Impact materiality
Actual or potential, positive or negative impacts on people or the environment (¶39).
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Materiality · the concept and the section
Information is material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions of the people who rely on it.
That sentence is shared, but accounting, audit and sustainability reporting each apply it to different users and different effects, so the same word decides different things.
The definition
The IFRS definition, now in Appendix A and paragraph B1 of IFRS 18, reads: information is material if omitting, misstating or obscuring it could reasonably be expected to influence decisions that the primary users of general purpose financial statements make on the basis of those financial statements.
Three verbs carry the test: leaving something out, getting it wrong and hiding it among detail can each make a difference.
The phrase “could reasonably be expected to influence” sets the bar: it is a judgement about likely influence, not a demand to prove that a reader changed their mind.
For accounting periods beginning before 1 January 2027 the same definition is paragraph 7 of IAS 1.
The IASB folded it into IFRS 18 when that standard replaced IAS 1, and the IFRS 18 page says the 2018 Definition of Material amendment is now included in Appendix A and paragraphs B1–B5.
IAS 8, retitled Basis of Preparation of Financial Statements, now says material information is defined in Appendix A of IFRS 18 and uses the word with the same meaning.
So a citation to “IAS 1 paragraph 7” is right for a 2026 year end and points at a replaced standard from 2027.
Sustainability standards borrow this sentence almost word for word, which is why the differences between them sit in whose decisions count and which effects are in view.
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Side by side
Each row below is a different test that happens to share a name.
Read across to see whose decisions count, what is being judged and whether any number is set.
| Whose decisions | What is judged | Any numeric threshold? | Where the rule is | |
|---|---|---|---|---|
| Accounting (IFRS) | Primary users of general purpose financial statements | Information in the financial statements | No; entity-specific judgement | IFRS 18 App A, ¶¶B1–B5; IAS 1 ¶7 before 2027 |
| Audit (UK) | Users of the financial statements as a group | Misstatements, individually or in aggregate | Set by the auditor; A8 percentages are examples | ISA (UK) 320 ¶¶2, 9–11, A4, A8 |
| UK SRS and ISSB (single, financial) | Primary users of general purpose financial reports | Sustainability-related risks and opportunities that could affect cash flows, access to finance or cost of capital | None specified (¶B19) | UK SRS S1 ¶¶3, 17–19, B13–B28 |
| ESRS (double) | Primary users, and other users of sustainability statements | Impacts on people and the environment, and risks and opportunities, either or both | Thresholds the undertaking sets (¶37) | Revised ESRS 1 ¶¶23, 35, 37, 40 |
| GRI (impact) | Stakeholders and other information users | The organisation’s most significant impacts on the economy, environment and people | The organisation sets and documents a cut-off | GRI 3, Steps 1–4 |
The first two rows are about the accounts, and the last three are about sustainability information.
The UK SRS row and the financial half of the ESRS row are close relatives: the joint ESRS–ISSB interoperability guidance says the definitions are aligned.
What separates the ESRS from UK SRS is the second question about impacts, and what separates both from GRI is that GRI asks only that second question.
Financial statements
In financial statements, materiality decides what is presented and disclosed.
The judgement is about a specific reporting entity: the same item can be material for one company and immaterial for another.
The definition was rewritten in 2018 to bring in the word “obscuring”, so that drowning a reader in immaterial detail counts as a failure alongside leaving things out.
IFRS 18 replaces IAS 1 for annual periods beginning on or after 1 January 2027, with earlier application permitted, as the IFRS 18 page states.
It did not rewrite IAS 1 wholesale: some paragraphs stayed in IFRS 18, and some moved to IAS 8 and IFRS 7.
A sustainability report’s materiality is not the same judgement, and the ISSB said so: its Basis for Conclusions, at BC69, says sustainability materiality judgements “will inevitably differ” from those for financial statements.
That is because sustainability disclosures look at prospects over longer horizons and at matters that do not meet the recognition rules for assets and liabilities.
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Audit
Auditors use materiality differently from preparers: the auditor turns the concept into amounts that drive how much testing is done.
ISA (UK) 320 paragraph 10 requires the auditor to determine materiality for the financial statements as a whole when setting the overall audit strategy.
Paragraph 9(a) defines performance materiality as an amount set below overall materiality “to reduce aggregation risk to an appropriately low level”.
Paragraph 9(b) defines aggregation risk as the probability that uncorrected and undetected misstatements together exceed materiality for the financial statements as a whole.
Paragraph A4 says determining materiality involves professional judgement, and that a percentage is often applied to a chosen benchmark as a starting point.
Paragraph A8 gives examples: five per cent of profit before tax from continuing operations for a profit-oriented manufacturer, or one per cent of total revenue or expenses for a not-for-profit, while higher or lower percentages may be appropriate.
Those are examples a UK auditor “may consider”, not rules, and A13 adds that performance materiality “is not a simple mechanical calculation”.
Nothing in the sustainability standards imports these percentages, so a 5% rule carried into a sustainability materiality assessment has no footing in either the ESRS or UK SRS.
Assurance of sustainability information is a separate field again, covered on sustainability assurance.
Set for the financial statements as a whole (¶10).
Lower levels for particular balances or disclosures where needed (¶10).
Lower again, to reduce aggregation risk (¶¶9, 11).
Revise as the audit progresses and record the amounts and factors (¶¶12–14).
UK SRS and the ISSB
UK SRS S1 applies single (financial) materiality.
Paragraph 18 says information is material if omitting, misstating or obscuring it could reasonably be expected to influence decisions that primary users of general purpose financial reports make on the basis of those reports.
Paragraph 3 frames the risks and opportunities in view as those that could reasonably be expected to affect the entity’s cash flows, its access to finance or cost of capital over the short, medium or long term.
Primary users are, in the standard’s own definitions, existing and potential investors, lenders and other creditors.
Paragraph B19 says the standard does not specify any thresholds for materiality or predetermine what would be material in a particular situation.
Paragraph B25 says an entity need not disclose information otherwise required if it is not material, even where the standard lists specific requirements or calls them minimum requirements.
The phrase “enterprise value” does not appear in UK SRS S1: the ISSB removed its definition and the words “to assess enterprise value” from the final IFRS S1, as its Basis for Conclusions records at BC67.
So the accurate name is single (financial) materiality, and “enterprise-value materiality” describes an exposure draft that did not survive.
The ISSB’s educational material of November 2024 explains the definition in four steps and says it does not add to or change the requirements.
The international original is set out on the IFRS S1 general requirements page, and the ISSB’s wider architecture on the ISSB framework page.
For listed companies, UK SRS reporting arrives on a comply-or-explain basis for periods beginning on or after 1 January 2027 under the FCA’s PS26/19.
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The EU test
The EU writes both limbs into Article 19a(1) of the Accounting Directive: information to understand the undertaking’s impacts on sustainability matters, and how sustainability matters affect its development, performance and position.
The revised ESRS 1, in Delegated Regulation (EU) 2026/1563, defines information as material when it could reasonably be expected to influence the decisions of primary users or of other users of the sustainability statement about the undertaking’s material impacts, risks and opportunities (¶23).
Paragraph 35 says double materiality has two dimensions and that impacts can be material exclusively from an impact perspective, irrespective of whether they are financially material.
Paragraph 40 assesses negative impacts on severity — scale, scope and irremediable character — and, if potential, on likelihood as a separate factor.
Paragraph 37 asks for appropriate qualitative considerations and quantitative thresholds, with no universal number.
Paragraph 24 says information that is not material shall not be disclosed, except supplementary information under section 8.2.
The phrase “materiality matrix” does not occur anywhere in the regulation, so a matrix is a presentation choice, not an ESRS output.
The concept, its legal source and the difference from UK SRS are on double materiality explained; the method is on running a double materiality assessment.
The revised standards apply to financial years beginning on or after 1 January 2027, and the twelve standards they cover are on ESRS.
Actual or potential, positive or negative impacts on people or the environment (¶39).
Risks and opportunities affecting development, position, performance, cash flows, access to finance or cost of capital (¶47).
The impact test
GRI 3: Material Topics 2021 defines material topics as those representing an organisation’s most significant impacts on the economy, environment and people, including impacts on their human rights.
Significance is the sole criterion, so financial effects on the organisation are not part of the GRI test.
GRI 3 assesses actual negative impacts on severity, and potential ones on severity and likelihood, with severity made of scale, scope and irremediable character.
That is the same architecture as revised ESRS 1 paragraph 40, which is no accident: the EFRAG–GRI joint statement says the ESRS adopted the same definition for impact materiality as GRI.
GRI 3 asks the organisation to rank its impacts, set a cut-off and document it, and allows a visual representation of the prioritisation for transparency.
The GRI Standards themselves say “material topics” and “most significant impacts”, not “impact materiality”, although GRI as an organisation uses that phrase in its commentary.
GRI 3 is effective for reports published on or after 1 January 2023, and the wider set is on the GRI Standards page.
Words people use
“Single materiality” and “dynamic materiality” are descriptive terms, not tests any standard defines.
Use them only with the lens named: single financial materiality is the UK SRS test, and single impact materiality is GRI’s.
Dynamic materiality describes something the standards do provide for: revised ESRS 1 paragraph 35 says an impact can be financially material from the start or become financially material.
Paragraph 34 then requires the undertaking to consider, at each reporting date, whether significant changes affect its earlier conclusions, and to update the assessment if they do.
UK SRS S1 paragraph B28 likewise requires an entity to reassess its materiality judgements at each reporting date.
So a page that says a standard “uses dynamic materiality” should be read as describing these provisions, not a third test.
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Numbers
A recurring error is to look for a percentage that makes a sustainability matter material.
None of the sustainability standards supplies one: each leaves the threshold to the reporting company and asks it to record what it chose.
Revised ESRS 1 AR 13 says the use of quantitative information or quantitative scoring is not necessarily required, and that a qualitative analysis may be sufficient.
AR 19 adds that in a top-down approach qualitative considerations may be enough, while a bottom-up approach may use either.
UK SRS S1 paragraph B19 says the standard does not specify thresholds or predetermine what is material in a particular situation.
The audit examples in ISA (UK) 320 paragraph A8 belong to the audit of financial statements and do not travel.
What the standards do ask is consistency and a record, which is why a working assessment keeps its scale and thresholds in writing; how a materiality assessment is run covers the working papers.
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Two questions, not one
Scope decides whether a company reports under a regime at all, and materiality decides what it says once it does.
From financial years beginning on or after 1 January 2027, the CSRD reaches undertakings that exceed both a net turnover of €450 million and an average of 1,000 employees, under Article 19a(1) of the Accounting Directive.
The threshold is cumulative: both limbs must be exceeded.
A UK company outside that scope may still be asked for information by an EU customer, but that is a request, not a materiality test applying to it; the voluntary standard sets out what a protected supplier can be asked.
UK SRS has no size test of its own: the FCA’s rules decide which listed companies report, and materiality then decides content.
How the two regimes sit together for a UK group is on CSRD and UK SRS compared, and what the CSRD requires covers the EU directive itself.
A scope test about the company, such as the CSRD’s 1,000 employees and €450 million from financial year 2027.
A materiality test about information, applied only once the regime applies.
How the definitions arrived
The dates below are when each instrument was issued, took effect or was published, read from the instrument or its owner.
Interoperability
The joint ESRS–ISSB interoperability guidance says the definition of financial materiality in the ESRS is aligned with the definition of materiality in IFRS S1.
What is not aligned is the regime, because the ESRS add the impact lens on top.
EFRAG’s IG 1 says one assessment can reflect both perspectives without two separate and independent processes, and that a GRI impact assessment is a good basis for the impact half.
IG 1 is non-authoritative and was written for the 2023 ESRS, so its paragraph references do not map onto the revised standards.
The interoperability guidance was published on 2 May 2024 and also maps 2023 paragraph numbers.
In practice a group reporting under both regimes can treat the financially material subset of an ESRS assessment as the starting point for UK SRS, and keep the impact-only findings on the EU side; UK SRS against the ESRS sets out the remaining differences.
The wider landscape is on global sustainability standards, and the industry-based topics the ISSB points to are on the SASB Standards page.
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The materiality section
Start from the question you have, not from the standard.
The route below runs from the concept to the reporting decision.
| Guide | The question it answers |
|---|---|
| Double materiality | The two lenses, where EU law writes them down, and how they differ from UK SRS. |
| Double materiality assessment | How an ESRS assessment is run, scored and recorded, and who can ask a UK company for one. |
| Materiality assessment | The process across frameworks, and when it is a double materiality assessment and when it is not. |
| Single vs double materiality | One lens or two: what each regime asks, and what carries over between them. |
| Financial materiality | The outside-in lens: effects on cash flows, finance and cost of capital, under UK SRS and the ESRS. |
| Impact materiality | The inside-out lens: severity, likelihood and the four kinds of impact. |
| Materiality matrix | What a matrix can show, why no standard requires one, and how it misleads. |
| UK SRS materiality | The UK SRS S1 test paragraph by paragraph, and how it relates to the ISSB. |
| Impacts, risks and opportunities | The unit of an ESRS assessment, and how impacts, risks and opportunities connect. |
| Materiality thresholds | Why no standard sets a number, and how to set and record your own. |
| Double materiality assessment template | A working register with every field tied to its paragraph, and a worksheet. |
| Double materiality examples | Four published FY2024 assessments, read from the companies’ own reports. |
| Stakeholder engagement | What the ESRS ask of engagement, and why no survey is required. |
| UK SRS S1 | The UK’s general requirements and its single (financial) materiality test. |
| IFRS S1 general requirements | The ISSB original and every UK difference. |
| ESRS | The twelve EU standards that double materiality decides between. |
| GRI Standards | The impact-only framework and its material topics. |
| SASB Standards | Industry-based disclosure topics the ISSB points to. |
What goes wrong
“Sustainability materiality is 5% of profit.”
That is an audit example from ISA (UK) 320 A8, and no sustainability standard adopts it.
“UK SRS uses enterprise-value materiality.”
The phrase is not in UK SRS S1, and the ISSB removed it from the final IFRS S1 (BC67).
“Under the ESRS a matter must be material both ways.”
Either perspective is enough (revised ESRS 1 ¶35).
“The ESRS require a materiality matrix.”
The phrase does not occur in Delegated Regulation (EU) 2026/1563.
“Report everything to be safe.”
Revised ESRS 1 ¶24 says immaterial information shall not be disclosed, outside supplementary information under section 8.2.
“The definition is in IAS 1 paragraph 7.”
For periods beginning on or after 1 January 2027 it is in IFRS 18 Appendix A.
This site explains the standards from their primary sources and offers no audit, assurance or assessment service.
Each source on this page is the instrument itself, read on or before 11 October 2026.
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Frequently asked
Materiality is the test that decides whether a piece of information belongs in a report.
In IFRS accounting, information is material if omitting, misstating or obscuring it could reasonably be expected to influence decisions that the primary users of general purpose financial statements make on the basis of those statements.
Sustainability standards use the same idea but change whose decisions count and what kind of effect is being judged.
For periods beginning on or after 1 January 2027 the IFRS definition sits in Appendix A and paragraph B1 of IFRS 18: information is material if omitting, misstating or obscuring it could reasonably be expected to influence decisions that the primary users of general purpose financial statements make on the basis of those financial statements.
For earlier periods the same definition is paragraph 7 of IAS 1.
It depends on the standard.
UK SRS S1 and IFRS S1 apply single (financial) materiality: information that could reasonably be expected to influence primary users’ decisions.
The ESRS apply double materiality, adding the undertaking’s impacts on people and the environment.
GRI applies an impact test only.
Materiality for the financial statements as a whole is the level the auditor sets for the accounts overall.
Performance materiality, defined in ISA (UK) 320 paragraph 9(a), is a lower amount set to reduce aggregation risk, meaning the chance that uncorrected and undetected misstatements together exceed overall materiality.
Not in any standard as a rule.
ISA (UK) 320 paragraph A8 gives examples — five per cent of profit before tax from continuing operations, or one per cent of revenue or expenses for a not-for-profit — and says higher or lower percentages may be appropriate.
UK SRS S1 paragraph B19 specifies no thresholds, and revised ESRS 1 paragraph 37 asks for qualitative considerations and quantitative thresholds the undertaking sets itself.
A descriptive name, not a defined test, for materiality judged through one lens.
In practice it usually means the financial lens of UK SRS S1 and IFRS S1.
Name the lens when you use the term, because GRI’s impact-only test is also single in that sense.
The EU test under the CSRD and the ESRS.
A sustainability matter is reported if it is material from the impact perspective, the financial perspective, or both.
Revised ESRS 1 paragraph 35 says impacts can be material exclusively from an impact perspective.
A descriptive term for the idea that what is material changes over time, including impacts that become financially material.
It is not a defined test in the ESRS, IFRS or GRI standards.
The mechanism in the ESRS is paragraph 35, which says an impact can become financially material, and paragraph 34, which requires a check for significant changes at each reporting date.
No. The phrase does not appear in UK SRS S1.
The ISSB removed the definition of enterprise value and the words to assess enterprise value from the final IFRS S1, as its Basis for Conclusions explains at BC67.
UK SRS S1 uses single (financial) materiality, judged by the decisions of primary users of general purpose financial reports.
Not by the revised ESRS: the phrase does not occur anywhere in Delegated Regulation (EU) 2026/1563.
UK SRS S1 does not require one either.
A matrix is a presentation choice, and under the ESRS it must not turn an either-or test into a both test.
No. GRI 3 asks for an organisation’s most significant impacts on the economy, environment and people, and its significance is the sole criterion. That resembles the impact half of double materiality.
The EFRAG–GRI joint statement says the ESRS adopted the same definition of impact materiality as GRI.
No. Scope decides whether a regime applies to a company at all; materiality decides what that company reports.
The CSRD applies from financial year 2027 to undertakings that exceed both €450 million net turnover and 1,000 employees, and only then does its double materiality test decide content.
You have to review it.
UK SRS S1 paragraph B28 requires materiality judgements to be reassessed at each reporting date.
Revised ESRS 1 paragraph 34 requires the undertaking to consider at each reporting date whether significant changes affect its earlier conclusions, and to update the assessment if they do.
Under the revised ESRS, no: paragraph 24 says the undertaking shall not disclose information prescribed by a disclosure requirement or datapoint if it is not material, except supplementary information presented under section 8.2.
UK SRS S1 paragraph B25 says immaterial information need not be disclosed, even where a standard lists it as a minimum requirement.
Sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
The 2018 Definition of Material now sits in Appendix A and ¶¶B1–B5; IFRS 18 replaces IAS 1 for periods beginning on or after 1 January 2027.
“Information is material if omitting, misstating or obscuring it could reasonably be expected to influence decisions…”
Points to IFRS 18 Appendix A for the meaning of material.
Paragraph 7 carried the definition for periods before 1 January 2027.
Audit materiality, performance materiality and aggregation risk; the percentages in A8 are examples.
Single (financial) materiality, judged by primary users’ decisions; no thresholds specified.
Why “enterprise value” was removed from the final standard, and why sustainability judgements differ from financial-statement ones.
Explanatory only; does not add to or change the requirements.
Lists the educational material at 19 November 2024.
The two limbs of double materiality, and the CSRD scope test from financial year 2027.
¶¶23, 24, 34, 35, 37 and 40; published 21 September 2026, applies from financial years beginning on or after 1 January 2027.
The impact test: an organisation’s most significant impacts; four steps; the organisation documents its own threshold.
The ESRS adopted the same definition of impact materiality as GRI.
Non-authoritative and written for the 2023 ESRS.
The financial-materiality definitions are aligned; the regimes are not.
Where UK SRS materiality becomes a reporting question for listed companies, from periods beginning 1 January 2027.