CSRD double materiality assessment — lessons learned from first-timers

Just completed our first CSRD double materiality assessment and wanted to share some things I wish I'd known going in. Maybe this helps someone else avoid the same mistakes.

Context: mid-cap manufacturing company, ~3,000 employees, operations in 4 EU countries.

Biggest surprises:

1. The sheer number of ESRS datapoints is insane — over 1,100 before you filter by materiality
2. Getting internal stakeholder participation was harder than external
3. The line between "impact" and "financial" materiality is blurrier than the theory suggests

Anyone else finished their CSRD double materiality assessment recently? Curious what your experience was.

Totally agree on point 2 — our operations managers treated the internal survey as low priority until the CFO sent a reminder email. After that, participation jumped overnight. Lesson: make sure the double materiality assessment has visible executive sponsorship from day one.

For us the biggest surprise was how much the results challenged our assumptions. We went in expecting climate to dominate everything but workforce topics (working conditions, equal treatment) ended up scoring highest on impact materiality. It changed our entire reporting focus.

On the 1,100+ datapoints: the double materiality assessment is specifically designed to reduce that number. Once you've determined which topics are material, you only report on the relevant datapoints. We went from 1,100+ to about 280, which is still a lot but way more manageable.

Thanks for sharing this, Olivia. One thing to flag for anyone reading: the CSRD double materiality assessment isn't a one-time exercise. The regulation expects you to revisit it periodically — especially when there are significant changes to your business model, operating context, or stakeholder expectations.

So whatever process you design, make it repeatable. Document it well enough that someone else could run it next year without starting from zero.

Thanks for sharing this, Olivia. One lesson from our experience that might help others: the political dynamics of a double materiality assessment are as important as the methodology.

Some business units will push hard to have certain topics deemed "not material" because they know materiality triggers reporting obligations. You'll hear arguments like "that doesn't apply to us" or "the impact is negligible" without much supporting evidence.

Our solution: we required every materiality judgment to be documented with evidence, not just opinions. If someone argues that water usage is not material, they need to provide consumption data and benchmarks to support that claim. It forced rigor into what was otherwise becoming a political negotiation.

Also, on Olivia's point about the 1,100+ datapoints — don't let that number paralyze you. The ESRS structure is actually well-designed for filtering. Once you complete the materiality assessment, the list of applicable datapoints shrinks significantly. But you need to do the materiality work properly; if you skip corners there, you either over-report (wasting resources) or under-report (compliance risk).

For anyone just starting: the EFRAG implementation guidance documents are free and quite practical. They walk you through the process step by step with examples. Don't buy expensive consultant guides until you've read the free materials first.