Does the Voluntary Standard Require a Double Materiality Assessment?
By Morten Rosén, Co-founder & CEO, Future Fluent · Reviewed by Dr. Max Rosvall Välme
No. The Voluntary Standard (VS, formerly VSME) does not require a double materiality assessment. That requirement belongs to the ESRS, which apply to companies in mandatory CSRD scope. VS uses a simpler "if applicable" principle instead.
Quick facts
- VS requires no double materiality assessment. This is a deliberate design choice.
- ESRS still require one. The revised ESRS adopted 3 July 2026 retained double materiality as the foundational methodology.
- VS uses an "if applicable" principle: you report a disclosure when it is relevant to your operations.
- The revised ESRS cut mandatory datapoints from over 1,000 to roughly 320.
- If you ran a DMA during CSRD preparation, that work is not wasted, but it is not required under VS.
Does VS require a double materiality assessment?
No. The Voluntary Standard does not require companies to carry out a double materiality assessment. Instead, disclosures are reported where they are applicable to the company's sector and operations. This is one of the clearest simplifications versus the ESRS.
The reasoning is practical. A double materiality assessment is a substantial project involving stakeholder engagement, impact analysis and financial risk mapping. Requiring it from a 300-person company reporting voluntarily would defeat the purpose of having a lighter standard.
What is a double materiality assessment?
A double materiality assessment identifies which sustainability topics matter to a company from two directions: impact materiality, meaning the company's effect on people and the environment, and financial materiality, meaning sustainability issues that affect the company's financial position.
Under the ESRS, the assessment determines what a company must report. You identify impacts, risks and opportunities, then disclose against the topics that emerge as material. It is the gateway step for every ESRS report, and it is usually the most time-consuming part.
Do the ESRS still require double materiality after the 2026 revision?
Yes. The revised ESRS, adopted by the European Commission on 3 July 2026, retained double materiality as the foundational assessment methodology. The revision reduced mandatory datapoints from over 1,000 to approximately 320, but it did not remove the materiality assessment itself.
So the simplification cut the volume of disclosure, not the analytical entry requirement. If you are in mandatory CSRD scope, you still run the assessment. If you are outside scope and reporting under VS, you do not.
I already did a double materiality assessment. Was it wasted?
Not entirely. A DMA gives you a documented view of which sustainability topics matter to your business and your stakeholders, which remains useful for strategy, risk management and customer conversations. It is simply not a required input for a VS report.
Be honest with yourself about the distinction, though. The DMA does not shorten your VS reporting work, because VS asks for specified disclosures regardless of what your assessment concluded. What it does give you is a defensible story when a large customer or a bank asks why you focus on the topics you do. See what carries over when you move from CSRD preparation to VS.
What does VS ask for instead of a materiality assessment?
VS asks for a defined set of disclosures organised into two modules. The Basic Module covers energy and emissions, pollution, biodiversity, water, resource use, workforce and governance basics. The Comprehensive Module adds targets, policies and value-chain items.
You work through the modules rather than deriving your own topic list. Where a disclosure does not apply to your operations, you say so. That is a fundamentally different exercise from an ESRS report, and a much shorter one. The Basic Module disclosures are specified in the standard itself.
Should I do a double materiality assessment anyway?
Only if it serves a purpose beyond compliance. If a major customer, investor or lender specifically asks for one, or you want a structured basis for your sustainability strategy, it has value. If your goal is to satisfy value-chain data requests, VS alone is enough.
My direct view, having sold ESG software to companies on both sides of this line: most mid-sized companies buy a materiality assessment because they were told it was mandatory, not because they needed the insight. If nobody is asking you for one, spend the budget on getting your emissions data right instead.
See whether the Voluntary Standard fits your company →
Frequently asked questions
Does VSME or VS require double materiality?
No. Neither the VSME standard nor its adopted version, the Voluntary Standard (VS), requires a double materiality assessment.
Which standard requires a double materiality assessment?
The ESRS, which apply to companies within mandatory CSRD scope. The revised ESRS adopted on 3 July 2026 retained the requirement.
What replaces materiality assessment in VS?
An "if applicable" principle. Companies report the standard's specified disclosures where they are relevant to their sector and operations.