How do we identify stakeholders and collect their input?

Use a 360 degree definition: a stakeholder is anyone who may affect your business or who your business may affect. For most companies that means customers, suppliers, business partners, employees and their representatives, sometimes government. The ESRS doesn’t require you to consult external stakeholders directly, but it does require you to disclose whether you did and how.

What the ESRS requires

You don’t have to build a separate standalone stakeholder process for your DMA. What you have to do is disclose whether you consulted outside stakeholders, what methodology you used if you did, how stakeholder views reach the company, and how they get escalated to senior management. 

One clarification that saves confusion later. When we talk about stakeholders we mean groups external to management. That includes your employees, because they’re a stakeholder group distinct from the people running the company.

Option one: internal experts as proxies

Your colleagues in HR know your employees. Your colleagues in procurement know your suppliers. They’re in contact with those groups daily and can represent their views.

This saves time and resources, and for many companies it’s the realistic option. Whether it works depends on how you set it up.

Make sure the right people are in the room, with real representation for each of your main stakeholder groups.

Brief them properly. This part gets skipped and it matters more than it sounds. You’re asking a colleague to stop representing the company and instead put themselves in the shoes of a stakeholder group. That’s a different job from the one they do every day, and it requires them to be impartial in a way their role doesn’t usually ask for. Without that briefing you get the company’s view of what suppliers think, which isn’t the same thing as what suppliers think.

Consider running a workshop rather than interviewing people individually. A social or environmental issue often affects more than one stakeholder group, and it’s difficult to balance the views of your HR colleagues against your risk colleagues when you’re sitting in the middle receiving them separately. Put them in a room to work it through and you get a consensus you can defend.

Option two: go to the source

Speaking to stakeholders directly takes more time and more resources. What you get in return is an outside perspective with nobody acting as a proxy, and protection against blind spots. Every organisation has views that are obvious to its customers and suppliers and invisible from the inside.

Again, some conditions. Check that the people you speak to really represent the group they stand for and know enough about your business to give you useful feedback.

Decide upfront where in the process you want their input. You won’t involve stakeholders from beginning to end. Do you want them helping identify impacts, prioritise them, or think about strategy? The ESRS doesn’t mandate any of this, which means the decision is yours and it should be a decision rather than something that happens by default.

Then think about collection method. A questionnaire works for large or dispersed groups. A workshop works when you can get representative people to give up the time, and gives you the same consensus benefit as the internal version.

The risk of skipping it

If you engage nobody and have no internal expert who knows those groups well enough to represent them credibly, important perspectives never reach the assessment at all. You’ll still be compliant. You’ll also end up with conclusions that the people affected by your business wouldn’t recognise.

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.

Simon Clow, Editorial Director, Kōan
Published 06 October 2026 · Last reviewed 22 September 2026

Simon Clow is Kōan’s editorial director. He began his career as an economic and financial journalist before moving into sustainability with the financial services sector, and co-founded Kōan.