Although the scope of the CSRD has been narrowed, the double materiality assessment remains a legal and strategic requirement for companies still in scope. 

The Omnibus package, updated in June 2025 and politically endorsed by the Council of the EU, proposes key adjustments to ease compliance. Although not yet law, it is under review by the European Parliament, with approval expected by late 2025 or early 2026. 

This table below summarises the main changes introduced: 

Under the CSRD, companies are required to assess sustainability topics from two complementary perspectives:  

This dual lens helps companies identify key risks, opportunities, and strategic priorities. Each material topic (such as climate change, data protection, or biodiversity) should be assessed in terms of: 

• Impacts: actual or potential positive or negative effects on people or the planet. 

• Risks: threats that could negatively affect the company. 

• Opportunities: factors that could create value or competitive advantage

HBX Group renews double materiality assessment in line with CSRD:

what does this mean? 

• Option 1: With external support  
  Hire a consultancy to guide the process, draft the report in line with ESRS, and prepare for external assurance. Ideal for companies seeking confidence and efficiency.  

• Option 2: Internally  
  Develop the report in-house using templates and tools, and contract only the mandatory external assurance. Suitable for organisations with internal capacity looking to optimise resources.  

Below is an example of the structured process followed by HBX Group to conduct its double materiality assessment: 

The assessment incorporates multiple sources of input, including stakeholder surveys, focus groups, interviews, sustainability standards, peer benchmarking, and both internal and sectoral risk analyses. 

• Strategic planning: helps anticipate regulatory and societal changes. 

• Risk management: strengthens resilience to climate, social, or reputational crises. 

• Effective collaboration: facilitates dialogue with partners and suppliers around shared sustainability goals. 

• Robust reporting: provides the foundation for CSRD-compliant sustainability disclosures. 

• Access to finance: enhances credibility with investors and financial institutions. 

Although many small and medium-sized enterprises (SMEs) are not directly covered by the CSRD, they may still be indirectly affected—especially if they operate within the value chains of larger companies that are subject to the directive.  

Example: An independent hotel that collaborates with a major tourism group might be asked to share data on its energy use, waste management, or labour practices. This information would help the larger group meet its own sustainability reporting obligations under the CSRD, even though the hotel itself is not legally required to report. ​

Currently, the CSRD does not establish a uniform sanctioning regime across the EU. However, it does require that sustainability reports undergo limited assurance by an external auditor.  

Non-compliance may also lead to indirect consequences such as loss of contracts, reduced access to financing, or reputational damage. ​