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Sustainability / ESG

Impact Materiality

Impact materiality (the inside-out perspective) captures a company's actual and potential, positive and negative impacts on the environment and society across its entire value chain.

Impact materiality is one of the two pillars of double materiality under the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS) that build on it. It follows the so-called inside-out perspective: the focus is on the impacts that the company itself exerts on people and the environment through its business activities, its products and services, and its business relationships. This fundamentally distinguishes it from financial materiality, which conversely asks how sustainability matters affect the company's economic situation.

A sustainability matter is material from an impact perspective when the company is significantly connected to its effects on the environment or society. Both actual and potential impacts are assessed, positive as well as negative, short-term as well as long-term. Under the ESRS, the decisive assessment criteria are the severity of the impact (scale, scope and, where relevant, irremediability) and, for potential impacts, additionally their likelihood of occurrence. The assessment explicitly covers the entire upstream and downstream value chain, not just the company's own operations.

In practice, identifying and assessing impacts is carried out through the IRO analysis (Impacts, Risks and Opportunities) prescribed in ESRS 2, with the involvement of affected stakeholders. The result directly drives the scope of reporting: topic-specific ESRS data points only have to be reported for material matters. Together with financial materiality, impact materiality therefore determines which environmental, social and governance topics a company must disclose in its sustainability statement, and it is the central starting point of every CSRD materiality assessment.

Legal Basis

ESRS 1 Section 3 (Double Materiality) and ESRS 2 IRO-1; Art. 19a/29a CSRD (Directive (EU) 2022/2464)

Practical Example

The compliance officer of a mid-sized textile manufacturer carries out the materiality assessment for the first CSRD report. From the impact perspective, she evaluates which negative effects the company causes: high water consumption and chemical use in its own dyeing facility, as well as potential violations of labour rights at suppliers in the upstream value chain. Given the severity and likelihood of these impacts, she classifies ESRS E3 (Water) and ESRS S2 (Workers in the value chain) as material, documents the assessment in a traceable manner, and thereby triggers the reporting obligation for the related data points.

FAQ

Impact materiality follows the inside-out perspective and asks what effects the company has on the environment and society. Financial materiality conversely looks (outside-in) at how sustainability matters affect the company's financial position. Together they form the double materiality of the CSRD.
Under ESRS 1, the severity of the impact is decisive, meaning its scale, scope and, where relevant, irremediability. For potential impacts, the likelihood of occurrence is added. Both actual and potential, positive and negative impacts across the entire value chain are assessed.
Yes. Impact materiality explicitly covers the company's own operations as well as the upstream and downstream value chain, including business relationships. Engaging affected stakeholders is an essential part of the assessment.

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