The 31 (94) Topics of the Materiality Analysis of CSRD (Updated 2025)

The materiality analysis is the process by which the undertaking determines material matters and material information to be reported on in its sustainability statement. The performance of an objective materiality assessment is pivotal to sustainability reporting which shall include relevant and faithful information about all impacts, risks and opportunities (IROs) across environmental, social and governance matters determined to be material from the impact materiality perspective or the financial materiality perspective or both.

ESRS 1 (2025) stipulates that a company can determine the materiality/immateriality of impacts, risks or opportunities (IROs) at the topic or sub-topic level ‘without further assessment’, ‘based on an analysis of strategy and business model’, including sector(s), geographies and characteristics of the upstream and downstream value chain (top-down approach). It is important to note the following restriction: if materiality (or immateriality) is not clearly evident from this top-down analysis, you must carry out a specific (in-depth) assessment for the IROs in question.

The materiality assessment process shall be designed to identify all material impacts, risks and opportunities and consequently also to exclude those that are not material. A materiality assessment that would meet the requirements of ESRS could include the following steps:

1. understanding the context and definition of the stakeholder engagement strategy;
2. identification of the list of potential material sustainability matters and impacts, risks and opportunities; and
3. determination of the final list of material matters based on an assessment of the materiality of the impacts, risks and opportunities.

The new 2025 ESRS list the following topics for the materiality analysis (see our guide about CSRD und ESRS):

1. Climate Change (Topic ESRS E1)
   – Climate change mitigation (Sub-topic ESRS E1)
   – Climate change adaptation (Sub-topic ESRS E1)
   – Energy (Sub-topic ESRS E1)
2. Pollution (Topic ESRS E2)
   – Pollution of air (Sub-topic ESRS E2)
   – Pollution of water (Sub-topic ESRS E2)
   – Pollution of soil (Sub-topic ESRS E2)
   – Substances of concern, including substances of very high concern (Sub-topic ESRS E2)
   – Microplastics (Sub-topic ESRS E2)
3. Water (Topic ESRS E3)
   – Water use, which include withdrawal, consumption, discharges and storage (Sub-topic ESRS E3)
4. Biodiversity and Ecosystems (Topic ESRS E4)
   – Drivers of biodiversity and ecosystem change (terrestrial and marine habitat change, invasive species) (Sub-topic ESRS E4)
   – State of species (Sub-topic ESRS E4)
   – The extent and condition of terrestrial and marine ecosystems (Sub-topic ESRS E4)
   – Ecosystem services (Sub-topic ESRS E4)
5. Circular Economy and Resource Use (Topic ESRS E5)
   – Resource inflows (Sub-topic ESRS E5)
   – Resource outflows related to products and services (Sub-topic ESRS E5)
   – Resource outflows (waste) (Sub-topic ESRS E5)
6. Own Workforce and Workers in the Value Chain (Topic ESRS S1 / S2)
   – Working conditions (including adequate wages, work-life balance, working time, secure employment, social protection) (Sub-topic ESRS S1/S2)
   – Social dialogue, freedom of association, works councils, participation rights of workers, and collective bargaining (Sub-topic ESRS S1/S2)
   – Health and safety (Sub-topic ESRS S1/S2)
   – Training and skills development (Sub-topic ESRS S1/S2)
   – Diversity and equal treatment (including gender equality, equal pay for work of equal value, employment and inclusion of people with disabilities, non-discrimination, anti-harassment, measures against violence) (Sub-topic ESRS S1/S2)
   – Other labour-related human rights (including child labour, forced labour, privacy and adequate housing, water and sanitation) (Sub-topic ESRS S1/S2)
7. Affected Communities (Topic ESRS S3)
   – Communities’ economic, social and cultural rights (including land-related impacts, security-related impacts, adequate housing and food, water and sanitation) (Sub-topic ESRS S3)
   – Communities’ civil and political rights (including freedom of expression, freedom of assembly, impacts on human rights defenders) (Sub-topic ESRS S3)
   – Rights of indigenous peoples (including free, prior and informed consent (FPIC), self-determination, cultural rights) (Sub-topic ESRS S3)
8. Consumers and End-users (Topic ESRS S4)
   – Information-related impacts for consumers or users (including privacy, access to information, freedom of expression) (Sub-topic ESRS S4)
   – Personal safety of consumers or end-users (including health and safety, protection of children, security of a person) (Sub-topic ESRS S4)
   – Social inclusion of consumers or end-users (including access to products and services, responsible marketing practices, non-discrimination) (Sub-topic ESRS S4)
9. Business Conduct (Topic ESRS G1)
   – Corporate culture, including anti-corruption and bribery, the protection of whistle-blowers and animal welfare (Sub-topic ESRS G1)
   – Political influence, including lobbying activities (Sub-topic ESRS G1)
   – Management of relationships with suppliers, including payment practices especially late payment to small- and medium-sized undertakings (SMEs) (Sub-topic ESRS G1)

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The following 94 topics (including Sub-Topics and Sub-Sub Topics) had to be evaluated according to the 2023 ESRS (Note that this has been depreciated):

Contact us to set-up the Materiality Analysis according to CSRD and ESRS in Europe.

Related Links:

• The 50% Illusion: Why the ESRS Exposure Draft’s “Datapoint Reduction” Is a Misleading Package
• The „S“ of ESG in the ESRS (updated)
• Why VSME Can Mean More Data Than ESRS—for SMEs and Their Banks
• The „E“ of ESG in the ESRS (Updated)
• The „G“ of ESG in the ESRS (Updated)