Double Materiality Is a Governance Exercise Before It Is a Reporting One
Materiality assessments often get treated as a workshop exercise ahead of the reporting cycle. Organisations that treat it as ongoing governance produce more defensible disclosures.
4 May 2026 · 5 min read
Under IFRS S1 and the double materiality approach used across CSRD and GRI-aligned reporting, materiality is not a single decision made once a year. It is a continuous judgement about which sustainability issues are financially material to the organisation and which activities are materially affecting people, the environment, or the wider economy.
In practice, many organisations still run materiality as an annual workshop: a cross-functional session, a scored matrix, a list of topics that feeds into the report. The output can look reasonable, but it rarely survives scrutiny from an assurance provider or an investor asking how the assessment was governed.
A more durable approach treats materiality determination as an ongoing governance process: clear ownership, a documented methodology for scoring financial and impact materiality, evidence trails for each judgement, and a mechanism for revisiting conclusions as circumstances change.
The difference matters most when a material topic is excluded. Being able to explain why an issue was assessed and not included — with evidence — is very different from being unable to explain the process that produced the list at all.