CSRD topical ESRS scoping What must be reported after the materiality assessment

No. Under the 2023 ESRS, ESRS 2 General Disclosures applies irrespective of the materiality assessment, while the other standards, disclosure requirements, and datapoints are subject to materiality. The undertaking reports material information and may omit non-material information subject to the specific IRO-2 rules.

Materiality does not make topical requirements voluntary. If a topical matter, disclosure requirement, or datapoint is material under double materiality, the undertaking must disclose the material information. The materiality assessment is also within the sustainability-statement assurance engagement.

The revised standards are not yet in force. Once applicable, they replace the 2023 ESRS 1 and ESRS 2 scoping mechanics. They keep double materiality and require the undertaking to apply ESRS 2, then report the material information for topics or sub-topics connected to material impacts, risks, or opportunities.

The revised ESRS expressly use a two-step sequence: identify topics related to material impacts, risks, or opportunities, then determine the information to report for those topics. They allow a top-down approach from the business model, strategy, sectors, geographies, and value chain where materiality or non-materiality is evident; a more specific assessment is required where it is not evident.

Under the 2023 ESRS, move from the material sustainability matter to the related disclosure requirements, then to the specific datapoints needed to meet those requirements. EFRAG's implementation guidance describes this as determining material matters first and then determining material information at the more granular level of disclosure requirements or datapoints.

The assessment should cover the undertaking's own operations and upstream and downstream value chain. It should also apply objective criteria and thresholds that fit the undertaking's facts and circumstances, because ESRS does not mandate one fixed sequence of steps for the materiality assessment.

Under the 2023 ESRS, IRO-2 requires the sustainability statement to list the disclosure requirements complied with and to make understandable which topics were omitted as not material as a result of the materiality assessment.

If climate change is assessed as not material and the undertaking omits all ESRS E1 disclosure requirements, ESRS 2 requires a detailed explanation of the materiality-assessment conclusions for climate change, including forward-looking analysis of conditions that could make climate change material in the future. For other non-material topics, the undertaking may provide a brief explanation of the materiality-assessment conclusions.

Some ESRS datapoints correspond to information used under other EU sustainable-finance frameworks, including SFDR, benchmark, and Capital Requirements Regulation disclosures. Under the 2023 ESRS, ESRS 2 IRO-2 requires a table of all EU-law-derived datapoints listed in Appendix B, showing where they appear in the sustainability statement or marking them as Not material.

The revised standards adopted in July 2026 retain the table and the Not material marker but place the list in Appendix A of ESRS 2. In either version, silence is not enough for these listed datapoints; use the appendix that belongs to the version applied.