Vitória Menezes Sanhudo (master’s student in European Union Law at the School of Law of University of Minho)

The harmonisation of corporate sustainability disclosure criteria has become increasingly relevant as a guarantee of a level playing field among companies and for the efficiency of the Internal Market. In this context, Directive (EU) 2022/2464 (CSRD) amends previous provisions, aiming to promote a more standardised sustainability reporting obligation, using the double materiality principle (DMP). It is deemed as necessary to analyse the conceptual evolution of materiality, from its origin in accounting to double materiality (enshrined in the CSRD Directive), its enforcement in the Directive under consideration, to evaluate the benefits and challenges of this dual perspective from a theoretical approach and, subsequently, to assess it from a more practical viewpoint, taking into account conclusions that can already be drawn from its introduction in the CSRD Directive.

The research question is as follows: in what way does the evolution of materiality in sustainability reporting prove to be positive, particularly with the incorporation of the DMP in the CSRD?

The concept of materiality

For a complete understanding of the CSRD Directive and the DMP, firstly, it is crucial to establish the conceptual basis that underpins them: materiality as a legal principle. The concept of material information emerged in the field of accounting at the beginning of the 20^th century, and its importance and scope have expanded over the years. In the EU, the Accounting Directive[1] is the central instrument for corporate financial reporting. Generally, all definitions formulated imply that information is material when its omission or misrepresentation can influence the economic decisions of the users that this concept aims to inform and benefit. Naturally, the definition of materiality varies according to the objective pursued by the reporting.[2]

There are two essential perspectives regarding what is relevant for corporate sustainability: that which protects shareholders and that which protects stakeholders. The former is based on the idea that a company is only responsible to its investors and should report on matters that may affect them; the latter advocates that reporting should concern the external impact that the company has or may have on stakeholders, those who have an interest in it, can be affected by it, or affect it (a similar orientation can translate into the need to consider environmental or social issues, for example).[3] The first conception can be associated with the concept of financial materiality (outside-in), which, according to the European Financial Reporting Advisory Group (EFRAG), considers the risks and opportunities for investors that a sustainability matter may entail; the second refers to impact materiality, which EFRAG defines as the impact a company may have on society or the environment regarding a particular issue (inside-out). Thus, the way legal instruments define materiality reveals a preference for one of the aforementioned philosophies.^[4]

The DMP, which represents the central concept of this study, encompasses both perspectives above, aligning their respective objectives. It arises from the idea that sustainability reporting becomes richer and more reliable when both financial materiality and impact materiality are taken into account. In this vein, it is necessary to address the CSRD Directive – where it has been established in a clear and binding manner – and its background.

The CSRD Directive: background and enshrinement of the DMP

In the 1990s, as Environmental, Social, and Governance (ESG) matters began to gain prominence, several developments emerged that introduced sustainability reporting standards. Thus, corporate sustainability reports began to be produced, albeit voluntarily, under the auspices of the Global Reporting Initiative (GRI – 1997), the Sustainability Accounting Standards Board (SASB), the Climate Disclosure Standards Board (CDSB), the International Sustainability Standards Board (ISSB), among other initiatives. The concept of materiality, as already mentioned, varies among instruments. For example, GRI focuses on impact materiality (inside-out), while ISSB standards refer to financial materiality (outside-in).[5]

In the EU regulatory sphere, it is important to first address the Accounting Directive, which harmonised the financial statements of EU companies’ management reports and was amended in 2014 by Directive NFRD,[6] which implemented, for a group of public-interest entities (broadly, listed companies with more than 500 employees), the obligation to also disclose non-financial information. It can be understood that a legislative trend began here towards considering corporate sustainability issues. However – and this was the justification for the new CSRD Directive[7] in 2022 (which amended the NFRD Directive) – the obligation provided for in the NFRD Directive fell short of expectations, as it allowed companies considerable discretion, not imposing explicit rules and processes to guide sustainability reports.[8]

The NFRD Directive aimed to introduce a sustainability reporting obligation for companies, through Article 19a, which was added to the Accounting Directive. However, the wording of the article (“information to the extent necessary for an understanding of the undertaking’s development, performance, position and impact of its activity”) leaves room for doubt regarding the concept of “impact.” In 2019, the Commission issued (non-binding) guidelines[9] that clarified this concept, defining it as the impact on society and the environment. It can be said that the NFRD Directive introduced a new perspective on materiality, clarified and formally identified as double materiality in the Commission’s guidelines[10] (as it required companies to report on both financial materiality and impact materiality). However, it lacked densification and enforceability. Essentially, it stipulated that companies should include in their management report sufficient information to understand the financial effects (on the company) and impact effects (on the external environment) of the listed sustainability matters, without imposing a standardized process or rules. And having nothing to report regarding the matters, companies would simply have to explain why – comply or explain.[11][12]

In this regard, given the lack of improvement in the reports produced under this Directive between 2014 and 2019[13] – and in line with the objectives arising from the “Action Plan: Financing Sustainable Growth”[14] (2018, updated in 2021) and the Green Deal (2019),[15] namely achieving climate neutrality by 2050 and, specifically here, “ensuring that across the EU, investors, insurers, companies, cities and citizens are able to access data and create tools to integrate climate change into their risk management practices”[16] – the need for a more efficient approach to non-financial reporting began to affirm itself. In December 2020, the European Parliament, through a Resolution on sustainable corporate governance, welcomed the Commission’s commitment to revise the Accounting Directive and affirmed the need to create a more demanding regime that mandates the disclosure of both financial and non-financial information. It demonstrated the objective to extend the obligation to include a wider range of companies and introducing mandatory auditing.[17]

Thus, alongside a movement towards harmonizing reporting standards at the international and EU levels,[18] in April 2021, a proposal to amend the NFRD Directive emerged, resulting in the adoption of the CSRD Directive in December 2022.

CSRD Directive: legal basis, implementation, scope, and objectives

The legal basis of the CSRD Directive rests on Articles 50 and 114 of the TFEU, which safeguard respect for freedom of establishment in the EU and the approximation of Member States’ legislation concerning the establishment and functioning of the internal market, taking into account the objectives set out in Article 26 of the TFEU. The latter defines the European Union’s internal market as a borderless economic area, based on the free movement of goods, services, persons, and capital, which presupposes measures to ensure the efficient functioning of the internal market by eliminating disparities between national regimes that could harm companies’ competitiveness. It is within this framework that the CSRD Directive emerges, whose main purpose is to harmonize and standardize the disclosure of ESG information, enhancing the quality and comparability of reported data. Recital 16 of the CSRD Directive emphasizes that the fragmentation of national rules harms comparability, justifying Union intervention to create standardizing rules. In this way, the CSRD Directive acts directly on the functioning of the internal market, promoting a level playing field and reducing information asymmetries, ensuring that investors, consumers, and stakeholders can make more informed economic decisions.[19]

This Directive was adopted with the purpose of expanding the scope of the NFRD and making obligations standardized, comparable, and audited. Thus, it unequivocally enshrines the DMP with well-defined reporting standards. It clearly imposes that companies must report how sustainability matters affect the company, the risks and opportunities they create (outside-in), and the extent to which the company’s activity affects the environment and society (inside-out).[20] The main innovations of the CSRD compared to the NFRD are as follows: it broadens its scope (more companies), follows detailed standards in sustainability reporting that use the DMP to define what should be reported, and creates an obligation for external audit of reports to ensure their reliability and comparability.[21]

What should be reported is detailed in Article 19a, paragraphs 1 to 3, of the CSRD, which can be summarized as the impacts a company may have on the environment and society, the risks and opportunities that sustainability issues may entail for the company, and the policies and incentive schemes for sustainability that it practices. However, the reporting obligations are described in greater detail in the European Sustainability Reporting Standards (ESRS), published by EFRAG.[22] The ESRS consist of 12 standards: the first two, general in nature, establish basic principles and define topics to be addressed regardless of their materiality. The remaining standards cover various aspects within ESG, defining sub-criteria for each of these topics that must be addressed if they are material.[23]

Implementation of the DMP under the CSRD Directive

It is important to understand how this materiality assessment operates. As indicated by EFRAG in its guidelines on the implementation of the CSRD Directive, the ESRS do not mandate a specific method of assessment. Since a single process would not serve all types of companies or economic activities with different characteristics, it encourages corporations to create a method that suits them and ensures the sufficiency of the required reporting.[24] Nevertheless, it offers a four-step model for assessment: 1) understanding the context; 2) identification of actual and potential IROs (impacts, risks, and opportunities) related to sustainability issues; 3) assessment and determination of material IROs; and 4) reporting. Step 1) consists of outlining the scope in which the company operates, its products, strategy, value chain, stakeholder interests, and the legal and regulatory framework in which the company is situated. In step 2), after establishing the “context,” it becomes easier to define which issues and topics are relevant. The essential here is to identify all ESG-related issues that are relevant, even if they are not part of the ESRS topics. This clarifies the purpose of producing reliable and useful information and a certain devotion to the DMP, as any ESG issue considered material (impact or financial) in the company’s context must be reported. There is a responsibility, on the part of companies, to identify important issues that the established topics do not expressly address.[25] In step 3), the selected issues identified as IRO are evaluated in order to determine whether they are material or not. The DMP requires the classification of any issue as material if it demonstrates materiality at either level (financial materiality or impact materiality). To determine this materiality, companies must establish quantitative or qualitative thresholds. For example, a quantitative threshold would be to define an issue as material if it affects more than 5% of annual profit, and a qualitative one would be to consider an issue as material if it is identified by more than 20% of stakeholders as concerning.[26][27]

Strengths and challenges in the implementation of the DMP

Subsequently, it is necessary to evaluate the DMP within the scope of sustainability reporting. The purpose is to identify the advantages and challenges resulting from its clear and prescriptive enshrinement in the CSRD Directive.

One of the advantages is the fight against greenwashing[28] and information overload. Voluntary reports, as they did not impose rules as clear as the CSRD Directive (and even some definition already indicated in the NFRD Directive), ended up allowing too much strategically chosen information to be disclosed, which led to a lack of clarity in reporting and greenwashing, as companies only reported information convenient to their reputation. This ultimately sabotaged the central purpose of producing truly useful reports for stakeholder decision-making.[29] As predicted by some authors in 2014, the best way to avoid this practice would be to compromise with greater transparency regarding what is considered material and why.[30] It can be concluded that, already in the NFRD Directive, and later with better-defined criteria in the CSRD Directive on how to assess materiality and explain that assessment, there has been progress in combating greenwashing.[31]

The DMP also demonstrates its virtue by adapting to different circumstances. Materiality is, naturally, dynamic, and it aims to identify information that, in a given period, for a given company, is sufficiently important to be reported. However, these circumstances are subject to change, and therefore their materiality may not be evident at one moment but may emerge at another. Thus, if materiality is defined in a regulatory instrument in an outside-in perspective, it may mean that, for example, stakeholders’ opinions regarding an environmental impact are not considered relevant unless they represent a risk or opportunity for the company. In this vein, the DMP represents an advancement compared to single materiality (whether financial or impact materiality), as it ensures that information is deemed material whether it is more relevant to shareholders or to stakeholders. It thus keeps pace with circumstances, without ignoring relevant changes in the opinion and behaviour of interested parties or investors. In this way, the DMP embraces the very dynamic essence of materiality, covering it in both matters of inside-out and outside-in impact.[32]

Regarding the challenges in applying the DMP specifically within the CSRD Directive, two main ones can be identified. The first results from the ambiguity and complexity of implementing double materiality. Although attempts have been made to clarify the procedure, such as the EFRAG guidelines, analysed earlier, the materiality assessment process remains largely non-homogeneous due to the lack of definition of this concept. This is particularly true for impact materiality, which requires considering different stakeholders – such as employees, customers, ecosystems – leading to the analysis of sometimes conflicting perspectives on what is or is not relevant.[33] The ambiguity of the concept, combined with the freedom companies have in assessing materiality, results in heterogeneous assessment processes, which can undermine the comparability of reports. In this regard, an analysis of the EURO STOXX 50 companies concluded that 34% of companies explained their materiality assessment process vaguely or unclearly, which also contributes to lower trust in its content among the report’s users.[34] The complexity of this assessment is a problem, as it requires extensive data collection. This involves having an organizational structure that collects, analyzes, and draws conclusions from a large volume of data, which not all companies possess. Faced with this burden, companies tend to report the minimum required (sometimes not the most relevant or essential), thus subverting one of the Directive’s purposes, which is to encourage companies to use these assessments as a work tool on internal aspects and to define business strategies in line with the principle of sustainability. Thus, it ends up becoming a purely compliance-driven process, with no value creation or strategy defining focus, which is not ideal. To address these issues, it is proposed to implement robust criteria for impact assessment and sector-specific processes that take into account the company’s branch of industry.[35]

The second challenge, already evidenced in the previous one, is the lack of data, in general, and particularly concerning the value chain. The difficulty in obtaining it becomes more obvious with regard to the value chain, whether in inbound logistics (suppliers) or outbound logistics (distributors), due to their extensive nature. As a solution, collaborative programs among suppliers are suggested, as they can to greater transparency in the value chain, and a phased approach to data collection, focusing initially, for example, on suppliers whose countries are referenced in social and environmental risk databases.[36]

DMP: Overview

As mentioned, the DMP represented innovation in sustainability reporting, first introduced in the NFRD Directive but enshrined in the CSRD Directive. Although the latter has already become applicable for the financial year of 2024 to a group of large companies (wave one), which had to report in 2025, it is not yet possible to draw deep conclusions about the specific use of the DMP in this context. However, it is pertinent to address some amendments that were proposed within the scope of the Omnibus I Package (February 2025). In 2024, the European Council, relying on reports by Enrico Letta and Mario Draghi, called for a priority on regulatory simplification, reinforced by the Budapest Declaration, which advocated for a clearer and smarter regulatory framework and a substantial reduction in administrative and reporting burdens, especially for small and medium-sized enterprises (SMEs). The Omnibus Package includes modifications to various EU legislative instruments on sustainability, including the CSRD Directive. It has already produced effects as it postponed the reporting obligation for smaller companies and made the ESRS criteria more flexible for wave 1 companies, so as not to oblige them, in the coming years, to report forecasts regarding the financial impacts of certain environmental risks.[37]

Meanwhile, in December 2025, the European Council and Parliament reached a political agreement on further simplification in these matters, in order to relieve companies of the unbearable burden that sustainability instruments may cause and which have already been identified. The scope of the CSRD Directive is expected to be reduced, applying only to companies representing a very considerable economic weight.[38] The amendments introduce a value chain cap, which limits information requests to companies in the value chain with up to 1000 employees, provide for the simplification of the ESRS (with expected adoption in 2026), and eliminate sector-specific obligations. This is relevant to the understanding of the DMP’s role, because, despite the flaws already found in the CSRD Directive, namely the excessively broad scope (which ended up covering companies without the preparation and capacity needed to conduct such detailed reporting), the complexity of the ESRS requirements, among others, the DMP remains untouched. It may even turn out, with these changes, that some of the issues associated with the DMP, such as the lack of definition, the complexity of the assessment, and the excessive burden of unnecessary data, are mitigated or prove to be less harmful as a result of these adjustments. This is because companies with less capacity will no longer be obliged to report, and the simplified ESRS requirements may contribute to a simpler materiality assessment or, at least, allow companies to focus only on the most important criteria.

Overall, the prevailing opinion on the DMP seems to be that it represents an added value, despite the difficulties it may entail, as beyond compliance, it also represents a company’s reflection on itself, which can contribute, if done correctly, to defining business strategies and positioning the company in a way that is beneficial for economic growth alongside the sustainability objectives that the EU aims to pursue.[39] Materiality is increasingly understood as a strategic concept, and its dual approach helps to meet the current demands and interests of investors and customers who, ever more, take sustainability issues into account in their decision-making processes.[40] The fact that companies report these issues from both an outside-in and an inside-out perspective reinforces stakeholder confidence once it contributes to the company’s transparency and accountability regarding environmental and social issues, which increases credibility and strengthens long-term relationships with investors, consumers, and regulators, who increasingly have a real perception of what a specific company represents and defends.

This view is demonstrated by companies and organizations that have already expressed their opinion that the EU should maintain this provision. A news report published in August 2025 shows that over 300 companies, investors, and organizations have approached the European Commission asking for the DMP provision to be maintained within the scope of the Omnibus amendments, arguing that it is essential for high-quality sustainability data.[41] The CEO of GRI, Robin Hodess, supported this initiative, stating that double materiality strengthens the EU’s competitiveness and allows for comparable and useful reporting for investors and other stakeholders.

As indicated above, these concerns have been addressed and recognized in the Omnibus I proposal, which does not mention the abandonment of the DMP. In this vein, the merits of this principle can be considered significant, despite the issues that may still require attention in the future.

Conclusion

The analysis carried out shows that the DMP represents a significant evolution in sustainability reporting, as it guarantees relevance to both the financial perspective (outside-in) and the impact perspective (inside-out). Its enshrinement in the CSRD Directive has clarified and standardized reporting criteria, ensuring greater comparability and transparency of ESG information. Despite the clear advantages, some challenges persist, such as the ambiguity of the principle, the complexity of the assessment process, the amount of data required, particularly in the value chain, and the heterogeneity of approaches among companies, which can compromise the comparability of reports.

The assessment of the principle’s implementation, taking into account the recent and planned amendments of the Omnibus I Package, indicates that, despite some practical problems, double materiality continues to be an added value. Despite proposing simplified requirements for smaller companies and adapting the ESRS, among other criteria, the amendments lead, ultimately to the reflection on the merits of the DMP as it is maintained intact. This positive assessment of the DMP is also reinforced by the opinions of several companies in the EU and by experts in the field who have advised maintaining this Principle in the Directive.

The DMP proves essential for guiding more informed economic decisions and promoting corporate responsibility. Thus, it can be concluded that the evolution of the concept of materiality to the DMP, with the CSRD, represents a positive development, although its implementation needs to be polished.

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[1] Directive 2013/34/EU of the European Parliament and of the Council of 26 June 2013.

[2] Måns Dunfjäll, “Materiality in transition: challenges and opportunities in corporate sustainability reporting under the CSRD,” European Journal of Risk Regulation 16, no. 3 (2025): 929, https://doi.org/10.1017/err.2025.10016.

[3] Dunfjäll, “Materiality in transition”, 932.

[4] Dunfjäll, “Materiality in transition”, 932-934.

[5] Christopher Nobes, “From no materiality to double materiality: a long-run conceptual analysis of corporate reporting regulation,” Accounting and Business Research 56, no. 1 (2026): 41–42. doi:10.1080/00014788.2025.2579303.

[6] Directive 2014/95/EU of the European Parliament and of the Council of 22 October 2014.

[7] Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022.

[8] Hélio Paiva Araújo, “Sustentabilidade e mercado financeiro na União Europeia: parâmetros e perspectivas de aplicação,” in Sustentabilidade, governança e integração regional em tempos de crise, ed. Jamile Bergamaschine Mata Diz et al. (Horizonte: Arraes Editora, 2020), 98–99.

[9] European Commission, Communication — Guidelines on Non-Financial Reporting: Supplement on Reporting Climate-Related Information, C/2019/4490, Official Journal of the European Union C 209 (June 20, 2019), accessed December 20, 2025, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52019XC0620(01).

[10] Małgorzata Macuda and Katarzyna Kobiela-Pionnier, “The double materiality principle and the sustainability reporting practices of Polish listed companies from the WIG30 Index,” The Theoretical Journal of Accounting 49, no. 2 (2025): 66, https://doi.org/10.5604/01.3001.0055.1487.

[11] Félix E. Mezzanotte, “Corporate sustainability reporting: double materiality, impacts, and legal risk.” Journal of Corporate Law Studies 23, no. 2 (2023): 638. doi:10.1080/14735970.2024.2319058.

[12] On the mentioned issues, see Mezzanotte, “Corporate Sustainability Reporting,” 636–38. Dunfjäll, “Materiality in Transition,” 934.

[13] Dunfjäll, “Materiality in Transition,” 934.

[14] Cf. European Commission, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions: Strategy for Financing the Transition to a Sustainable Economy, COM(2021) 390 final (Brussels, 2021), accessed December 20, 2025, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52021DC0390.

[15] Cf. recitals 1 and 2 of Directive (EU) 2022/2464 (CSRD).

[16] European Commission, Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions: The European Green Deal, COM(2019) 640 final (Brussels, 2019), 6, accessed December 20, 2025, https://eur-lex.europa.eu/legal-content/PT/ALL/?uri=CELEX:52019DC0640.

[17] Cf. recital 5 of Directive (EU) 2022/2464 (CSRD) and European Parliament, European Parliament Resolution of 17 December 2020 on the Implementation of the Return Directive (2019/2208(INI)), CELEX: 52020IP0362, December 17, 2020, accessed December 20, 2025.

[18] Cf. European Financial Reporting Advisory Group (EFRAG), Proposals for a Relevant and Dynamic EU Sustainability Reporting Standard-Setting: Final Report (2021), accessed December 20, 2025, https://finance.ec.europa.eu/document/download/23a44c64-c980-468c-ad15-ee2ea5e2e83f_en?filename=210308-report-efrag-sustainability-reporting-standard-setting_en.pdf.

[19] Tommaso Michieli, Corporate accountability for climate change in the EU: exploring the interaction and coherence of due diligence obligations (master’s thesis, University of Eastern Finland, 2025), 42–45, https://erepo.uef.fi/server/api/core/bitstreams/d7e10fd3-530f-41d5-9df3-62327d2ab5f8/content.

[20] Macuda e Kobiela-Pionnier, “The double materiality principle”, 64-65.

[21] Mezzanotte, “Corporate sustainability reporting”, 659.

[22] Dunfjäll. “Materiality in transition”, 935.

[23] Cf. PwC Portugal, “Diretiva de Reporte Corporativo de Sustentabilidade (CSRD),” accessed December 20, 2025, https://www.pwc.pt/pt/servicos/auditoria/servicos-sustentabilidade/reporting/csrd-diretiva-reporte-corporativo-sustentabilidade.html.

[24] Cf. EFRAG, EFRAG IG 1: Materiality Assessment Implementation Guidance (May 2024), accessed December 20, 2025, https://www.efrag.org/sites/default/files/sites/webpublishing/SiteAssets/IG%201%20Materiality%20Asse ssment_final.pdf, §§ 63–64.

[25] Cf. EFRAG. EFRAG IG 1, § 11.

[26] Dunfjäll. “Materiality in transition”, 938.

[27] Cf. EFRAG. EFRAG IG 1, pp. 19-25 e Dunfjäll. “Materiality in transition”, 935-938.

[28] Philip Förster, “The double materiality principle (Article 19a NFRD) as proposed by the Corporate Sustainability Reporting Directive: an effective concept to tackle green washing?” in European Yearbook of International Economic Law 2022, ed. Jelena Bäumler et al. (Heidelberg: Springer, 2022), 355, https://doi.org/10.1007/8165_2022_90.

[29] Josef Baumüller and Michaela-Maria Schaffhauser-Linzatti. “In search of materiality for nonfinancial information – reporting requirements of the Directive 2014/95/EU”, NachhaltigkeitsManagementForum 26 (2018): 102. doi:10.1007/s00550-018-0473-z.

[30] Robert G. Eccles and Michael P. Krzus, The integrated reporting movement: meaning, momentum, motives, and materiality (Hoboken: John Wiley & Sons, 2014).

[31] Förster, “The double materiality principle”, 355-357.

[32] Förster. “The double materiality principle”, 357-358.

[33] Dunfjäll. “Materiality in transition”, 938-939.

[34] Chiara Mio, Marisa Agostini e Francesco Scarpa. Sustainability reporting: conception, international approaches and double materiality in action (Cham: Palgrave Macmillan / Springer Nature, 2024), 140.

[35] Dunfjäll. “Materiality in transition”, 939-940.

[36] European Financial Reporting Advisory Group (EFRAG). State of Play as of Q2 2024: Implementation of European Sustainability Reporting Standards (ESRS) — Initial Observed Practices from Selected Companies. July 2024, accessed December 20, 2025, https://www.efrag.org/sites/default/files/media/document/2024-07/EFRAG_ESRS%20initial%20observed%20practices%20Q2%202024%20final%20version.pdf, 18.

[37] European Commission, “Corporate Sustainability Reporting,” Finance – European Commission, last modified December 9, 2025, accessed December 20, 2025, https://finance.ec.europa.eu/capital-markets-union-and-financial-markets/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en.

[38] European Union companies with more than 1,000 employees and a net annual turnover exceeding €450 million, as well as non-European groups exceeding €450 million in turnover in the EU and having at least one subsidiary or branch in the Union with turnover exceeding €200 million.

[39] EVEA Conseil, “Double materiality under the CSRD: understand, assess, act,” EVEA Conseil (blog), July 25, 2025, accessed December 20, 2025, https://evea-conseil.com/en/news/article/csrd-double-materiality-analysis.

[40] Cornis van der Lugt, María Andérez, and Matt MacFarland, “The State of Double Materiality in Corporate Reporting,” S&P Global Sustainable1, February 12, 2025, accessed December 20, 2025, https://www.spglobal.com/sustainable1/en/insights/special-editorial/double-materiality-is-gaining-traction-in-corporate-reporting.

[41] Gavin Hinks, “EU faces calls to retain ‘double materiality’,” Board Agenda, August 5, 2025, accessed December 20, 2025, https://boardagenda.com/2025/08/05/eu-faces-calls-to-retain-double-materiality/.

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