Various elements related to materiality testing are scattered throughout all twelve ESRS standards issued by the European Commission in the summer of 2023. Fundamental issues, such as the description of the double materiality principle, definitions of impact materiality and financial materiality, and detailed parameters for each of these perspectives are included in Chapter 3 of ESRS 1. The application requirements in this standard also include, in AR16, a structured, three-level list of 90 sustainability topics that a company should consider in its materiality assessment. In addition, each of these topics is discussed in detail in the corresponding thematic standard.
ESRS 2, in turn, contains several disclosure requirements that must be met when disclosing the results of the materiality assessment. First of all, based on IRO-1, the materiality assessment process must be described in detail. SBM-3 requires a list of all significant impacts, risks, and opportunities identified as a result of the assessment. This list must be supplemented with fairly detailed information, e.g., whether a given impact results from the company's business model and strategy and how it is related to them, or whether the impact is exerted within the company's operations or in its value chain. IRO-2, on the other hand, regulates the manner of compiling a list of standards and disclosure requirements that have been identified as material as a result of the assessment and are therefore included in the report.
The GRI standards approached materiality in a less formalized manner and were based solely on the perspective of material impact. The principles of financial materiality set out in financial reporting standards (specifically IAS 1) are much more concise in terms of guidance on what materiality means. Conducting a materiality assessment in accordance with ESRS standards is therefore a new skill that report preparers must learn.
Of course, it is best to learn through practice, but sometimes it is worth listening to expert advice first. This Friday (September 20, 2023), the Polish Association of Listed Companies is organizing webinar dedicated to researching materiality. At MATERIALITY ACADEMY, we have launched a new course covering all aspects of significance testing. It discusses not only theoretical principles, but also presents a practical process for conducting a materiality assessment that can be applied in any company or capital group.
Conducting a thorough materiality assessment can be difficult the first time around. However, it is important to devote sufficient time and attention to it. Mistakes can come back to haunt you in the form of a report that is too broad or too narrow in scope, leading to problems during the audit stage. In subsequent years and with subsequent editions of the study, it will be easier – primarily because we will deepen our analysis of those issues about which we did not have sufficient knowledge during the first study.
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