For organisations, this means they do not automatically have to repeat their existing DMA in full. The simplifications create scope for a targeted, top-down approach that makes better use of existing information and processes. Companies do not need to analyse every sustainability topic in equal depth. A more detailed assessment is particularly important for topics where it is not yet clear whether they are sufficiently material to be included in the report.
The extent to which this actually reduces the effort involved depends on the maturity of the existing assessment, the availability of information and the organisation’s experience with sustainability reporting. For first-time reporters, a sound evidence base, professional judgement and clear documentation remain essential.
Why the DMA revision matters now
Under the revised ESRS, decision-usefulness becomes the overarching principle for sustainability reporting. Every datapoint included should be relevant to the decisions of investors and other users. For the DMA, this creates more scope to start from the organisation’s strategy, business model, sector and value chain.
The revised ESRS therefore offer opportunities to make the DMA more targeted, but they do not automatically make the process straightforward. The urgency is growing: our CSRD Benchmark shows that more than 70% of companies had already revised their DMA for 2025, often reactively because they still treat it as a compliance requirement. As a result, they are missing the opportunity to make effective use of the new simplifications.
Our benchmark of more than 500 sustainability statements from 24 countries and 68 sectors shows that a top-down approach can help focus effort on the impacts, risks and opportunities that are genuinely relevant.
What has changed: 2023 ESRS versus a simplified DMA
Here are the key differences:
| Area  | 2023 ESRS | DMA under revised ESRS |
| Identifying IROs | Start with the full list of ESRS topics, including sub-topics and sub-sub-topics, and assess the relevance of each item. | Use a top-down approach based on the simplified topic list, without sub-sub-topics. Still describe IROs in sufficient detail to provide a sound basis for robust reporting. |
| Stakeholder engagement | Broad stakeholder input for both identification and scoring, with the engagement method documented for each stakeholder group and each ESRS topic. | Existing channels can be used to validate uncertain IROs. The focus shifts to the outcomes of stakeholder engagement rather than the process itself |
| Scoring and assessment | Scoring is required for all IROs. Unclear guidance on prevention, mitigation and remediation measures often led to recurring discussions with auditors. | Identify material IROs based on strategic insight and available information. Carry out a more detailed assessment only for topics whose materiality is uncertain. New guidance on mitigation measures makes the assessment more realistic and straightforward. |
| Determining materiality | Materiality is often determined using score-driven thresholds. | Greater emphasis is placed on qualitative considerations, such as common practice within the sector, supported by evidence and a clear rationale, rather than relying solely on quantitative thresholds. |
Less repetition, more targeted assessment
Many companies invested considerable time and effort in their first DMA, including extensive internal stakeholder engagement, detailed scoring methodologies and substantial documentation. The revised ESRS introduce more principles-based guidance and potential simplifications. This creates an opportunity to use the DMA as the foundation for three purposes: a coherent and decision-useful sustainability narrative, better internal steering, and a common basis for CSRD, ISSB, the EU Taxonomy and CSDDD.
Repeating the original DMA in full is therefore not necessarily required. Existing assessments, engagement processes and other available information can be reused, provided they remain appropriate and sufficiently substantiated. The focus can be on topics where it is not yet clear whether they are material.
Gross versus net assessment
When assessing negative impacts and risks, companies may take into account the extent to which existing controls and mitigation measures reduce the severity or likelihood of risks. Where measures are demonstrably effective, the net risk may be assessed as lower, for example in the area of workplace safety.
At the same time, IROs that require sustained and substantial mitigation to remain below the materiality threshold, or that are particularly sensitive to stakeholders, such as human rights, should still be reported even when the net risk is low. Take stakeholder expectations on sensitive topics into account and balance them against internal steering needs and strategic relevance.
Proportionality: collect no more data than necessary
Proportionality is permitted, but decisions must be supported by evidence and clearly documented. A robust evidence base therefore remains important. For organisations reporting for the first time in particular, demonstrating and documenting proportionality may still require considerable effort.
Where value-chain data is difficult to access, companies can apply a cost-benefit assessment, weighing the cost to the organisation against the value of the information to users. In some cases, regional and sectoral risk data or country risk indices may provide sufficient insight into value-chain risks without requiring primary data to be collected from suppliers further down the chain.
Report what matters
The revised approach calls for a fair and decision-useful view. Report what users genuinely need, not every available datapoint. The additional scope for top-down conclusions and qualitative assessments can help companies leave out immaterial details while providing targeted explanations where standard reporting would give an incomplete or misleading picture of an important topic.
Where standard datapoints do not provide sufficient nuance, entity-specific disclosures may be necessary or may offer a valuable addition. In this way, the DMA can act as a strategic filter: reducing noise and sharpening the focus on the impacts, risks and opportunities that truly matter.
What does this mean for organisations?
For companies with an existing DMA, the revision mainly means they can assess relevance in a more targeted way. Three points are important:
- Reassess the existing DMA in light of your strategy. Consider your business model, sectors and value chain. Do not repeat bottom-up assessments where sufficient evidence already supports a clear conclusion. Focus more in-depth analysis on topics where materiality remains uncertain.
- Use existing processes and information. It may not be necessary to repeat the original stakeholder analysis in full if existing engagement processes and evidence remain appropriate. For example, make use of information from risk management processes and bring sustainability, finance and risk management together to assess the impacts, risks and opportunities relevant to the organisation.
- Connect the DMA with other reporting and assessment processes. Align the DMA, where possible, with CSDDD, the EU Taxonomy and ISSB. Collecting information once and using it for multiple purposes can help organisations reduce duplication and complexity.
How technology can support a more targeted DMA
Technology can improve the consistency and focus of the DMA, but it does not replace company-specific judgement, validation or documentation. It can help organisations carry out the DMA more efficiently and with greater focus, particularly when gathering, analysing and substantiating information. Examples include:
- Automated benchmarking to identify changing expectations within the sector at an early stage.
- Technology-enabled external scanning to link signals from trusted sources to IROs.
- AI-assisted tools to draft IRO descriptions, which experts can then refine.
- Technology-supported IRO scoring to develop consistent rationales without complex spreadsheets.
Overall, the revised ESRS provide more scope for a targeted and better-substantiated DMA. This can help the DMA contribute to your organisation’s strategy, risk management and internal steering.
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