Double materiality and ESRS E1 climate: what you can and cannot omit
The double materiality assessment decides which ESRS disclosures you report. Climate change is treated differently from every other topic, and this page explains why.
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Impact materiality and financial materiality
Double materiality has two dimensions, impact materiality and financial materiality, and the undertaking must consider how they interact. An impact can be material purely from an impact perspective, whether or not it is financially material. It becomes financially material when it is reasonably expected to affect financial performance, financial position, cash flows, access to finance or cost of capital over the short, medium or long term.
Under the simplified ESRS, the starting point is generally the assessment of impacts, and the undertaking must also look for material risks or opportunities unrelated to its impacts, such as physical risks. At each reporting date, it must consider whether significant changes could affect earlier conclusions and, if so, review and update the assessment.
Why ESRS E1 is a special case
For any topic other than climate change, an undertaking that concludes the topic is not material omits all the disclosure requirements of the corresponding standard and may briefly explain the conclusions of its materiality assessment. Climate change is different: an undertaking that omits all disclosure requirements of ESRS E1 must give a detailed explanation of its conclusions, including a forward-looking analysis of the conditions that could make climate change material in the future.
The simplified ESRS keep this logic: the basis for concluding that climate change is not material must be disclosed when all E1 disclosure requirements are omitted.
In practice, this means an undertaking cannot treat climate change like biodiversity or any other topic: a short statement is not enough, and the explanation is disclosed under ESRS 2 IRO-2, the disclosure requirement on the ESRS disclosure requirements covered by the sustainability statement.
What ESRS E1 covers
In the original set of ESRS, E1 contains disclosure requirements on the transition plan for climate change mitigation, policies, actions and resources, targets, energy consumption and mix, gross Scope 1, 2 and 3 and total GHG emissions, GHG removals and carbon credits, internal carbon pricing, and anticipated financial effects from physical and transition risks.
Frequently asked questions
Do asset managers have to assess the impacts of the investments they manage?
Where an undertaking manages investments under a fiduciary duty on behalf of clients, without retaining the risks or rewards of ownership, it is not expected to assess the impacts, risks and opportunities related to those investments.
What kind of changes trigger an update of the assessment?
Changes may relate to the undertaking's activities, structure, business relationships, understanding of impacts, risks or opportunities, assessment methodologies, or the external environment.
Which areas did the Commission change from EFRAG's advice in the simplified ESRS?
Among others: materiality and the materiality assessment, fair presentation, the ability to omit information, anticipated financial effects, greenhouse gas emissions and climate transition plans.
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