Three Double Materiality Mistakes

A double materiality assessment does not have to be a six-month project

Double materiality is the step that decides everything downstream. It determines which topics you report on, which data you have to collect, and how much work the rest of the reporting cycle becomes. Done well, it narrows the scope. Done badly, it expands it, and the cost shows up months later when a team is collecting data for topics that were never material in the first place.

The assessment itself is not conceptually difficult. An organisation looks at its sustainability topics from two directions: the impact the business has on people and the environment, and the effect those same topics have on the financial position of the business. A topic that is significant from either direction is material and must be reported.

The difficulty is almost never the concept. It is the way the process is run. Three mistakes account for most of the wasted effort.

Mistake one: treating it as a workshop rather than a record

Many assessments are run as a series of workshops. Stakeholders are consulted, topics are debated, a matrix is produced, and the conclusions are written into a slide deck that becomes the reference document.

The judgement in that process is often sound. The problem is what survives it. When an auditor asks in eighteen months why a topic was scored as it was, who was consulted, and what evidence supported the threshold, a slide deck does not answer the question. The reasoning existed in the room and left with the people in it.

A double materiality assessment is not a conclusion. It is a record: topics, scores, the basis for each score, who provided input, and when. If that record is not captured as the assessment happens, it has to be reconstructed later from memory, which is both slow and unconvincing.

Mistake two: assessing every topic at the same depth

The ESRS topic list is long, and there is a natural instinct to give each entry equal attention. This is the single largest consumer of time in a first assessment.

A proportionate assessment moves quickly through topics that are obviously immaterial, documents briefly why they were dismissed, and reserves real analytical effort for the handful of topics where the answer genuinely is not obvious. A logistics company does not need three workshops to conclude that its water consumption is not material. It does need serious work on its transport emissions and its workforce.

Screening out a topic still requires a written justification. But a justification is a paragraph, not a project.

Mistake three: disconnecting the assessment from the data collection

This is the expensive one. The assessment is completed by one group, often with external support, and delivered as a finished document. Data collection is then set up separately by a different group, working from that document.

The translation step is where the cost appears. Someone has to read the assessment, work out which disclosure requirements follow from each material topic, and build a collection plan from scratch. Topics get missed. Data gets collected for topics that were screened out. And when the assessment is revisited the following year, none of that mapping work carries forward.

When the assessment and the collection plan live in the same system, the material topics generate the data requirements directly, and next year’s review starts from last year’s reasoning rather than a blank page.

What a proportionate process looks like

• Score against a defined threshold. Decide what qualifies as material before scoring, not after seeing the results.
• Capture the basis with the score. One or two sentences per topic, recorded at the time.
• Log stakeholder input as evidence. Who was consulted, in what form, and what they said.
• Let material topics drive the collection plan rather than re-deriving it by hand.
• Treat it as a living assessment. Next year is a review of what changed, not a fresh start.

Handled this way, a double materiality assessment stops being the most expensive phase of the reporting cycle and starts doing what it was designed to do: reducing the amount of work that follows it.

Planmark runs the assessment as structured data rather than a document. Scores, justifications and stakeholder input are recorded in place, and the resulting material topics feed straight into the data collection plan.