How often should a double materiality assessment be updated?

Update your DMA when something material changes, either in your business or in your market environment. A merger, a restructuring, entry into a new market, a major shift in the value chain, or new regulation. Between those events, review the results regularly to confirm they still hold. A trigger event rarely means starting the whole assessment again.

What should trigger a review

The ESRS requires an annual review at each reporting date to evaluate whether significant changes occurred. While a full re-assessment isn't needed without a trigger, the evaluation of potential triggers must happen annually.

Set out at the start which kinds of change should trigger a review. An acquisition or divestment. A new market. A material shift in the value chain. New regulation. Then assign someone ownership of tracking those changes between cycles, because a trigger nobody is watching for doesn’t function as a trigger.

A trigger rarely means starting over

A trigger event rarely justifies going back to a blank page. Usually you’re asking whether specific conclusions still hold given what changed, and updating the ones that don’t.

The failure mode we see is the opposite problem. Plenty of companies treat the first DMA as a single deliverable. It’s completed, signed off, published, and everyone moves on. The next cycle comes round and the work starts from nothing, because the methodology and the evidence were never stored in a way that anyone could pick up a year later.

That’s time and budget spent twice. The first DMA is usually the most expensive one you’ll do. Every cycle after that should be faster and sharper, and it will be, but only if the first one was built with the second one in mind.

Keep the methodology and evidence file accessible and comprehensible to people who weren’t involved the first time.

Review the methodology as well as the results

The revised ESRS, adopted on 3 July 2026, gives everyone a reason to look at the method.

The DMA hasn’t changed drastically. But the top-down approach is now explicitly the recommended route, and the topics list has moved from AR 16 to ESRS 1 Appendix A, which stops at sub-topic level. Both are methodological changes rather than changes to what is material.

If you’re a Wave 1 company continuing under the 2023 ESRS for FY2026, your existing conclusions are probably still valid under the ESRS methodology. Probably valid and audit-proof are different standards. Worth checking whether your methodology holds up under top-down logic, whether conclusions are documented at topic and sub-topic level, and whether your evidence trail meets current auditor expectations, which have moved even where the standards haven’t.

What you have to disclose about updates

Under ESRS 2 you state the date of your most recent assessment and describe any significant methodology changes compared with prior reporting periods. That requirement is a good reason to record methodology decisions as you make them. Reconstructing what changed and why, two years later, is harder than it sounds.

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 15 October 2026 · Last reviewed 21 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.