Double materiality assessment: a step-by-step process
A working process for running a double materiality assessment, from scoping and stakeholder input to scoring, sign-off and documentation, with the evidence an auditor will want to see.
A double materiality assessment (DMA) decides which sustainability topics you report on. It looks at two things: how your business affects people and the environment (impact materiality) and how sustainability matters affect your business (financial materiality). If you need the concept first, read what is a double materiality assessment.
What the revised ESRS change
The Commission adopted revised ESRS on 3 July 2026, and advisory sources report publication in the Official Journal in September 2026. Double materiality stays. The revised text is described as moving towards a top-down starting point based on the business model and strategy, with a more detailed look only where materiality is not obvious, and it adds a relief for undue cost or effort. Check the final text for how this applies to you. The original ESRS (2023) described the process under the disclosure requirement IRO-1 and the result under IRO-2, and EFRAG published implementation guidance on materiality assessment in 2024.
Step 1: Understand the business and value chain
Write down your activities, sites, products, main suppliers, customers and the countries involved. This is the map you will test topics against. EFRAG's guidance on the value chain is a useful companion.
Step 2: Build a long list of topics
Start from the ESRS topics: climate, pollution, water and marine resources, biodiversity, resource use and circular economy, own workforce, workers in the value chain, affected communities, consumers and end-users, and business conduct. Add company-specific topics where they matter.
Step 3: Gather input
Talk to the people who know the business and to those affected by it. This usually includes management, operations, procurement, HR, key customers and suppliers, and, where practical, employee representatives. Record who you consulted, when and how. Do not claim wider engagement than happened.
Step 4: Identify impacts, risks and opportunities
For each topic, list actual and potential impacts, and the risks and opportunities that follow. Link each to a place in the business or value chain.
Step 5: Score and set thresholds
Agree a scoring scale before you score anything. Impacts are usually rated on scale, scope, irremediable character and likelihood. Financial effects are rated on size and likelihood. Write the threshold for "material" down, and keep it the same for every topic.
Step 6: Challenge the result
Have a person outside the working group test the outcome. Ask: what would an outsider expect to see that is missing? Which topics did we exclude and why?
Step 7: Approve and map to datapoints
Get formal sign-off from management or the board. Then map each material topic to the disclosure requirements and datapoints it triggers. EFRAG's list of ESRS datapoints is designed to help with that mapping, and a draft list for the revised standards was published in August 2026.
Step 8: Document the audit trail
Keep the method note, the long list, the scores, the minutes of the challenge session and the sign-off. Assurance providers will ask for these. See what auditors ask for.
Refresh it
Revisit the assessment when your business changes materially and at least once a year to confirm that it still holds.
Tools and advisers
wetando
Leipzig and Berlin consultancy offering materiality analysis, CO2 accounting and sustainability reporting alongside wider business advice.
preeco
Ulm-based compliance software suite with a sustainability module for ESG reporting, materiality analysis and supplier risk assessment.
Sweep
Sustainability data platform for carbon accounting, double materiality and CSRD reporting.
Footprint Intelligence
Munich-based AI sustainability platform for carbon footprints, double materiality analysis and CSRD, VSME and GRI reporting.
Datamaran
Software for ESG risk monitoring and materiality assessment using regulatory and public data.
PHINEO
Berlin non-profit advisory offering double materiality analysis and CSRD compliance support for organisations.
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Official sources
- EFRAG: implementation guidance on materiality assessment and value chain
- EFRAG news on the revised ESRS delegated act
This guide is general information, not legal, tax or investment advice. Rules change; check the official sources and talk to an adviser before you rely on it.
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