Partner
Consultant, Head of Sustainability Services, Sustainability Auditor IDW
Revised ESRS: Need for Action in the Double Materiality Assessment
- Existing DMAs must be adapted to the requirements of the revised ESRS.
- DMA conclusions must be reviewed annually and updated as necessary.
- The review and the required revision can be efficiently combined.
On July 3, 2026, the EU Commission published the delegated act on the revised European Sustainability Reporting Standards (ESRS).
The revised standards contain numerous changes and clarifications, including those regarding the double materiality assessment (DMA).
Companies that have already conducted a DMA now face the challenge of adapting existing processes and their methodology to the new requirements, which can have a direct impact on the results.
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Need for DMA Adjustments Due to ESRS Clarifications
The logic of the double materiality assessment remains in place even with the revised ESRS. We have already presented the new clarifications in detail in our article from December 10, 2025.
In addition to methodological simplifications such as the top-down approach or greater flexibility in the depth of assessment, the revised ESRS also contain specific adjustment requirements that must be taken into account.
- Materiality of information: According to the revised ESRS, information is considered material if its omission or misstatement could influence the decisions of the users of the sustainability report. For companies, this means in particular that their material topics and the material datapoints derived from them must be critically reviewed. In the sense of the newly introduced “fair presentation” principle, non-material information should, in principle, no longer be part of the report in the future. Voluntary inclusion remains possible, but only if clearly labeled as non-material.
- Revision of IROs: IROs must also be reviewed and, if necessary, re-evaluated with regard to actual and potential impacts. Actual negative impacts are to be assessed based on their real occurrence in the reporting year. In doing so, the effects of actions already implemented from previous years may be taken into account, but not actions of the current reporting year (gross vs. net consideration). In the case of potential negative impacts, prevention and mitigation actions may only be included if their effectiveness can be plausibly demonstrated. The materiality of information must always be taken into account.
- Adjustment of datapoint derivation: Previously, the mapping of IROs identified as material was typically based on the former ESRS 1 AR 16 list. This was slightly modified in the course of the ESRS revision; the previous sub-sub-topics are completely omitted. Therefore, companies must first assign the results of the DMA to the new ESRS 1 Appendix A list of topics. The material datapoints are then derived on this basis.
Annual Review of the DMA
The revised ESRS continue to emphasize that companies subject to reporting requirements must review their double materiality assessment annually.
According to ESRS 1, companies must assess at each reporting date whether significant changes have occurred that could have an impact on the previous conclusions of the materiality assessment. This explicitly includes changes in:
- Business activities, structure, or business relationships
- Understanding of impacts, risks, and opportunities (IROs)
- External environment and regulatory framework
- Assessment methods or data availability
Significance for Companies
The revised ESRS require both an annual review of existing double materiality assessments and their targeted adjustment to the new requirements. This creates a twofold need for action for companies.
With our DMA Quick-Fix, we efficiently combine both processes and bring existing analyses to an audit-proof status. In doing so, we build specifically on the existing approaches and results of our clients.
Please feel free to contact us.