How do we document the DMA process so it stands up to scrutiny?

Build documentation while the assessment happens. Every methodological decision, scoring rationale and stakeholder consultation should generate a record at the moment it occurs, filed sequentially so an auditor can follow the process from first scoping decision to signed-off result. Separately, ESRS 2 requires you to publish a description of the process itself.

Start on day one

The single most useful habit is collecting documents from the first day of the assessment and filing them in sequence. Scorecards, spreadsheets, longlists, meeting minutes. An auditor should be able to pick the file up and see how the process started and every step that led to the final results being approved.

Do that and the audit conversation is short. Skip it and there’s a lot of back and forth, because every question requires the team to go and reconstruct an answer.

Write it while you’re doing it

The methodology document and the evidence file should be growing alongside the assessment rather than being assembled from memory at the end.

Accuracy is the reason, more than tidiness. Reasoning recorded months later is the reasoning people can remember, which isn’t reliably the reasoning they applied at the time. Retrospective documentation also tends to be smooth in a way that real decision-making isn’t, and auditors notice when a process reads as though nobody ever changed their mind.

Where the approach did change partway through, record it. A documented change of direction is a sign of a live process. An undocumented one looks like an inconsistency.

Timing pressure is what breaks this

DMAs almost always take longer than companies expect, and documentation is the first thing sacrificed when time runs short.

Start too late and the parts that get squeezed are the parts an auditor looks at hardest. Documentation written retrospectively because nobody had time to record reasoning as decisions were made. Judgement calls taken quickly and never revisited. None of it looks like a shortcut at the time, and all of it surfaces months later in assurance.

Start too early and you’ve got a different problem, which is an assessment that no longer reflects the business by the time you report.

Plan backwards from the reporting deadline, give the methodology and evidence file more room than feels necessary, and build in a checkpoint before you report to review whether anything material has changed since the assessment was made. A DMA that’s early and unchecked is no safer than one done in a rush.

What you publish about the process

Some of this gets published. Under ESRS 2 you disclose a description of the process itself: its scope and governance, the methodology and thresholds you used, whether and how stakeholder views were incorporated, and the date of the assessment along with any significant methodology changes since last time.

Writing that section is much easier when the underlying records exist. It’s close to impossible when they don’t, short of inventing something, which is why generic regulatory text tends to appear in the reports where the evidence file is thin.

The test

If a junior colleague sat down a year from now and tried to reconstruct the logic of any conclusion from the documentation alone, could they? If not, the documentation isn’t finished, however complete it feels to the people who were there.

Kōan has worked on materiality assessments for 9 years, with companies from listed multinationals to first-time reporters across Europe, Asia and the US. If you want a second pair of eyes on your methodology before your auditor finds the gaps, get in touch.

Dixie De Winne, Kōan
Published 21 October 2026 · Last reviewed 04 October 2026

Dixie De Winne works on reporting and regulatory projects at Kōan, including double materiality assessments, gap analyses and reporting roadmaps.