Questions & Answers

Question-ID: 1039

Release Date: Oct 31, 2024


Questions & Answers

We are trying to understand how changing the materiality of a sustainability matter over the three timeframes influences Disclosure Requirements e.g., whether the matter of water is deemed not material for the short- and medium-term impact materiality but material in the long-term. Does that mean the matter is deemed material and disclosure is required even though it only becomes material in the long-term?

Key Terms
  • Time horizon

Background

ESRS 1 paragraph 43 states:’ ‘A sustainability matter is material from an impact perspective when it pertains to the undertaking’s material actual or potential, positive or negative impacts on people or the environment over the short-, medium- or long-term. …’.

ESRS 1 paragraph 49 states: ‘A sustainability matter is material from a financial perspective if it triggers or could reasonably be expected to trigger material financial effects on the undertaking. This is the case when a sustainability matter generates risks or opportunities that have a material influence or could reasonably be expected to have a material influence, on the undertaking’s development, financial position, financial performance, cash flows, access to finance or cost of capital over the short-, medium- or long-term. …’.

Answer

Yes. ESRS 1 paragraph 43 states for impact materiality, and paragraph 49 for financial materiality, that: ‘A sustainability matter is material … when it pertains to / if it triggers … over the short-, medium- or long-term.’ The time horizons are connected with an ‘or’, meaning that the impact / financial materiality must not occur during all three-time horizons. It is sufficient that materiality occurs during any of the time horizons.

If a matter is assessed as material in the long-term, the matter is considered material, and the related Disclosure Requirements are applicable. Attention should be paid to the possible omission of metrics when following paragraph 43 of ESRS 1.

See also Question ID 1019 – Sustainability matter expected to become material in the future.


Relations

Paragraph
Content
2023 ESRSESRS 1 - GENERAL REQUIREMENTS...3.5 Financial materiality49.

A sustainability matter is material from a financial perspective if it triggers or could reasonably be expected to trigger material financial effects on the undertaking. This is the case when a sustainability matter generates risks or opportunities that have a material influence, or could reasonably be expected to have a material influence, on the undertaking’s development, financial position, financial performance, cash flows, access to finance or cost of capital over the short-, medium- or long-term. Risks and opportunities may derive from past events or future events. The financial materiality of a sustainability matter is not constrained to matters that are within the control of the undertaking but includes information on material risks and opportunities attributable to business relationships beyond the scope of consolidation used in the preparation of financial statements.

2023 ESRSESRS 1 - GENERAL REQUIREMENTS...3.4 Impact materiality43.

A sustainability matter is material from an impact perspective when it pertains to the undertaking’s material actual or potential, positive or negative impacts on people or the environment over the short-, medium- or long-term. Impacts include those connected with the undertaking’s own operations and upstream and downstream value chain, including through its products and services, as well as through its business relationships. Business relationships include those in the undertaking’s upstream and downstream value chain and are not limited to direct contractual relationships.

2023 ESRSESRS 1 - GENERAL REQUIREMENTS...3.5 Financial materiality49.

A sustainability matter is material from a financial perspective if it triggers or could reasonably be expected to trigger material financial effects on the undertaking. This is the case when a sustainability matter generates risks or opportunities that have a material influence, or could reasonably be expected to have a material influence, on the undertaking’s development, financial position, financial performance, cash flows, access to finance or cost of capital over the short-, medium- or long-term. Risks and opportunities may derive from past events or future events. The financial materiality of a sustainability matter is not constrained to matters that are within the control of the undertaking but includes information on material risks and opportunities attributable to business relationships beyond the scope of consolidation used in the preparation of financial statements.

2023 ESRSESRS 1 - GENERAL REQUIREMENTS...3.4 Impact materiality43.

A sustainability matter is material from an impact perspective when it pertains to the undertaking’s material actual or potential, positive or negative impacts on people or the environment over the short-, medium- or long-term. Impacts include those connected with the undertaking’s own operations and upstream and downstream value chain, including through its products and services, as well as through its business relationships. Business relationships include those in the undertaking’s upstream and downstream value chain and are not limited to direct contractual relationships.

2023 ESRSESRS 1 - GENERAL REQUIREMENTS3. Double materiality as the basis for sustainability disclosures43.

A sustainability matter is material from an impact perspective when it pertains to the undertaking’s material actual or potential, positive or negative impacts on people or the environment over the short-, medium- or long-term. Impacts include those connected with the undertaking’s own operations and upstream and downstream value chain, including through its products and services, as well as through its business relationships. Business relationships include those in the undertaking’s upstream and downstream value chain and are not limited to direct contractual relationships.

2023 ESRSESRS 1 - GENERAL REQUIREMENTS...3. Double materiality as the basis for sustainability disclosures49.

A sustainability matter is material from a financial perspective if it triggers or could reasonably be expected to trigger material financial effects on the undertaking. This is the case when a sustainability matter generates risks or opportunities that have a material influence, or could reasonably be expected to have a material influence, on the undertaking’s development, financial position, financial performance, cash flows, access to finance or cost of capital over the short-, medium- or long-term. Risks and opportunities may derive from past events or future events. The financial materiality of a sustainability matter is not constrained to matters that are within the control of the undertaking but includes information on material risks and opportunities attributable to business relationships beyond the scope of consolidation used in the preparation of financial statements.

2023 ESRSESRS 1 - GENERAL REQUIREMENTS3.4 Impact materiality43.

A sustainability matter is material from an impact perspective when it pertains to the undertaking’s material actual or potential, positive or negative impacts on people or the environment over the short-, medium- or long-term. Impacts include those connected with the undertaking’s own operations and upstream and downstream value chain, including through its products and services, as well as through its business relationships. Business relationships include those in the undertaking’s upstream and downstream value chain and are not limited to direct contractual relationships.