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 [Responsible Production & the Circular Economy](/categories/responsible-production-circular-economy)

 # What the Revised ESRS Mean for Double Materiality

 

##### The revised European Sustainability Reporting Standards significantly simplify reporting requirements, but double materiality remains at their core. The next challenge is turning that principle into practical business decision-making.

 

 

 Oct 5, 2026 3:20 PM ET

  Campaign:  [Policy and Regulation](/news/campaign/policy-and-regulation)  ![worker in textile factory](https://3blcdn.com/styles/carousel_2x/s3/2026-10/revised-esrs-blog-cascale-2048x1335_1791227262.jpg)

 

by Gabriele Ballero, [Cascale](https://cascale.org/?utm_source=website&utm_medium=blog&utm_campaign=public-affairs-publications)

### **Key Takeaways**

- The revised ESRS cut reporting requirements significantly, and double materiality remains the basis for deciding what to report.
- The standards now reward focus: concentrating assessment where material impacts, risks and opportunities are actual or potential, which for most consumer goods companies means the manufacturing value chain.
- Existing facility-level data can strengthen that prioritization. It supports the regulatory assessment rather than replacing it.
- Manufacturers are often asked for similar information in different formats. Better alignment between regulation and existing systems is the most practical way to reduce that burden.
- Implementation experience from brands and manufacturers have already informed the revised version of ESRS.

### **Double Materiality Remains at the Core**

The European sustainability reporting landscape has changed considerably over the past year.

The revised European Sustainability Reporting Standards (ESRS), now published in the Official Journal of the European Union, significantly simplify reporting requirements. Mandatory data points have been reduced by around 60 percent, processes have been streamlined, and greater flexibility has been introduced for companies applying the standards.

One important principle, however, remains firmly in place: double materiality.

Under the revised ESRS, companies must continue to consider both their material impacts on people and the environment and the sustainability-related risks and opportunities that can affect their business.

The question is therefore no longer whether double materiality will survive regulatory simplification. It is how companies can apply it effectively, taking into consideration the flexibility added on how companies can conduct this assessment..

### **From Reporting Requirements to Better Decisions**

Double materiality has the greatest value when it goes beyond determining what appears in a sustainability report.

Environmental and social impacts across global value chains — from emissions and water use to working conditions — can increasingly interact with financial risks through regulation, resource constraints, supply disruption, and changing market expectations. Understanding these connections can help companies determine where sustainability issues are most significant and where action is needed.

The revised ESRS recognize this need for greater focus. Rather than requiring companies to assess every possible sustainability issue across every part of their value chain, the standards allow companies to implement the “top-down approach” allowing companies to conduct their assessment starting from their business model. This allows organisations to spare resources and focus those on what truly matters- better prioritization on how they address those sustainability impacts.

For most consumer goods companies, that prioritization points to the manufacturing value chain, where much of the environmental impact sits and where good facility-level data matters most. This is where Cascale’s public affairs team aims to bridge the gaps for companies navigating increased reporting obligations and greater supply chain oversight.

### **Connecting Policy, Data and Implementation**

The next challenge is practical. Companies already use sustainability methodologies, datasets and management systems to understand environmental and social performance across their operations and supply chains. As regulation evolves, companies need greater clarity on how those existing systems relate to new regulatory expectations.

This does not mean turning voluntary sustainability frameworks into compliance tools. Regulatory requirements and performance frameworks serve different purposes. However, there is real value in understanding where they align, where existing data can support regulatory readiness, and where gaps remain.

That is work Cascale has started. The team has begun mapping how the frameworks it stewards relate to regulatory requirements, and a more detailed look at how the Higg Facility Environmental Module (FEM) relates to the revised ESRS is now getting underway. The aim is clarity for members on where facility data can inform their assessments and support their ESRS preparation ESRS aligned report. Of course, this is not a claim that any tool delivers compliance.

Better alignment matters most for manufacturers, who are often asked to provide similar sustainability information multiple times, in different formats, for different customers. Reducing that duplication is one of the most practical benefits simplification could bring.

The flow of information should also work in both directions. Implementation experience from companies and manufacturers can provide policymakers and those developing the standards with valuable evidence about whether reporting requirements are practical, whether the necessary data exists, and where additional clarity may be needed.

### **From Compliance to Strategy**

The revised ESRS represent an important moment for sustainability reporting in Europe. They reduce complexity, but they do not remove the underlying need for companies to understand their impacts, risks and opportunities.

For Cascale, the role is twofold: helping members understand what the revised standards mean for them in practice, and bringing the implementation realities of brands and manufacturers, particularly in producing countries, to the people refining the rules.

As sustainability regulation matures, the objective should not simply be to generate more information. It should be to make sustainability information more useful — helping companies understand what matters, act on it, and contribute evidence that supports better policy and better business decisions.

That is where double materiality can move beyond reporting and become part of strategy.

Cascale members can follow these developments through the [Policy & Public Affairs Knowledge Hub](https://connect.cascale.org/topics/53745/feed) and monthly policy monitoring. For more on how facility-level environmental data supports prioritization, see our [Higg Facility Tools content](https://cascale.org/tools-programs/higg-index-tools/facility-tools/).

*Gabriele Ballero is Cascale's manager of public affairs.*



 

 

 

 

 

 

 

 [![Cascale logo](/sites/default/files/2024-02/logo_Cascale.png)](/profiles/cascale)

 

 

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