ESRS
“Appropriate qualitative considerations and quantitative thresholds”, chosen by the undertaking (¶37).
Qualitative may suffice (AR 13, AR 19).Materiality · the working file
Double materiality assessment template: the register the ESRS imply
A double materiality assessment template is a working register, not an official form: neither the ESRS nor EFRAG prescribes one.
The revised ESRS 2 IRO-1 says what the statement must disclose about the process, and the revised ESRS 1 Chapter 3 says how each matter is judged, so a register whose fields follow those paragraphs is the template.
The worksheet on this page builds one with you, applying the severity and either-lens rules as you go.
Is there an official template?
No official template exists, and that is deliberate
The revised ESRS fix the criteria and the disclosure, and leave the working format to the undertaking.
EFRAG’s IG 1 says the ESRS do not mandate a specific process, and it is non-authoritative and written for the 2023 standards.
Read why a register beats a form
Because the process is inside the limited assurance opinion under Article 34(1), the useful template is the one an assurance provider can trace from conclusion back to evidence.
IRO-1 asks for the process and decision steps, the methods, inputs and assumptions, the thresholds, and when the assessment was last updated, and it warns against boilerplate.
A register with one row per matter answers each of those questions directly, which a narrative alone does not.
The method behind each column is on the double materiality assessment, and the concept on double materiality explained.
EFRAG’s guidance page lists no implementation guidance for the revised ESRS as at 11 October 2026, and what IG 1 to IG 3 still offer is set out separately.
What the ESRS do fixExplore
Module 01 / 04
The criteria
Severity, likelihood, magnitude and the either-lens rule in revised ESRS 1 Chapter 3.
Module 02 / 04
The disclosure
IRO-1 on the process, IRO-2 on the results, SBM-3 on strategy.
Module 03 / 04
The method
Left to the undertaking: top-down, bottom-up or both, qualitative or scored.
Build your register
A double materiality worksheet that applies the rules as you go
Add one matter at a time: choose its topic and lens, score it, and the worksheet shows the conclusion and the paragraph it rests on.
Severity is the highest of scale, scope and irremediable character, because any one of them can make a negative impact severe (AR 22).
Likelihood is asked only for potential impacts, and for a potential human rights impact severity decides (¶40).
Positive impacts use scale and scope, plus likelihood if potential, and are never netted against negative ones (¶¶41, 44).
Risks and opportunities use magnitude and likelihood (¶50), and a matter material on either lens is material (¶35).
The 1 to 5 scales and the single threshold are the worksheet’s convention, not the standard’s, and nothing you enter is stored or sent.
When the register is built, copy it as CSV into your own working file and add the evidence column the worksheet leaves to you.
Double materiality · working register
Impact material
¶40 and AR 22: actual negative impact, severity 3 (highest of the three) against 3.
Rules: revised ESRS 1 ¶40 (negative impacts: severity from scale, scope and irremediable character; likelihood for potential impacts; severity first for human rights), ¶41 (positive impacts: scale and scope, plus likelihood if potential), AR 22 (any one factor can make an impact severe, so the highest is taken), ¶50 (risks and opportunities: likelihood and magnitude) and ¶35 (either lens is enough).
The 1–5 scales and the single threshold are this worksheet’s convention: the ESRS set no numeric threshold (¶37) and do not require quantitative scoring (AR 13).
Nothing is stored or sent; the register lives in this page until you leave it.
The fields
Eighteen fields, each tied to a paragraph
The fields fall into four groups: what the matter is, what kind of matter it is, how it was assessed, and what was concluded.
Every one traces to a paragraph of the revised ESRS 1 or ESRS 2, so the register doubles as the IRO-1 evidence file.
Read the full field list with its paragraphs
| Field | What it records | Where the rule is |
|---|---|---|
| Matter | A short description of the impact, risk or opportunity | Revised ESRS 1 ¶25 |
| ESRS topic and sub-topic | E1–E5, S1–S4, G1 or entity-specific; the sub-topic where one applies | ¶¶29–30; ¶11 for entity-specific |
| Value-chain location | Own operations, upstream or downstream; business relationships beyond direct contracts | ¶39 |
| Lens | Impact, or risk or opportunity (record both rows if both apply) | ¶35 |
| Impact kind | Actual or potential; negative or positive | ¶¶39–41 |
| Scale, scope, irremediable character | Scores or qualitative ratings; irremediable for negative impacts only | ¶40, AR 22 |
| Likelihood (impact) | Potential impacts only | ¶¶40–41 |
| Human-rights flag | Severity takes precedence over likelihood for potential negative human rights impacts | ¶40 |
| Time horizon | Short, medium or long term; not every horizon needs analysing | ¶39, AR 15(b) |
| Policies and actions taken into account | Implemented and reasonably effective only; remediation in the year not counted for actual impacts | ¶43, AR 27 |
| Source of the risk or opportunity | A material impact, a dependency, or another factor such as climate hazards or regulation | ¶48 |
| Magnitude and likelihood (financial) | Potential magnitude of financial effects and likelihood of occurrence | ¶50 |
| Threshold applied | The qualitative consideration or quantitative threshold, as recorded | ¶37, AR 13, AR 19 |
| Route | Top-down from strategy and business model, or bottom-up | ¶¶27–28, AR 9–10 |
| Evidence and stakeholder input | Due-diligence engagement, sector data, risk-management outputs; survey optional | ¶¶32–33, ¶42, AR 23–24, AR 29 |
| Conclusion | Material or not; material on either lens is material | ¶35 |
| Disclosure it feeds | IRO-1 (process), IRO-2 (results), SBM-3 (strategy) | Revised ESRS 2 |
| Date and reviewer | When last updated, and by whom | ¶34; ESRS 2 IRO-1 |
Record one row per sub-topic rather than per standard, because ¶30 limits reporting to the material information for a material sub-topic.
Where a matter is both an impact and a source of financial risk, two linked rows keep the two judgements separate, as ¶35 treats them.
The thresholds column is the one most often left blank, and it is the one IRO-1 asks about by name.
- 1
Identify
Matter, topic, sub-topic and value-chain location.
- 2
Characterise
Impact kind, or the source of the risk or opportunity.
- 3
Assess
Severity, likelihood, magnitude and the threshold applied.
- 4
Conclude
Material on either lens, with the evidence and the disclosure it feeds.
Impact columns
Scoring impacts in the template: severity, then likelihood
An impact row needs to say which of four kinds it is before it can be scored, because the rule differs for each.
The three severity characteristics are defined in AR 22: scale is how serious or how beneficial, scope how widespread, and irremediable character how far the harm could be put right.
Read the impact rules a template must respect
Averaging the three characteristics breaks AR 22, under which any one of them can make a negative impact severe.
Multiplying severity by likelihood for an actual impact is also wrong: likelihood applies only to potential impacts.
¶43 settles gross and net: record the policies taken into account, and include only implemented ones that can reasonably be assumed to work.
AR 15 means the template need not score every characteristic or every time horizon where a conclusion is already clear, but it should say so.
The full treatment is on impact materiality, and the impacts, risks and opportunities vocabulary on impacts, risks and opportunities.
Four kinds of impact rowExplore
Module 02 / 04
Potential negative
Severity and likelihood; human rights: severity first.
Financial columns
Scoring risks and opportunities: magnitude and likelihood
A financial row records where the risk or opportunity comes from, how large its financial effect could be and how likely it is.
Its scope is wider than the financial statements: ¶46 calls financial materiality an expansion of financial-statement materiality.
Read the financial columns in detail
AR 29 names the internal risk-management framework as a valuable input, so the risk register is a natural source for these rows.
AR 31 asks for likely scenarios and anticipated financial effects not yet in the financial statements to be considered.
The joint ESRS–ISSB interoperability guidance says the ESRS definition of financial materiality is aligned with IFRS S1, so these rows are the ones a UK SRS register can reuse.
More on the outside-in lens is on financial materiality.
Where a financial row comes fromExplore
Module 01 / 04
A material impact
An impact can be financially material from the start or become so.
Module 02 / 04
A dependency
On natural, human or social resources, whatever the impact.
Module 04 / 04
The test
Likelihood combined with potential magnitude of financial effects.
The threshold column
Record your threshold, because no standard sets one
The threshold column is where a template earns its keep, because every framework leaves the number to the reporter.
The revised ESRS 1 ¶37 asks for “appropriate qualitative considerations and quantitative thresholds” and names no figure.
Read how thresholds are set and recorded
AR 19 says that in a top-down approach qualitative considerations may be enough, and in a bottom-up approach either qualitative considerations or quantitative thresholds may be used.
UK SRS S1 ¶B19 says the standard “does not specify any thresholds for materiality or predetermine what would be material in a particular situation”.
GRI 3 asks the organisation to arrange impacts from most to least significant, define a cut-off and document it.
Audit percentages do not transfer: the ESRS and UK SRS import none of them, as materiality thresholds explains.
Who sets the threshold?
UK SRS and GRI
UK SRS S1 sets no thresholds (¶B19); GRI 3 asks the organisation to define and document one.
Entity-specific in every case.Questionnaire and survey
A double materiality questionnaire is optional, not required
People search for a double materiality questionnaire or survey because surveys became a habit, but the revised ESRS do not demand one.
AR 24 says engagement carried out in due diligence provides “a valuable input to its materiality assessment, without the need to put in place a separate engagement process for the materiality assessment”.
Read when a survey helps, and illustrative question themes
An undertaking may still seek direct input from affected stakeholders or their representatives, users and experts, including feedback on its conclusions (AR 24).
AR 23 lists the typical categories: workers in the own workforce and value chain, affected communities, and consumers and end-users, with attention to those in vulnerable situations; nature may be considered a silent stakeholder.
If a survey is used, it is one input in the evidence column, not the assessment itself.
Illustrative themes for such a survey, not drawn from any standard: which impacts respondents experience or observe; how severe and widespread they are; whether any could not be put right; and which risks or opportunities they expect the business to face.
A survey cannot replace the scoring: AR 22 and ¶40 still decide severity, whatever respondents rank first.
The engagement rules in full are on double materiality stakeholder engagement.
Inputs to the registerExplore
Module 01 / 04
Due diligence
Engagement with affected stakeholders in ongoing due diligence is a key input.
Module 02 / 04
No separate process
That engagement serves the assessment without a separate engagement process.
Module 03 / 04
Sector data
Average regional or sector data can stand in for supplier input.
Module 04 / 04
Risk management
The internal risk-management framework is a valuable input.
What the register feeds
From template to statement: the ESRS 2 disclosures
The register is not published; what it produces is.
The process columns answer IRO-1, the conclusion column answers IRO-2, and the source and strategy notes feed SBM-3.
Read how the columns map to the disclosures
IRO-1 asks for a concise description of the decision-making steps, the methods, inputs and assumptions, and the qualitative considerations or quantitative thresholds applied, and it warns against boilerplate.
IRO-2 asks for the list of material impacts, risks and opportunities and the disclosure requirements met; if climate is concluded not material, it asks for the basis of that conclusion.
Keeping the date and reviewer column current is what lets IRO-1 say when the assessment was last updated.
Where the rows end upExplore
Module 01 / 04
IRO-1
The process: steps, methods, inputs, thresholds, and when it was last updated.
Module 02 / 04
IRO-2
The results: the material impacts, risks and opportunities, and the disclosure requirements met.
Other frameworks
The same template for UK SRS or GRI
One register can serve three frameworks if the rows are tagged by lens.
For UK SRS, keep the financial rows: information is material if it could reasonably be expected to influence decisions of primary users of general purpose financial reports (S1 ¶18).
Read the UK SRS and GRI variants
UK SRS S1 ¶B25 says information that is not material need not be disclosed even where a standard lists it as a minimum requirement, and ¶B28 requires judgements to be reassessed at each reporting date.
The ISSB’s educational material describes four steps — identify, assess, organise, review — and is explanatory, not part of the Standards.
For GRI materiality, keep the impact rows: GRI 3 makes significance “the sole criterion” and asks for the threshold to be documented.
How the frameworks compare is on materiality assessment for any framework and UK SRS materiality.
Three registers, one evidence baseExplore
From register to picture
A matrix is drawn from the register, not instead of it
The phrase “materiality matrix” does not appear anywhere in Delegated Regulation (EU) 2026/1563.
A matrix can still help a board read the register, as long as a matter high on one axis and low on the other stays material.
Read how to draw one honestly
Plot severity or magnitude against the threshold you recorded, not against an average.
Mark impact-only and financial-only matters as material, because ¶35 makes either lens enough.
The pitfalls are on the materiality matrix question.
The completed register
Disclosure
IRO-1 and IRO-2 draw on the rows: process, thresholds, results.
Optional picture
A matrix can plot the rows, provided either-lens matters stay material.
Filling the register across a year
When each part of the template gets filled in
This is an illustrative order of work, not a timetable the ESRS prescribe.
The point is that the register is maintained, not rebuilt: ¶34 asks only whether significant changes affect the earlier conclusions.
- 01 / Version01
Record which ESRS applies
For FY2026 one of three options, stated in the statement; from FY2027 the revised ESRS. - 02 / Long list02
Add a row per matter
Screen all ten topical standards, then add entity-specific matters. - 03 / Route03
Mark top-down or bottom-up
Topic by topic, with the strategy and business-model analysis behind it. - 04 / Score04
Fill the impact and financial columns
Severity as the highest factor; likelihood only where potential. - 05 / Evidence05
Attach the inputs
Due-diligence engagement, sector data, risk-management outputs. - 06 / Report date06
Check for significant changes
Update only the rows where something significant changed, and date the review.
What the template is built on
The instruments behind the template, by date
Each instrument below changed what a template has to hold.
Dates are those of the instruments themselves, as at 11 October 2026.
- 1 January 202301
GRI 3 effective
Material topics as the most significant impacts; the organisation documents its threshold. - 31 July 202302
- 31 May 202403
- 19 November 202404
ISSB educational material
Four steps to identify material information; explanatory only. - 25 February 202605
UK SRS published
UK SRS S1 keeps single (financial) materiality and sets no thresholds. - 21 September 202606
Revised ESRS in the Official Journal
DR (EU) 2026/1563; applies to financial years beginning on or after 1 January 2027.
What goes wrong in templates
Template mistakes that change the result
Most template errors come from spreadsheet habits that the revised ESRS 1 rules out, and the same rules are the test for any software or adviser.
A formula that averages scale, scope and irremediable character, or multiplies every impact by likelihood, will under-report serious impacts.
Read the full list
Counting a policy that is only planned breaks AR 27.
Netting a positive impact against a negative one breaks ¶44.
Reporting rows found immaterial breaks ¶24, which says immaterial ESRS information “shall not” be disclosed, apart from supplementary information under section 8.2.
Treating a survey ranking as the conclusion skips the severity rules altogether.
Worked results from published statements are on double materiality examples.
If a customer sent you a template
A supplier with an average of 1,000 employees or fewer may decline information beyond the voluntary standard’s capped datapoints when the request is for the customer’s CSRD reporting.
The Commission says the cap “does not impose or imply any obligation” on companies in the value chain; see its note of 6 May 2026 and the voluntary standard for suppliers.
Check your templateExplore
Frequently asked
Questions people ask
Is there an official double materiality assessment template?
No. Neither the ESRS nor EFRAG prescribes a template.
The revised ESRS 2 IRO-1 sets out what must be disclosed about the process — the steps, methods, inputs, thresholds and when the assessment was last updated — so a working register built to answer IRO-1 is the practical template.
What fields should a double materiality assessment template have?
At minimum: the matter; its ESRS topic and sub-topic; where in the value chain it sits; whether it is an impact or a risk or opportunity; for impacts, actual or potential, negative or positive, scale, scope, irremediable character and, for potential impacts, likelihood; for risks and opportunities, their source, magnitude and likelihood; the threshold applied; the route (top-down or bottom-up); the evidence; the conclusion; and the date and reviewer.
Do I need a stakeholder survey or questionnaire?
No. The revised ESRS 1 makes engagement with affected stakeholders carried out in ongoing due diligence a key input (¶42), and AR 24 says that engagement is enough, without a separate engagement process for the materiality assessment.
A survey is an optional extra input, not a requirement.
Does the template need a scoring scale?
Not under the ESRS.
Quantitative information or scoring is not necessarily required and a qualitative analysis may be sufficient (AR 13).
If you use a scale, record it and apply it consistently, because the process is inside the limited assurance opinion for a CSRD reporter.
How is severity scored in the template?
From three characteristics — scale, scope and irremediable character — and any one of them can make a negative impact severe (AR 22). So take the highest, not the average.
Likelihood is a separate field used only for potential impacts, and for a potential human rights impact severity takes precedence over likelihood (¶40).
Should the template net policies against impacts?
Only implemented ones.
Actual negative impacts are assessed as they manifested in the reporting year, and potential negative impacts take account of prevention and mitigation only if the policies and actions are implemented and can reasonably be assumed to work (¶43).
A policy that merely implies future actions is not considered (AR 27).
Does the template need a materiality matrix?
No. The phrase does not appear in Delegated Regulation (EU) 2026/1563.
A matrix can be drawn from the register as an optional picture, but the register is what IRO-1 and an assurance provider rely on.
What threshold should the template use?
Your own, recorded.
The revised ESRS 1 ¶37 asks for “appropriate qualitative considerations and quantitative thresholds” without setting a number, and UK SRS S1 ¶B19 sets no threshold either.
GRI 3 asks the organisation to define and document its threshold.
Can I use the same template for UK SRS?
Use the financial half.
UK SRS S1 applies single (financial) materiality: information is material if omitting, misstating or obscuring it could reasonably be expected to influence decisions of primary users of general purpose financial reports (¶18).
Impact-only rows stay on the EU side unless they would affect cash flows, access to finance or cost of capital.
How often is the register updated?
At each reporting date the undertaking considers whether significant changes could affect its earlier conclusions and updates the assessment if so (revised ESRS 1 ¶34).
UK SRS S1 ¶B28 likewise requires materiality judgements to be reassessed at each reporting date.
Which ESRS paragraph numbers should the template cite for FY2026?
The version you report under.
For financial years starting in 2026 an undertaking may use the 2023 ESRS, the 2023 ESRS with eight reliefs, or the revised ESRS in full, and must say which (DR (EU) 2026/1563 Art 2).
The paragraph numbers differ between them.
Does a UK supplier need this template to answer a customer?
Usually not.
A supplier with an average of 1,000 employees or fewer in the preceding financial year may decline information beyond the voluntary standard’s capped datapoints when the request is for the customer’s CSRD reporting, and a full assessment is well beyond those datapoints.
Is the worksheet on this page an official tool?
No. It applies the revised ESRS 1 rules for severity, likelihood and the either-lens test to scores you choose, on a 1–5 convention that is the worksheet’s own.
Nothing you enter is stored or sent.
Can EFRAG’s IG 1 serve as the template?
It can inform the method but not the paragraph references.
IG 1 is non-authoritative and written for the 2023 ESRS, and EFRAG lists no implementation guidance for the revised ESRS as at 11 October 2026.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 13 sources fromEUR-LexCouncil of the EUEFRAGDepartment for Business and TradeIFRS FoundationGlobal Reporting Initiative
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — revised ESRS 1, Chapter 3 (¶¶22–55, AR 8–AR 33), and Article 2
Every field in the register below maps to a paragraph here; FY2026 version choice in Article 2.
- Council of the EUC(2026) 5010 final, Annex I — the revised ESRS as transmitted
The same text before Official Journal publication.
- EFRAGESRS Knowledge Hub — revised ESRS 2, IRO-1, IRO-2 and SBM-3 (delegated-act text)
What the statement must say about the process and its results.
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026 — Art 34(1)
The assurance opinion covers “the process carried out by the undertaking to identify the information reported”.
- EFRAGIG 1: Materiality Assessment Implementation Guidance (May 2024)
Non-authoritative; written for the 2023 ESRS; one assessment, both perspectives (¶65).
- EFRAGESRS implementation guidance documents — project page
No guidance for the revised ESRS is listed as at 11 October 2026.
- Department for Business and TradeUK SRS S1 — ¶¶17–19, B19, B25, B28
The single (financial) materiality register a UK reporter keeps.
- IFRS FoundationSustainability-related risks and opportunities and the disclosure of material information — educational material (November 2024)
Four steps; explanatory, not part of the Standards.
- Global Reporting InitiativeGRI 3: Material Topics 2021 — Step 4 and Disclosures 3-1 to 3-3
The organisation defines and documents its own threshold.
- EUR-LexDirective (EU) 2026/470 (Omnibus I) — the value-chain cap
A protected supplier may decline information beyond the voluntary standard.
- European CommissionFeedback on sustainability reporting standards: the value chain cap, 6 May 2026
The cap “does not impose or imply any obligation” on companies in the value chain.
- IFRS Foundation / EFRAGESRS–ISSB Standards Interoperability Guidance, §1.1
The financial-materiality definition is aligned; the regimes are not.
- EUR-LexCommission Delegated Regulation (EU) 2023/2772 — the 2023 ESRS
The version IG 1 was written for, and one of the FY2026 options.
Continue reading
Read next
Method
The double materiality assessment
The method each column of the template follows.
Vocabulary
Impacts, risks and opportunities
What each row of the register is, and how the ESRS define it.
Thresholds
Materiality thresholds
Why no standard gives you the number for the threshold column.
The hub
Materiality, all four tests
What material means in accounts, audit, UK SRS, the ESRS and GRI.