Standards and reporting
Materiality matrix
A materiality matrix is a visual summary of assessment results whose usefulness depends on clear axes, a stated method and a reviewable evidence trail.
What does a materiality matrix actually show?
Use a matrix to explain assessment results rather than substitute for the criteria and decisions that produced them ESRS 1 chapter 3.
Module 01 / 03
Purpose
State the reporting question the graphic supports.
Module 02 / 03
Method
Explain what each position represents.
Module 03 / 03
Record
Link the graphic to the underlying assessment.
Read the detailed guidance and evidence
Revised ESRS specifies materiality requirements rather than a compulsory matrix format, so a visual is an editorial presentation choice.
The assessment method explains the decisions and the assessment template retains the working record.
What should the axes mean?
Define each axis in the chosen reporting context instead of assuming every materiality chart measures the same thing.
| Record | Useful content | Review question |
|---|---|---|
| Axis label | A stated criterion and reporting perspective. | What is being compared? |
| Position | An explained summary of a judgement. | Can the reader trace the decision? |
| Boundary | The entities, activities and period assessed. | Would a different boundary change the result? |
| Uncertainty | A visible limitation or linked note. | Does a precise point imply unsupported precision? |
Read the detailed guidance and evidence
ESRS double materiality considers impact and financial perspectives in their own right, while UK SRS focuses on financial information for primary users ESRS 1 paragraphs 23–26 UK SRS S1 paragraphs 3 and 18.
Must a matter score highly on both axes?
No: a material impact, risk or opportunity can require relevant information without both materiality perspectives passing a combined test ESRS 1 paragraphs 23–26.
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Impact
Assess effects on people and environment.
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Financial
Assess risks and opportunities affecting financial prospects.
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Selection
Determine the material information for the relevant matter.
Read the detailed guidance and evidence
A diagram that reports only the upper-right corner can mislead if it suppresses a matter material from one perspective.
The financial materiality guide develops the financial pathway rather than treating stakeholder popularity as a finance measure.
What does the fictional example contain?
The fictional Halden Equipment case keeps two conclusions and their supporting evidence behind each point.
| Record | Useful content | Review question |
|---|---|---|
| Contractor concern | Potential harm to contractor workers. | What supports the impact judgement? |
| Operational dependency | A specialist repair provider supports production. | What could affect financial prospects? |
| Evidence gap | The affected population is unresolved. | Has uncertainty been hidden by the chart? |
| Reporting decision | Information selected after assessment. | Does the point connect to the final disclosure? |
Read the detailed guidance and evidence
Halden is invented and the chart does not certify its reporting position.
The example deliberately avoids numerical scores so the explanation cannot be mistaken for an official threshold.
How should impact severity enter the explanation?
Actual negative impacts are assessed by severity, while potential negative impacts combine severity and likelihood with a specific human-rights qualification ESRS 1 paragraph 40.
Module 01 / 03
Severity
Consider scale, scope and irremediable character where relevant.
Module 02 / 03
Likelihood
Apply it to potential rather than actual negative impacts.
Module 03 / 03
Human rights
Severity takes precedence for potential negative human-rights impacts.
Read the detailed guidance and evidence
Halden’s fictional reviewer keeps that reasoning in the record instead of multiplying unrelated numbers simply to create coordinates.
Positive impacts are assessed separately without netting them against negative impacts ESRS 1 paragraph 44.
Do you need a five-point numerical scale?
Qualitative analysis may be sufficient and the revised ESRS does not prescribe a universal scoring model ESRS 1 AR 13 and AR 19.
| Record | Useful content | Review question |
|---|---|---|
| Method | Describe qualitative considerations or justified thresholds. | Can another reviewer understand the conclusion? |
| Calibration | Explain how the chosen method is applied consistently. | Is a default presented as law? |
| Override | Retain a reasoned change and reviewer. | Was a score altered without evidence? |
| Outcome | Keep the assessment conclusion distinct from a score. | Does the number conceal judgement? |
Read the detailed guidance and evidence
UK SRS S1 also specifies no universal materiality threshold, so an imported percentage cannot settle its information-materiality decision UK SRS S1 paragraph B19.
Can survey results decide the matrix?
Relevant engagement can inform materiality, but a popularity ranking is not a substitute for assessing the applicable criteria ESRS 1 AR 24–25.
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Who
Identify the groups represented and limitations.
Module 02 / 03
What
Retain the issue and supporting information.
Module 03 / 03
How
Explain how the evidence informs the decision.
Read the detailed guidance and evidence
Halden’s fictional worker concern remains visible even if a broader survey prioritises a different subject.
The assessment record should preserve vulnerable or differing perspectives rather than averaging away the issue.
How do GRI and financial materiality differ?
Label the reporting basis because GRI identifies significant organisational impacts, while financial reporting standards focus on decision-useful sustainability-related financial information GRI 1 section 2.2 IFRS S1 paragraphs 3 and 18.
| Record | Useful content | Review question |
|---|---|---|
| GRI | Impacts and their significance. | Are impact criteria being replaced by financial exposure? |
| IFRS or UK SRS | Information for primary-user decisions. | Is stakeholder interest being mistaken for material financial information? |
| ESRS | Separate impact and financial perspectives. | Is one material perspective being suppressed? |
| Presentation | Purpose-specific explanation. | Can the reader tell which basis applies? |
Read the detailed guidance and evidence
GRI 3 provides its own process for determining material topics and reporting management of them GRI 3 section 1 and disclosures 3-1 to 3-3.
Does a plotted topic determine every disclosure?
No: revised ESRS distinguishes selecting material matters from selecting material information and adds entity-specific information where needed ESRS 1 paragraphs 11 and 25–30.
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Matter
Retain the assessment conclusion.
Module 02 / 03
Information
Identify the material answer required.
Module 03 / 03
Evidence
Support the particular disclosure.
Read the detailed guidance and evidence
A coloured point labelled workforce does not automatically require every imaginable worker datapoint.
The ESRS datapoints guide explains why a list is not a universal company checklist.
EFRAG’s draft supporting list expressly cannot replace the standard or be used as a checklist Explanatory note, paragraph 1.
Which source version should accompany the chart?
Retain the reporting instrument and guidance edition so a historical methodology does not silently become the source of revised paragraph references.
| Record | Useful content | Review question |
|---|---|---|
| Revised ESRS | Published instrument and applicable year. | Are the requirement references current for this basis? |
| Historical IG1 | Non-authoritative 2023-standards guidance. | Is older guidance clearly labelled? |
| Education | Explanatory material and date. | Is an illustration mistaken for a requirement? |
| Comparison | Dated interoperability mapping. | Does a historical comparison claim current equivalence? |
Read the detailed guidance and evidence
EFRAG’s guidance page identifies IG1–IG3 as support for the 2023 standards IG1 disclaimer EFRAG guidance status.
IFRS educational material adds no requirements, and the joint 2024 interoperability guidance concerns its stated standards basis IFRS materiality education Joint interoperability guidance.
What should a reviewer ask before publication?
Trace selected points to evidence and test what the visual could cause a reader to misunderstand.
Module 01 / 03
Axes
Are criteria and perspective explained?
Module 02 / 03
Selection
Are single-perspective material matters retained?
Module 03 / 03
Precision
Are limitations visible rather than disguised by exact coordinates?
Read the detailed guidance and evidence
Halden’s fictional reviewer finds that the chart omitted an unresolved topic and adds a linked explanation of its review status.
That adjustment improves transparency without claiming that the visual itself decides the final reporting conclusion.
The principles guide develops clarity and verifiable support.
What should software or consultants hand over?
Request the underlying evidence and decisions as well as the chart so another reviewer can inspect how it was produced.
| Record | Useful content | Review question |
|---|---|---|
| Method | Criteria, axes and any chosen thresholds. | Can the logic be explained without a salesperson? |
| Evidence | Source records and uncertainty. | Can points be traced? |
| History | Changes and review reasons. | Can earlier decisions be reconstructed? |
| Export | Editable register and report mapping. | Can the next team continue the work? |
Read the detailed guidance and evidence
The double materiality software guide provides a demonstration brief and the consultancy guide separates service outputs.
The standards homepage identifies the wider reporting basis before a diagram is selected.
When is a matrix worth using?
Use it where it helps readers understand an assessment and keep the fuller record available where the picture would otherwise oversimplify.
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Clarity
The graphic answers a reader’s question.
Module 02 / 03
Limits
Complexity and uncertainty remain understandable.
Module 03 / 03
Traceability
Each point connects to a reviewable record.
Read the detailed guidance and evidence
A short table or written explanation may communicate a small set of conclusions more clearly than coordinates.
The fictional Halden case is a teaching aid and does not prescribe how an actual undertaking must present its results.
How can a team build a useful matrix?
This editorial nine-step workflow supports clear presentation rather than prescribing an ESRS procedure.
- 101
Fix the purpose
Name reporting basis and audience. - 202
Define the boundary
Record period and activities assessed. - 303
Assess the matters
Use the applicable criteria and evidence. - 404
Keep perspectives separate
Retain impact and financial conclusions. - 505
Define the axes
Explain what the plotted positions mean. - 606
Preserve uncertainty
Keep unresolved evidence visible. - 707
Map disclosures
Connect conclusions to selected information. - 808
Challenge the visual
Test omission, precision and misunderstanding. - 909
Retain the file
Keep method, evidence and review history.
Frequently asked
Questions people ask
Does ESRS require a matrix?
Revised ESRS specifies assessment and disclosure requirements rather than a mandatory matrix format.
Must a topic be high on both axes?
No: materiality can arise from either perspective and the information selection follows the relevant conclusion.
Is a five-point scale compulsory?
No: qualitative analysis may be sufficient.
Can a survey determine the result?
Engagement can inform assessment but does not replace the applicable materiality criteria.
Does a material topic require every datapoint?
No: topic selection and information selection are distinct decisions.
Can software certify the matrix?
A tool can support the record but the chart does not establish reporting compliance or replace undertaking-specific judgement.
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 2026/1563
- Department for Business and TradeUK SRS S1
- IFRS FoundationIFRS S1 issued text
- Global Reporting InitiativeGRI 1 Foundation 2021
- Global Reporting InitiativeGRI 3 Material Topics 2021
- EFRAGIG1 Materiality Assessment, May 2024
- EFRAGESRS implementation guidance documents
- IFRS FoundationMaterial information educational material, November 2024
- EFRAG Secretariat2026 draft datapoints explanatory note
- IFRS Foundation and EFRAGESRS–ISSB interoperability guidance, May 2024