How to Write an RFP for a Double Materiality Assessment

EFRAG reviewed 905 assured sustainability statements for financial year 2025 and found climate change material for 99% of companies. The State of Play 2026 also found that the average company named 6.4 material topics out of 10 but set measurable targets for only 3.3. A double materiality assessment that tells you climate is material has told you what everyone already knew. The value is in the specifics, the thresholds and the evidence behind them.

A double materiality assessment (DMA) decides which sustainability impacts, risks and opportunities are material from an impact perspective, a financial perspective or both, and therefore what a company reports under the ESRS. You need one if you report under the CSRD or align with the ESRS voluntarily. The RFP succeeds when it buys documented decisions instead of a longer list.

What this work should deliver

The outcome is a defensible conclusion on what to report, with the reasoning written down. That means a register of material impacts, risks and opportunities, the thresholds used to judge them, the evidence for each conclusion, management approval and a short description of the process for the IRO-1 disclosure. A colorful matrix is optional; the audit trail is not.

Set the boundaries first:

• Legal status. Whether the group is in scope, from which financial year and whether subsidiaries report separately. Our CSRD overview has the phase-in table.
• Method. How far the assessment can rely on top-down conclusions and where it needs a bottom-up look.
• Value chain depth. Which upstream and downstream activities to examine, and what data you may ask suppliers for.
• Inputs you already own. Due diligence records, the enterprise risk register, grievance data and prior materiality work.
• Links to other work. The corporate GHG inventory, the transition plan and the report itself, which our sustainability report RFP guide covers.

Who this is for. Sustainability, finance and risk leads at EU companies and groups reporting under the CSRD, non-EU groups with EU operations above the thresholds, and companies adopting the ESRS voluntarily. It is the wrong template for a GRI-only materiality review or a brand perception survey.

Rules and standards to cite

• Scope after Omnibus I. The CSRD now covers EU companies with more than 1,000 employees and more than €450 million in net turnover, and non-EU groups with more than €450 million in EU turnover and an EU subsidiary or branch above €200 million, according to the European Parliament. Companies with fewer than 1,000 employees need not give larger business partners more than the voluntary standard covers, and sector-specific reporting becomes voluntary.
• Timing. The Commission’s delegated regulation of July 3, 2026 applies the revised ESRS to financial years beginning on or after January 1, 2027, optional for 2026. Companies staying on the old standards for 2026 may still use the new top-down approach and the undue-cost relief for the DMA. The Commission says the revision cuts mandatory datapoints by more than 60%. The stop-the-clock directive had already postponed companies originally due to report for 2025 or 2026.
• The method. Revised ESRS 1 lets a company conclude on a topic top-down from its strategy, business model, sectors, geographies and value chain (paragraph 27). It asks for reasonable and supportable information available without undue cost or effort, and says an exhaustive search is not required. It judges negative impacts by severity (scale, scope and irremediable character) and potential ones by likelihood as well (paragraph 40).
• Stakeholders. The same standard makes engagement with affected stakeholders, carried out through ongoing due diligence, a key input to impact materiality (paragraph 42). Affected stakeholders include workers in the company and its value chain, affected communities, and consumers and end-users.
• Disclosure. ESRS 2 disclosure IRO-1 requires a concise description of the process, including methods, thresholds, whether it drew on due diligence and stakeholder consultation, changes from the prior period and when the assessment was last updated.
• The regulator’s intent. The Commission’s explanatory memorandum says the new rules aim to reduce the risk that assurance providers inadvertently encourage companies to report unnecessary information or "dedicate excessive resources to the materiality assessment process." It adds that the top-down approach lets a company avoid assessing each individual impact, risk or opportunity.
• Related standards. GRI 3 defines material topics by impact on the economy, environment and people, which covers only the impact side. The CSDDD now applies from July 26, 2029 to companies with more than 5,000 employees and €1.5 billion in turnover, and its due diligence feeds the impact assessment.

Sample scope of work

Six tasks cover a first assessment under the revised ESRS.

Task 1. Context and top-down screen. Most conclusions should come from here.

The Consultant shall analyze the [Company]’s strategy, business model, sectors, geographies and upstream and downstream value chain, and for each ESRS topic shall propose a documented top-down conclusion where the evidence supports one, identifying the topics that require further assessment.

Task 2. Targeted assessment of open topics.

For topics not concluded in Task 1, the Consultant shall identify actual and potential impacts, risks and opportunities using reasonable and supportable information available without undue cost or effort, focusing on the activities and value chain stages where material matters are likely to arise.

Task 3. Affected stakeholder input. Use what due diligence already gathers.

The Consultant shall review existing due diligence, grievance and engagement records, and shall conduct [number] interviews with affected stakeholders or their credible representatives and [number] with internal experts, documenting how each input changed or confirmed a conclusion.

Our stakeholder engagement plan RFP guide covers engagement design in depth.

Task 4. Impact and financial scoring.

The Consultant shall assess impacts by severity and likelihood, and risks and opportunities by likelihood and potential magnitude of financial effects over short, medium and long time horizons as defined in ESRS 1, with thresholds agreed with [Finance and Risk] and aligned to the enterprise risk register.

Financial materiality belongs with the finance team. A consultant working without them produces scores nobody in finance will defend.

Task 5. Validation and approval.

The Consultant shall present results, thresholds and borderline cases to [management and the audit committee], record the approval, and deliver the list of material topics and the disclosure requirements that follow from them.

Task 6. Assurance file and refresh procedure.

The Consultant shall compile an evidence file for each conclusion, draft the IRO-1 process description, and deliver a procedure for the annual check of whether significant changes affect earlier conclusions.

Deliverables to require

• Context analysis and value chain map.
• Topic-by-topic record of top-down conclusions and the evidence for each.
• Register of impacts, risks and opportunities, with scores and thresholds.
• Stakeholder engagement record showing who was engaged, how, and what changed as a result.
• Financial materiality workpapers linked to the risk register.
• Approval record from management and the relevant board committee.
• List of material topics mapped to ESRS disclosure requirements, including what the company will not report and why.
• Draft IRO-1 disclosure and an annual refresh procedure.
• An evidence file organized for the assurance provider.

How to evaluate proposals

Growthfund’s framework RFP is a published model of the price-quality trade-off. It scored the technical proposal at 60% and price at 40%, and let each portfolio company decide with management whether its report needed a double materiality analysis.

Two cautions. Growthfund required 15 or more years of experience for the core team manager; recent assessments that passed assurance tell you more than tenure. And if the firm that will assure your statement also offers to design the assessment, check independence rules before you let it; our sustainability assurance guide explains the roles.

Timeline

Our planning estimate for a first assessment is four to six months if the inputs exist, and the phase durations below are suggested allocations. The one published benchmark is Growthfund, which gave its consultant six months for full reports that could include the analysis.

Finish before the first reporting year’s data collection starts, because the conclusions decide which datapoints you collect. EFRAG found 82% of companies updated their assessment between 2024 and 2025, so budget a refresh every year even when nothing major changes.

Budget and cost drivers

We found no published budget for a stand-alone DMA. The clearest public figures bundle the assessment with reporting: in its framework RFP for 2023 reports, due by the end of 2024, Greece’s Growthfund set these ranges, excluding VAT:

• €5,000 to €9,000 per small portfolio company, for a GRI-referenced report including a double materiality analysis where management wanted one.
• €12,000 to €16,000 per large company or group, for reports referencing GRI and SASB on the same basis.
• €40,000 to €50,000 for the holding company’s own report and a portfolio-wide roll-up.

What moves cost:

• The number of legal entities and whether subsidiaries need their own assessments.
• Value chain complexity and the number of countries.
• Engagement design: interviews with affected stakeholders cost more per contact than a survey and yield more.
• How much can be concluded top-down from existing evidence.
• Integration with the risk register and finance team.
• Assurance readiness: evidence files and walkthroughs take time.

The Commission expects the revised standards to lower reporting costs by more than 30% per company. Part of that saving depends on actually using the top-down approach, so ask for it by name.

Red flags in proposals

• Starts every topic from a generic long list of 100 or more sustainability matters, with no top-down screen.
• Relies on a broad opinion survey of employees, customers and investors as the main evidence.
• Scores "importance to stakeholders" against "importance to the business" instead of severity, likelihood and financial effects.
• Leaves thresholds undocumented, or sets them without finance and risk.
• Promises a fixed number of material topics before seeing evidence.
• Produces a matrix but no evidence file, IRO-1 draft or approval record.
• Treats the assessment as a one-time project with no refresh procedure.

How we’d approach it

We’d start from the business model and existing due diligence, conclude top-down wherever the evidence allows, and spend engagement time on the affected stakeholders whose input can change a conclusion. The deliverable we’d care most about is the evidence file, because that is what the next refresh and the assurance review both depend on. Our DMA guide and the comparison of single and double materiality cover the concepts behind the scope.