Navigating Double Materiality in ESG: Practical Steps for Businesses
Introduction to Double Materiality
Double materiality emerged as a concept relatively recently, but has been gaining interest as a practical, actionable conceptualization of ESG outputs. Materiality itself traditionally focused on how a factor impacted firm financial performance, a decidedly unidirectional approach. Double materiality looks to identify both the financial materiality of an issue as well as the impact materiality, which assess the material impact upon society and the environment. Rising stakeholder demands and regulatory pressures are making double materiality more and more prevalent in today’s business climate. To practically navigate double materiality, companies must adopt comprehensive strategies that integrate both financial and societal/environmental dimensions into their decision-making processes.
The EU Commission’s Supplementary Directive 2013/34/EU states, “…double materiality as the basis for sustainability disclosures”. The two dimensions of double materiality, impact and financial, are further noted as being ‘…inter-related and the interdependencies between these two dimensions shall be considered” (section 3.3). This is best visualized in the following graphic:
Image credits: Worldfavor, July 2023
As shown, the assessment impact or financial materiality are interconnected and mutually reinforcing. The impacts are, from a company perspective, split between impact inwards and impact outwards, meaning the materiality of an issue as it impacts the company itself (impact inwards) and the material impact of a company’s actions on society and the environment (impact outwards). In today’s reporting climate, those two directions are seen as more closely related than ever before.
In industries such as Aerospace, the concept of materiality is closely linked to innovation. Companies like SpaceX, Orbex, or Collins Aerospace have defined themselves as organisations with a sustainability element. This is a clear demonstration of the circular nature of double materiality, in that the impact materiality (the firm’s sustainability efforts) are directly impacting the financial materiality (inwards impact in the form of sales and customers, outwards impact in the form of environmental innovation and positive social investment) and vice versa. For instance, when discussing potential environmental impacts of manufacturing for aerospace and defense technologies, S&P Global argued that the climate transition would be significantly material for stakeholders as manufacturing and transportation emissions require long-term strategic planning but is less likely to impact near-term credit (S&P Global, 2022).
In defining impacts, it is important to note that risk and opportunities are both components of impact, but that they are not necessarily the entirety of the impact. For instance, an environmental impact may become financially material due to changing weather patterns. Conversely, a financial issue may develop impact materiality through a change in regulations or soft law pressures.
Practical Steps for Businesses
To effectively navigate double materiality, businesses need to implement a series of practical steps, encompassing governance, stakeholder engagement, data collection, and reporting.
1. Establish Strong Governance Frameworks
Leadership and Oversight: Establish a governance framework that includes oversight by the board of directors or a dedicated ESG committee. This structure should ensure that double materiality is integrated into the company’s strategic objectives.
Roles and Responsibilities: Clearly define roles and responsibilities for ESG initiatives across various departments, with a defined company-wide strategy to ensure efficiency of data collection and reporting. Assign senior executives to oversee both financial and impact materiality aspects, ensuring alignment with the company’s overall strategy.
2. Engage Stakeholders
Identifying Stakeholders: Identify and actively engage with key stakeholders, including investors, employees, customers, suppliers, regulators, and local communities. Understanding their concerns and expectations is vital for addressing both financial and impact materiality.
Dialogue and Collaboration: Engage in open and continuous dialogue with stakeholders through surveys, meetings, and advisory panels. Collaboration with stakeholders helps in identifying material ESG issues that are relevant from both financial and impact perspectives.
3. Conduct Materiality Assessments
Materiality Matrix: Develop a materiality matrix that plots ESG issues based on their importance to stakeholders (impact materiality) and their potential financial impact on the company (financial materiality). This visual tool helps prioritize ESG issues that require attention.
Dynamic Assessments: Conduct regular materiality assessments to adapt to evolving ESG landscapes and stakeholder expectations. This ensures that the company remains responsive to new challenges and opportunities.
4. Integrate ESG into Risk Management
Risk Identification: Identify ESG-related risks that could affect the company’s financial performance and societal impact. This includes environmental risks (e.g., climate change), social risks (e.g., labor practices), and governance risks (e.g., corruption).
Risk Mitigation: Develop and implement strategies to mitigate identified risks. This might involve adopting sustainable practices, improving supply chain transparency, or enhancing corporate governance standards.
5. Develop Robust Data Collection and Reporting Mechanisms
Data Collection Systems: Implement robust data collection systems to gather accurate and reliable ESG data. Use technology solutions like IoT, blockchain, and AI to enhance data accuracy and transparency.
Reporting Standards: Align reporting with established frameworks such as the Global Reporting Initiative (GRI), Sustainability Accounting Standards Board (SASB), and Task Force on Climate-related Financial Disclosures (TCFD). These frameworks provide guidelines for comprehensive and comparable ESG reporting.
Integrated Reporting: Consider adopting integrated reporting, which combines financial and ESG information into a single report. This approach provides a holistic view of the company’s performance and its impacts, enhancing transparency and accountability.
6. Foster a Culture of Sustainability
Employee Engagement: Educate and engage employees at all levels about the importance of double materiality and sustainable practices. Encourage employees to contribute ideas and initiatives that promote sustainability.
Incentives and Recognition: Establish incentive programs to reward employees for their contributions to ESG goals. Recognize and celebrate achievements in sustainability to reinforce the company’s commitment to double materiality.
Challenges and Solutions
Data Complexity
In speaking to any ESG practitioner, one of the first challenges to arise is data collection. The data itself is often spread throughout a company, does not fit neatly into easily-organised spreadsheets, or may be difficult to understand in differing contexts (i.e. data from suppliers regarding their carbon emissions may not be shared in the format required by reporting standards).
To address this, companies can invest in advanced data management tools, third party support or automation systems, and design internal systems for data collection. It will be an investment of time and personnel but is also likely to be regulated and required in the near future.
Stakeholder Alignment
Particularly in industries with heavy manufacturing or extractive practices, it may be difficult to align stakeholder interests in a manner that is socially and environmentally material, without sacrificing financial performance. Engaging with stakeholders and third-party expertise while seeking innovative solutions and long-term strategic planning allows companies to effectively address ESG concerns.
Conclusion
Navigating double materiality requires a strategic and integrated approach that aligns financial performance with societal and environmental impacts. By establishing robust governance frameworks, actively engaging stakeholders, conducting dynamic materiality assessments, integrating ESG into risk management, developing comprehensive reporting mechanisms, and fostering a culture of sustainability, companies can effectively integrate double materiality. Success in this area not only enhances corporate reputation and stakeholder trust but also drives long-term value creation in an increasingly sustainability-focused world.
Resources
Boeke, E., York, B. N., London, D. M., Tsocanos, B., York, N., & Paris, P. G. (2022). Sustainable Finance Credit Ratings ESG Materiality Map Aerospace And Defense.
Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 supplementing Directive 2013/34/EU of the European Parliament and of the Council as regards sustainability reporting standards, (2023).
Sean Michael Kerner. (2024, April). Double Materiality. Https://Www.Techtarget.Com/Whatis/Definition/Double-Materiality#:~:Text=Double%20materiality%20acknowledges%20risks%20and,Environment%20and%20society%20at%20large.
S&P Global. (n.d.). Materiality Mapping: Providing Insights Into The Relative Materiality Of ESG Factors https://www.spglobal.com/esg/insights/featured/special-editorial/materiality-mapping-providing-insights-into-the-relative-materiality-of-esg-factors
Worldfavor. (2023, July). CSRD: what is the double materiality assessment? Https://Blog.Worldfavor.Com/Csrd-What-Is-the-Double-Materiality-Assessment.
Erika Anderson’s work has focused on ESG and sustainability in the tech and finance space for the better part of a decade. In working closely with industry partners, she focuses primarily on issues of sustainable finance, social and environmental intersections, and actionable research for strategic ESG implementation. She also serves as Co-Founder of the Guam Human Rights Initiative, a collaborative research nonprofit focused on human rights issues on Guam and throughout the Pacific.
A Guide for MiCA sustainability disclosures for cryptoassets
Scottish Fintech Company, Zumo wrote a very detailed guide on the implications of the Markets in Crypto-Assets Regulation (MICA) and its sustainability disclosure requirements for the crypto industry. The central idea is that MICA’s new regulations will significantly impact how cryptoassets are reported, particularly concerning their environmental sustainability.
Key takeaways from the article begin by explaining;
- The MICA framework, established by the European Union, aimed at creating a unified regulatory environment for cryptoassets. This regulation addresses issues such as market integrity, consumer protection, and the environmental impact of digital currencies.
- MICA mandates that cryptoasset service providers must disclose detailed information about the sustainability of their operations. This includes the energy consumption and carbon footprint associated with the production and use of cryptoassets. The article highlights that these disclosures are crucial for fostering transparency and accountability in the crypto sector.
- The challenges that crypto firms may face in complying with MICA’s sustainability requirements, including the technical difficulty of measuring energy consumption accurately, the cost of compliance, and the need for standardised reporting methods. Zumo Tech emphasises that while these hurdles are significant, they are essential for the long-term viability of the industry.
- Zumo Tech outlines the broader implications of MICA on the crypto industry. The regulation is expected to drive innovation towards more energy-efficient technologies and practices. It could also influence investor behaviour, as greater transparency may attract environmentally conscious investors. The article suggests that, in the long run, these changes could lead to a more sustainable and resilient crypto ecosystem.
The guide written by Zumo provides a comprehensive overview of MICA’s sustainability disclosure requirements and their potential impact on the crypto industry. The regulation will enhance transparency and drive sustainability, but it presents significant compliance challenges.
To read the full guide, click the link here.
The European Sustainability Reporting Standards and Opportunities for Financial Services
This white paper introduces the European Sustainability Reporting Standards (ESRS), which underpin the Corporate Sustainability Reporting Directive (CSRD); a core component of the EU’s Sustainable Finance Framework. It introduces the key concepts of the standards, and breaks down the disclosure requirements of cross-cutting and topical standards, such as biodiversity and ecosystems so that:
1. Corporations have a better understanding of what they must produce to adhere to the standards; and
2. Financial Services have a better understanding of what metrics they will have available to them to better assess risk, develop new financial products and ease their own disclosure requirement burden, through a direct mapping of the ESRS-SFDR only datapoints provided in Annex A.
3. Prepares the reader for the data mapping of White Paper 3: Mapping ESRS Disclosure Datapoints to Relevant Datasets in the series, where specific topics and datapoints are mapped directly to relevant datasets that can be used as part of their analysis.
A key learning is that the ESRS disclosures will be provided in digitally tagged format, eXtensible Business Reporting Language (XBRL), simplifying reporting and presenting new opportunities across the Financial Services sector, such as enhanced investment analysis, including aggregation of sector/country level data and automated analysis, or integration into traditional analysis workflows.
The EU Green Deal and the Sustainable Finance Framework
This white paper is the first in a set exploring the use of geospatial data in Environmental,Social and Governance (ESG) regulations. This first paper introduces the EU’s Green Deal and Sustainable Finance Framework to set the scene for exploring the European Sustainability Reporting Standards (ESRS) in detail.
The ESRS are a focal point as they are the most substantial and, importantly, first mandatory sustainability standards that demand a double materiality approach. This requires a joint assessment of the impact the corporation is having on the environment and society, and the financial risks and opportunities that sustainability factors are having on the corporation. Simply put, if you adhere to the ESRS, then you are likely to satisfy other sustainability standards or frameworks.
The ESRS are a foundational element of the Corporate Sustainability Responsibility Directive (CSRD), the Sustainable Finance Reporting Directive (SFDR) and the Corporate Sustainability Due Diligence Directive (CSDDD), which together contribute to the EU’s Sustainable Finance Framework. These are mandatory directives within the EU and present the first opportunity to assess corporations on a level playing field using double materiality. The aim of this set of white papers is to present the reader with information to:
a. Understand the EU sustainability landscape, and its place within the international sustainability landscape;
b. Demonstrate the link between corporate reporting and sustainable finance, by discussing the relationship between the CSRD, SFDR and CSDDD;
c. Identify the opportunities within Financial Services due to the introduction of mandatory standards using double materiality, specifically the ESRS;
d. Demonstrate how geospatial data can be used to aid the disclosure requirements of the ESRS.
Equifax UK and CienDos Partner to Revolutionise Financed Emissions Reporting
FinTech Scotland’s strategic partner Equifax UK has partnered with Scottish fintech CienDos to launch the Financed Emissions Calculator™, a game-changing solution designed to streamline sustainability reporting and help financial institutions track their carbon footprint with greater precision.
Transforming financed emissions calculations
The Financed Emissions Calculator™ is the first-to-market solution that automates the traditionally manual and error-prone processes of measuring financed emissions. Built on Equifax’s fully cloud-native infrastructure, this innovative tool combines Equifax’s commercial credit insights with CienDos’ advanced emissions data methodologies. The result? A powerful platform that provides lenders with robust, auditable, and transparent carbon values based on sector-specific emission factors.
Financial institutions can now:
- Enhance accuracy in emissions reporting
- Improve traceability of carbon data across portfolios
- Align with regulatory compliance under frameworks like IFRS S2
- Make informed lending and investment decisions to support net-zero targets
Why financed emissions matter
Financed emissions are the greenhouse gas (GHG) emissions indirectly attributed to financial institutions through their lending and investment activities. Unlike direct emissions, which stem from an organisation’s own operations, financed emissions come from the projects and businesses that banks, insurers, and asset managers fund. In many cases, financed emissions make up up to 95% of a financial institution’s total carbon footprint, forming a crucial part of Scope 3.15 reporting requirements.
Until now, many institutions have relied on high-level estimations and manual spreadsheets, making it difficult to track real-time emissions or project future climate impact scenarios. The Financed Emissions Calculator™ changes this landscape by offering an automated, data-driven solution that enhances transparency and enables more effective decision-making.
Equifax UK’s ESG Product Manager, Brad Davies, emphasised the critical role of financial institutions in tackling climate change:
“The role of financial institutions in helping to combat climate change is gaining significant attention, but indirect financed emissions associated with loans and other credit lines are among the most complex to track. By integrating environmental data with leading financial risk assessments, the Financed Emissions Calculator™ empowers UK lenders to measure and mitigate their climate impact. We’re excited to partner with CienDos to fill the knowledge gaps for clients with this first-to-market solution.”
CienDos Chief Executive Julia Salmond highlighted the collaboration’s impact on simplifying sustainability reporting:
“Equifax and CienDos have a shared vision to simplify the complex reporting requirements around financial firms’ carbon footprints. As a critical player at the heart of the UK financial ecosystem, Equifax’s extensive commercial credit data successfully combines with our own market-leading emissions data technology to help transform the management of portfolio emissions for firms, delivering greater accuracy and precision for their financed emissions reporting needs.”
Systems in the Making: the Role of Companies in Implementing Sustainability Policy and Reporting
This paper focuses on the implementation of corporate sustainability, or Environment, Social and Governance, reporting. The introduction from 2023 of mandatory reporting is a key milestone in sustainability.
Adopting a comparative case method, we identify as related case studies Materiality (in reporting), Transition (in corporate strategy), and Stewardship (in fund management). We compare these by applying the theory-led themes of system openness, the agency or power of coalitions in producing and acting upon reports, contests in the qualification of key data, and through business exchanges related to or enabled by sustainability reports.
Drawing on a two-year applied project, we elaborate upon policy, regulation, business and industrial markets, and business relationships. We find that Materiality is the most stable and well-framed system. It produces key outcomes in depicting a reporting company’s sustainability risks and opportunities. Transition is the most open, influenced by global and jurisdiction task forces, for example tasked with achieving net zero policy obligations.
Stewardship in the UK articulates a set of principles, which guide fund managers in engaging with investee companies. We conclude that sustainability policy is at the same time setting in progress the forming of three systems, corresponding to this paper’s three case studies. Each has its own development, function and sets of facts, though each is beginning to achieve its function through interactions and exchanges with the other two.
Zumo’s Amelie Arras Joins MENA Fintech Association’s Sustainable Fintech Alliance as Co-Chair
The MENA Fintech Association (MFTA) has announced the appointment of Amelie Arras, representing Scottish fintech Zumo, as the new Co-Chair of its Sustainable Fintech Alliance. Teaming up with sustainability advocate Gihan Hyde, this powerful partnership aims to drive initiatives that advance sustainability in the fintech and digital asset sectors across the MENA region and beyond.
Championing Sustainability Through Collaboration
Amelie Arras is passionate about sustainable growth through technology and collaboration and brings a wealth of expertise to her new role. She expressed her excitement for the opportunity to drive meaningful change, stating:
“I am honoured to join as co-chair of the MENA Fintech Association Sustainability Alliance, to champion the incredible potential of the fintech and digital asset sectors in creating sustainable opportunities for both people and the planet. The journey toward meaningful impact requires strong collaboration across everyone in our industries, and that is precisely what the Sustainability Alliance aims to foster. By encouraging education, upskilling, and the exploration of innovative technologies, our goal is not only mobilising the sector but also empowering the UAE to lead by example on global sustainability. Together, we can drive change that resonates far beyond our industry.”
Aligning with the UAE’s Sustainability Goals
The appointment comes at a time when the UAE is solidifying its role as a global leader in sustainability and innovation. As the nation continues to set benchmarks for environmental leadership, the Sustainable Fintech Alliance will amplify this momentum by harnessing the transformative power of fintech and digital assets.
From advancing green finance solutions to exploring blockchain applications that promote transparency in carbon offsetting, the Alliance under Amelie Arras and Gihan Hyde’s leadership will serve as a beacon for sustainable progress in the region.
Open Finance and Carbon Neutral Banking
Recent industry insights show that banks still face significant constraints in measuring indirect Green House Gas (GHG) emissions owing to data limitations and a lack of harmonised methodologies.
At the same time, banks and other financial institutions hold large volumes of consumer data that can be leveraged to estimate GHG emissions albeit financial transaction data are privately owned with restricted access. This paper discusses how an open finance framework can be used to aggregate consumer transaction data across multiple financial products to compute carbon footprints.
It highlights a step-by-step approach to carbon footprint estimation and discusses the consideration for using microdata for emission computation.
CBI and Zumo Partner to Track Sustainability in Digital Assets
Commercial Bank International (CBI), a UAE-based bank, has entered into a strategic partnership with Scottish fintech Zumo. This collaboration will focus on exploring methods to track the sustainability of digital assets—a step in CBI’s ongoing work to bring innovative, environmentally conscious digital solutions to its clients.
The UAE is rapidly positioning itself as a centre for digital asset growth and regulatory clarity, with projections suggesting that the nation’s digital asset market will grow from $453.20 million in 2024 to $616.80 million by 2028. As digital assets become a more established part of the financial landscape, both CBI and Zumo aim to contribute to a framework that prioritises transparency and environmental awareness.
Giovanni Everduin, Chief Strategy & amp; Innovation Officer at CBI, commented on the partnership:
“Our partnership with Zumo marks a significant milestone in CBI’s ongoing commitment to innovation and sustainability. Aligned with our vision of partnership driven innovation, we look forward to collaborating with Zumo to become one of the first banks in the world to provide carbon footprint insights with carbon offsetting for digital assets. This revolutionary capability will ensure
that, as digital assets become further embedded within the financial ecosystem, customers and institutions have the required tools and data to ensure their sustainability goals are tracked and achieved.”
For Zumo, the partnership represents an opportunity to extend their focus on sustainability within the digital asset sector.
Clark Povey, Zumo’s Chief Operating Officer, shared his perspective:
“We’re delighted to announce our strategic partnership with Commercial Bank International, one of the UAE’s most innovative banks, headquartered in Dubai. Our collaboration with CBI will see Zumo’s pioneering digital assets and blockchain technology complement CBI’s financial expertise and innovative approach to drive sustainability. Zumo solves the biggest challenges in digital
assets for financial institutions by providing business-critical technologies to navigate the rapidly evolving digital asset landscape, and with Zumo’s technology and leadership in sustainability of digital assets, the exciting journey ahead is just beginning..”
Zumo’s platform is designed to help financial institutions address sustainability challenges within digital assets. It provides tools to meet MiCA’s sustainability disclosure requirements in the EU, simplifying how crypto asset service providers
(CASPs) can publish environmental sustainability indicators for distributed ledgers. With these tools, CASPs can provide transparent, accessible data on the environmental impact of their digital assets.
Zumo is committed to decarbonising digital assets and plays and important role as an early signatory of the Crypto Climate Accord and the Abu Dhabi Sustainable Finance Declaration.
H2C.org Launches the World’s First Global Market for Green Hydrogen Certificates
H2C.org is launching the first global market and registry for the international trade in green hydrogen certificates. Following in the footsteps of renewable energy and sustainable aviation fuel registries, H2C.org enables the green premiums and carbon removal rights of green hydrogen to be sold discretely from each ton of fuel. H2C.org is set to catalyse international markets for green Hydrogen with nearly 2,000 production projects currently under development globally.
By uncoupling Green Premium Certificates from green hydrogen fuels, H2C.org enables a global market of beneficiaries to decarbonise their Scope1, 2 & 3 emissions and supply chains directly. Meanwhile producers can strike off-take agreements at prices closely aligned to cheaper production methods. H2C.org provides the missing link to create viable international markets for green hydrogen and financing green premiums.
First Carbon Investments founded the H2C.org initiative. Their CEO, Peter Ellen, notes, “Launching H2C.org is a pivotal moment for the emergence of global hydrogen markets. Green Hydrogen is primed to transform sectors, including heavy industry, transport, and agriculture, for a low-carbon future. Developing large export markets is a critical step in developing interoperable and resilient demand and supply.”
The Green Hydrogen industry has been constrained by significant cost premiums associated with producing hydrogen from renewable energy sources. Ellen notes, “There is huge momentum for Green Hydrogen, but bulk international off-takers operate in low margin, high volume industries, where increases in fuel costs are hard to support. Deploying green hydrogen eliminates emissions from global supply chains, benefiting Scope 1,2 and 3 carbon accounts across many value-added goods and services. H2C.org enables all those beneficiaries to remove emissions from their supply chains by buying Green Premium Certificates.”
Scope 1 beneficiaries include heavy industry, transport, shipping, and agriculture, with Scope 3 covering most value-added manufacturing and services, from automobiles to technology and consumer goods. H2C.org provides a direct and cost-effective way for organisations to remove carbon emissions from supply chains while reducing dependency on third-party off-setting.
Today, the largest and most significant green hydrogen production projects are on the cusp of delivering portable energy to some of the world’s highest emitting sectors, often referred to as hard-to-decarbonise industries. Green hydrogen offers a viable replacement for fossil fuels because it delivers renewable energy in a portable, energy-intense, liquid form that can leverage existing infrastructure. In the near term, it will allow organisations and countries to meet corporate and national commitments.
“We see export-focused projects harnessing 4GW+ of dedicated renewable energy to electrolyse seawater for the annual production of 1mn+ metric tons of green hydrogen and ammonia. These projects will drive global transformations and develop resilient markets, and H2C.org enables off-takers to buy at a viable cost.”
H2C.org is now inviting key players to join as development partners. This pragmatic initiative allows partners to be at the forefront of the global hydrogen economy. Ellen notes, “Supply and demand signals are significant, and H2C.org already counts over 100GW of partners with a particularly strong MENA representation. We believe those projects alone represent a 0.7% reduction in global emissions. Together with partners, we are on a mission to make a
giga-ton impact.”
About H2C
H2C, founded by First Carbon Investments, is a groundbreaking initiative designed to accelerate the adoption of low-carbon hydrogen and its derivatives through Green Premium Certificates. They aim to facilitate the development of $trillion global markets for clean technologies. With multiple standards emerging to validate the provenance of green
hydrogen, H2C.org provides an interoperable registry and market to enable global trade.
About First Carbon Investments
First Carbon Investments is dedicated to accelerating the transition to clean technologies globally across the energy, transport, and heavy industry sectors. Leveraging expertise in catalytic finance and provenance management, they invest in and support the development of low-carbon fuels, helping to reduce the world's carbon footprint effectively and sustainably. Founded by industry visionaries with extensive experience in high-growth and global finance, FCI combines strategic insight with practical solutions to meet the demands of the evolving low-carbon economy. Through its comprehensive platform, FCI offers catalytic finance, provenance management, and management consulting services, fostering partnerships that enable the effective implementation of transformative environmental solutions.
For media enquiries, contact info@first-carbon.com
For more information, visit first-carbon.com or contact our media relations team.
To join our network of partners, visit Development Partner Signup or contact us at info@h2c.org or go to h2c.org for more information.