CSRDQuestion bankESRS

CSRD and ESRS Double Materiality Interview Question Bank

Use these prompts to run evidence-focused interviews for an ESRS materiality assessment across own operations, upstream value chain, and downstream value chain.

The questions are based on ESRS double materiality concepts: impacts, risks and opportunities, affected stakeholders, value-chain scope, impact severity, financial effects, thresholds, and reportable evidence.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

This question bank helps sustainability, finance, risk, legal, procurement, operations, and assurance teams collect evidence for an ESRS . It does not replace the undertaking's judgement. Record the ESRS edition used: the Commission adopted revised ESRS on 3 July 2026. Check Official Journal publication, entry into force, and the act's reporting-year application provisions before using them; the adoption announcement alone does not establish the applicable edition. Use the questions to surface facts, affected stakeholder views, value-chain hotspots, financial dependencies, assumptions, thresholds, and open evidence gaps before deciding which impacts, risks and opportunities (IROs) are material.

Section 1

How to run the interviews

Structure interviews around the ESRS materiality assessment purpose: understand the undertaking's context, identify actual and potential impacts, risks and opportunities, assess materiality, and prepare disclosures about the process and outcome.

Each answer should identify the business activity, geography, value-chain location, affected stakeholder or user group, evidence source, uncertainty, and proposed follow-up. Treat unsupported assertions as leads to investigate, not as final materiality conclusions.

  • Start with business model and value-chain context: activities, products and services, geographies, business relationships, upstream actors, downstream actors, and known external trends.
  • Use affected-stakeholder interviews to understand actual and potential impacts on people and the environment, including severity, likelihood, time horizon, and whether the matter differs by site, country, product, or supplier group.
  • Use finance, risk, treasury, investor relations, and commercial interviews to test whether sustainability matters create risks or opportunities that could affect performance, position, cash flows, access to finance, or cost of capital.
  • Record the assessment threshold being tested, the evidence offered, the data gap if evidence is incomplete, and whether the answer supports impact materiality, financial materiality, both, or neither.
  • Record the ESRS legal version and reporting year so later changes to topic lists, disclosure references, or reliefs do not alter the interview record silently.
  • Avoid asking interviewees to vote on whether an ESRS topic is material without first asking for the underlying impact, risk, opportunity, dependency, value-chain connection, and evidence.
Section 2

Context and value-chain questions

Use these questions before scoring. ESRS materiality work needs the undertaking's own operations and upstream and downstream value chain, but it does not require equal depth for every actor. The interview should identify where material IROs are likely to arise.

Ask for concrete examples, documents, systems, contracts, complaints, incident data, supplier information, customer-use information, and external evidence that can be tested after the interview.

  • Which activities, products, services, geographies, and business relationships create the largest sustainability exposure for this part of the business?
  • Where do the most important upstream inputs, suppliers, outsourced services, financing relationships, or raw materials sit in the value chain?
  • Which downstream uses, customers, distributors, end users, waste streams, or end-of-life routes could create impacts or dependencies?
  • Which value-chain actors are linked to known hotspots because of geography, sector, worker profile, resource use, emissions, pollution, communities, product safety, or waste?
  • Which business relationships are indirect but still connected to the undertaking's products, services, operations, or investments?
  • What evidence shows whether the matter is limited to own operations, upstream value chain, downstream value chain, or several of those locations?
  • Where does the undertaking have limited data or limited ability to influence the actor, and what estimates, proxies, supplier records, or external sources could still support the assessment?
Section 3

Impact materiality questions

Impact materiality interviews should find actual and potential impacts on people or the environment. For negative impacts, ask for facts that help assess severity; for potential negative impacts, also ask about likelihood and time horizon.

Stakeholder input is useful because affected stakeholders can explain how they are or could be affected. The interview record should distinguish what the stakeholder experienced, what the undertaking inferred, and what still needs corroboration.

In these questions, scale means how grave a negative impact is or how beneficial a positive impact is. Scope means how widespread it is, such as the number of people affected or the geographical extent of environmental damage. Irremediable character means whether, and to what extent, affected people or the environment can be restored to their prior state.

  • Who is affected or could be affected by the activity, product, service, site, supplier, customer use, or business relationship?
  • Is the impact actual, potential, positive, negative, or a mix? What happened, what could happen, and over what time horizon?
  • For a negative impact, what does the evidence show about scale, scope, and irremediable character?
  • For a potential negative impact, what evidence supports the likelihood assessment, and is there a severe human-rights dimension that should not be downplayed by low probability alone?
  • For a positive impact, what evidence supports scale and scope, and for potential positive impacts what supports likelihood?
  • Does the matter differ by country, site, subsidiary, worker group, community, customer group, or value-chain tier in a way that aggregation would obscure?
  • Which grievance records, incident data, audits, worker or community input, scientific evidence, media reports, peer information, or due-diligence findings support or challenge the interviewee's view?
  • Could an action taken to address one sustainability matter create a material negative impact or material risk in another matter?
Section 4

Financial materiality questions

Financial materiality interviews should test how sustainability matters may affect the undertaking, including through dependencies, transition effects, physical effects, regulation, market access, customers, suppliers, financing, insurance, and cost of capital.

The strongest answers connect a sustainability matter to a risk or opportunity, then to likelihood, potential magnitude, time horizon, affected financial line or business driver, and the evidence used by management.

  • Which sustainability-related dependencies are important to the business model, such as natural resources, human resources, social relationships, suppliers, permits, infrastructure, or customer trust?
  • Could this matter reasonably affect revenue, margin, operating costs, capital expenditure, asset values, provisions, cash flows, access to finance, insurance, or cost of capital?
  • Which business plans, budgets, risk registers, impairment analyses, supplier strategies, customer contracts, lending discussions, or investor questions already reflect this matter?
  • Is the financial effect current, expected, contingent, or plausible but not yet quantified? What evidence supports that view?
  • What likelihood and magnitude thresholds are being applied, and are they consistent with how sustainability risks are discussed internally?
  • Could an impact identified in the impact-materiality interview become financially material over the short, medium, or long term?
  • Are there sustainability risks or opportunities that are financially material even though they do not arise from the undertaking's own impacts?
Section 5

Threshold, evidence, and disclosure questions

Interview outputs should be usable by the people preparing ESRS 2 IRO-1 (the assessment process), IRO-2 (the disclosures covered in the statement), and SBM-3 (material impacts, risks and opportunities and their interaction with strategy and the business model) and by reviewers who need to understand how judgement was exercised. The ESRS do not prescribe a single interview file format, but the assessment needs enough supportable evidence to explain the process and outcome.

Keep the question bank focused on the claim being tested. A broad interview summary is weaker than a record that links each materiality conclusion to source evidence, threshold logic, opposing evidence, data limitations, and next action.

  • Which ESRS topic, sub-topic, sub-sub-topic, or entity-specific matter does the answer relate to?
  • Which IRO statement is supported by the answer, and is it phrased precisely enough to assess?
  • What qualitative or quantitative threshold is being applied for impact materiality or financial materiality?
  • What evidence would change the conclusion, and who owns obtaining it?
  • If a disclosure requirement, datapoint, or metric is omitted as not material, what is the documented rationale?
  • If climate change is assessed as not material, what evidence supports the detailed explanation required by ESRS?
  • Which policies, actions, targets, metrics, estimates, proxies, or entity-specific disclosures may be needed if the IRO is material?
  • What should be preserved for assurance: interview date, interviewee role, topic, value-chain location, evidence cited, judgement made, reviewer, and unresolved limitations?
  • Which ESRS edition, reporting period, and disclosure-reference version will the materiality team use when converting this answer into the IRO register?
  • Which follow-up action, evidence owner, due date, and decision owner will close each unresolved interview point before the materiality conclusion is approved?
Recommended next step

Turn CSRD interviews into traceable evidence

This question bank helps connect ESRS interview answers to IRO statements, materiality thresholds, value-chain evidence, and disclosure-ready review notes.

Section 6

Questions to avoid or tighten

Weak double materiality interviews often generate opinions without evidence. Replace generic rating questions with prompts that identify the specific IRO, affected people or environmental receptor, value-chain location, financial pathway, threshold, and evidence.

Do not present EFRAG implementation guidance as binding law. Use it as non-authoritative support for applying the binding ESRS text, and keep the final materiality judgement tied to the undertaking's facts and circumstances.

  • Avoid: Is this topic material? Better: Which impact, risk, or opportunity are we testing, where does it arise, and what evidence supports it?
  • Avoid: How important is this topic from 1 to 5? Better: What does the evidence show about scale, scope, irremediability, likelihood, or financial magnitude?
  • Avoid: Do suppliers have this issue? Better: Which upstream or downstream actors are likely linked to the IRO, including indirect relationships and hotspots?
  • Avoid: Did stakeholders rank this highly? Better: Which affected stakeholders are impacted, what did they report, and how does that inform severity, likelihood, or completeness?
  • Avoid: Can we leave this out? Better: What materiality conclusion, threshold logic, not-material rationale, or required explanation supports omitting it?
  • Avoid: Who owns the topic? Better: Which function owns the evidence, data correction, threshold judgement, disclosure drafting, and unresolved gap?
Primary sources

References and citations

xbrl.efrag.org7 citations
Referenced sections
  • Public EFRAG-hosted rendering of ESRS Set 1 used for double materiality, affected stakeholders, IROs, value-chain relevance, impact materiality, financial materiality, thresholds, and ESRS 2 materiality disclosures.
  • ESRS 1 and ESRS 2 ground the interview structure by defining double materiality, affected stakeholders, IROs, and required process disclosures.
  • ESRS 1 requires the materiality assessment to consider own operations plus upstream and downstream value-chain connections where IROs are likely to arise.
Show 4 more
  • ESRS 1 defines impact materiality and the severity criteria that interview questions should collect evidence for.
  • ESRS 1 defines financial materiality by reference to material financial effects and primary users' decisions.
  • ESRS 1 and ESRS 2 ground the need to disclose materiality-assessment processes, thresholds, outcomes, and certain not-material conclusions.
  • ESRS 1 grounds the need for a materiality assessment based on IROs, criteria, thresholds, value-chain focus, and stakeholder relevance.
"Double materiality has two dimensions"
More quoted passages
"upstream and downstream value chain"
"scale, scope, and irremediable character"
"financial position, financial performance, cash flows"
"the process to identify and assess"
"Materiality assessment is the starting point for sustainability reporting under ESRS."
efrag.org6 citations
Referenced sections
  • EFRAG source identifying IG 1 Materiality Assessment and IG 2 Value Chain as implementation guidance used to shape the interview prompts.
  • EFRAG's implementation-guidance page identifies IG 1 on materiality assessment and IG 2 on value chain as support materials for ESRS implementation.
  • EFRAG IG 2 supports focusing value-chain interviews on likely material IROs rather than every individual actor.
Show 3 more
  • EFRAG IG 1 supports using stakeholder engagement and objective evidence to identify and assess impacts.
  • EFRAG IG 1 supports financial-materiality interviews focused on likelihood, magnitude, time horizons, and business evidence.
  • EFRAG's implementation guidance page identifies IG 1 and IG 2 as non-authoritative implementation support rather than replacing ESRS.
"IG 1 Materiality Assessment"
More quoted passages
"Final IG 1 to 3"
"IG 2 Value Chain"
"implementation guidance documents"
ec.europa.eu3 citations
Referenced sections
  • Commission Q&A used for ESRS adoption context, ESRS 2 mandatory status, materiality-assessment scope, and assurance context.
  • The Commission Q&A explains that ESRS 2 is mandatory, other standards are subject to materiality assessment, and materiality assessment is subject to assurance.
  • The Commission Q&A supports avoiding voluntary-language shortcuts for disclosure requirements that are material.
"ESRS 2 is mandatory"
More quoted passages
"Disclosure requirements subject to materiality are not voluntary"
"must be disclosed if it is material"
finance.ec.europa.eu2 citations
Referenced sections
  • Commission announcement of revised ESRS adoption and scrutiny; the final act determines entry into force and reporting-year application.
  • Commission announcement of the revised ESRS adopted on 3 July 2026 and the scrutiny process; check subsequent publication and application provisions separately.
efrag.org
Referenced sections
  • EFRAG source confirming the finalisation of IG 1, IG 2, and IG 3 used as support material for materiality assessment and value-chain implementation.
"Finalization of Three EFRAG ESRS IG Documents"
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