UK SRS S1 or IFRS S1
Single (financial) materiality: information that could reasonably influence primary users’ decisions.
UK listed companies, comply or explain, from periods beginning 1 January 2027.Ask direct questions about your own reporting — your thresholds, your dates, what you file and when.
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Materiality · the method, framework by framework
A materiality assessment is how a company decides which sustainability information belongs in its report.
The method is broadly the same everywhere, but the framework decides the test: financial for UK SRS, impact or financial for the ESRS, impact only for GRI.
Start with the framework
The first decision in any materiality assessment is not a score but a framework.
Every framework asks what is material, and they answer to different readers.
A UK listed company reporting against UK SRS on the FCA’s comply-or-explain basis applies UK SRS S1, a single (financial) materiality test.
A group the CSRD reaches applies the ESRS, which add the impact lens, so its exercise is a double materiality assessment.
A company reporting voluntarily on its impacts against GRI applies GRI 3, which asks only about impacts.
The FCA’s PS26/19 asks listed companies in the UKLR 6, 14, 15, 16 and 22 categories to report against UK SRS on a comply-or-explain basis for periods beginning on or after 1 January 2027.
That is a disclosure regime with an explanation route, not an unconditional duty, and what comply or explain requires sets out what an explanation must say.
The CSRD applies from financial years beginning on or after 1 January 2027 to undertakings exceeding both 1,000 employees and €450 million of net turnover, under the consolidated Accounting Directive.
Undertakings that reported for financial years 2024 to 2026 in the first wave fall outside the CSRD from 2027 unless they also meet that test.
A UK group meets the ESRS through an EU subsidiary or an EU listing, and CSRD reporting for UK groups covers the routes.
Many companies run more than one test from one evidence base, which is why the order matters: choose the framework, then the method follows.
| Framework | Whose decisions | The test | Status for a UK company |
|---|---|---|---|
| UK SRS S1 | Primary users of general purpose financial reports (¶18) | Could it reasonably be expected to influence their decisions; effects on cash flows, access to finance or cost of capital (¶3) | Comply or explain for listed companies from 2027; voluntary otherwise |
| ESRS | Primary users and other users of sustainability statements (ESRS 1 ¶23) | Impact materiality or financial materiality, or both (¶35) | Only where the CSRD reaches the group |
| GRI 3 | Stakeholders and other information users | The organisation’s most significant impacts on the economy, environment and people | Voluntary |
Single (financial) materiality: information that could reasonably influence primary users’ decisions.
UK listed companies, comply or explain, from periods beginning 1 January 2027.Double materiality: impact or financial, either alone being enough.
Groups above 1,000 employees and €450m turnover, from FY2027.Impact materiality: the most significant impacts on the economy, environment and people.
Voluntary reporting.The three lenses
“Single materiality” is a descriptive label, not a defined test.
The defined test in UK SRS S1 ¶18 is whether omitting, misstating or obscuring information could reasonably be expected to influence decisions that primary users of general purpose financial reports make.
UK SRS S1 ¶3 frames those effects as the entity’s cash flows, its access to finance or cost of capital over the short, medium or long term.
The phrase “enterprise value” appears nowhere in UK SRS S1, and the ISSB removed it from the materiality wording of the final IFRS S1.
The IFRS S1 Basis for Conclusions records that the ISSB removed it from the exposure-draft description of materiality and aligned the definition with the IASB’s (BC67).
It also says materiality judgements for sustainability-related financial disclosures “will inevitably differ” from those for financial statements (BC69), so audit percentages do not transfer.
GRI 3 sits at the other end: its material topics are the organisation’s most significant impacts, and the Standard says significance is “the sole criterion”.
The ESRS put the two together: ¶35 says impacts “can be material exclusively from an impact perspective, irrespective of whether they are financially material”.
The joint ESRS–ISSB interoperability guidance says the ESRS definition of financial materiality is aligned with IFRS S1, so the regimes differ by the second question, not the first.
The concept is set out in full on double materiality and its two lenses, and the definition across accounting and audit on what materiality means.
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The method
Strip the vocabulary away and every framework asks for the same six moves.
Understand the business, identify what could matter, assess it against the test, decide and document, disclose, then review.
The differences lie in what “assess” means and in what has to be written down.
| Framework | Its own steps | Where |
|---|---|---|
| GRI 3 | Understand the organisation’s context · identify actual and potential impacts · assess the significance of the impacts · prioritise the most significant impacts for reporting | GRI 3, Section 1, Steps 1–4 |
| ISSB education material | Identify potentially material information · assess whether it is material · organise it in the draft disclosures · review the draft | IFRS Foundation, November 2024, Chapter 3 |
| Revised ESRS 1 | Identify topics with material impacts, risks or opportunities, then determine the information to report (¶25); top-down or bottom-up by topic (¶¶27–28) | DR (EU) 2026/1563, Annex I |
| Revised ESRS 1, impacts | Understand activities, relationships and stakeholders · identify actual and potential impacts · assess and determine the topics to report | AR 20 |
| UK SRS S1 | Apply ¶¶B13–B37 to identify and disclose material information; reassess at each reporting date | ¶19, ¶B28 |
The ISSB’s educational material says it “is not part of IFRS Sustainability Disclosure Standards and does not add to or change the requirements”, so its four steps are a way of working, not a rule.
EFRAG’s IG 1 offered four illustrative steps for the 2023 ESRS; it is non-authoritative and its paragraph references belong to the old text.
The revised ESRS 1 lets a company reach a conclusion on a whole topic “without further assessment” from its strategy and business model, and assess specifically only where the answer is not evident (¶27).
That top-down route is a method choice, not an exemption: the criteria still apply, and the analysis behind the conclusion has to be on file.
Business model, value chain, geographies, sectors and stakeholders.
The sustainability matters that could be material under your test.
Apply the framework’s criteria: financial effects, impacts, or both.
Record the threshold, judgements and evidence.
Report the material information, and nothing immaterial under the ESRS.
Reconsider at each reporting date.
Across a reporting year
The steps sit naturally across a reporting year, with the conclusions revisited rather than rebuilt.
This sequence is an illustration of practice, not a timetable any framework prescribes.
Building the long list
A materiality assessment that starts from the topics a company already planned to talk about has skipped the step that matters.
The long list should come from evidence about the business, not from the agenda.
Industry context is the quickest way in, and the SASB Standards set out disclosure topics industry by industry.
The SASB Standards cover 77 industries across 11 sectors, classified by the Sustainable Industry Classification System, according to the IFRS Foundation’s SICS industry list.
UK SRS S1 ¶55(a) says an entity “may refer to and consider the applicability of the disclosure topics in the SASB Standards”, and ¶58(a) says the same of the metrics.
That “may” is a UK change: the UK made the SASB reference permissive, while ¶59 still requires an entity to identify the sources of guidance it applied.
Under the ESRS, the starting universe is the ten topical standards, and the revised ESRS 1 lets value-chain matters be assessed using average regional data, sector data or generally available information (¶33).
Under GRI 3, Step 2 identifies actual and potential impacts, negative and positive, across the organisation’s activities and business relationships.
The SASB Standards guide and the GRI Standards guide cover each source in more depth.
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Assessing
Impact severity is assessed on three factors in both the ESRS and GRI 3: scale, scope and irremediable character.
Likelihood is a separate factor, used for potential impacts, not a fourth part of severity.
Financial materiality under the ESRS combines the likelihood of occurrence with the potential magnitude of the financial effects (¶50).
The revised ESRS 1 ¶40: actual negative impacts are assessed on severity; potential negative impacts on severity and likelihood.
¶41 is the positive-impact mirror: scale and scope, plus likelihood for potential impacts.
AR 22 says “any of the three characteristics (scale, scope and irremediable character) can make a negative impact severe”, which is why averaging the three is a mistake.
GRI 3 uses the same three characteristics and the same human-rights rule.
Under UK SRS S1 an impact is assessed only as the source of a risk or opportunity to the entity, judged by its effect on cash flows, access to finance or cost of capital (¶3).
The revised ESRS 1 AR 13 says quantitative information or scoring “is not necessarily required” and a qualitative analysis may be sufficient.
The ESRS scoring rules, a worked example and a scoring grid are on how to run a double materiality assessment.
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Thresholds
Every framework leaves the materiality threshold to the company.
What every framework does ask is that the threshold is reasoned, applied consistently and written down.
A percentage borrowed from financial-statement audit is not a sustainability threshold.
UK SRS S1 ¶B19: “this Standard does not specify any thresholds for materiality or predetermine what would be material in a particular situation.”
The ISSB educational material says the same of IFRS S1, citing the same paragraph.
The revised ESRS 1 ¶37 asks for material impacts, risks and opportunities to be determined “supported by appropriate qualitative considerations and quantitative thresholds”, and AR 19 says qualitative considerations may be enough in a top-down approach.
GRI 3 Step 4: “Where to set the threshold is up to the organization”, and it “should document this threshold”.
UK SRS S1 ¶B25 adds that information that is not material need not be disclosed even if a standard lists it as a minimum requirement.
The revised ESRS 1 goes further: information that is not material “shall not” be disclosed, except supplementary information under its section 8.2 (¶24).
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Stakeholders
Under the revised ESRS, engagement with affected stakeholders carried out in ongoing due diligence is “a key input” to the impact assessment (¶42).
AR 24 says those results serve the materiality assessment “without the need to put in place a separate engagement process”.
No framework covered here makes a stakeholder survey a requirement.
AR 23 lists the typical categories of affected stakeholders: workers in the own workforce and value chain, affected communities, and consumers and end-users, with particular attention to those in vulnerable situations.
It adds that “nature may be considered a silent affected stakeholder”.
AR 24 also allows direct input from affected stakeholders, their representatives, users of sustainability reporting and other experts, including feedback on the conclusions.
Under UK SRS S1 the reference point is the information needs of primary users — existing and potential investors, lenders and other creditors — rather than affected stakeholders.
So a UK SRS assessment draws more on investor dialogue and risk management, and an ESRS or GRI one more on due diligence.
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What it produces
None of these frameworks asks for a standalone “materiality report”.
The assessment surfaces inside the report, in disclosures each framework names.
Building the evidence file to answer those disclosures line by line is the efficient way to run the exercise.
| Framework | Process disclosure | Results disclosure |
|---|---|---|
| ESRS | ESRS 2 IRO-1: decision steps, methodologies, inputs, assumptions, thresholds | ESRS 2 IRO-2 (material impacts, risks and opportunities; disclosure requirements met) and SBM-3 (interaction with strategy) |
| GRI | Disclosure 3-1 Process to determine material topics | Disclosure 3-2 List of material topics; Disclosure 3-3 Management of material topics |
| UK SRS S1 | Judgements that most affect the disclosures (¶¶74–76) | The material sustainability-related financial information |
ESRS 2 IRO-1 asks for information specific to the company’s own process, and the revised standards discourage boilerplate that merely restates the criteria.
Under GRI 3, reasons for omission are permitted only for Disclosure 3-3.
For a CSRD reporter, the limited assurance opinion covers the process used to identify the information reported, so the evidence behind the conclusions matters as much as the conclusions; sustainability assurance covers the engagement.
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Illustrative worked example
The company and every figure below are invented, to show the method, not a finding about any real company.
A UK-listed manufacturer reports against UK SRS on the FCA’s comply-or-explain basis, and its EU subsidiary is inside the CSRD.
The group builds one long list and runs it through both tests.
| Matter (illustrative) | UK SRS S1 (financial) | ESRS (impact or financial) |
|---|---|---|
| Rising carbon costs on energy-intensive sites | Material: could affect cash flows and cost of capital | Material: financial, and the emissions are an impact (E1) |
| Excessive hours at a third-tier supplier | Not material on present evidence: no expected effect on cash flows | Material on impact alone: scale makes it severe (S2) |
| Flood exposure at one plant | Material: physical risk to operations | Material: financial, a risk not arising from an impact (¶36) |
| Water use at a site outside water-stressed areas | Not material | Assessed and not material, so it shall not be reported (¶24) |
The financially material matters overlap, because the joint guidance says the two financial definitions are aligned.
The supplier-hours matter is reported only under the ESRS, because only the ESRS ask about impacts for their own sake.
If that impact later threatened a contract or a financing covenant, it would become a financial matter under UK SRS too.
The threshold reasoning for each line is what an assurance provider, or an investor, would want to see.
The matrix question
The phrase “materiality matrix” does not occur anywhere in Delegated Regulation (EU) 2026/1563.
UK SRS S1 does not ask for one either.
GRI 3 says an organisation “can provide a visual representation of the prioritization”, which a matrix can be, but it is a choice.
A matrix plotting impact against financial effect is a working tool, and it carries a trap under the ESRS.
A matter material on one axis is material even if it sits at zero on the other (¶35), so a matrix that highlights only the top-right corner has turned an either test into a both test.
Averaging severity on one axis hides the rule that any one of scale, scope or irremediable character can make an impact severe (AR 22).
A table of material topics with the reasoning beside each is often the clearer record.
The process, thresholds and results each framework names.
A matrix, chart or table, chosen by the company.
How the standards arrived
The rules a materiality assessment follows have been rewritten in stages, and the dates decide which text applies.
For a financial year beginning in 2026, an ESRS reporter may still choose the 2023 standards, with or without listed reliefs, and must say which it used.
What goes wrong
The commonest mistake is running the wrong test for the report in hand.
The second is treating a presentation tool, the matrix, as the assessment itself.
Averaging scale, scope and irremediable character understates severe impacts (AR 22).
Letting likelihood bury a potential human rights impact breaks the precedence rule in both the ESRS and GRI 3.
Reporting everything “to be safe” is now a defect under the ESRS (¶24), and unnecessary under UK SRS (¶B25).
Rebuilding from scratch every year wastes effort: the duty is to review for significant changes (ESRS 1 ¶34; UK SRS S1 ¶B28).
Citing IG 1 paragraphs against the revised ESRS points at a text that no longer exists in that form.
Calling UK SRS “enterprise-value materiality” imports exposure-draft language the final standards dropped.
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For UK companies
For most UK companies the materiality assessment is a financial one, run for UK SRS.
The impact half arrives through an EU entity, an EU customer, or a choice to report on impacts voluntarily.
UK SRS S1, paragraph by paragraph, sets out the materiality paragraphs, and the two UK standards together place them in context.
The ISSB baseline is on the IFRS S1 guide and the ISSB framework.
For the EU side, the CSRD explained and the ESRS read from the UK set out scope and standards.
A supplier answering a CSRD customer can decline over-cap requests if it is a protected undertaking, as the voluntary standard guide explains.
Wider context is on ESG reporting in the UK, and the conclusions feed a board-approved ESG strategy.
Pick the framework first; it decides the test.
Then follow the same six steps, document the threshold, and review at each reporting date.
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Frequently asked
A materiality assessment is the process a company uses to decide which sustainability matters, and which information about them, belong in its report.
The framework decides the test: UK SRS and the ISSB standards ask what could influence investors and lenders, the ESRS add impacts on people and the environment, and GRI asks only about impacts.
The same exercise under another name.
“ESG” describes the subject matter; the framework the company reports against decides whether the test is financial, impact or both.
Understand the business and its value chain, identify the sustainability matters that could be material, assess them against the test your framework sets, decide and document what crosses the line, prepare the disclosures, and review the conclusions at each reporting date.
Each framework words those steps differently, but none prescribes a numeric threshold.
Only when the framework is the ESRS.
A double materiality assessment applies both the impact and the financial lens, and a matter material through either is reported.
Under UK SRS S1 the assessment is single (financial) materiality; under GRI it is impacts only.
A listed company reporting against UK SRS on the FCA’s comply-or-explain basis must judge what information is material under UK SRS S1, which is a financial test.
A double materiality assessment is needed only where the CSRD reaches the group or a customer asks for one.
Not a universal one.
UK SRS S1 ¶B19 says the Standard does not specify any thresholds; the revised ESRS 1 asks for appropriate qualitative considerations and quantitative thresholds without fixing a number; GRI 3 asks the organisation to set and document its own cut-off.
No framework covered here requires one.
The revised ESRS 1 makes engagement with affected stakeholders carried out in ongoing due diligence a key input, and AR 24 says no separate engagement process for the materiality assessment is needed.
No. The phrase does not occur in Delegated Regulation (EU) 2026/1563, and UK SRS does not ask for one.
GRI 3 says an organisation can provide a visual representation of its prioritisation; a matrix is one presentation choice, not an output any of these standards prescribes.
UK SRS S1 ¶B28 requires materiality judgements to be reassessed at each reporting date.
The revised ESRS 1 ¶34 requires the undertaking at each reporting date to consider whether significant changes affect its earlier conclusions and to update the assessment if so.
Neither requires a fresh exercise from scratch every year.
Under the ESRS, the process goes into ESRS 2 IRO-1 and the results into IRO-2 and SBM-3.
Under GRI, Disclosures 3-1, 3-2 and 3-3.
Under UK SRS S1, the material information itself, together with the judgements disclosed under the Standard’s general requirements.
One evidence base can.
The joint ESRS–ISSB guidance says the ESRS definition of financial materiality is aligned with IFRS S1, so the financially material subset of an ESRS assessment is the natural starting point for UK SRS S1.
The impact-only findings stay on the EU side.
Not under UK SRS.
UK SRS S1 ¶55(a) says an entity may refer to and consider the applicability of the disclosure topics in the SASB Standards, which is a UK change from the international text.
The SASB Standards cover 77 industries across 11 sectors.
IG 1 is non-authoritative and was written for the 2023 ESRS.
Its paragraph references do not match the revised ESRS, and EFRAG lists no implementation guidance for the revised standards as at 11 October 2026.
No. It is a descriptive shorthand.
The defined test in UK SRS S1 ¶18 is whether omitting, misstating or obscuring information could reasonably be expected to influence decisions that primary users of general purpose financial reports make.
Sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Single (financial) materiality: what could reasonably influence primary users’ decisions; no thresholds; reassessed at each reporting date.
A four-step process; explanatory only, not part of the Standards.
Why “enterprise value” was removed, and why sustainability materiality judgements differ from financial-statement ones.
¶¶22–37 and AR 13, AR 19, AR 20, AR 22–AR 25: the double materiality assessment as published on 21 September 2026.
What an ESRS statement discloses about the assessment process and its results.
The two limbs of EU sustainability reporting, and the 1,000-employee and €450m scope test.
Four steps; severity is scale, scope and irremediable character; the organisation sets and documents its threshold.
Non-authoritative, and written for the 2023 ESRS.
IG 1 to IG 3 relate to the 2023 ESRS; no guidance for the revised ESRS is listed as at 11 October 2026.
UK SRS on a comply-or-explain basis for listed companies, for periods beginning on or after 1 January 2027.
The ESRS financial-materiality definition is aligned with IFRS S1; ESRS add the impact lens.
Industry-based disclosure topics, maintained by the ISSB.
77 industries across 11 sectors.
For undertakings protected by the value-chain cap.