Matrix
One of the four, aggregated per topic.
Not required or mentioned in the revised ESRS.Materiality · published examples
Double materiality examples: four published assessments, read side by side
Double materiality examples are easiest to learn from in the statements companies have already published, because the process and its results are disclosed under ESRS 2.
This page reads four FY2024 statements — BASF, Ørsted, ING and Ahold Delhaize — and records what each company says it did, in its own words.
All four applied the 2023 ESRS, so they show method and presentation, not the paragraph numbers of the revised standards that apply from 2027.
At a glance
Four double materiality examples, compared on what they disclosed
Each company was a first-wave CSRD reporter publishing its first ESRS sustainability statement for the 2024 financial year.
The comparison below uses only what each statement says; where a statement is silent, the cell says so.
Read the comparison table
| BASF (chemicals) | Ørsted (energy) | ING (banking) | Ahold Delhaize (food retail) | |
|---|---|---|---|---|
| Steps described | Three | Five, after an initial “understanding the context” step | Five | Eight |
| Scoring | “a 5-point scale”, threshold “based on the sum of the factors assessed” | Five degrees, “crucial” to “minimal”; threshold at “significant” | “predetermined materiality thresholds”; bands Material / Important / Informative–Minimal | “a five-point scale”; “a threshold or cut-off point” |
| Presentation of results | Tables of material impacts, and of opportunities and risks | A matrix “aggregated per ESRS topic”, with IRO tables | A table of the ten ESRS topics | A table of material sustainability matters |
| Stated as not material | ESRS S4 | Water and pollution | Topics under S2 and S3 | Business conduct |
| Stakeholder input described | Advisory councils, civil society forum, data analyses | In-house experts as a proxy | Validation through stakeholders’ engagement (step 4) | One-on-one interviews and a survey |
The rows describe disclosure, not quality: a shorter description is not a weaker assessment, and this page draws no conclusion about any company’s process.
What to compareExplore
Module 01 / 04
Steps
BASF three, ING five, Ørsted five plus an initial context step, Ahold Delhaize eight.
Module 02 / 04
Scale
Five-point scales (BASF, Ahold Delhaize); five degrees (Ørsted); threshold bands (ING).
Module 04 / 04
Not material
S4 (BASF); water and pollution (Ørsted); S2 and S3 (ING); business conduct (Ahold Delhaize).
Example 1 · chemicals
BASF: three steps, a 5-point scale, results in tables
BASF says it “carried out a double materiality assessment in accordance with the ESRSs for the first time in 2024”.
It describes three steps and a scoring stage in which impacts, risks and opportunities were scored “on a 5-point scale” and classed as material “whenever they exceeded defined thresholds”.
Read what BASF disclosed
Impacts were reviewed “in terms of their severity, scale and scope”, with irremediability assessed for negative impacts and likelihood estimated for potential impacts.
For impacts it set “a uniform threshold based on the sum of the factors assessed”, which “was assigned a higher weighting to negative impacts”.
Opportunities and risks “were assessed in terms of their financial magnitude and likelihood of occurrence”, using its existing risk management criteria.
The results are presented in tables headed “Results of the double materiality assessment for the 2024 business year”, one for material impacts and one for opportunities and risks.
It states that ESRS S4 Consumers and End Users “was not material, hence we do not report on it”, because as a B2B company it markets “only a very small portion of our products directly to consumers and end users”.
It plans “to update this assessment on an annual basis”.
Source: BASF Report 2024, Sustainability Statement, pp. 167–168; also available as a web page.
BASF’s assessmentExplore
Module 01 / 04
Step 1
A list of potential sustainability matters, with direct and indirect stakeholder input.
Module 02 / 04
Step 2
Experts and advisory councils identify and validate risks and opportunities.
Example 2 · energy
Ørsted: a matrix per topic, five degrees of materiality
Ørsted reports that “40 impacts, risks, and opportunities (IROs) have been assessed as material” and that “Seven ESRS topics are material to Ørsted”.
It is the only one of the four to show its outcome in a matrix, which it describes as “a high-level outcome of our DMA … aggregated per ESRS topic”.
Read what Ørsted disclosed
It explains that “the highest-scoring IRO within a topic determines the placement of that topic in the matrix”.
It says its method was “based on the ‘IG1: Materiality Assessment Implementation Guidance’ published by EFRAG in May 2024”.
Scale, scope and irremediable character were scored and weighted equally for severity; likelihood was “weighted 1:1 with the ‘severity’ score”, but for a potential human rights impact “‘severity’ took precedence over ‘likelihood’ (3:1 weighting, respectively)”.
There were “five degrees of materiality”, from “crucial” to “minimal”, and “the materiality threshold was set at ‘significant’”.
Its five process steps are engagement of stakeholders, scoping of IROs, assessment of IROs, validation and calibration, and final review and approval.
A separate Ørsted report says water and pollution were “assessed to be below our materiality level for our CSRD reporting”.
Sources: Ørsted Annual report 2024, pp. 67 and 73–74 · Water and pollution data 2024.
Ørsted’s assessmentExplore
Module 01 / 04
40 IROs
7 positive impacts, 23 negative impacts, 8 risks and 2 opportunities assessed as material.
Module 02 / 04
7 topics
E1, E4, E5, S1, S2, S3 and G1 have their own chapters; six have “double materiality”.
Module 03 / 04
Threshold
Five degrees; IROs scored “significant” or “crucial” are material.
Module 04 / 04
Human rights
Severity over likelihood at 3:1 for potential human rights impacts.
Example 3 · banking
ING: five steps, a gross approach, the business it finances
ING says this was “the first year that we have performed our double materiality assessment in accordance with ESRS”, replacing an assessment based on GRI.
As a financial institution, it says impact materiality “refers to the business we finance”.
Read what ING disclosed
Its five steps are: identification of activities and business relationships; identification of relevant sustainability matters; execution of the assessment; validation through stakeholders’ engagement; and approval by the management boards and Supervisory Board.
It assessed impacts, risks and opportunities “against predetermined materiality thresholds”, and its outcome table uses bands labelled Material, Important and Informative–Minimal.
It says assessment “follows a ‘gross’ approach, meaning without taking mitigating actions, initiated by ING, into account”.
It states that its assessment “did not indicate materiality for topics under S2 and S3 for ING’s value chains, however ING does consider these important topics”.
Its Sustainability Statement has topical chapters on climate change, biodiversity and ecosystems, own workforce, consumers and end-users, and business conduct.
ING’s assessmentExplore
Module 01 / 04
Value chain
Six value chain segments; impacts include “the business we finance”.
Module 02 / 04
Five steps
Activities, matters, assessment, stakeholder validation, board approval.
Module 03 / 04
Gross approach
Assessed without taking ING’s mitigating actions into account.
Example 4 · food retail
Ahold Delhaize: eight steps and a table of material matters
Ahold Delhaize describes eight steps, from sustainability due diligence to strategic implications.
It used “a five-point scale that standardizes evaluations across scale, scope, irremediability and likelihood”.
Read what Ahold Delhaize disclosed
It gathered stakeholders’ interests through “one-on-one interviews and a survey”.
Its long list drew on standards, previous assessments, due diligence, peer and rating reports, and “an AI-based application that provided data-driven insights”.
Risks and opportunities were assessed against thresholds “informed by existing ERM and SDD thresholds, as well as the materiality threshold used for the audited financial statements”.
It applied “a threshold or cut-off point” to separate material from non-material matters, and its executive committee approved the result.
Its material matters are grouped as climate, nature and circularity on the environmental side, and own workforce, labour and human rights in the value chain, community impacts and customers on the social side.
It states that its process “concluded that business conduct is not a material sustainability matter”.
It plans a light annual review and “a thorough DMA every three to four years”.
Source: Ahold Delhaize Annual Report 2024, sustainability statements, pp. 93–97 and 171.
Ahold Delhaize’s assessmentExplore
Module 01 / 04
Long list
Built from standards, prior assessments, due diligence, peers, ratings and an AI-based application.
Module 02 / 04
Scoring
A five-point scale across scale, scope, irremediability and likelihood.
Module 03 / 04
Thresholds
Informed by ERM, due-diligence and financial-statement materiality thresholds.
Module 04 / 04
Not material
Business conduct; no other governance matter identified.
Read against the revised ESRS
What the examples show against the 2027 rules
The four statements were prepared under the 2023 ESRS, so they are examples of choices companies made, not of what the revised standards require.
Read against the revised ESRS 1 in Delegated Regulation (EU) 2026/1563, four points stand out.
Read the four points
A matrix is a choice: one company used one, three did not, and the phrase does not appear anywhere in the revised regulation.
Numeric scales are a choice too: each company set its own, and the revised ESRS 1 ¶37 asks only for “appropriate qualitative considerations and quantitative thresholds”, with AR 13 adding that a qualitative analysis may be sufficient.
Gross and net now have a rule: revised ESRS 1 ¶43 assesses actual impacts as they manifested and potential impacts net only of implemented prevention and mitigation.
Stakeholder input varied from a survey to expert proxies, and revised ESRS 1 AR 24 says engagement in ongoing due diligence is enough, without a separate engagement process.
Each company also stated topics it found not material, which the revised standard turns into a rule: under ¶24 non-material ESRS information “shall not” be disclosed, apart from supplementary information under section 8.2.
Presenting the results
Tables
Three of the four, listing impacts, risks and opportunities.
Closer to what IRO-2 asks for.What every example has to contain
The four disclosures behind every published assessment
Every one of the four examples places its assessment in the same ESRS 2 disclosures, which is what makes them comparable at all.
The process goes into IRO-1, the results into IRO-2, and the link to strategy into SBM-3.
- 1
IRO-1
How the company identified and assessed its impacts, risks and opportunities.
- 2
IRO-2
What it found material, and which disclosure requirements it met.
- 3
SBM-3
How those matters interact with its strategy and business model.
- 4
Topical sections
The material topics, reported sub-topic by sub-topic.
Read what IRO-1 asks for
The revised ESRS 2 IRO-1 asks for the process and decision steps and the “qualitative considerations or quantitative thresholds” applied, and how impacts were assessed and prioritised on severity and likelihood.
That is why each of the four statements describes its scale and threshold, even though no standard prescribes one.
ESRS 2 outputsExplore
Module 01 / 04
IRO-1
The process: steps, methods, inputs, thresholds and when it was last updated.
Module 02 / 04
IRO-2
The material impacts, risks and opportunities, and the disclosure requirements met.
Module 04 / 04
Topical chapters
Only the material topics and sub-topics are reported (¶30).
An illustrative disclosure
A double materiality assessment report example, built from the revised rules
The text below is invented: no company, figure or conclusion in it is real.
It shows the shape an IRO-1 and IRO-2 disclosure can take under the revised ESRS.
Illustrative only — an invented company
Process (IRO-1). We assessed all ten topical standards. For climate and own workforce we took a top-down approach under ESRS 1 ¶27, concluding from our strategy and business model; for the remaining topics we assessed individual impacts, risks and opportunities (¶28).
We scored negative impacts on scale, scope and irremediable character, and potential impacts also on likelihood; for potential human rights impacts severity took precedence (¶40).
We scored risks and opportunities on likelihood and potential magnitude of financial effects (¶50).
We used a qualitative scale of low, medium and high, and treated “high” on any one severity factor as material.
Our input from affected stakeholders came from our ongoing due diligence engagement (¶42, AR 24).
We last updated the assessment at 31 December, after checking for significant changes (¶34).
Results (IRO-2). Material: E1 climate change mitigation and energy; S1 working conditions; S2 working conditions in our value chain; G1 corporate culture.
Not material and therefore not reported: E2, E3, E4, E5, S3, S4 and the other G1 sub-topics.
A real disclosure is specific to the company’s own process, and the revised ESRS 2 warns against boilerplate that recites the standard.
A worksheet for building the evidence behind such a disclosure is on the double materiality assessment template guide.
The disclosures themselves are described in the EFRAG Knowledge Hub’s rendering of revised ESRS 2.
Why these are FY2024 statements
From the first published examples to the revised standards
The examples date from the first year of ESRS reporting, and the standards changed afterwards.
- 31 July 202301
First ESRS adopted
Delegated Regulation (EU) 2023/2772 sets the standards the FY2024 statements applied. - 31 May 202402
EFRAG IG 1 published
Non-authoritative materiality guidance for the 2023 ESRS; Ørsted says it based its method on it. - FY202403
First wave-one statements
The four statements on this page report on the 2024 financial year. - 21 September 202604
Revised ESRS published
Delegated Regulation (EU) 2026/1563 replaces Annex I in full; paragraph numbers move. - FY202705
Revised ESRS apply
Financial years beginning on or after 1 January 2027; FY2026 offers a three-way choice.
Reading a published assessment
How to read a company’s double materiality disclosure
Published examples are most useful when read in a fixed order, so that one company’s choices can be compared with another’s.
- 01 / Version01
Which ESRS did it apply?
FY2024 statements use the 2023 standards; FY2026 statements must say which version they used. - 02 / Process02
- 03 / Results03
Read IRO-2 and SBM-3
Material impacts, risks and opportunities, and the disclosure requirements met. - 04 / Omissions04
Find what is not material
A stated non-material topic tells you as much as a material one. - 05 / Presentation05
Treat a matrix as a summary
Check the table behind it: either lens alone makes a matter material.
Frequently asked
Questions people ask
Where can I see a real double materiality assessment?
In the sustainability statement of any company reporting under the ESRS.
The process sits in the ESRS 2 IRO-1 disclosure and the results in IRO-2 and SBM-3.
This page reads four FY2024 statements — BASF, Ørsted, ING and Ahold Delhaize — from each company’s own website.
Did these companies use a double materiality matrix?
One of the four did. Ørsted shows "a high-level outcome of our DMA" in a matrix aggregated per ESRS topic.
BASF and Ahold Delhaize present their results in tables, and ING in a table of the ten ESRS topics with threshold bands.
The revised ESRS neither require nor mention a matrix.
What scale did they use to score impacts?
BASF and Ahold Delhaize each describe a five-point scale. Ørsted describes five degrees of materiality, from "crucial" to "minimal", with the threshold at "significant".
ING describes predetermined thresholds with bands labelled Material, Important and Informative–Minimal.
The ESRS themselves set no numeric scale.
How many topics did they find material?
Ørsted reports seven material ESRS topics and 40 material impacts, risks and opportunities.
BASF reports material impacts under nine standards (E1–E5, S1–S3, G1).
ING’s statement has five topical chapters.
Ahold Delhaize groups its material matters into seven clusters.
Counts are not comparable across companies, because each described its own level of aggregation.
Which topics did they conclude were not material?
BASF: S4 Consumers and End Users, because only a very small portion of its products are sold directly to consumers. Ørsted: water and pollution, assessed below its materiality level.
ING: topics under S2 and S3.
Ahold Delhaize: business conduct.
Did they survey stakeholders?
Approaches differ.
Ahold Delhaize describes one-on-one interviews and a survey.
BASF describes direct input from advisory councils and a civil society forum, plus indirect input from data analyses. Ørsted used in-house subject-matter experts as a proxy for stakeholders’ views.
The revised ESRS say engagement in ongoing due diligence is enough, without a separate engagement process (AR 24).
Did they take mitigation into account?
ING says its assessment "follows a 'gross' approach, meaning without taking mitigating actions, initiated by ING, into account". Ørsted says current mitigation actions were considered when scoring the scale of actual negative impacts.
The revised ESRS 1 ¶43 sets a rule for FY2027: actual impacts as they manifested, and potential impacts net only of implemented prevention and mitigation.
Are these FY2024 examples still valid for FY2027?
As examples of method, yes; as templates for paragraph references, no.
All four applied the 2023 ESRS (Delegated Regulation (EU) 2023/2772).
From financial years beginning on or after 1 January 2027 the revised ESRS apply, and every ESRS 1 paragraph number moved.
Did the companies follow EFRAG IG 1?
Ørsted says its method is based on EFRAG’s IG 1 of May 2024.
The other three describe their own processes.
IG 1 is non-authoritative and written for the 2023 ESRS.
How often will they repeat the assessment?
BASF says it plans to update the assessment annually.
Ahold Delhaize describes a light annual review and a thorough assessment every three to four years.
The revised ESRS 1 ¶34 requires a check at each reporting date for significant changes, not a full rebuild.
What should a double materiality assessment report contain?
The ESRS do not ask for a separate report.
The statement discloses the process (IRO-1), the material impacts, risks and opportunities and the disclosure requirements met (IRO-2), and how they interact with strategy (SBM-3).
Is this page a ranking of how good these assessments are?
No. It describes what each company published, in its own words, with page references. It does not judge, score or rank any company’s assessment.
Where is a template I can adapt?
An illustrative disclosure is on this page, and a working worksheet is on the double materiality assessment template guide.
Neither is an official format.
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 12 sources fromBASF SEØrsted A/SING Groep N.V.Koninklijke Ahold Delhaize N.V.EUR-LexEFRAG
- BASF SEBASF Report 2024 — Sustainability Statement, Double Materiality Assessment, pp. 167–168
Three steps, a 5-point scale against defined thresholds, results in tables; S4 not material.
- BASF SEBASF Report 2024 — Double Materiality Assessment (web version)
The same section and its results tables in HTML.
- Ørsted A/SAnnual report 2024 — Double materiality assessment (p. 67) and Methodology and process (pp. 73–74)
40 material IROs, seven material topics in a matrix, five degrees of materiality.
- Ørsted A/SWater and pollution data 2024
Water and pollution assessed below its materiality level.
- ING Groep N.V.2024 Annual Report — Sustainability Statement, double materiality assessment, pp. 97–98
Five steps, a gross approach, a table of the ten ESRS topics; S2 and S3 not material.
- Koninklijke Ahold Delhaize N.V.Annual Report 2024 — Sustainability statements, Impact, risk and opportunity management, pp. 93–97; governance, p. 171
Eight steps, a five-point scale, a table of material matters; business conduct not material.
- EUR-LexCommission Delegated Regulation (EU) 2023/2772 — the 2023 ESRS
The standards all four FY2024 statements applied.
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — revised ESRS 1, Chapter 3
The method from financial years beginning on or after 1 January 2027; no materiality matrix in the text.
- EFRAGESRS Knowledge Hub — revised ESRS 2, IRO-1 and IRO-2
What a statement discloses about the process and its results.
- EFRAGIG 1: Materiality Assessment Implementation Guidance (May 2024)
Non-authoritative and written for the 2023 ESRS; Ørsted says its method is based on it.
- EFRAGESRS implementation guidance documents
No guidance for the revised ESRS is listed as at 11 October 2026.
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026 — Art 19a(1)
The two limbs of EU sustainability reporting, and the current scope test.