Established model
Double materiality
European Commission; developed in EFRAG’s reporting standards · 2019
A sustainability matter is material if it affects the company’s finances, or if the company significantly affects people and the environment — either is enough.
Its place in the frameworkVision Core›Responsibility
What it does
Conventional materiality looks from the outside in: what could change the company’s value. Double materiality adds the view from the inside out: what the company does to the world. The practical consequence is that a company cannot leave out a serious impact simply because it does not yet cost the company anything.
- Reach for it when
- When deciding what a responsibility report must cover, and when the list of priorities contains only the issues that threaten revenue.
- Where it stops
- Assessing impact is judgement-heavy, and the process can become a compliance exercise that ranks topics without changing decisions. It governs what is reported, not what is done.
European Commission, Guidelines on Non-Financial Reporting: Supplement on Reporting Climate-Related Information, 2019; Directive (EU) 2022/2464 (Corporate Sustainability Reporting Directive); European Sustainability Reporting Standards developed by EFRAG, 2023.
Why it sits at Responsibility
The organisation’s effect on people, society and the environment, and what it is prepared to commit to about that effect — stated plainly enough for someone outside to check.
A model is only useful when you reach for it at the right moment. This one answers a question that arises here — so it is filed here, and nowhere else. These are the working areas it serves:
- Impact and materialityEuropean Commission, Guidelines on non-financial reporting: supplement on reporting climate-related information (2019), which set out double materiality; EFRAG, ESRS 1 General Requirements (2023); UN Guiding Principles on Business and Human Rights (2011) on severity as scale, scope and irremediability.
- Commitments and targetsWRI & WBCSD, The GHG Protocol Corporate Accounting and Reporting Standard (revised edition, 2004) on base years and recalculation; Science Based Targets initiative, Corporate Net-Zero Standard (2021).
- EthicsLynn Sharp Paine, “Managing for Organizational Integrity”, Harvard Business Review (1994), on integrity-based as distinct from compliance-based programmes; Rushworth Kidder, How Good People Make Tough Choices (1995), on right-versus-right dilemmas.
- DisclosureGRI, GRI Standards (2016 onward); ISSB, IFRS S1 and IFRS S2 (2023); Lyon & Maxwell, “Greenwash: Corporate Environmental Disclosure under Threat of Audit”, Journal of Economics & Management Strategy (2011).
What it touches elsewhere
Nothing in a business is decided on its own. A conclusion reached with this model at Responsibility lands in these other cores, whether or not anyone follows it there.
- PurposeStakeholder rationale in Purpose names whom the organisation exists to serve, and core values hold what it has declared it will not trade. This object covers everyone its activity affects and turns those values into conduct standards.
- ComplianceCompliance holds the legal minimum and the controls around it, including any legal duty to report on sustainability. Ethics here starts where the law stops asking.
- GovernanceThe board’s oversight and the enterprise risk register sit in Governance. Climate and other sustainability risks found by the materiality assessment are registered there, not here.
- Supply ChainSourcing owns how suppliers are chosen and managed. The conduct expected of them is set in Ethics, and their impacts are assessed within the value-chain boundary here.
- StakeholdersStakeholder reporting covers what each group is told in general. Disclosure here is limited to the sustainability statement and the claims made within it.
- FinanceFinancial reporting owns the statutory accounts. The sustainability statement sits beside them and has to reconcile with them where the two touch the same numbers.
- Brand CoreEnvironmental and social claims in marketing draw on the claim substantiation file here; the brand narrative carries them, it does not originate them.
Filed at the same place
These answer questions that arise at Responsibility too. Where they disagree with this one, the disagreement is the useful part.
- The triple bottom lineAccount for a company’s social and environmental results as seriously as its financial ones.
- Doughnut economicsA good economy stays above a social foundation of basic needs and below an ecological ceiling set by the planet.
- Theory of changeSpell out, step by step, why the things you do should lead to the change you want to see.
- Right-versus-right dilemmasThe hardest ethical choices are not between right and wrong but between two things that are both right.
- The GRI StandardsA widely used common structure for reporting an organisation’s impacts on the economy, the environment and people.
- Science-based targetsSet emissions targets by what climate science says is needed, not by what seems achievable from where the company stands.
Elsewhere in Vision Core
These are other people’s models, named here so you can go to the source and use them properly. The Omnigoal is not affiliated with their authors and is not endorsed by them; nothing of theirs is reproduced here — no canvas, no diagram, no wording. Each is described in our own words, with the originator credited, because the framework is a place to put thinking, not a replacement for the people who did it. Model names and trademarks belong to their respective owners and are used here only to refer to the work itself.
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