5 min read

Double Materiality Assessment: The Complete ELI5 Guide

Understanding double materiality - the foundation of CSRD reporting. Learn how to identify what matters for your sustainability reporting

October 3, 2025ClearComply Team

The One-Minute Summary

Double materiality means looking at sustainability from two angles:

  1. Impact Materiality: How your business affects the world (environment and people)
  2. Financial Materiality: How sustainability issues affect your business financially

Under CSRD, you must report on both. If something is material from either perspective, you need to include it in your reporting.

The Two-Way Mirror Analogy

Think of double materiality as a two-way mirror:

  • Looking OUT: You see how your business impacts the world (pollution, jobs, community)
  • Looking IN: You see how the world's changes impact you (climate risks, regulations, reputation)

Both views matter equally under CSRD. This is different from traditional reporting that only cared about the "looking in" part.

Why Double Materiality Matters

The Old Way (Single Materiality)

Companies only reported sustainability issues if they affected profits. A factory's pollution only mattered if it led to fines or lost customers.

The New Way (Double Materiality)

Now that same pollution matters regardless of financial impact. If it significantly harms the environment or community, you must report it - even if you face no fines or customer backlash.

Breaking Down the Two Types

Impact Materiality (Inside-Out)

Question: How does our business affect the environment and society?

Examples:

  • Your carbon emissions contributing to climate change
  • Fair wages and working conditions for employees
  • Water consumption in water-stressed regions
  • Waste sent to landfills
  • Community employment opportunities

Key point: This matters even if there's no immediate financial consequence to your business.

Financial Materiality (Outside-In)

Question: How do sustainability issues affect our financial performance?

Examples:

  • Carbon taxes increasing your costs
  • Extreme weather disrupting your supply chain
  • Skilled worker shortages affecting productivity
  • Changing consumer preferences affecting sales
  • New regulations requiring expensive upgrades

Key point: This is what investors traditionally care about.

How to Conduct a Double Materiality Assessment

Step 1: Identify Your Impacts (2-3 days)

Map out all the ways your business interacts with the environment and society:

  • What resources do you consume?
  • What do you emit or discharge?
  • Who do you employ?
  • Who uses your products/services?
  • What communities do you operate in?

Practical tip: Walk through your entire value chain from suppliers to end-of-life disposal.

Step 2: Identify Your Dependencies (2-3 days)

Map out what you depend on that could be affected by sustainability issues:

  • Natural resources needed
  • Stable climate conditions
  • Skilled workforce availability
  • Social license to operate
  • Regulatory permits

Practical tip: Ask "What could disrupt our business model?"

Step 3: Engage Stakeholders (1-2 weeks)

You can't do this in a bubble. Talk to:

  • Employees
  • Customers
  • Suppliers
  • Local communities
  • Investors
  • NGOs relevant to your industry

What to ask them:

  • What impacts of our business concern you most?
  • What sustainability risks do you see for our company?
  • What should our priorities be?

Step 4: Score and Prioritize (3-5 days)

Rate each topic on two scales:

Impact Materiality Scale:

  • Scale of impact (how big?)
  • Scope of impact (how many affected?)
  • Irremediability (can it be fixed?)
  • Likelihood (how probable?)

Financial Materiality Scale:

  • Magnitude of financial effect
  • Likelihood of occurrence
  • Time horizon

Step 5: Create Your Materiality Matrix (1 day)

Plot all topics on a matrix:

  • X-axis: Financial Materiality (low to high)
  • Y-axis: Impact Materiality (low to high)

Anything scoring high on EITHER axis is material and must be reported.

Common Double Materiality Topics by Industry

Most Industries:

  • Climate change (emissions)
  • Own workforce conditions
  • Business ethics
  • Energy use

Manufacturing:

  • Resource consumption
  • Waste and circular economy
  • Product safety
  • Supply chain labor

Services:

  • Data privacy
  • Diversity and inclusion
  • Skills development
  • Customer satisfaction

Retail:

  • Product sustainability
  • Supply chain impacts
  • Consumer information
  • Packaging waste

Practical Example: A Furniture Manufacturer

Let's walk through double materiality for "Wood Sourcing":

Impact Materiality Assessment:

  • Deforestation impact: HIGH (contributes to habitat loss)
  • Community impact: MEDIUM (affects forest communities)
  • Climate impact: MEDIUM (forests are carbon sinks)
  • Overall: MATERIAL ✓

Financial Materiality Assessment:

  • Supply risk: MEDIUM (certification requirements increasing)
  • Price risk: HIGH (sustainable wood costs more)
  • Reputation risk: HIGH (customers care about forests)
  • Overall: MATERIAL ✓

Result: Wood sourcing is double material - report required on forestry practices, certification, sourcing policies, and targets.

The 3 Most Common Mistakes

Mistake 1: Only Considering Financial Materiality

Many companies still think like investors and ignore impact materiality. Under CSRD, this means missing half the picture.

Mistake 2: Setting Thresholds Too High

Being conservative might seem safe, but reporting on clearly material topics is mandatory. When in doubt, include it.

Mistake 3: Doing It Once and Forgetting

Materiality changes over time. Plan to update your assessment every 1-2 years or when major changes occur.

Tools and Templates

What You Need:

  1. Stakeholder interview templates
  2. Scoring methodology document
  3. Matrix visualization tool
  4. Documentation templates

Helpful Resources:

  • EFRAG's materiality assessment guidance
  • Industry-specific materiality maps (SASB)
  • Peer company reports for benchmarking
  • Stakeholder engagement specialists

Your 30-Day Action Plan

Week 1: Internal assessment

  • Map impacts and dependencies
  • Review existing stakeholder feedback
  • Identify key stakeholders to engage

Week 2: Stakeholder engagement

  • Conduct interviews/surveys
  • Host stakeholder workshop
  • Gather external perspectives

Week 3: Analysis and scoring

  • Score all topics
  • Create preliminary matrix
  • Identify clear material topics

Week 4: Validation and documentation

  • Review with leadership
  • Validate with key stakeholders
  • Document methodology and results

The Bottom Line

Double materiality is the foundation of your entire CSRD reporting. Get this right, and everything else follows. Get it wrong, and you'll either report on the wrong things or miss mandatory disclosures.

Remember: It's not about what YOU think is material - it's about what IS material from both impact and financial perspectives. Be thorough, be inclusive in your stakeholder engagement, and document everything.

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