Materiality Assessment Process
Four Step Process
With the Omnibus consultations concluding, we now have clarity on the most efficient process for conducting a CSRD regulatory compliant double materiality process. We set this process out below, together with an optional step that some reporters find helpful. The whole process takes about 8 weeks.
Step 1 - Open source analysis

- Using our open source framework, Mettle analyses how your company is discussed across media, regulatory, investor and internal sources against ESRS taxonomy
- Peer group and industry is included for vital context
- Mettle calculates impact and financial materiality based on EFRAG criteria. This methodology has been validated with Big 4 assurance providers
- Mettle creates a draft 2x2 of the most relevant IROs for your business
Step 1b - Optional stakeholder input

- Mettle offers a simple AI chatbot tool to collect input from a wider group of stakeholders
- This replaces traditional stakeholder surveys with a more targeted approach
- This can run in parallel with the initial analysis or be used after the draft 2x2 to test and refine priorities
Step 2. Workshop

- Mettle runs a workshop with your nominated team to review the draft matrix
- Dives into the methodology and source data using Mettle's dashboard
- Any company-specific context is taken into consideration and the draft 2x2 matrix amended accordingly
- The CSRD reporting team has full visibility of the data and how the IROs were selected
Step 3. Management input

- The CSRD reporting team then bring in senior leadership to review, challenge or confirm the IROs.
- Mettle provides structure and materials for you to run this part internally.
Step 4. Finalisation and output

Once confirmed, Mettle generates the final 2x2 along with:
- Short narrative for each IRO
- Explanation of why it's included o List of relevant Disclosure Requirements (DRs) under ESRS or ISSB
- Structured documentation to support assurance or audit