ProcessSustainability

Running a double materiality assessment that stands up to assurance

A double materiality assessment decides which sustainability matters a company reports on under ESRS by testing each one twice: for its impact on people and the environment, and for its financial effect on the company. Done well, it is a documented sequence of judgements with evidence, thresholds and owners, not a survey-driven matrix, and the record of how it was done is itself subject to assurance.

Reviewed 6 min read

On this page
  1. Who needs this assessment after the Omnibus changes
  2. The assessment as a pipeline from context to disclosure
  3. Six steps, each with a record an assurer can follow
  4. Impact materiality and financial materiality side by side
  5. Documentation to keep for limited assurance
  6. A hypothetical food manufacturer separates the two tests
  7. Questions and answers
  8. Sources

Who needs this assessment after the Omnibus changes

The assessment as a pipeline from context to disclosure

inside-outoutside-in01Business and value chain02Long list of IROs03Impact scoring04Financial scoring05Thresholds and validation06Disclosure mapping
  1. Business and value chain

    Activities, business relationships, geographies and the people and ecosystems each one touches.

  2. Long list of IROs

    Candidate impacts, risks and opportunities, built from the ESRS sustainability matters and your own evidence.

  3. Impact scoring

    Severity and, for potential impacts, likelihood, judged with input from affected stakeholders.

  4. Financial scoring

    Likelihood and magnitude of effects on cash flows, financing and cost of capital.

  5. Thresholds and validation

    Pre-agreed cut-offs applied, results consolidated and challenged by management.

  6. Disclosure mapping

    Each material matter linked to ESRS disclosure requirements and a named data owner.

Conceptual flow of a double materiality assessment. Impact and financial scoring run in parallel on the same long list; it is not a timeline.

Six steps, each with a record an assurer can follow

  1. Map the business model, value chain and affected stakeholders

    Describe own operations and the upstream and downstream value chain by activity and geography, and list who is affected at each point: workers in the value chain, communities, consumers, and nature as a silent stakeholder. EFRAG's IG 1 distinguishes affected stakeholders from users of the sustainability statement, and both groups matter here3.

    Output
    Value-chain map and stakeholder register
    Owner
    Sustainability lead with strategy
  2. Build the long list of impacts, risks and opportunities

    Start from the list of sustainability matters in ESRS 1 Appendix A2 and add company-specific ones from incident logs, grievance data, supplier audits, sector guidance and existing risk registers. Phrase each item as a specific impact, risk or opportunity, not a topic name.

    Output
    Long list with evidence references
    Owner
    Sustainability analyst
  3. Assess impact materiality

    For actual negative impacts, judge severity from scale, scope and irremediable character; for potential impacts, combine severity with likelihood. For potential negative human rights impacts, severity takes precedence over likelihood2. Positive impacts are judged on scale, scope and, if potential, likelihood.

    Output
    Impact scores with rationale
    Owner
    Subject-matter experts, informed by stakeholder engagement
  4. Assess financial materiality

    Ask whether each matter triggers, or could reasonably be expected to trigger, material effects on development, financial position, performance, cash flows, access to finance or cost of capital, judged by likelihood and magnitude2. Use the enterprise risk register's scales where possible so the two processes agree.

    Output
    Financial scores with rationale
    Owner
    Finance and enterprise risk
  5. Set thresholds, consolidate and validate

    Agree thresholds before scoring, apply them, merge duplicates across business units, and test the result with management and stakeholder representatives. Record every change made at validation and who made it.

    Output
    Approved list of material matters
    Owner
    Management sponsor, audit committee informed
  6. Map material matters to disclosure requirements

    General disclosures under ESRS 2 apply regardless of materiality; topical requirements follow from what is material. Link each disclosure requirement to a data owner, a source system and a first-year data gap.

    Output
    Disclosure map and data plan
    Owner
    Reporting lead with data owners

Impact materiality and financial materiality side by side

AspectImpact materialityFinancial materiality
Question askedDoes the company affect people or the environment?Does the matter affect the company's financial prospects?
CriteriaScale, scope, irremediable character; likelihood if potentialLikelihood and magnitude of financial effects
Main evidenceStakeholder input, incident data, supplier audits, scientific sourcesRisk register, financial plans, scenario results, lender and customer terms
Typical ownersSustainability, human rights, environment, health and safetyFinance, treasury, enterprise risk, strategy
Time horizonsShort, medium and long term, as defined in ESRS 12Same horizons: the reporting period, up to five years, and beyond five years2

A matter is material if it passes either test. Most climate matters pass both; some community or biodiversity impacts pass only the first, and that is enough.

Documentation to keep for limited assurance

The CSRD requires assurance to cover the process used to identify the information reported, not only the numbers1.

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A hypothetical food manufacturer separates the two tests

Questions and answers

How often should a double materiality assessment be refreshed?

Review it every reporting cycle and redo it fully when something significant changes: an acquisition, a new market, a major incident or new evidence about value-chain impacts. A light annual review that records why the conclusions still hold is usually enough in stable years, and it keeps the assurance trail current.

Can we reuse an ISSB or GRI materiality assessment?

Partly. A GRI assessment is built on impact materiality and gives a strong start on the inside-out test. An assessment prepared for IFRS S1 looks at financial materiality from an investor's view. Neither alone meets ESRS, which requires both tests, but combining their evidence avoids starting from a blank page.

What do auditors most often ask about the assessment?

Expect questions on how the long list was built, why thresholds sit where they do, how affected stakeholders were heard, why specific matters were judged not material and how financial scores tie to the risk register. Clear written rationale for exclusions tends to matter more than the visual matrix.

Should the assessment be based on a stakeholder survey?

A survey can inform it, but it should not decide it. Severity and financial effects are judged on evidence; a survey mostly measures awareness. Use targeted engagement with affected groups or their representatives for impact questions, and internal finance and risk experts for financial ones.

Sources

  1. Directive (EU) 2022/2464 as regards corporate sustainability reporting (CSRD) — EUR-Lex · checked 10 October 2026
  2. Commission Delegated Regulation (EU) 2023/2772 as regards sustainability reporting standards — EUR-Lex · checked 10 October 2026
  3. ESRS implementation guidance documents (IG 1 Materiality Assessment) — EFRAG · checked 10 October 2026
  4. Corporate sustainability reporting — European Commission · checked 10 October 2026
  5. Directive (EU) 2025/794 amending Directives (EU) 2022/2464 and (EU) 2024/1760 as regards application dates — EUR-Lex · checked 10 October 2026
  6. Directive (EU) 2026/470 on certain corporate sustainability reporting and due diligence requirements (Omnibus I) — EUR-Lex · checked 10 October 2026

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