Blog series: Ten Lessons from CSRD Wave 1 for Wave 2
Phase I: Project preparation · Lesson 2 of 10
Wave 1 companies have already made the mistakes Wave 2 companies don’t need to repeat. In this ten-part series, we share the lessons they learned the hard way, one practical lesson at a time. Wave 2 companies (more than 1,000 employees and more than €450 million net turnover) report for the first time in 2028, covering FY2027.
A double materiality assessment (DMA) is not a separate ESG exercise. It’s a risk analysis conducted through an ESG and financial lens. That means it belongs inside your existing risk management process, not next to it.
Let ERM do the heavy lifting
Enterprise risk management already has the muscle a good DMA needs: entity-specific judgement about what genuinely matters. Wave 1 shows that a well-run DMA frequently surfaces financial and operational risks that had never been formally considered before.
The real value: permission to leave things out
A DMA should help you report only on your most important sustainability challenges, and leave less relevant topics out. That takes courage. If everything is material, nothing is.
A tight set of impacts, risks and opportunities (IROs) is cheaper to assure and cheaper to review each year. It’s also far more likely to inform strategy than an exhaustive list nobody can act on.
Apply common sense, too. Once a topic is self-evidently relevant, it doesn’t need a lengthy justification. A brewer doesn’t have to explain why water matters to its business.
Put the DMA early, and connect it
The DMA determines which Disclosure Requirements you report against, so it belongs early in the process. Once it’s finalised and approved, link each IRO to its Disclosure Requirement. That single step streamlines everything that follows in data collection.
Practical actions
- Route the DMA through ERM, using the same entity-specific judgement already applied to financial risk.
- Be deliberate about what you leave out. A tight IRO set beats an exhaustive one.
- Map each approved IRO to its Disclosure Requirement immediately, before data collection starts.
Under ESRS 2026: strengthened
Most of this lesson is now written into ESRS 1. Materiality can be concluded top-down at topic level without scoring every IRO, an exhaustive search is explicitly not required, and leaving non-material topics out is now an obligation. The open question is assurance: no provider has yet tested a lean, top-down DMA under the new rules, so it must be defensible, not just shorter.
Next in the series: Lesson 3, Work backwards from what each disclosure requirement is trying to show.
Read all ten lessons
Want all ten lessons in one place? Download the whitepaper “Ten Lessons from CSRD Wave 1 for Wave 2”, or book a demo to see how the Salacia platform supports each phase of your CSRD cycle.
