Examining the Pitfalls in CSRD-Aligned Double Materiality Assessments: A Guide for Companies

Editorial TeamEditorial Team
March 26th, 2024
3:16 PM

The CSRD will revolutionize sustainability reporting, aligning it with financial disclosures by requiring comprehensive ESG reporting, necessitating a substantial expansion in disclosure scope regardless of previous practices.


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The European Union's Corporate Sustainability Reporting Directive (CSRD) stands as a pivotal regulation poised to revolutionize your company's approach to sustainability reporting. Designed to elevate reporting standards to parity with financial disclosures, the CSRD mandates comprehensive reporting on environmental, social, and governance (ESG) topics. Regardless of past nonfinancial reporting practices, compliance with the CSRD necessitates a significant expansion of disclosure scope and depth.

To meet CSRD requirements, companies must undertake a "double materiality" assessment, broadening the traditional focus on financial materiality to encompass impacts on stakeholders and society. This approach recognizes that both financial and impact materiality are integral and interconnected. Material risks and opportunities stem from the complex interplay of natural, human, and social resources, with potential implications unfolding over time.

Successfully navigating this assessment demands a nuanced understanding of materiality from dual perspectives, ensuring comprehensive identification of sustainability impacts, risks, and opportunities. By embracing this holistic approach, your company can effectively meet CSRD obligations and contribute to a more transparent and sustainable future.


Dual Perspectives: Financial and Impact Materiality

Financial materiality involves assessing how sustainability issues could impact a company's financial performance and position across short, medium, and long-term horizons. If omitting or misstating sustainability information could influence decisions made by primary users of financial reports, these matters are deemed material. On the other hand, impact materiality focuses on the tangible or potential effects on people or the environment directly linked to a company's operations and value chain. These impacts, whether positive or negative, span short, medium, and long-term timelines.

This dual perspective adds complexity to materiality assessments. The European Sustainability Reporting Standards (ESRS), outlining CSRD reporting requirements, mandate companies to independently evaluate the materiality of sustainability matters from both financial and impact viewpoints. Disclosure is required if a sustainability matter is deemed material from either perspective. To make these determinations, companies will likely require a deeper understanding of sustainability issues within their value chain to effectively measure and assess financial and impact materiality. These steps represent a new frontier for many companies, necessitating a comprehensive approach to sustainability reporting.


Navigating Materiality Assessment Challenges

Currently, there lack of consensus on materiality assessment practices, with recently proposed implementation guidance by EFRAG offering some flexibility. In this dynamic environment, companies must steer clear of common pitfalls during the design and execution of their materiality assessments. Building a solid foundation in this regard is paramount for CSRD reporting.

To aid in this endeavor, we have identified prevalent pitfalls observed during materiality assessments and provided key insights to help companies avoid similar missteps. By addressing these challenges proactively, companies can equip themselves to handle queries from senior management, audit committees, and assurance processes with confidence.


Shortcuts in Materiality Assessment

Rapidly producing a materiality assessment without proper documentation can expose companies to compliance risks. Focusing solely on speed neglects the need to document the assessment process, sources of information, and level of detail required for disclosing material impacts, risks, and opportunities. A thorough and documented materiality assessment not only mitigates compliance risks but also saves time and resources in the long run, even if the process requires refinement over time. Leveraging inputs from a double materiality assessment and considering all elements can ultimately lead to a more efficient reporting process.  

Lack of Depth in Materiality Assessment

Performing a high-level materiality assessment that overlooks subtopics, impacts, risks, and opportunities, or fails to consider the value chain, exposes companies to compliance risks. Analysis at the topic level without delving into specific impacts and mapping them to components of the value chain limits the coverage and accuracy of the assessment. To produce decision-useful disclosures and streamline reporting, it's crucial to consider subtopics and their alignment with the value chain.


Overreliance on ESRS List

Relying solely on the ESRS list of sustainability matters overlooks entity-specific topics and industry-specific frameworks crucial for a comprehensive materiality assessment. Disclosure of sector-specific information provides stakeholders with vital insights into the impacts and financial implications of sustainability matters. While the ESRS allows for disclosures based on other frameworks like International Financial Reporting Standards (IFRS) or Global Reporting Initiative, clear labeling is necessary in reporting to ensure transparency and alignment with regulatory requirements.