Under the European Sustainability Reporting Standards (ESRS), organizations can leverage their ongoing dialogue with stakeholders for the materiality assessment. The ESRS explicitly acknowledges that stakeholder engagement plays a fundamental role in assessing material impacts, risks, and opportunities.
Stakeholder Engagement is Central to Materiality Assessment
ESRS 1 and ESRS 2 emphasize that organizations should integrate stakeholder perspectives into their materiality assessments. Engagement with affected stakeholders is central to the undertaking's ongoing due diligence process and sustainability materiality assessment. This includes processes to identify and assess actual and potential negative impacts, which inform the identification of material sustainability topics.
ESRS Does Not Mandate a Specific Stakeholder Engagement Approach
While stakeholder input is considered valuable, the ESRS does not prescribe a mandatory format or behavior for engagement. Companies have flexibility in determining how they engage with stakeholders.
IG 1 Materiality Assessment FAQ 15 states:
'The ESRS require disclosure on the materiality assessment and its outcomes but do not mandate specific behavior on stakeholder engagement or the due diligence process.'.
Stakeholders Can Provide Objective Evidence
The materiality assessment should be based as much as possible on objective data and evidence, but stakeholder perspectives can be a source of supporting evidence for impact materiality.
The relevance of stakeholder input depends on how much they are affected by an organization's activities (severity and likelihood of impacts).
Due Diligence and Materiality Assessment
The due diligence process includes stakeholder engagement, which informs the materiality assessment. Organizations must report how they integrate stakeholder feedback into identifying and assessing material issues.
Nature as a Silent Stakeholder
The ESRS even recognizes that ecological data and conservation indicators should be considered as proxy indicators for stakeholder engagement where human stakeholders are absent (e.g., in cases of biodiversity impact assessments).
Thus, the statement in the question is false. Organizations are encouraged to utilize their existing stakeholder engagement mechanisms to inform their materiality assessments under ESRS.
Official Reference:
Commission Delegated Regulation (EU) 2023/2772.
Compilation Explanations January - November 2024.
ESRS 1 & 2 Guidelines on Double Materiality.