2026 is the year in which the double materiality analysis (DMA) will evolve from a compliance exercise to a strategic tool. Whereas in 2024 the DMA was still primarily a CSRD obligation, organisations are now investing in a pragmatic review of their materiality analysis. And rightly so: companies that use their DMA strategically are building competitive advantage, better risk management and future-oriented decision-making.
For those who are not yet fully familiar with the concept, double materiality looks at ESG themes from two perspectives:
A topic is material if it meets at least one of these two criteria. Together, they form a 360° picture of what matters to your company and its stakeholders: the basis for your sustainability strategy and reporting.
1. Annual updates become the norm
For many CSRD companies, 2026 will be all about DMA updates. After the initial materiality analysis in 2024-2025, it will be time to review the results and make adjustments. After all, numerous external developments influence the materiality of companies, such as:
Internal developments also make it important to keep your finger on the pulse. Think of company acquisitions or divestments, geographical expansion, product diversification, strategic reorientation (e.g. transition to a circular business model), and so on.
Recommendation: schedule an annual light review to check whether material topics are still relevant.
2. First DMA was a baseline measurement: refinement is needed
For many organisations, the DMA in 2024–2025 was a first, and therefore served primarily as a baseline measurement. In practice, it turned out that data was often not yet mature: ESG information was not always complete or sufficiently quantitatively substantiated, which meant that the materiality scoring was not always robust and consistent. In addition, understanding of the concept of double materiality within organisations was still in its infancy.
Now that companies have additional data and practical experience at their disposal and have been able to benchmark their DMA against their peers, previous assumptions can be reassessed. Updating the DMA is not merely a repetitive exercise, but a necessary step in the further professionalisation and strategic anchoring of materiality analysis.
Are you unsure whether your DMA scores are still robust? Contact us for a brief maturity scan.
3. Auditors are setting stricter requirements
External auditors are looking with increasing scrutiny at methodological consistency, data quality and source references, and the decision-making process. An audit-proof DMA requires tight documentation and clear decision-making criteria. Many companies are taking the next step in this area this year.
The revised ESRS standards, which will be gradually rolled out from mid-2026, will lead to a fundamental simplification of sustainability reporting. The DMA can also be approached in a much more practical way.
Starting from your business strategy and sector context is sufficient to determine the topics relevant to your company. Management determines the ESG priorities and you can then involve your stakeholders in a targeted manner to challenge and validate the results. Lengthy bottom-up consultations are no longer necessary, nor is an exhaustive scoring of all IROs (impacts, risks and opportunities) and (sub)topics. This means that companies can implement their DMA more quickly and deploy it in a much more targeted manner by focusing clearly on what is truly material.
The EU Omnibus (2025) exempts a large group of medium-sized companies from the CSRD obligation. Nevertheless, there are good reasons to implement a DMA voluntarily:
Risk management and better access to capital: early detection of ESG risks (water, climate, supply chain, etc.) and integration into Enterprise Risk Management. Stronger ESG ratings lead to better conditions for green financing or to greater visibility among investors.
More efficient and data-driven resource allocation: a substantiated DMA helps to allocate budgets based on financial interest and ESG impact for your company and its stakeholders.
Faster innovation: material topics such as circular business models trigger new product development and innovative business models.
Competitive advantage and reputation: public procurement increasingly requires CSRD-compliant reporting, while B2B customers integrate ESG performance into their supplier selection. The output of your DMA also strengthens your sustainability claims and thus helps to avoid greenwashing risks.
How often should you update your DMA?
We recommend an annual light review to integrate the impact of new regulations, geopolitical shifts, internal changes and stakeholder priorities. A more thorough review is needed every 2 to 3 years.
Is a DMA only relevant for companies subject to CSRD?
No. A DMA offers strategic value for all organisations that want to proactively manage ESG risks or strengthen their competitive position.
What is the role of AI in DMA?
AI can assist with stakeholder analysis, thematic clustering of interviews, and benchmarking with peers. However, strategic decisions remain human. Context and nuance are crucial in this regard.
"Lamifil sees reporting based on a DMA as a lever for value creation and trust. Thanks to our sustainability efforts, we have already been able to secure important contracts with network operators Elia and Infrabel in Belgium and TenneT in the Netherlands. They also gave us a better EcoVadis score and contributed to the renewal of our ISO 14001 certificate."
Pantarein guides organisations from initial design to strategic implementation – with proven methodologies, sector expertise and a practical focus.
What we offer:
Contact us and discover how we can guide your organisation from compliance to strategy.
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