One request, one entity
Often done in-house against the revised ESRS 1 method — after checking the value-chain cap.
Materiality · a neutral buyer’s guide
Double materiality software vs consultants: what any provider must produce
Double materiality software vs consultants is the wrong first question: the right one is what the assessment must produce, because every route ends in the same ESRS 2 disclosure and the same assurance opinion.
This page compares the routes by what they deliver against the revised ESRS, and lists the questions that separate a sound method from a weak one.
This site is an independent reference: it provides none of these services, ranks no firm or vendor and publishes no prices.
Start from the output
What the double materiality assessment must produce, whoever runs it
Every route — your own team, a software platform or an outside adviser — has to end in the same place: a process the undertaking can describe in ESRS 2 IRO-1 and results it reports in IRO-2 and SBM-3.
The revised ESRS 2 also warns against boilerplate: the description must be specific to the undertaking’s own process, not a recital of the standard (ESRS 2 AR 24).
Read what IRO-1, IRO-2 and SBM-3 ask for
IRO-1 ¶35 asks for five things: the process and decision-making steps with value-chain coverage, methodologies, inputs, assumptions and thresholds; how impacts were prioritised on severity and likelihood; whether due diligence and stakeholder consultation informed the assessment; significant changes from the prior period; and when the assessment was last updated.
ESRS 2 AR 24 says the undertaking “shall focus on information that is specific to its own materiality assessment process” and avoid “standardised, generic disclosures, sometimes referred to as ‘boilerplate’”.
IRO-2 then lists the material impacts, risks and opportunities and the disclosure requirements met, and SBM-3 links them to strategy and the business model.
⚠ ESRS 2 numbers its own IRO-1 application requirements AR 22 to AR 25, so “AR 24” here is the anti-boilerplate rule, not the ESRS 1 engagement rule of the same number.
The method itself is set out on how to run a double materiality assessment, and a field-by-field register on the assessment template.
ESRS 2 IRO-1 ¶35Explore
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Process
(a) The decision steps, value-chain coverage, methodologies, inputs, assumptions and the qualitative considerations or quantitative thresholds.
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Prioritisation
(b) How impacts were assessed and prioritised on severity and likelihood, and how actions were considered.
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Inputs
(c) Whether due diligence informed it, and how consultation with affected stakeholders and experts informed it.
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Change and date
(d) Significant changes from the prior period; (e) when the assessment was last updated.
The test it has to pass
The process sits inside the assurance opinion
For a CSRD reporter the limited assurance opinion covers the process the undertaking carried out to identify the information reported, so the method has to stand up, not only the conclusions.
That is the practical test for any provider: will its work leave an evidence trail an assurance provider can follow?
Read the assurance points that matter when choosing
Article 34(1) of the Accounting Directive puts “the process carried out by the undertaking to identify the information reported” inside the opinion, together with compliance with the ESRS and the Taxonomy Article 8 disclosures.
Directive (EU) 2026/470 removed the power to adopt reasonable-assurance standards and set 1 July 2027 for the limited-assurance standards.
The statutory auditor gives the opinion by default, and Member States may allow a different statutory auditor or an accredited independent assurance services provider.
One rule is settled for public-interest entities: the EU audit regulation lists “preparing sustainability reporting” among the services a statutory auditor may not provide to its audit client (Regulation (EU) No 537/2014, Article 5(1)(c)).
Outside that case, whether a firm that assures a statement may also advise on the assessment behind it is governed by independence rules this page does not summarise; raise it with the firm and your audit committee before engaging anyone for both.
The rest is set out under assurance under the CSRD.
Limited assuranceExplore
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What is covered
The opinion covers “the process carried out by the undertaking to identify the information reported”.
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Only limited
The reasonable-assurance path was deleted by Omnibus I.
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Standards
The Commission must adopt limited assurance standards by 1 July 2027.
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Who assures
The statutory auditor by default; Member States may allow another auditor or an accredited independent assurance services provider.
The three routes
In-house, software or an adviser: what each is good for
This site is an independent reference, not a provider of any of the three, so this is the shape of the decision rather than a pitch.
A one-off assessment triggered by a single customer request is often done in-house against the method — after checking whether the customer can require it at all.
Read the reasoning behind each route
In-house work keeps the knowledge in the business and is often enough where one entity faces one request and the standard’s method can be followed directly.
Assessment software earns its place where the cycle repeats across several entities, because a system of record and an audit trail are easier to assure than a spreadsheet rebuilt each year.
Independent advice earns its fee on the judgement calls: a contested threshold, a group-level top-down structure, or a first evidence file for assurance; ESG consulting services itemises what advisers sell, and choosing a sustainability reporting consultancy covers how to judge one.
The routes combine: many undertakings use software as the register and bring in advice for specific judgements.
Software that also does carbon accounting is a separate decision, compared under carbon reporting software and the ESG software comparison.
None of these descriptions is a statement about any named firm or product, and none implies a price.
What is the job?
A repeating cycle, several entities
Where a system of record and an audit trail beat a spreadsheet rebuilt each year.
Contested judgements
Where independent advice helps: a disputed threshold, a group top-down structure, a first file for assurance.
Illustrative reasoning, not cost advice.
What a tool cannot decide
Software records the double materiality judgement; it does not make it
The revised ESRS 1 leaves several decisions to the undertaking, and no tool or adviser can take them on its behalf.
A provider can structure, record and challenge those judgements; the undertaking remains responsible for them.
Read which decisions stay with the undertaking
The top-down route under ¶27 depends on whether materiality is evident from the undertaking’s strategy, business model, sectors, geographies and value chain.
¶37 asks for “appropriate qualitative considerations and quantitative thresholds”, and AR 13 says a qualitative analysis may be sufficient, so the threshold is a choice to record.
¶32 sets the evidence standard — reasonable and supportable information available without undue cost or effort — and ¶34 the review at each reporting date.
A tool that hides these choices behind defaults makes them for you without saying so.
Judgements stay yoursExplore
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Route
Whether a topic’s materiality is evident from strategy and business model, or needs a specific assessment (¶27).
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Threshold
Appropriate qualitative considerations and quantitative thresholds, chosen by the undertaking (¶37).
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Evidence
Reasonable and supportable information available without undue cost or effort (¶32).
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Review
Whether significant changes at the reporting date require an update (¶34).
Rules a tool or adviser must get right
Six revised ESRS 1 rules to test any method against
A scoring tool or a consultant’s template encodes the method, so its defaults decide your results.
Test any method against the revised ESRS 1 rules below before you rely on it.
Read all six rules and why they matter
| Rule | What to check | Where it is |
|---|---|---|
| Severity is not an average | Any one factor at the threshold makes a negative impact severe | Revised ESRS 1 AR 22 |
| Likelihood only for potential impacts | Actual impacts scored on severity alone; human-rights severity takes precedence | Revised ESRS 1 ¶40 |
| Either lens is enough | Impact-only and financial-only matters both flow through as material | Revised ESRS 1 ¶35 |
| Gross and net | Only implemented, effective actions reduce a potential impact; plans do not | Revised ESRS 1 ¶43, AR 27 |
| Shall not disclose immaterial information | The tool does not push every datapoint into the statement | Revised ESRS 1 ¶24 |
| Top-down is allowed | A topic-level conclusion from strategy and business model is supported and documented | Revised ESRS 1 ¶27, AR 9 |
The full method, with a worked example, is on the double materiality assessment, and the threshold question on materiality thresholds.
Rules to testExplore
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Severity
Any one of scale, scope and irremediable character can make a negative impact severe — never an average (AR 22).
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Likelihood
Only for potential impacts; for a potential human-rights impact, severity takes precedence (¶40).
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Gross and net
Only implemented policies and actions reduce a potential impact; planned ones do not (¶43, AR 27).
Questions to ask
Questions to ask any double materiality provider before you choose
The same questions work for software, an adviser and your own team.
Each answer should point to something you can see, not a promise.
| Ask | A good answer shows | Why it matters |
|---|---|---|
| How does your scoring handle severity? | Highest of scale, scope and irremediable character; likelihood only for potential impacts | AR 22 and ¶40 change results |
| Which ESRS version does it apply? | All three FY2026 options, a stated version, and the revised ESRS for FY2027 | DR (EU) 2026/1563 Art 2 requires the version to be stated |
| How are thresholds set and recorded? | Your threshold, written down and applied consistently | IRO-1 ¶35(a) asks for it; no standard sets one |
| Where does stakeholder input come from? | Due-diligence engagement first; a survey only if it adds something | ESRS 1 ¶42 and AR 24 |
| What evidence trail does it leave? | Inputs, scores, reasons and dates per matter, retrievable for assurance | Art 34(1): the process is assured |
| Can I export the full register? | A complete export in a reusable format | The undertaking owns the assessment and revisits it each year (¶34) |
| How are paragraph references kept current? | Revised ESRS numbering, not IG 1’s 2023 references | IG 1 is non-authoritative and 2023-numbered |
| Does it separate the UK SRS view? | A financial-only view for UK SRS S1 | UK SRS applies single (financial) materiality |
An illustrative selection process
Choosing between software and consultants, step by step
This sequence is an illustration of one sensible order, not a procurement rule.
- 01 / Who asks01
Confirm the obligation
Are you in CSRD scope, or answering a customer request the value-chain cap may limit? - 02 / Version02
Fix the ESRS version
FY2026 offers three options; FY2027 applies the revised ESRS. - 03 / Scope03
Size the work
How many entities, and which topics need bottom-up rather than top-down assessment? - 04 / Test04
Test the method
Run one matter through each candidate’s scoring and check it against the six rules. - 05 / Evidence05
Check the evidence trail
Can the output answer IRO-1 ¶35 line by line, and can you export it? - 06 / Assurance06
Talk to the assurer early
Agree what evidence they will expect, and raise any independence question.
What a method must have absorbed
Rule changes every double materiality provider should already reflect
A method built for the first wave of reports in 2025 needs updating for the revised standards.
These are the dated changes to check for, as at 11 October 2026.
- 31 July 202301
- 31 May 202402
- 18 March 202603
Omnibus I in force
New scope test, the value-chain cap, limited assurance only. - 21 September 202604
Revised ESRS published
Delegated Regulation (EU) 2026/1563; new paragraph numbers; top-down allowed; immaterial information “shall not” be disclosed. - FY202705
Revised ESRS apply
Financial years beginning on or after 1 January 2027, with no version choice. - 1 July 202706
Limited assurance standards due
The Commission’s deadline for adopting them.
Guidance provenance
When a provider cites IG 1, check the paragraph numbers
Many methods were built on EFRAG’s IG 1, which is a sound description of the process but carries 2023 paragraph references.
For FY2027 the revised ESRS 1 is the reference, so ask how a provider maps its steps to the new paragraphs.
Read the guidance status in detail
EFRAG finalised IG 1, IG 2 and IG 3 on 31 May 2024 as non-authoritative guidance relating to the 2023 ESRS.
Its project page says it would not issue updated guidance for the simplified ESRS before Commission adoption, and as at 11 October 2026 lists none for the revised standards.
The mapping from IG 1’s ideas to revised paragraphs is set out under materiality assessment and the assessment guide.
IG 1 statusExplore
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Non-authoritative
Where it seems to contradict the ESRS, the ESRS take precedence.
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Still useful
One assessment reflecting both perspectives, not two separate processes (¶65).
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No update yet
No guidance for the revised ESRS is listed as at 11 October 2026.
Before you buy anything
You may not need a double materiality assessment at all
A UK supplier asked by an EU customer is often protected by the value-chain cap, and a full assessment goes well beyond the capped datapoints.
A UK listed company reporting against UK SRS needs only the financial lens.
Read the checks in detail
Under Directive (EU) 2026/470, a CSRD reporter may not require more from a protected undertaking, for its CSRD reporting, than the voluntary standard specifies.
The Commission’s note of 6 May 2026 says the cap does not impose or imply any obligation on companies in the value chain to provide sustainability information.
What the capped questions are is set out under the voluntary standard for suppliers, and whether a company is in scope at all under CSRD thresholds.
UK SRS S1 applies single (financial) materiality judged by the decisions of primary users, with no thresholds specified (¶B19) and reassessment at each reporting date (¶B28).
Check firstExplore
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Value-chain cap
A supplier with 1,000 employees or fewer may decline information beyond the voluntary standard for a customer’s CSRD reporting.
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No obligation
The cap “does not impose or imply any obligation” on value-chain companies.
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CSRD scope
From FY2027, both 1,000 employees and €450m net turnover must be exceeded.
What goes wrong
Six buying mistakes that show up at assurance
Buying a matrix, not a method
The revised ESRS neither require nor mention a matrix; IRO-1 asks for the process.
Accepting averaged severity
Any one factor can make a negative impact severe (AR 22).
Running a survey because “the ESRS require it”
They do not; due-diligence engagement is the key input (ESRS 1 ¶42, AR 24).
Boilerplate process descriptions
ESRS 2 AR 24 asks for information specific to your own process.
No export
The register must be reusable at the next reporting date (¶34).
2023 references in a 2027 statement
IG 1 and the 2023 ESRS use different paragraph numbers.
If you run it yourself
An in-house double materiality assessment, in outline
Running it yourself means following Chapter 3 of the revised ESRS 1 and keeping the evidence an assurer will ask for.
The register fields are listed on the double materiality assessment template, with a worksheet that applies the scoring rules.
Read the in-house checklist
Choose top-down or bottom-up for each topic, and write down the strategy and business-model analysis behind a top-down conclusion.
Assess impacts first, then risks and opportunities, including those unrelated to impacts such as physical climate risk.
Record the threshold you apply and the reasons for each conclusion.
Use due-diligence engagement as the stakeholder input, as set out under stakeholder engagement.
How published assessments describe their own process is compared under double materiality examples, and the unit of the assessment is explained under impacts, risks and opportunities.
- 1
Route
Top-down or bottom-up for each topic (¶¶27–28).
- 2
Impacts first
Severity, and likelihood for potential impacts (¶¶36, 40).
- 3
Financial
Likelihood and magnitude of financial effects (¶50).
- 4
Record
Thresholds, evidence and dates for IRO-1 (¶37).
About this page
Why this guide names no firms and no prices
A buyer’s guide written by a seller is a sales page, so this one is written by a site with nothing to sell.
It compares what each route must produce against the standard, and leaves the choice of provider to you.
Read more about how to use this guide
The questions above apply equally to software, advisers and an in-house team, and none of them depends on a provider’s name.
The wider context of what material means across frameworks is on materiality explained, and the picture many providers sell is examined under the materiality matrix.
Related lenses outside the ESRS are covered under GRI materiality, the SASB materiality map, dynamic materiality and materiality in accounting.
Talking it through
This site provides none of the three routes.
To talk through your own situation, book a free 15-minute call, or read the reference pages first.
An independent referenceExplore
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No services
This site runs no assessments and sells no software.
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No ranking
No firm or vendor is ranked or recommended.
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No prices
No fees, estimates or characterised costs are published.
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Sources
Every rule cited is from the law or the standard itself.
Frequently asked
Questions people ask
Should I use double materiality software or a consultant?
It depends on the job, not on the label.
A one-off assessment for a single customer request can often be done in-house against the revised ESRS 1 method; a repeating cycle across several entities is where a system of record earns its place; and contested judgements or a first assurance file are where outside advice helps.
Whatever you choose, the output must answer ESRS 2 IRO-1 and stand up to limited assurance.
Which firms do double materiality assessments?
Many kinds of organisation offer them: consultancies, audit and accountancy firms, and software vendors. This site does not rank or recommend any of them.
It sets out what any provider must produce and the questions that separate a sound method from a weak one.
Does this site provide double materiality services?
No. It is an independent reference with no clients and nothing for sale. It describes the options so that you can choose between them.
What must a double materiality assessment produce, whoever runs it?
An evidence trail that answers ESRS 2 IRO-1 ¶35: the process and decision steps, value-chain coverage, methodologies, inputs, assumptions and thresholds; how impacts were prioritised on severity and likelihood; whether due diligence and stakeholder consultation informed it; significant changes from last year; and when it was last updated.
The results feed IRO-2 and SBM-3.
Can my statutory auditor also run my double materiality assessment?
The assurance provider gives a limited assurance opinion on the process the undertaking carried out to identify the information reported.
Who may provide that opinion is set by Article 34 of the Accounting Directive and national law.
Whether the same firm may also advise is a question for the applicable independence rules, which this page does not summarise; ask the firm and your audit committee.
Do I need software that produces a materiality matrix?
No. The revised ESRS neither require nor mention a materiality matrix.
A tool that only shows a matrix, without the register and reasoning behind it, does not produce what IRO-1 asks for.
What should I check in a scoring tool?
That it does not average severity: any one of scale, scope and irremediable character can make a negative impact severe (revised ESRS 1 AR 22).
That it applies likelihood only to potential impacts, gives severity precedence over likelihood for a potential human-rights impact (¶40), treats either lens as enough (¶35), and records the threshold you set.
Do I need a stakeholder survey tool?
Not for the ESRS.
Engagement with affected stakeholders carried out in ongoing due diligence is the key input, and the revised ESRS 1 says no separate engagement process is needed for the materiality assessment (AR 24).
A survey can be one input if it helps.
Is a provider still using EFRAG IG 1 a problem?
Not for method: IG 1 is a useful description of the process.
But it is non-authoritative and written for the 2023 ESRS, so its paragraph references do not match the revised ESRS that apply from FY2027.
Ask how the provider maps its method to the revised paragraphs.
Does a UK supplier asked by an EU customer need any of this?
Often 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.
A full assessment goes well beyond that.
Does UK SRS need a double materiality tool?
No. UK SRS S1 applies single (financial) materiality to the decisions of primary users, so the impact half of a double materiality tool is not needed for it.
A UK group that also reports under the ESRS can use the financially material subset as its starting point.
What should happen to my data if I change provider?
You should be able to export the full register — matters, scores, thresholds, evidence references and dates — in a form you can reuse.
The assessment is the undertaking’s responsibility and has to be revisited at each reporting date, so it should not be locked inside one provider’s system.
Which ESRS version should a provider support for FY2026?
All three options: the 2023 ESRS as amended by Delegated Regulation (EU) 2025/1416, those standards with eight named reliefs including top-down materiality, or the revised ESRS in full.
The undertaking must state which it applied.
From FY2027 the revised ESRS apply with no choice.
How much does a double materiality assessment cost?
This site does not publish prices or estimate costs.
The scope of the work — how many entities, how many topics need a bottom-up assessment, how much evidence already exists from due diligence — drives the effort, whoever does it.
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 EUEFRAGEuropean CommissionDepartment for Business and TradeFinancial Reporting Council
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — revised ESRS 1 Chapter 3 and ESRS 2 IRO-1
The method a tool or adviser must implement, and what the statement must say about the process; applies from FY2027, with a version choice for FY2026.
- Council of the EUC(2026) 5010 final, Annex I — the revised ESRS as transmitted
The same text before publication.
- EUR-LexCommission Delegated Regulation (EU) 2023/2772 — the first ESRS
The 2023 standards and their paragraph numbering, which FY2027 statements no longer use.
- EFRAGESRS Knowledge Hub — revised ESRS 2, IRO-1, IRO-2 and SBM-3
The disclosures the assessment feeds.
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026 — Art 34 and Art 19a(3)
The limited assurance opinion covers the process; who may provide it; the value-chain cap.
- EUR-LexDirective (EU) 2026/470 (Omnibus I)
Limited assurance only; standards due by 1 July 2027; the value-chain cap.
- EUR-LexCommission Delegated Regulation (EU) 2026/1560 — the voluntary standard
The capped datapoints a protected supplier may limit itself to.
- 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.
- EFRAGIG 1: Materiality Assessment Implementation Guidance
Non-authoritative; written for the 2023 ESRS.
- 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 General Requirements — ¶¶17–18, B19, B28
Single (financial) materiality: the UK asks for none of the impact work.
- Financial Reporting CouncilAssurance standards
The UK assurance standards; assurance of UK SRS reporting is not required.
- European CommissionCommission adopts revised sustainability reporting standards, 3 July 2026
The revision every provider’s method must now reflect.
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