GENESIS AND ETHICAL ASPECTS OF DETERMINING MATERIALITY IN SUSTAINABILITY REPORTING

Abstract

This article provides a theoretical and methodological substantiation of the transformation of the materiality concept during the global transition from voluntary to mandatory sustainability reporting between 2023 and 2025. The research examines the evolution of impact materiality (based on GRI standards) and financial materiality (rooted in the IIRC’s integrated reporting framework, SASB, IFRS S1/S2, and SEC rules), alongside their integration into the double materiality concept under the European Sustainability Reporting Standards (ESRS). A significant focus is placed on the IRO (Impacts, Risks, Opportunities) approach, which forms the core of double materiality assessment.
Through a comparative analysis of energy sector sustainability reporting for 2024, the article illustrates the methodological gap between single and double materiality approaches, particularly regarding Scope 3 emissions and biodiversity. The revision and postponement of the ESRS are justified by the excessive administrative burden and the risk of undermining the global competitiveness of EU companies. 
The study further analyzes the implications of the "Omnibus" amendments to the CSRD, which significantly increased the scope of professional judgment and associated subjectivity risks. Consequently, the paper identifies potential ethical threats arising from this subjectivity. Based on the 2025 International Code of Ethics for Professional Accountants, a map of ethical threats–including self-interest, advocacy, and pressure–is developed, and specific safeguards are proposed to maintain objectivity and integrity throughout the ESRS materiality assessment process. The research concludes that double materiality is not merely a technical requirement, but a strategic model for long-term value creation.