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.
Module 01 / 03
Affected people
Identify whose interests are or could be affected.
Module 02 / 03
Information
Learn about the nature and context of effects.
Module 03 / 03
Judgement
Apply the relevant criteria after examining the evidence.
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.
| Evidence question | Review approach | What to avoid |
|---|---|---|
| Affected group | People experiencing or potentially experiencing an effect | Only people easiest to contact |
| Representative | Someone with a relevant basis for representing experience | Treating every intermediary as equally informed |
| Technical expert | Someone who can help interpret the effect | Confusing technical judgement with lived experience |
| Information user | Someone using the resulting report for decisions | Assuming 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.
Module 01 / 03
Existing channels
Review relevant engagement already undertaken.
Module 02 / 03
Coverage
Check whose experience those channels capture.
Module 03 / 03
Gaps
Design additional work where useful evidence is absent.
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.
| Evidence question | Review approach | What to avoid |
|---|---|---|
| Purpose | What issue was the engagement designed to understand? | Using satisfaction data as a complete impact assessment |
| Coverage | Who participated and who may be missing? | Calling a convenient sample representative |
| Timing | Does the evidence describe the current activity? | Reusing an outdated account after a major change |
| Interpretation | Can 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.
Module 01 / 03
Issue
Understand the contact barrier and its consequences.
Module 02 / 03
Participants
Seek relevant affected experience and informed representatives.
Module 03 / 03
Evidence
Connect accounts with the service-process record.
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.
| Evidence question | Review approach | What to avoid |
|---|---|---|
| Experience | What happened when you tried to use the contact route? | Which ESG topic is most popular? |
| Consequence | What did that change mean for you? | How many points should we give accessibility? |
| Context | Were another route or support options available? | Would you endorse our improvement programme? |
| Uncertainty | What 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.
Module 01 / 03
Provenance
Retain the context and basis of each account.
Module 02 / 03
Difference
Separate conflicting evidence from different experiences.
Module 03 / 03
Review
Identify the evidence needed to resolve uncertainty.
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.
| Evidence question | Review approach | What to avoid |
|---|---|---|
| Source context | Participant category, route and relevant activity | Unnecessary personal details in a general register |
| Reported effect | An accurate account of the experience | A rewritten quote that strengthens the claim |
| Other evidence | Process records or expertise that may explain it | Assuming internal data is automatically decisive |
| Assessment implication | The criterion or information gap affected | A 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.
Module 01 / 03
Affected group
Explain the effect experienced or anticipated.
Module 02 / 03
Financial user
Explain information relevant to resource decisions.
Module 03 / 03
Assessment team
Keep the reporting tests distinct.
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.
| Evidence question | Review approach | What to avoid |
|---|---|---|
| Acknowledge the contribution | Explain its intended use and next steps | Promising a particular materiality result |
| Follow up gaps | Ask focused questions where the account is unclear | Repeating broad surveys without resolving the issue |
| Communicate appropriately | Explain relevant process or decision developments | Publishing sensitive individual accounts unnecessarily |
| Track action separately | Keep response progress linked to the evidence | Presenting 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.
Module 01 / 03
Context
Identify the environmental effect being investigated.
Module 02 / 03
Expertise
Seek relevant scientific or technical interpretation.
Module 03 / 03
Limits
Explain what a proxy source cannot establish.
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.
| Evidence question | Review approach | What to avoid |
|---|---|---|
| Basis | What experience or expertise informs the contribution? | Assuming a title establishes knowledge of this activity |
| Coverage | Which group or environmental condition is addressed? | Claiming universal representation |
| Limitations | What 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.
Module 01 / 03
Coverage
Show who and what the work considered.
Module 02 / 03
Interpretation
Explain how input changed the assessment.
Module 03 / 03
Limitations
Keep gaps, disagreement and uncertainty visible.
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.
- 101
Define the question
State the impact or financial-information uncertainty the engagement should help resolve. - 202
Map affected groups
Identify relevant experience across activities and relationships, including less visible groups. - 303
Review existing evidence
Inspect engagement already undertaken and its purpose, timing and coverage. - 404
Identify missing voices
Explain whose experience is absent before choosing additional methods. - 505
Choose an appropriate route
Design a practical way for relevant people or representatives to contribute. - 606
Ask about effects
Use clear questions about experience and consequences rather than a popularity score. - 707
Interpret carefully
Compare sources, preserve disagreements and document limitations in the evidence. - 808
Connect the assessment
Explain how the information informs the relevant criteria and conclusions. - 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.
| Step | Review |
|---|---|
| Adapt | Set the actual reporting basis, boundary, period and selected requirements |
| Retain evidence | Connect source records and judgements to each answer |
| Review | Resolve 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.
- Official JournalRevised ESRS, Regulation (EU)2026/1563, Annex I
- EUR-LexAccounting Directive 2013/34/EU, consolidated 18 March 2026
- Global Reporting InitiativeGRI 1: Foundation 2021
- Global Reporting InitiativeGRI 2: General Disclosures 2021
- Global Reporting InitiativeGRI 3: Material Topics 2021
- Department for Business and TradeUK SRS S1, February 2026
- EFRAGIG 1 Materiality Assessment, May 2024, non-authoritative 2023-ESRS guidance
- OHCHRUN Guiding Principles on Business and Human Rights, Principles 17–18
- OECDOECD Guidelines for Multinational Enterprises,2023
- UN Global CompactThe Ten Principles
Continue reading
Read next
Assessment method
Place engagement within the wider process.
Impact materiality
Connect accounts with the relevant criteria.
GRI materiality
Understand material-topic determination.
Worked examples
Practise keeping two conclusions separate.
Assessment software
Test evidence, access and interpretation handovers.