EFRAG’s draft IG1: materiality assessment implementation guidance 

We have responded to EFRAG’s draft IG 1 Materiality Assessment Implementation Guidance (MA IG). We appreciate this guidance as it simplifies the key concept in the European Sustainability Reporting Standards (ESRS). However, we recognise that the guidance could be further improved before the first publication by providing more guidance and practical examples on:

• incorporating the value chain in the materiality assessment
• distinguishing between material matters and the materiality of information
• linking users and stakeholders
• understanding the financial aspect of double materiality.

We appreciate that providing guidance on other concepts may take longer, but should not hold back the first publication of the MA IG. EFRAG should consider providing future guidance on the following key challenges in making materiality assessments :

• value chain considerations for financial institutions, conglomerates and groups
• social topics
• consolidation and group considerations.

We suggest EFRAG collaborates with the International Sustainability Standards Board (ISSB) and the Global Reporting Initiative (GRI) in providing implementation support on the materiality assessment.

We also provide some ideas for EFRAG and the European Commission to consider in the future, which would further help implementation:

• aligning contents with the Q&A platform
• considering future ESRS amendments
• updating the ESRS Basis for Conclusions
• reactivating the European Lab.