What counts as a significant change that requires a DMA update?

The revised ESRS name three areas: the business, the value chain and the assessment methodology. In practice, typical triggers are acquisitions or divestments, new products, markets or geographies, major shifts in the supply chain, serious incidents, new regulation affecting the business model, new concerns raised by affected stakeholders, and changes to scoring scales, thresholds or the gross and net logic. This list is practical guidance, not legal text; the company has to judge and document what is significant in its own case.

Do we have to redo our DMA because of the revised ESRS?

Not automatically. There is no requirement to repeat a double materiality assessment just because the standards changed. But companies moving to the revised ESRS for FY2026 or FY2027 should review their existing assessment, in particular the gross vs. net treatment of potential impacts, positive impacts, the filter for non-material information, ESRS 2 judgements and whether top-down conclusions can replace disproportionate bottom-up scoring. If that review changes the methodology, the affected parts must be updated.

What do you have to disclose about updating the double materiality assessment?

ESRS 2 IRO-1 asks for a concise description of the assessment process, significant changes to it compared with the previous period and when the assessment was last updated. Boilerplate should be avoided. In practice, this means stating the date of the last update, what triggered it and which topics or IROs changed, or explaining briefly why no significant changes occurred.

How long does an annual review of a double materiality assessment take?

As a rough practice value, not a regulatory figure: a light review without significant changes takes a few person-days, a partial update of individual topics two to four weeks, and a full redo of a CSRD double materiality assessment around six to ten weeks with a structured tool. Spreadsheet-based or consultant-led projects often take longer. The effort depends mostly on how well last year's assessment was documented.

Which tools help run a continuous double materiality assessment?

A continuous DMA needs one place where IROs, scores, thresholds, stakeholder links, evidence and comments are kept together, plus an audit trail that shows who changed what and when. Spreadsheets can work for a one-off assessment but make year-on-year changes hard to trace. Specialised software such as Materiality Master keeps this record in one assessment, lets you duplicate last year's assessment as the starting point for the new reporting year and transfer an assessment built under the 2023 ESRS into the revised topic structure; its annual plan (€2,499 per year) includes unlimited assessments and users.

Double Materiality Assessment Update: Every Year? (2026)

Q: Do you have to repeat your double materiality assessment every year?

No. Under the revised ESRS (ESRS 1 paragraph 34), a company must consider at each reporting date whether significant changes have occurred in its business, its value chain or its assessment methodology, and update the double materiality assessment only if they have. What is required every year is the check itself. ESRS 2 IRO-1 also asks companies to disclose when the assessment was last updated and to avoid boilerplate descriptions.

Your first double materiality assessment (DMA) probably took months: workshops, long IRO lists, stakeholder interviews, scoring debates and an auditor who wanted to see every step. Now the next reporting cycle is coming, and the obvious question is whether you have to do it all again. For wave-one CSRD reporters preparing FY2026 and FY2027 reports, and for companies that ran a voluntary DMA in 2024 or 2025, the revised ESRS give a clear answer.

In short: You do not have to repeat your double materiality assessment every year. Under the revised ESRS, you have to consider at each reporting date whether significant changes have occurred in your business, value chain or assessment methodology, and update the DMA only if they have (ESRS 1 §34). ESRS 2 IRO-1 asks you to disclose when you last updated the assessment and to avoid boilerplate. So the annual task is a documented review, not a full redo. Companies moving to the revised ESRS (optional for FY2026, mandatory from FY2027) should additionally check their existing DMA against five points: gross vs. net, positive impacts, the information filter, ESRS 2 and top-down conclusions.

This article explains what the rules require, which events typically count as significant changes, how to organise a proportionate annual review, how to migrate a 2024/25 assessment to the revised ESRS and what a "continuous" DMA looks like in practice. If you are new to the topic, start with our overview of the materiality assessment or the step-by-step guide to the CSRD double materiality assessment.

Do you have to repeat your double materiality assessment every year?

No. The 2023 ESRS did not explicitly regulate updates, which led many companies to assume an annual full re-run was expected. The revised ESRS, adopted as Delegated Regulation (EU) 2026/1563, close that gap:

Rule	What it says	What it means for you
ESRS 1 §34	At each reporting date, consider whether significant changes have occurred (business, value chain, methodology); update the DMA only if they have	An annual check is mandatory, an annual redo is not
ESRS 2 IRO-1	Concise description of the process, significant changes to it and when the assessment was last updated; avoid boilerplate	The date of your last update and what changed become part of the disclosure
2023 ESRS	Updates not explicitly regulated	The new rule is a relief for wave-one reporters

KPMG summarises it as: annual updates are not needed unless circumstances or management judgement warrant them. The key word in §34 is consider. You still have to look, decide and be able to show that you looked. A sustainability statement that simply repeats last year's DMA without any evidence of a review is exactly the kind of boilerplate IRO-1 warns against. We show what a good IRO-1 text looks like in our ESRS 2 IRO-1 disclosure example.

Which rules apply in FY2026 and FY2027?

The revised ESRS were published in the Official Journal on 21 September 2026 and enter into force on 10 November 2026. The timing matters for your next update:

Financial year	Options	Effect on your DMA update
FY2026	2023 ESRS, revised ESRS in full, or 2023 ESRS with eight reliefs (incl. the top-down DMA approach and the undue cost or effort and value chain reliefs)	You choose; the option must be stated in the sustainability statement
FY2027 onwards	Revised ESRS mandatory for all companies in scope	At the latest now, your DMA must work under the revised rules

Two further reliefs are directly relevant to updates. Acquisitions can be left out of the DMA and the sustainability statement for one year, so a deal closed late in the year does not force an immediate re-assessment. And if you conclude that climate change is not material, IRO-2 §37(b) now only requires the basis for that conclusion, no longer the detailed forward-looking analysis demanded in 2023. All other changes are explained in our article on the double materiality assessment under the revised ESRS.

What counts as a "significant change"?

The revised ESRS name the three areas (business, value chain, methodology) but do not define a list of triggers. The following checklist is practical guidance from assessment practice, not legal text. Use it as a screening tool at each reporting date and document your conclusion for every line.

Trigger	Examples	Typical consequence
Mergers, acquisitions, divestments	New subsidiary, sale of a business unit	Assess the affected activities (note the one-year relief for acquisitions)
New products, markets or geographies	Entry into a high-risk sourcing country, new product line	Add or rescore IROs for the affected topics
Supply chain shifts	New key raw material, switch of main suppliers, nearshoring	Review value chain IROs; sector or regional data are acceptable (§33)
Major incidents	Serious accident, environmental incident, human rights allegation	Reassess severity and likelihood of related IROs
Regulatory changes	New regulation affecting your business model, carbon pricing, product rules	Reassess financial risks and opportunities
Stakeholder concerns	New concerns raised via grievance mechanisms, works council, NGOs or customers	Check whether new IROs or new evidence exist (due diligence engagement is sufficient, §42)
Methodology changes	New scoring scales or thresholds, switch to the revised ESRS gross and net logic, top-down instead of bottom-up	Update the affected parts and disclose the change under IRO-1

If none of these applies, the result of your review is "no significant changes", and that is a perfectly valid outcome, as long as it is documented. Changing thresholds is a methodology change in its own right; our article on materiality thresholds explains how to set and justify them.

A practical annual review process

A proportionate annual cycle has three possible outcomes. Decide which one applies after the trigger screening, not before.

Level	When it applies	What you do	Rough effort*
Light review	No significant changes	Run the trigger checklist, confirm material topics and thresholds, update evidence, record the conclusion and the date	A few person-days
Partial update	Significant changes in individual topics, or migration to the revised ESRS	Rescore or add the affected IROs, re-apply thresholds, update stakeholder input where needed, sign-off	About 2 to 4 weeks
Full redo	Fundamental change of business model, large merger, or a first DMA that is not defensible	New assessment from context analysis to sign-off	About 6 to 10 weeks with a structured tool, often longer with spreadsheets or consultants

*Rough practice values for a mid-sized CSRD reporter, not regulatory figures. Effort depends mainly on how well the previous assessment was documented.

For most wave-one companies, the realistic pattern is: partial update in the year they move to the revised ESRS, light reviews in the following years, and a full redo only when the business changes fundamentally.

A light review or partial update typically runs through these steps:

Collect change signals from strategy, M&A, risk management, procurement, incident reports and grievance mechanisms.
Screen against the trigger checklist and decide the review level.
Update the affected IROs: descriptions, scores, time horizons, value chain stage, evidence.
Re-apply your thresholds and check whether any topic moves above or below the line.
Get management sign-off on the result.
Update your IRO-1 disclosure: date of the last update, what triggered it, what changed, or why nothing significant changed.
Check the datapoint mapping if a material topic was added or dropped.

What to document for the auditor

Under limited assurance, your auditor will want to see that the §34 consideration actually took place. Keep at least:

The completed trigger checklist with a short rationale per line, dated and signed off.
A change log of IROs, scores and thresholds compared with the previous year (previous value, new value, who, when, why).
Evidence for new or changed assessments (documents, data, stakeholder input).
The management approval of the updated result.
The IRO-1 text referencing the date of the last update.

Our DMA audit checklist covers the full list of what auditors check.

Moving a 2024/25 DMA to the revised ESRS

If your existing assessment was built on the 2023 ESRS, either as a wave-one reporter or as a voluntary DMA, these are the concrete migration steps. Most of them change the methodology, so expect a partial update in the migration year.

Choose your FY2026 basis. Decide between the 2023 ESRS, the revised ESRS in full, or the 2023 ESRS with reliefs, and state it in the sustainability statement. From FY2027 the revised ESRS apply.
Map your topics to Appendix A. The topic list moved from ESRS 1 AR 16 to Appendix A and is now non-binding guidance. E3 is now called "Water", marine resources moved to E5, and sub-sub-topics are gone: fold your sub-sub-topic IROs into the relevant sub-topics. You no longer have to document a conclusion for every line. Our ESRS topics list 2026 shows the new structure. In Materiality Master, you can transfer an existing 2023-ESRS assessment into this structure and then work through the remaining steps.
Rescore gross vs. net (§43). Potential negative impacts may only be reduced by prevention and mitigation actions that are already implemented and can reasonably be assumed to be effective. Actual impacts are assessed as they manifested: mitigation from previous periods counts, remediation during the reporting period does not. Any IRO scored net of planned measures needs a new score.
Separate positive impacts (§44). Assess positive impacts on their own, without netting against negative ones. Remove "positive impacts" that are only remediation of your own negative impacts or compliance with the law.
Simplify where the outcome is evident. Replace disproportionate bottom-up scoring of obviously material or obviously immaterial topics with a documented top-down conclusion (§27). Keep the detailed assessment where the outcome is not evident (§28). You are not required to assess every possible IRO (§32).
Apply the information filter (§24). You "shall not disclose" information that is not material. Drop such content, or label it clearly as supplementary information (§§107–108).
Revisit ESRS 2 judgements. ESRS 2 disclosure requirements are now "likely to result in material information for all undertakings".
Restructure your disclosures. IRO-1 describes the process, significant changes and the date of the last update; the description of your material IROs now sits in IRO-2, while SBM-3 focuses on their interaction with strategy, business model and financial effects.
Re-map your datapoints. Material topics determine which datapoints you report under EFRAG's 2026 draft datapoint list (359 datapoints instead of 1,144 in the 2024 IG 3 list).

What a "continuous" double materiality assessment means

A continuous DMA is not a DMA that is redone all the time. It is an assessment that is carried forward from year to year instead of being rebuilt as a project every year: the IROs, scores, thresholds, stakeholder input and evidence stay in one place, and each year you change only what changed. That is exactly the logic of §34, and it is where most of the time savings are. Teams that say "our DMA takes forever" usually lose the time on reconstructing last year's reasoning from scattered spreadsheets, emails and slide decks, not on the assessment itself.

In Materiality Master, a continuous DMA works like this:

All IROs in one structured assessment. IROs with their descriptions, impact type, value chain stage, time horizon, scale and probability live in one assessment, structured along the revised ESRS topic list.
Duplicate last year's assessment. Copy last year's DMA as the starting point for the new reporting year and change only what changed. The original stays as the record of the previous year.
Transfer a 2023-ESRS DMA to the revised ESRS. An assessment built under the 2023 ESRS can be transferred into the revised topic structure (Appendix A: E3 "Water", marine resources under E5, no sub-sub-topics). After the transfer, review the scores for gross vs. net (§43), positive impacts (§44) and the information filter (§24), as described in the migration steps above.
Thresholds per IRO type are set in the assessment settings and documented in one place (how thresholds work).
Stakeholders linked to IROs, so you can show whose input informed which judgement.
Evidence linked to each IRO via document links; the files stay in your own storage. Comments capture the reasoning behind changes.
An audit trail logs who changed what and when, with previous and new values. In a light review or partial update, that log is your year-on-year change record for the auditor.
Once the material topics are confirmed, the Datapoints Mapping Tool translates them into the revised ESRS datapoints.

Duplicate last year's DMA and move it to the revised ESRS

Copy last year's assessment as the starting point for the new reporting year, transfer a 2023-ESRS assessment into the revised topic structure and change only what changed. The audit trail shows your auditor what changed and when.

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Key takeaways

No automatic annual repeat: revised ESRS 1 §34 requires a review at each reporting date and an update only if significant changes occurred in the business, the value chain or the methodology.
Disclose the date of your last update under ESRS 2 IRO-1 and avoid boilerplate.
Use a trigger checklist (practical guidance, not legal text) and choose between light review, partial update and full redo.
The migration year to the revised ESRS usually means a partial update: Appendix A structure, gross vs. net, positive impacts, information filter, IRO-2 and SBM-3.
A continuous DMA starts from a copy of last year's assessment and keeps everything in one place, so each cycle only touches what changed.

Running your DMA every year, for several entities or for several clients? The Materiality Master annual plan (€2,499 per year) includes unlimited assessments and users. Compare all plans on our pricing page or try the app for free.