Raising the Bar: Increasing Quality of Impact Data and Double Materiality Assessment

The European Union's Corporate Sustainability Reporting Directive (CSRD) represents a significant shift in sustainability reporting. As part of the EU Green Deal, it emphasizes the importance of transparency and accountability in corporate activities. A key component of this directive is the Double Materiality Assessment (DMA). CSRD companies are required to evaluate their sustainability matters from two distinct perspectives: financial materiality and impact materiality.

The CSRD mandates that companies independently assess whether a sustainability matter is material from a financial or impact perspective—or both. A matter is considered material if it requires disclosure from just one of these perspectives. This dual approach adds complexity to materiality assessments but also ensures a more comprehensive and fact-based understanding of a company's sustainability footprint.

Data Quality in Double Materiality Assessments 

During these first few years of CSRD reporting, DMAs are often conducted with estimates based on the “best possible information” proxy data, generic data models, indirect stakeholder feedback, and publicly available scientific research. The availability of actual products and site-specific data is often limited. Although these estimations and limitations are expected now, future DMAs will require businesses to develop their data. By coordination and stakeholder communication, more accurate, recent, and specific data may need to be produced to achieve better performance and realize competitive advantage.

The Path Forward: Improving Data Quality and Stakeholder Communication 

The CSRD has put into motion a need to genuinely connect businesses, not only within the organization but across its value chain. As business systems mature, the quality of sustainability-related information will probably increase. Data standardization will enable businesses to report consistent metrics at the site level, leading to richer KPIs and increased visibility of progress.

Value chain partner communication will also need to mature to keep up with CSRD demands. Businesses are increasingly being expected to understand, not estimate or model where raw materials come from, how that material enters their supply chain, and what are the impacts to the people and communities along the way.

The Key to More Accurate Sustainability Reporting 

To effectively conduct a DMA, companies must move beyond merely estimating impacts. They will need to adopt a granular approach that includes compiling and coordinating site-level assessments to directly measure sustainability impacts. This involves a detailed analysis of operations at each site, considering local environmental, social, and governance (ESG) factors, and aligning them with broader corporate sustainability goals.

The transition to this level of detail in sustainability reporting is challenging but necessary. It allows for a more accurate and actionable understanding of a company's sustainability impacts and the risks and opportunities associated with them. By doing so, companies can not only comply with the CSRD but also demonstrate their commitment to sustainable practices to stakeholders and society at large.

Additional Resources 

For further information on conducting a DMA in line with the CSRD, resources such as the European Financial Reporting Advisory Group's (EFRAG) recently published Materiality Assessment Implementation Guidance (MAIG) and Value Chain Implementation Guidance (VCIG) provide considerations and insights into this complex undertaking. These resources provide detailed instructions and considerations that can help companies navigate the complexities of double materiality and enhance the quality of their sustainability reporting.

Conclusion: The Future of Double Materiality and Sustainability Reporting 

The transition to comprehensive sustainability reporting through Double Materiality Assessments presents both challenges and opportunities for businesses. While the complexity of data collection and the current reliance on proxy information may seem daunting, the future demands more accuracy, transparency, and collaboration across the value chain. By embracing these changes, companies can not only meet the evolving regulatory requirements under the CSRD but also position themselves as leaders in sustainability.

As businesses enhance their data collection practices and strengthen communication with stakeholders, they will be better equipped to provide meaningful insights into their sustainability efforts. This, in turn, will build trust with stakeholders and create a competitive advantage in a marketplace increasingly focused on sustainability. With the right tools, resources, and mindset, companies can rise to the challenge and contribute to a more sustainable future.

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