Most guides explain what a double materiality assessment (DMA) is. This one shows you what a finished one looks like. Below we walk through a complete, realistic double materiality assessment example for a fictional mid-sized manufacturer — from the value chain map to scored impacts, risks and opportunities (IROs), thresholds, the materiality matrix and, finally, the ESRS datapoints the company has to report.
In short: A double materiality assessment follows six steps: (1) understand the business and value chain, (2) identify affected stakeholders and users, (3) build a long list of IROs, (4) score impacts on severity and likelihood and risks/opportunities on financial magnitude and likelihood, (5) apply thresholds to decide what is material, and (6) document the result and map it to ESRS disclosures. In the example below, 5 of 10 ESRS topics turn out to be material.
If you are new to the concept itself, start with our step-by-step guide to the CSRD double materiality assessment and come back here for the practical application. The example reflects the revised ESRS adopted in 2026, which keep the double materiality principle but give companies more flexibility in how they run the process.
The example company: PumpTec GmbH
All numbers and findings are illustrative. PumpTec is a composite of the kind of companies we work with every day:
| Characteristic | PumpTec GmbH (fictional) |
|---|---|
| Business | Develops and manufactures industrial pumps for water utilities, energy and chemicals |
| Size | 1,450 employees, €540 million net turnover |
| Own operations | Headquarters and two plants in Germany (machining, assembly), one foundry in Czechia |
| Upstream | Steel and cast-iron suppliers (EU and Asia), electric motors, electronics |
| Downstream | Distributors in 40 countries, direct sales to utilities via public tenders, service and spare parts |
| Reporting status | In scope of the CSRD after the Omnibus simplification (above 1,000 employees and €450 million turnover) |
PumpTec's sustainability manager runs the assessment with a core team of four (sustainability, finance, HR, procurement) and reports to the CFO. The full assessment takes about six weeks.
Step 1: Understand the business context and value chain
Before anyone talks about "topics", the team maps where value is created and where sustainability matters could arise. This is the step most often skipped — and the one auditors ask about first.
PumpTec's team collects existing material first: the strategy paper, the risk register, supplier spend data, HSE incident statistics, customer and investor questionnaires, and the previous non-financial report. (Our DMA document checklist lists everything worth gathering at this stage.)
The value chain map looks like this:
- Upstream: steel and cast-iron production (energy- and emission-intensive), castings from Asian suppliers, electric motors containing copper and rare-earth magnets.
- Own operations: a foundry (heat, noise, heavy lifting), CNC machining, painting lines, assembly and testing.
- Downstream: pumps run for 15–25 years at customer sites; electricity consumption in the use phase dwarfs manufacturing emissions. Sales partly via public tenders in markets with elevated corruption risk.
Output of step 1: a one-page value chain map with the main activities, locations, business relationships and the data sources used — which later becomes part of the documentation of the process.
Step 2: Identify affected stakeholders and users of the report
The ESRS distinguish two groups: affected stakeholders, whose interests are or could be affected by the company, and users of sustainability statements, such as investors, lenders and business partners. PumpTec engages both, proportionately:
| Stakeholder group | Type | How PumpTec engaged them |
|---|---|---|
| Own employees and works council | Affected | Two workshops at the plants, works council interview |
| Supplier workers (castings, Asia) | Affected | Proxy: NGO reports, supplier audit results, interview with an industry initiative |
| Utilities and industrial customers | User / affected | Analysis of tender requirements and customer questionnaires |
| Banks and investors | User | Interview with the house bank, review of ESG data requests |
| Local communities around the foundry | Affected | Complaints log, conversation with the municipality |
For potentially vulnerable groups that cannot be engaged directly — like supplier workers — credible proxies are legitimate. Our article on stakeholder analysis in double materiality explains how to prioritise and engage each group, and the help article on conducting a stakeholder assessment in Materiality Master shows how to record it.
Step 3: Build the long list of impacts, risks and opportunities
Next, the team builds a long list of IROs. The ESRS topical standards (E1–E5, S1–S4, G1) serve as a checklist so nothing obvious is missed, complemented by sector sources and the inputs from steps 1 and 2. Each IRO is described as a concrete statement, not a topic label. If the difference between impacts, risks and opportunities is new to you, read our explainer on IROs under the CSRD first.
An extract from PumpTec's long list (the full list contained 34 IROs):
| ESRS topic | IRO | Type | Value chain |
|---|---|---|---|
| E1 Climate change | (1) GHG emissions from purchased steel and castings and from energy use in the foundry | Negative impact, actual | Upstream, own ops |
| E1 Climate change | (2) Energy-efficient pumps reduce customers' electricity consumption | Positive impact, actual | Downstream |
| E1 Climate change | (3) Rising carbon costs on steel inputs (EU ETS, CBAM) | Risk (medium term) | Upstream |
| E1 Climate change | (4) Growing demand for high-efficiency pumps driven by energy regulation | Opportunity (short to medium term) | Downstream |
| E2 Pollution | (5) VOC emissions from painting lines | Negative impact, actual | Own ops |
| E5 Resource use and circular economy | (6) Consumption of virgin steel and limited take-back of end-of-life pumps | Negative impact, actual | Upstream, downstream |
| E5 Resource use and circular economy | (7) Steel and copper price volatility | Risk (short term) | Upstream |
| S1 Own workforce | (8) Serious injuries in foundry and machining | Negative impact, potential | Own ops |
| S1 Own workforce | (9) Shortage of skilled machinists and engineers | Risk (medium term) | Own ops |
| S2 Workers in the value chain | (10) Forced or excessive overtime at Asian castings suppliers | Negative impact, potential | Upstream |
| G1 Business conduct | (11) Bribery in public tenders via distributors | Negative impact, potential | Downstream |
| G1 Business conduct | (12) Fines and exclusion from tenders after a corruption case | Risk (medium term) | Downstream |
Top-down where it is obvious. The revised ESRS allow a company to conclude on a topic's materiality without IRO-level scoring when the outcome is evident from its business model, sectors and value chain (ESRS 1 §27), and they do not require an exhaustive search for every possible IRO (§32). PumpTec uses this for biodiversity and affected communities — no plant is near a protected area, and there are no relevant community grievances — and documents the reasoning in two short paragraphs. The bottom-up scoring below focuses on the topics where the answer is not obvious.
Note how one topic can carry several IROs of different types. Climate change alone produces a negative impact, a positive impact, a risk and an opportunity — which is exactly why rating a topic as "high/medium/low" is not enough.
Step 4: Score impacts and financial effects
PumpTec defines its scoring methodology before rating anything and has it approved by the CFO. This sequence matters: auditors want to see that thresholds were not tuned after the results were known.
Impact materiality scoring
Each impact is rated on a 1–5 scale:
- Scale — how grave the impact is (or how beneficial, for positive impacts)
- Scope — how widespread it is (number of people, size of area)
- Irremediable character — how hard it is to reverse (negative impacts only)
- Likelihood — for potential impacts only
Severity is the average of scale, scope and irremediable character. For actual impacts, the impact score equals severity. For potential impacts, the score is the average of severity and likelihood — except for potential human rights impacts, where severity takes precedence over likelihood, as ESRS 1 §40 requires. PumpTec applies this by using the severity score alone whenever it is 4.0 or higher.
Gross or net? Following ESRS 1 §43, PumpTec scores actual impacts as they actually occurred, and reduces potential impacts only for prevention measures that are already implemented and effective — not for measures that are merely planned. The foundry's certified safety management system counts; the supplier audit programme that starts next year does not.
Financial materiality scoring
Each risk and opportunity is rated on:
- Magnitude — potential effect on cash flows, financial position, cost of capital or access to finance (1 = less than €0.5m, 5 = more than €15m EBIT impact, calibrated to PumpTec's financial risk management scales)
- Likelihood — probability of occurrence within the relevant time horizon (1 = remote, 5 = virtually certain)
The financial score is the average of magnitude and likelihood. Using the same scales as the enterprise risk management system is a deliberate choice: it connects the DMA to existing governance and makes the results easier to defend.
The scores
Impact materiality scores
| IRO | Scale | Scope | Irremed. | Likelihood | Score |
|---|---|---|---|---|---|
| (1) GHG emissions (steel, foundry) | 4 | 4 | 4 | actual | 4.0 |
| (2) Efficient pumps cut customer electricity use | 3 | 4 | – | actual | 3.5 |
| (5) VOC emissions from painting | 2 | 2 | 2 | actual | 2.0 |
| (6) Virgin steel use, limited take-back | 3 | 3 | 3 | actual | 3.0 |
| (8) Serious injuries (foundry, machining) | 4 | 2 | 4 | 4 | 3.7 |
| (10) Forced/excessive overtime at suppliers | 5 | 4 | 5 | 2 | 4.7 ¹ |
| (11) Bribery in public tenders | 3 | 2 | 2 | 2 | 2.2 |
¹ Potential human rights impact: severity (4.7) takes precedence over the low likelihood.
Financial materiality scores
| IRO | Magnitude | Likelihood | Score |
|---|---|---|---|
| (3) Carbon costs on steel inputs | 4 | 4 | 4.0 |
| (4) Demand for high-efficiency pumps | 4 | 3 | 3.5 |
| (7) Steel and copper price volatility | 3 | 4 | 3.5 |
| (9) Shortage of skilled workers | 3 | 4 | 3.5 |
| (12) Fines and tender exclusion | 4 | 2 | 3.0 |
Step 5: Apply thresholds and decide what is material
PumpTec sets a threshold of 3.0 for both dimensions. A sustainability matter is material if at least one IRO passes the impact threshold or the financial threshold. Aggregated per ESRS topic (highest IRO score per dimension), the result is:
| ESRS topic | Impact score | Financial score | Material? |
|---|---|---|---|
| E1 Climate change | 4.0 | 4.0 | ✅ Both dimensions |
| E2 Pollution | 2.0 | 1.5 | ❌ |
| E3 Water | 1.7 | 1.3 | ❌ |
| E4 Biodiversity and ecosystems | – | – | ❌ Top-down conclusion |
| E5 Resource use and circular economy | 3.0 | 3.5 | ✅ Both dimensions |
| S1 Own workforce | 3.7 | 3.5 | ✅ Both dimensions |
| S2 Workers in the value chain | 4.7 | 2.5 | ✅ Impact only |
| S3 Affected communities | – | – | ❌ Top-down conclusion |
| S4 Consumers and end-users | 2.0 | 2.0 | ❌ |
| G1 Business conduct | 2.2 | 3.0 | ✅ Financial only |
Two results deserve attention:
- S2 Workers in the value chain is material on impact grounds alone. A purely financial ("outside-in") view — such as the ISSB approach — would have missed it.
- G1 Business conduct is material only from the financial perspective: the bribery impact itself scores below the threshold, but the financial consequences of a case would be significant.
Borderline results (E5 sits exactly on 3.0) are discussed in a calibration workshop, and the reasoning is documented. Thresholds are a judgement call that you have to justify — our help article on adjusting thresholds in a materiality assessment shows how to configure and document them.
The materiality matrix
PumpTec visualises the result in a matrix — impact materiality on the vertical axis, financial materiality on the horizontal axis, the 3.0 thresholds as dividing lines. The two topics concluded top-down (E4, S3) have no scores and are therefore not plotted:
A matrix is not mandatory under the ESRS, but management boards like it — and it makes the "impact only" and "financial only" topics immediately visible.
Want to run this assessment in software instead of spreadsheets?
Materiality Master guides you through every step of this example — stakeholders, IROs, scoring, thresholds, the matrix and the audit trail. Book a free demo and see it with your own data.
Book a DemoStep 6: Validate, document and map to ESRS datapoints
Validation and approval
The results go through three checks: a plausibility review against the risk register and peer reports, a validation round with the works council and the house bank, and formal approval by the management board. Every change to a score after the first rating round is recorded with a reason — in Materiality Master the audit trail does this automatically.
Documentation for the auditor
The sustainability statement has to describe the process (ESRS 2 IRO-1), the material IROs (ESRS 2 IRO-2) and how they interact with the strategy and business model (ESRS 2 SBM-3). PumpTec's audit file therefore contains: the value chain map, the stakeholder engagement log, the full IRO long list, the scoring methodology with its approval, the scored results, the threshold rationale and the board approval.
From material topics to datapoints
Only now does the reporting work begin. PumpTec's five material topics determine which disclosure requirements apply — and, with the revised ESRS, the number of datapoints is much smaller than under the 2023 standards. Our article on EFRAG's 2026 draft list of ESRS datapoints explains what changed.
To translate material topics into a concrete datapoint list, PumpTec uses the ESRS Data Points Mapping Tool, which returns the relevant datapoints for each material topic — mandatory or conditional, with guidance on what data to collect. You can also browse every datapoint yourself in the free ESRS Datapoint Explorer.
Five mistakes this example avoids
- Rating topics instead of IROs. "Climate change: high" says nothing. PumpTec rated 34 specific IROs and aggregated afterwards.
- Ignoring the value chain. PumpTec's two most severe impacts (steel emissions and supplier labour conditions) sit upstream — not in its own plants.
- Setting thresholds after scoring. The methodology was approved before the first rating.
- Netting out human rights impacts with low likelihood. Severity prevails for potential human rights impacts.
- Treating the DMA as a one-off. PumpTec reviews the assessment annually and re-runs it when the business changes — for example after an acquisition.
How long does a double materiality assessment like this take?
For a company of PumpTec's size and complexity, six to ten weeks is realistic with a structured tool; spreadsheet-based projects often take three to six months because versions, comments and evidence end up scattered across files. (We compared both approaches in why software beats Excel for materiality assessments.) AI can shorten the long-list phase considerably — see how AI is transforming double materiality assessments.
Key takeaways
- A double materiality assessment example is most useful when it shows IRO-level scoring, not just a matrix.
- Score impacts on severity (scale, scope, irremediable character) and likelihood; score risks and opportunities on financial magnitude and likelihood.
- For potential human rights impacts, severity takes precedence over likelihood.
- A topic is material if it passes either threshold — impact-only and financial-only topics are both reported.
- Define and approve the methodology and thresholds before scoring, and document every step for the auditor.
- Use the result to scope your reporting: map material topics to ESRS datapoints with the ESRS Data Points Mapping Tool.
Ready to run your own? Materiality Master gives you this exact workflow — from stakeholder mapping to the matrix and datapoints — in one place. See the plans and pricing.
