Double materiality asks for the good you do without telling you how to prove it. Here’s how.

European Sustainability Reporting Standard (ESRS) 1 defines impact as “positive and negative” effect on people and the environment. Hence “double materiality”.

The negative side gets a method. The positive gets a field to fill in. Every criterion the standards use to decide whether an impact is material — scale, scope, irremediable character — was built to evaluate harm, and the guidance that has grown up around them is guidance about harm.

But that leaves the most quoted paragraph in most corporate reports, the one about the good the company does, as the least evidenced material in it. Here is where positive impact actually appears in the standards, why the machinery struggles with it, and what a positive-impact claim needs to be worth reading.

Double materiality: An imbalance between good and bad

Notwthstanding everything that the EU Omnibus took out of the earlier versions of the Corporate Sustainability Reporting Directive (CSRD) and  the Corporate Sustainability Due Diligence Directive (CSDDD), a key principle was left in as we explained in an earlier blog:

The due diligence directive concerns itself with harm, the reporting standard with the good organisations do

But that’s where the reporting standard stops. It tells you that your positive impacts count, that they can be material in their own right, and that you should report them. It does not tell you how to establish that they happened.

Start with your own last materiality assessment (the work, not the output). How much of it was about harm?

For almost every company the answer is nearly all of it. Which is odd, because it is not what the standard says.

• ESRS 1 defines impacts as “positive and negative sustainability-related impacts that are connected with the undertaking’s business, as identified through an impact materiality assessment”
• Section 3.4 says it again: impacts are “actual or potential, positive or negative impacts on people or the environment”

Positive impacts under ESRS1

A sustainability matter is disclosable if it is material from the impact perspective or the financial perspective. Either test is sufficient on its own. Positive impacts sit inside that impact test on the same footing as negative ones. Run the assessment properly and it should produce separate ranked lists: negative impacts, positive impacts, risks, opportunities, each with a threshold applied.

The revised standards, adopted in July 2026 and expected to apply from financial year 2027, then tighten what qualifies. A positive impact is not mere compliance with the law, and it is not the reduction of your own negative impact. Emitting less is not the same as doing good.

The machinery was built for harm

The materiality of an impact turns on its severity, and severity has three components: scale, scope and irremediable character. Scale is how intense the impact is. Scope is how widespread. Irremediable character is how hard it would be to put right. Any one of the three can be enough on its own to make a negative impact severe; they are not averaged into a single score.

Take them one at a time, with a positive impact in mind.

• Scale asks how intense the harm is. Applied to a skills programme the question is answerable, but nobody asks it in that form: how much better off is one person who went through it?
• Scope asks how widespread the impact is. The standard’s own gloss, for impacts on people, is the number of people adversely affected. The definition of the criterion does not contemplate the possibility that the number might be a good one
• Irremediable character asks how difficult the damage would be to reverse. To ask that of an apprenticeship, for example, makes no sense. For positive impacts, irremediability falls away, and materiality rests on scale and scope, with likelihood added where the impact is potential rather than actual

So the positive test is the harm test with one dimension deleted and nothing put in its place. And the dimension deleted is the one about how long the effect lasts.

None of this is a flaw. A criterion set built to grade harm grades harm extremely well, which is what it is for. But you cannot pick it up, turn it around and expect it to grade good!

Double Materiality in theory: Asymmetry inside one pillar

The consequence shows up inside a single pillar of a single report, a few pages apart.

Turn to the adverse side of your social disclosures and there is a defined criterion set, a documented scoring exercise, thresholds that someone decided and wrote down, a disclosed process, and an assurance provider who has asked how the judgements were reached.

Now turn to the positive side. Hours volunteered. Funds donated. People reached. A photograph.

“People reached” illustrates the problem. It is scope reported without scale: a count of how many people the activity touched, standing in for how much better off any of them ended up. On the adverse side of the same report that would not survive an afternoon: nobody would accept “communities harmed: 4,000” as an impact assessment.

But it’s usually the positive paragraph that gets quoted and reported. It is the one the annual report showcases, the one Comms builds a campaign around, the one read aloud at the results presentation, the one the board is proudest of.

The most amplified claim in the report is usually the one with the least method behind it.

Nobody is being dishonest. The good half was simply never given anything to be honest with. When 44% of investors say sustainability reporting contains unsupported claims to a large or very large extent, they are not usually thinking about the emissions figures.

The adverse side hedges carefully: potential impacts, assessed likelihood, matters we consider material. The positive side almost never hedges. It gives a round number and a photograph of people smiling. The confidence gap between the two halves is not explained by the evidence behind them.

Double Materiality in practice: A positive mirror of the harm severity test?

If the harm test cannot be turned around, build its mirror image. That does not need a new framework: the standards have given you the shape, and completing it takes five questions.

Depth, not reach

The mirror of scale is how much better off one person is. Not how many attended and not how many hours went in: what changed for one identifiable human being, expressed in a way that could turn out to be wrong. A participation count can never answer this, which is precisely why it is the number most often published.

Who, specifically

The mirror of scope is the beneficiary group, named and counted. It is a harder number than attendance and a more honest one, because it forces the distinction between the people who took part and the people whose lives are measurably different. Those are rarely the same list, and the gap is where the learning is.

Persistence, not irremediability

This is the dimension the standards drop, and the one that matters most. The harm side asks how difficult the damage would be to reverse. The mirror asks how long the benefit lasts once your funding stops. It is the most revealing question anyone can ask about a social programme and almost nobody asks it — of a mentoring scheme, a training place, a multi-year community grant. Ask it and some programmes look considerably better than their budget line suggests. Some look considerably worse.

Additionality

The revised standards are unusually firm on this, and it is the strictest thing they say about the good: a positive impact is not mere compliance with the law, and it is not the reduction of your own negative impact. Read that as a qualification test rather than a measurement method. Before asking how big a positive impact is, ask whether it is one. Cutting your own emissions is not a benefit conferred on anybody, and meeting an obligation you were already bound by does not become impact because it was written up in the impact section. Apply the test honestly and the list gets shorter. A short list of things that genuinely qualify is worth more than a long one that does not.

Whose word

On the harm side, severity is informed by the people affected. The mirror is evidence from the people who benefited, rather than programme self-report. The team that ran the initiative is not a neutral witness to its value, however good the team is.

Five questions, none of which needs a mandate, a regulator or a monetary figure. If you do want to compare a volunteering hour with a training place, a common unit is one credible route to it. There is a fuller set of tests any social number has to pass, which we outlined here.

The good you do deserves better than assertion

The positive paragraph is the part of the report you actually want people to read. It should be the part that can be checked.

That is not an argument about disclosure. Nothing compels most companies to publish a word about their positive impact, and nothing in the standards asks anyone to put a price on it. You know how many hours your people gave. The question worth answering is what those hours changed.

At Thrive we build the measurement layer that answers the double materiality challenge, on methodology governed independently through the Impact Evaluation Standard rather than held as a feature of our own product. If your organisation wants to showcase the good it does with as much confidence and evidence as is mandated for negative impacts, get in touch to find out more.

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