How do we turn the assessment into a reporting and action plan?

Once scoring is complete, the results drive 3 things: mapping material IROs to ESRS standards and disclosure requirements to establish what you must report, disclosing your process and methodology, and describing your material impacts, risks and opportunities in detail. Everything in your Sustainability Statement traces back to those results.

The three reporting outputs

Map findings to the standards. Take your validated impacts, risks and opportunities and map them to the corresponding topical ESRS disclosure requirements. That determines the scope and structure of your statement and tells you what data you need to collect.

Disclose the process. Governance and scope, methodology and thresholds, stakeholder input, and the date and any methodology changes since your last assessment.

Describe the IROs. For each one, state whether it’s actual or potential, positive or negative, which sustainability topic it belongs to, and where it sits in the value chain. Include an index pointing readers to where each disclosure requirement is addressed, which helps readers and helps auditors.

If you concluded that climate change isn’t material, ESRS E1 requires an explicit justification rather than silent omission.

Wave 1: what to do now

Decide on FY2026 early adoption of the revised standards, and decide soon rather than letting your reporting timeline force it. If you’re switching, have the DMA reviewed against top-down logic before you draft disclosures. Reworking a materiality conclusion once disclosures are half-written costs considerably more than getting the order right.

If you’re staying on the 2023 ESRS for FY2026, check whether your methodology holds under top-down logic, whether conclusions are documented at topic and sub-topic level, and whether the evidence trail meets current auditor expectations.

Re-check your gross impact assessments. If mitigation or remediation crept into the original conclusions rather than being disclosed separately, correct it.

Revisit aggregation. Where results vary by sector, subsidiary, country or site, that variation has to be disaggregated and reported at the level where it arises. A water risk concentrated in one country belongs at country level rather than diluted into a global average, and the reasoning behind the decision needs documenting.

Wave 2: build it right from the start

Start the business model analysis now, using the adopted revised text as the reference point. Scope using the top-down approach from the outset rather than retrofitting a bottom-up process later.

Decide your aggregation logic early, meaning which variations by sector, subsidiary, country or site are likely to need separate disclosure. Map the value chain and identify likely material topics in parallel.

The delegated act was adopted on 3 July 2026 and is in the scrutiny period with the Parliament and Council. Treat the scrutiny period and Official Journal publication as confirmation points rather than starting points. The structural work, meaning business model analysis, stakeholder mapping and value chain scoping, doesn’t depend on the final wording of individual datapoints.

What the assessment gives you beyond the report

The DMA surfaces critical risks and supply chain dependencies early, which gives leadership validated data for decisions about where capital goes. It acts as a filter that drops non-material topics, which saves time and reporting budget. And it gives you something to show B2B customers running their own value chain analysis.

Compliance is why the assessment is mandatory. The rest of it is why doing the assessment well pays for itself.

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.

Melina Gkiolma, Sustainability Consultant, Kōan
Published 28 October 2026 · Last reviewed 09 October 2026

Melina Gkiolma is a sustainability consultant at Kōan, specialising in CSRD and ESRS. She previously worked at Deloitte Luxembourg and is a One Young World Ambassador.