Double materiality assessment has become a central mechanism of sustainability reporting under the European Sustainability Reporting Standards, which link material sustainability matters to strategy, the business model, and management responses. Existing research has examined reporting obligations, implementation practices, and regulatory discretion but has paid considerably less attention to the methodological integration of materiality assessment into management control. The far-reaching simplification of the ESRS reduces disclosure obligations without resolving this integration problem. As a conceptual design paper, this study examines how regulatory discretion can be structured so that double materiality assessment generates decision-useful information for sustainability strategy, corporate planning, and enterprise risk management. It connects the ESRS with the literature on Sustainability Management Control, corporate planning, and risk management. The resulting four-level model structures the assessment as a principle-based sequence of methodologically grounded managerial judgments across analytically distinct but feedback-linked levels: identification and measurement, reference frame selection, interpretation and validation, and aggregation and materiality judgment. A common information base produces a regulatory reporting portfolio for period t and a broader management control portfolio for period t + 1. The sustainability statement thereby becomes the regulatory output of a broader management control process. By specifying the methodological transitions from materiality assessment to managerial use, the paper contributes an integrated conceptual architecture and derives an empirical research agenda.
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René Berg (2026) studied this question.
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