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Standards and reporting

Materiality Stakeholder Engagement

Useful engagement helps an assessment team understand effects and evidence gaps without turning materiality into a popularity contest.

What is stakeholder engagement meant to establish?

Engagement with affected stakeholders informs the evidence about impacts, rather than deciding materiality through a vote on preferred sustainability topics Revised ESRS 1, paragraph 42 and AR 24.

Understand effectsRequirements and evidence

Module 01 / 03

Affected people

Identify whose interests are or could be affected.

Read the detailed guidance and evidence

The design question is what the assessment team needs to understand and whose experience can help it understand that issue.

The Accounting Directive distinguishes information about the undertaking’s impacts from information about its development, performance and position, so participation should not blur those purposes Accounting Directive, Article 19a(1).

A broad survey about favourite ESG themes may reveal interests, but it can miss a serious effect experienced by a small or less visible group.

Use the sustainability reporting standards hub to identify the reporting basis and the assessment method for the wider decision process.

Who belongs in the engagement map?

Revised ESRS describes affected stakeholders across operations and direct and indirect upstream and downstream relationships, including proxies such as civil society and trade unions Revised ESRS 1, paragraph 42 and AR 23.

Editorial participant map; categories can overlap and need explanation in the actual context.
Evidence questionReview approachWhat to avoid
Affected groupPeople experiencing or potentially experiencing an effectOnly people easiest to contact
RepresentativeSomeone with a relevant basis for representing experienceTreating every intermediary as equally informed
Technical expertSomeone who can help interpret the effectConfusing technical judgement with lived experience
Information userSomeone using the resulting report for decisionsAssuming report users represent every affected group

Must the company run a new survey?

Revised ESRS allows existing due-diligence engagement results to inform materiality without a separate engagement process, while also allowing direct input into the assessment Revised ESRS 1, AR 24.

Reuse thoughtfullyRequirements and evidence

Module 01 / 03

Existing channels

Review relevant engagement already undertaken.

Read the detailed guidance and evidence

Start by reviewing relevant worker dialogue, complaints, community engagement and other existing records rather than commissioning a questionnaire before defining the information gap.

GRI 2 asks organisations to describe their stakeholder-engagement approach, including categories, purpose and how meaningful engagement is sought GRI 2, disclosure 2-29.

The OECD Guidelines place identifying and assessing adverse impacts within a wider due-diligence cycle of action, tracking and communication, so an assessment survey should not be treated as the whole response OECD Guidelines 2023, commentary 15.

An editorial gap review tests whether existing information is sufficiently relevant, current and specific for the decision, without assuming every channel has equal coverage.

How can existing evidence be screened?

These editorial questions distinguish useful engagement records from records that merely demonstrate that a contact occurred.

Editorial evidence screening rather than a mandatory questionnaire design.
Evidence questionReview approachWhat to avoid
PurposeWhat issue was the engagement designed to understand?Using satisfaction data as a complete impact assessment
CoverageWho participated and who may be missing?Calling a convenient sample representative
TimingDoes the evidence describe the current activity?Reusing an outdated account after a major change
InterpretationCan the assessor trace what was actually said?Keeping only a favourable presentation summary

How would a fictional repair service design engagement?

In this fictional case, a repair-service group investigates whether its contact arrangements create barriers for some customers instead of relying only on general satisfaction results.

Fictional access reviewRequirements and evidence

Module 01 / 03

Issue

Understand the contact barrier and its consequences.

Read the detailed guidance and evidence

The group receives detailed accounts from customers who cannot use one of its contact routes, while its existing satisfaction survey mainly reaches customers who completed a booking.

The assessment team recognises that the survey’s response population may exclude the very people whose experience it needs to understand.

It plans an appropriate way to gather those accounts and uses synthetic examples in internal planning rather than circulating identifiable customer stories unnecessarily.

The UN Guiding Principles call for meaningful consultation with potentially affected groups and other relevant stakeholders when assessing human-rights impacts, but are an internationally endorsed standard rather than a new UK statutory survey duty UN Guiding Principles 18 and commentary.

Which questions produce usable information?

This fictional editorial interview design asks about experience, mechanism and uncertainty without requiring participants to score the company’s overall sustainability.

Original fictional prompts; the appropriate method depends on the actual participants and circumstances.
Evidence questionReview approachWhat to avoid
ExperienceWhat happened when you tried to use the contact route?Which ESG topic is most popular?
ConsequenceWhat did that change mean for you?How many points should we give accessibility?
ContextWere another route or support options available?Would you endorse our improvement programme?
UncertaintyWhat are we missing or misunderstanding?Please confirm the proposed materiality conclusion

How should conflicting accounts be handled?

Stakeholder evidence is an input to assessing significant impacts, and GRI 3 retains impact significance as the criterion for material topics rather than the number of supporting responses GRI 3, steps 3–4.

Preserve disagreementRequirements and evidence

Module 01 / 03

Provenance

Retain the context and basis of each account.

Read the detailed guidance and evidence

In the fictional repair case, completed bookings and satisfactory internal response times do not necessarily contradict an account from a customer who could not start the process.

The reviewer first asks whether the records cover different populations, routes or periods before treating one source as disproving the other.

A small number of detailed accounts can identify an important evidence gap, while a large response count does not establish seriousness, causation or representativeness.

Record limitations and the reason for preferring an interpretation so that the assessment does not silently convert unresolved disagreement into a consensus claim.

What belongs in the interpretation record?

An editorial interpretation record connects what participants said with the assessment question and the remaining uncertainty.

Fictional review structure; it does not establish the repair group’s materiality result.
Evidence questionReview approachWhat to avoid
Source contextParticipant category, route and relevant activityUnnecessary personal details in a general register
Reported effectAn accurate account of the experienceA rewritten quote that strengthens the claim
Other evidenceProcess records or expertise that may explain itAssuming internal data is automatically decisive
Assessment implicationThe criterion or information gap affectedA majority vote on whether harm matters

How do affected stakeholders and investors differ?

UK SRS S1’s financial-information purpose concerns primary users, while GRI considers significant impacts and ESRS double materiality considers both dimensions UK SRS S1, objective and paragraphs 17–19 GRI 3, introduction Revised ESRS 1, paragraph 35.

Ask the right questionRequirements and evidence

Module 01 / 03

Affected group

Explain the effect experienced or anticipated.

Read the detailed guidance and evidence

An investor interview can help the team understand a financial-information question without representing every customer affected by the fictional contact barrier.

Conversely, an affected customer need not estimate the company’s future cash flows for their experience to inform the impact assessment.

The same engagement programme can collect relevant information for both inquiries, provided the questions and interpretation keep their purposes visible.

Use impact materiality and financial materiality assessment to develop the two lines of reasoning rather than forcing one group to speak for the other.

What should happen after people contribute?

This editorial feedback plan distinguishes assessment communication from the separate work of addressing an identified impact.

Editorial follow-through; a listening exercise is not itself evidence of an improved outcome.
Evidence questionReview approachWhat to avoid
Acknowledge the contributionExplain its intended use and next stepsPromising a particular materiality result
Follow up gapsAsk focused questions where the account is unclearRepeating broad surveys without resolving the issue
Communicate appropriatelyExplain relevant process or decision developmentsPublishing sensitive individual accounts unnecessarily
Track action separatelyKeep response progress linked to the evidencePresenting a consultation as proof the impact ended

How can environmental effects be represented?

Revised ESRS recognises nature as a possible silent affected stakeholder, which makes the choice and interpretation of relevant evidence important Revised ESRS 1, AR 23.

Interpret relevant evidenceRequirements and evidence

Module 01 / 03

Context

Identify the environmental effect being investigated.

Read the detailed guidance and evidence

A public preference survey cannot itself measure an environmental condition or represent every ecological effect of an activity.

An editorial evidence plan identifies relevant observations, studies or expertise, preserves their limits and avoids presenting a person’s general concern as a site-specific scientific finding.

What should the team ask about a proxy source?

These editorial questions test relevance without suggesting one representative can settle every issue.

Editorial source-quality review for representatives, proxies and experts.
Evidence questionReview approachWhat to avoid
BasisWhat experience or expertise informs the contribution?Assuming a title establishes knowledge of this activity
CoverageWhich group or environmental condition is addressed?Claiming universal representation
LimitationsWhat cannot be concluded from this source?Replacing uncertainty with a stronger summary

What should the reporting team receive?

GRI 1’s reporting principles include accuracy, balance and verifiability, which support preserving the evidence and its limitations instead of only the favourable summary GRI 1, section 4.

Make evidence usableRequirements and evidence

Module 01 / 03

Coverage

Show who and what the work considered.

Read the detailed guidance and evidence

A useful handover contains the engagement purpose, participant categories, method, evidence references, interpretation and unresolved gaps without turning the report into a repository of personal accounts.

The UN Global Compact warns that good practices in one area do not offset harm elsewhere, so positive feedback should not erase an unrelated concern in the interpretation UN Global Compact, Ten Principles.

EFRAG IG 1 is non-authoritative May 2024 guidance about the 2023 ESRS, while the revised regulation applies from financial years beginning 1 January 2027 and provides specified 2026 choices EFRAG IG 1, disclaimer Regulation 2026/1563, Articles 2–3.

An assessment-software brief or consultancy brief can request this evidence handover and a clear account of coverage, rather than a promised consensus or guaranteed compliance result.

The double materiality worked examples show how original fictional cases preserve separate impact and financial reasoning.

How can the team plan useful engagement?

This is an editorial preparation sequence rather than a prescribed assessment method or a conformity checklist.

  1. 101

    Define the question

    State the impact or financial-information uncertainty the engagement should help resolve.
  2. 202

    Map affected groups

    Identify relevant experience across activities and relationships, including less visible groups.
  3. 303

    Review existing evidence

    Inspect engagement already undertaken and its purpose, timing and coverage.
  4. 404

    Identify missing voices

    Explain whose experience is absent before choosing additional methods.
  5. 505

    Choose an appropriate route

    Design a practical way for relevant people or representatives to contribute.
  6. 606

    Ask about effects

    Use clear questions about experience and consequences rather than a popularity score.
  7. 707

    Interpret carefully

    Compare sources, preserve disagreements and document limitations in the evidence.
  8. 808

    Connect the assessment

    Explain how the information informs the relevant criteria and conclusions.
  9. 909

    Hand over and follow through

    Retain the review record and distinguish communication from action on the underlying issue.

Can you download an editable working resource?

This original preparation resource supports evidence and review and does not establish reporting conformity.

Download engagement plan (CSV)

Editorial working resource, not a prescribed or government-approved form.
StepReview
AdaptSet the actual reporting basis, boundary, period and selected requirements
Retain evidenceConnect source records and judgements to each answer
ReviewResolve open issues before making the final reporting claim

Frequently asked

Questions people ask

Does ESRS require a separate stakeholder survey?

Revised ESRS allows existing due-diligence engagement results to inform materiality without a separate engagement process, while permitting additional direct input.

Who are affected stakeholders?

They are individuals or groups whose interests are affected or could be affected by the undertaking’s activities and relevant business relationships.

Can survey scores determine materiality?

They can contribute evidence, but the assessment must still apply the relevant criteria rather than replacing significance with popularity.

Can representatives or experts contribute?

Yes, revised ESRS recognises representatives, proxies and other experts as possible sources of input, while their relevance and evidential limits still need consideration.

Does investor engagement replace affected-group engagement?

No, investors can inform financial-information questions while affected groups provide different evidence about impacts, so the assessment should preserve the different purposes.

What should a consultant or software provider hand over?

An editorial brief can request coverage, methods, evidence references, interpretation, unresolved gaps and how input informed decisions, with no promise that a tool or engagement exercise certifies the result.

Sources

Primary sources

Primary provisions and official owner guidance checked on 26 October 2026; historical and draft resources are labelled in the guide.

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