, and linking recommendations to finance so that findings translate into measurable results.

• Codify the audit cycle. Establish in secondary legislation a minimum, repeatable sequence—planning, audit execution, issuance of recommendations, and formal follow-up—and require a single, consolidated annual implementation report that lists each recommendation, its responsible authority, milestones, and completion status to ensure continuity and accountability.
• Upgrade digital auditability. Accelerate the development of the national Pollutant Release and Transfer Register and integrate electronic permitting systems, inspection protocols, and citizen alerts submitted via the EcoAlert application into one unified, regularly updated risk index that prioritises inspections and enforcement where potential impacts and non-compliance risks are highest.
• Build capacity where it counts. Direct technical assistance toward (i) instruments of the waste economy such as extended producer responsibility and the roll-out of regional landfills and sorting facilities, (ii) continuous and quality-controlled surface and groundwater monitoring, and (iii) standardised sampling procedures and laboratory quality assurance/quality control so that audit evidence is robust and defensible.
• Leverage international transparency. Use the first Biennial Transparency Report under the United Nations Framework Convention on Climate Change as a template for methods, verification steps, and public disclosure in adjacent themes such as waste management and air quality, and embed relevant guidance from the International Organization of Supreme Audit Institutions into the Court of Accounts’ performance-audit methodology.
• Move from pilots to scale through financing. Link priority audit recommendations to concrete project pipelines supported by initiatives such as EU4Environment and international financial institutions, and define a small set of “audit indicators” that function as disbursement or phase-gate conditions so that funding is explicitly tied to the closure of audit findings.

5.2.3. Cross-Cutting: Turning Audit Evidence into Outcomes

Including a short, shared set of actions helps the paper move from country-specific diagnostics to implementable steps that apply across institutional contexts. The points below translate the empirical findings into practical levers that Bulgaria and Moldova can deploy in parallel—irrespective of different starting capacities.

• Ensure continuity of the audit cycle. Establish multi-year audit programmes with scheduled re-checks every 12–18 months for the most critical recommendations, assign a single responsible authority for each item, and publish timelines and completion statuses so that follow-up is predictable and accountable.
• Make data usable across systems. Require machine-readable, open formats and common identifiers for facilities and permits, and expose open application programming interfaces that interlink electronic permitting, the Pollutant Release and Transfer Register (PRTR), water and waste registries, and enterprise environmental management data from the Eco-Management and Audit Scheme and ISO 14001, so that indicators are comparable and evidence is verifiable.
• Engage stakeholders in follow-up. Standardise public releases to include a plain-language executive summary and a technical annex, define participation windows for comments, and invite non-governmental organisations and academic experts to periodic review sessions focused on the status of implementing audit recommendations.
• Link recommendations to budgets. Map every major audit recommendation to an explicit budget line at the level of programme, measure, or project, and use results-based conditions in domestic and external financing so that funds are disbursed when implementation milestones are met.
• Share what works and scale it. Organise Bulgaria–Moldova peer-learning sprints on themes such as risk-based inspections, roll-out of the Eco-Management and Audit Scheme, and operation of the Pollutant Release and Transfer Register, and produce short, replicable “how-to” protocols with responsible owners and timelines that are published on ministry portals and revisited annually.

6. Conclusions

This study set out to provide a systematic, comparative examination of environmental auditing practices in Bulgaria and Moldova from 2020 to 2025, framed by three central research questions. The findings offer clear answers to these questions and articulate the linkages between research results, theoretical implications, and practical applications.

First, addressing RQ1 on structural features, the analysis reveals that the regulatory and institutional frameworks are fundamentally shaped by the countries’ distinct relationships with the European Union. Bulgaria’s system is deeply integrated within the EU’s multi-level governance, creating a dense network of accountability anchored in directives and cohesion policy. In contrast, Moldova’s architecture, while innovative, remains in a consolidation phase, strategically sequencing legal approximation and capacity-building to align with EU standards.

Second, concerning RQ2 on substantive themes, both countries prioritize core environmental domains such as waste, water, and air quality. A critical divergence, however, lies in the orientation of audit outcomes. Bulgaria’s audits have evolved toward performance-oriented and strategic aims, including climate adaptation and resource efficiency. Moldova’s audits, meanwhile, retain a more diagnostic character, primarily surfacing systemic gaps in infrastructure and enforcement.

Third, in response to RQ3 on procedural mechanisms, a significant divergence in maturity is evident. Bulgaria employs standardized, risk-based methodologies, robust follow-up mechanisms, and leverages digital systems like the EMAS registry to ensure transparency and data interoperability. Moldova’s procedures, while progressing through INTOSAI-aligned methods and international transparency frameworks (e.g., UNFCCC BTRs), remain critically dependent on capacity-building as a core procedural component.

Theoretically, these findings demonstrate the utility of the S-B-P (Structural, Substantive, Procedural) analytical framework for deconstructing and comparing complex audit systems. The framework successfully illuminates how different governance starting points—full EU integration versus EU-aligned reform—produce distinct audit pathways. Bulgaria exemplifies a ‘compliance-plus’ model, where auditing acts as a strategic steering tool directly informing policy and budget cycles. Moldova follows a ‘diagnostic-to-standardization’ pathway, where audits primarily catalyze institutional learning and incremental reform.

The practical implications are significant. For policymakers in Bulgaria, the priority is to deepen the ‘compliance-plus’ model by enhancing data integration and closing assurance gaps in complex areas like Scope 3 emissions. For Moldova, the imperative is to codify the audit cycle and accelerate digitalization to lock in diagnostic gains. For the international community, the study underscores that three levers are universally critical for amplifying audit impact: (1) continuous audit cycles with formal recommendation tracking, (2) interoperable digital data systems, and (3) structured stakeholder engagement in the follow-up process.

Acknowledging the limitations of this document-based study, future research should triangulate these findings with primary data from inspectorates and corporate surveys and test causal pathways linking audit recommendations to tangible performance indicators. Despite this limitation, the S-B-P framework offers a replicable template for assessing how environmental auditing translates into governance outcomes, providing clear guidance on where future policy and research investments can be most effectively prioritized.

In addition to these considerations, the study has several limitations that should be acknowledged. First, the analysis covers the period 2020–2025, which restricts the temporal scope and may not capture longer-term developments in environmental auditing. Second, the comparative results are sensitive to the thresholds used in qualitative normalization, and some patterns vary when coding specifications are adjusted. Third, cross-country comparisons may involve structural asymmetries and potential endogeneity, as institutional capacity, data availability, and regulatory maturity differ between Bulgaria and Moldova. These limitations do not undermine the empirical observations but delineate the boundaries within which our interpretations should be read.