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SwedenFAR

FAR resets double materiality guide to ESRS, trims over-readings

FAR's rewritten guide anchors double materiality in ESRS and corrects common over-readings: no actor-by-actor value-chain map, no full re-analysis yearly, no policy per topic, no published workfile.

By Taxxa AI OyPublished 15 October 2026

Accounting & Reporting

Industry: Across industries

Double materiality analysis is the foundation of sustainability reporting under the European Sustainability Reporting Standards, ESRS. FAR has rewritten its guide to anchor every step in ESRSFAR — and the rewrite narrows several widespread misunderstandings about what reporters must do.

A sustainability matter is material when it meets the criteria for impact materiality or financial materiality, or both. Impact materiality covers how the company affects people and the environment through its own operations and its business relationships in the value chain — actual and potential, positive and negative impacts, from greenhouse-gas emissions and resource use to working conditions and human rights. Financial materiality covers sustainability-related risks and opportunities that have, or can reasonably be expected to have, material effects on the company's financial position, results, cash flows, access to finance or cost of capital over the short, medium or long term — arising from climate change, rule changes, the company's own impacts or its dependence on natural resources and labour.

CSRD requires companies in scope to report on both their impact on people and the environment and how sustainability matters affect the company financially, with the requirements specified in ESRS. The analysis decides which sustainability matters and disclosures are material for reporting; it can also feed strategy and risk management, but reporting duties must be kept separate from duties to take particular measures in the business.

Companies obliged to report under ESRS must assess materiality from both perspectives. Who is covered, and when the duty starts, depends on applicable legislation and transitional rules, and group relationships and exemptions can affect the duty. The rules are in flux: the EU has decided to narrow CSRD's scope — through the Omnibus 1 directive, only companies with more than 1,000 employees and turnover above 450 MEUR will be covered once implementedFAR — and Sweden has postponed the reporting start for certain company categories. Preparers must therefore distinguish decided EU changes, their implementation in Swedish law, and which rules apply to a given financial year.

ESRS prescribes no single fixed workflow; the method must fit the company's operations and circumstances. Stakeholder engagement is central to due diligence and the materiality assessment under ESRS 1, and dialogue with affected stakeholders can supply important input — but ESRS does not generally prescribe a particular form of stakeholder dialogue.

The value chain need not be mapped actor by actor.FAR Companies must consider both their own operations and impacts connected through business relationships, products and services, upstream and downstream, without limiting the assessment to direct contractual relationships — but where chain information cannot be collected after reasonable efforts, ESRS 1 permits estimates using sector-average data or other proxies, provided the result still meets the qualitative characteristics of information.Europa

A prior analysis need not be redone in full every yearFAR: at each annual reporting round the company must assess whether earlier conclusions still hold, updating on material changes.FAR And the report need not publish the whole internal analysis fileFAR, nor must the company hold a policy for every material matterFAR — the sustainability report discloses the process and the material impacts, risks and opportunities identified, and a matter can require reporting even where the company has no policy, measures or targets for it yet.FAR Conversely, companies outside the reporting duties that supply data to reporting business partners do not thereby become CSRD reporters or obliged to run a full double materiality analysis under ESRS.FAR

Legal basis: Commission Delegated Regulation (EU) 2023/2772 (ESRS 1), including the double materiality principle and the value-chain estimation rulesEuropa, and Directive (EU) 2022/2464 (CSRD) as amended by the Omnibus 1 directive.FAR

Review the double materiality analysis against the ESRS wording — drop over-readings on actor-by-actor mapping, yearly full re-analysis, a policy per matter and published workfiles — and check transitional rules for which financial year the duty bites.

Sources