AMF, the French Financial Markets Authority assessed a sample of ESRS statements published by French listed companies under the CSRD for financial year 2024.<\/p>\n
This report is very valuable as it gives you information on what the financial marketplace is expecting from your sustainability reports. We will send you the information regrouped by subject. Below you will a summary of the key findings related to the Double Materiality Assessment (DMA) process (ESRS 1 & ESRS 2 IRO-1).<\/strong><\/p>\n \u00a0<\/strong><\/p>\n Overall, a heterogeneity was noted with regard to the level of detail and degree of compliance with the required data points on the presentation of the DMA process (IRO-1 data points).<\/p>\n Some companies provide detailed explanations per topic while others present more generic information on how the process was conducted.<\/p>\n Compliance with all IRO-1 data points was generally partial. For instance, a large number of companies do not disclose the topical IRO-1 associated with their non-material topics, although these are always to-be disclosed data points.<\/p>\n Specific information on the DMA process related to social topics is provided only in very rare cases.<\/p>\n <\/p>\n Input parameters, sources\/assumptions<\/strong><\/p>\n Some companies provide incomplete or boilerplate<\/em><\/strong> disclosures on the input parameters used (for instance, only focusing on material topics or providing broad references applicable to all topics such as \u201cindustry benchmarks\u201d).<\/p>\n Others disclose very specific information on the sources\/assumptions that informed the DMA process.<\/p>\n For social-related topics information on input parameters is often not specified, contrary to other environmental topics.<\/p>\n Some companies provided interesting contextual information on the methodology used in relation to certain materiality criteria. For example, they explain that<\/p>\n <\/p>\n Duplicating the content of ESRS 1<\/strong><\/p>\n Many provide extensive explanations on the definition of impact materiality and financial materiality and the different criteria that must be considered in application of the ESRS (often by duplicating the content of ESRS 1).<\/p>\n These elements can be useful for non-expert readers in the context of the first ESRS application.<\/p>\n However, in some cases, the IRO-1 disclosures have little informative value as they reproduce the content of ESRS 1 with no or few methodological explanations specific to the issuer (for instance, only boilerplate<\/em><\/strong> disclosures stating that judgements were applied).<\/p>\n Therefore, it is sometimes difficult to understand how the two processes for impact and financial materiality are designed in practice.<\/p>\n <\/p>\n Unclear distinction between a risk and an impact<\/strong><\/p>\n In some cases, the distinction between a risk and an impact is not clear due to misuse of terminology (e.g. use of the term \u00ab risk \u00bb associated with the description of an impact<\/strong>) or because the company explains that the same materiality threshold is used for both impact and risks.<\/p>\n <\/p>\n Information on impact<\/u> materiality thresholds is very often generic or missing, limiting the understanding of the DMA methodology used and demonstrating the need for further guidance in this area.<\/p>\n Example of generic disclosures are:<\/p>\n Companies may have had difficulties identifying relevant thresholds at consolidated level and only defined generic thresholds at macro level.<\/p>\n A focused assessment of E2 and E4 disclosures showed that the information on how impact thresholds are determined is generally not provided at the topic-level although materiality depends on the nature of topics<\/strong>.<\/p>\n <\/p>\n Conducting an assessment at the level of IRO (vs. at the higher level of topics only) is important since companies should present their IROs and how they manage them, in line with CSRD objectives.<\/p>\n It is key to maintain the assessment of actual and potential impact as well as risks before taking into consideration mitigation efforts, to provide a complete overview of the company\u2019s sustainability profile (meaning not a net assessment).<\/p>\n The most useful data points in IRO-1 are information on the input parameters and their link with the materiality thresholds specific to sustainability topics, as well as information on the nature of financial thresholds (several good practices were identified in 2025).<\/p>\n These disclosures are most useful when the company specify which inputs (sources, tools) were used in relation to a particular sustainability topic (e.g. mention of databases such as UNEP\u2019s ENCORE, WWF\u2019s Water Risk Filter in relation to specific environmental topics or mention of specific rating tools for the business conduct topic). Many companies also cited the Aqueduct water risk tool from the Word Resources Institute to assess water-related risks.<\/p>\n Good practices include the following information in IRO-1:<\/p>\n Good practices already observed for financial thresholds include:<\/p>\n <\/p>\n As a good practice, several companies explicitly report challenges related to the execution or scope of their materiality assessment<\/p>\n However, the consequences of these difficulties are not always clear (reliability of data? limited scope\/coverage? etc.) and the reasons for limitations were not always given.<\/p>\n Examples of challenges and limits identified by companies are:<\/p>\n Very few auditors specifically point out limits in the company\u2019s DMA process.<\/p>\n <\/p>\n Source: <\/strong>https:\/\/www.amf-france.org\/sites\/institutionnel\/files\/private\/2025-10\/amf_study_csrd_reporting_the_way_forward_2025.pdf<\/p>\n \u00a0<\/u><\/p>\n When you use Cleerit ESG to structure and document your IROs and double materiality assessment you increase both ESRS compliance and make CSRD useful for your business as it will help you identifying issues material for your resilience and competitiveness. Contact us if you want to know more >>><\/a><\/p>\n","protected":false},"excerpt":{"rendered":" AMF, the French Financial Markets Authority assessed a sample of ESRS statements published by French listed companies under the CSRD for financial year 2024. This report is very valuable as it gives you information on what the financial marketplace is expecting from your sustainability reports. We will send you the information regrouped by subject. Below […]<\/p>\n","protected":false},"author":1,"featured_media":2132,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1,5],"tags":[],"class_list":{"0":"post-2131","1":"post","2":"type-post","3":"status-publish","4":"format-standard","5":"has-post-thumbnail","6":"hentry","7":"category-csrd","8":"category-esrs","10":"post-with-thumbnail","11":"post-with-thumbnail-large"},"_links":{"self":[{"href":"https:\/\/cleeritesg.com\/index.php\/wp-json\/wp\/v2\/posts\/2131","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/cleeritesg.com\/index.php\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/cleeritesg.com\/index.php\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/cleeritesg.com\/index.php\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/cleeritesg.com\/index.php\/wp-json\/wp\/v2\/comments?post=2131"}],"version-history":[{"count":2,"href":"https:\/\/cleeritesg.com\/index.php\/wp-json\/wp\/v2\/posts\/2131\/revisions"}],"predecessor-version":[{"id":2136,"href":"https:\/\/cleeritesg.com\/index.php\/wp-json\/wp\/v2\/posts\/2131\/revisions\/2136"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/cleeritesg.com\/index.php\/wp-json\/wp\/v2\/media\/2132"}],"wp:attachment":[{"href":"https:\/\/cleeritesg.com\/index.php\/wp-json\/wp\/v2\/media?parent=2131"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/cleeritesg.com\/index.php\/wp-json\/wp\/v2\/categories?post=2131"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/cleeritesg.com\/index.php\/wp-json\/wp\/v2\/tags?post=2131"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}Presentation of the DMA process (in IRO-1)\u00a0 <\/strong><\/h2>\n
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Information on materiality thresholds<\/strong><\/h2>\n
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Good practices <\/strong><\/h2>\n
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Limits and difficulties identified by companies or auditors on the DMA<\/strong><\/h2>\n
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