ESG와 중대성 평가(Materiality Assessment) ― EU의 사례를 중심으로 ―

The reason why corporate sustainability matters are reported to the public is to change corporate activities in the direction of promoting the sustainability of the community, and as a means, it is intended to provide useful information to stakeholders affected who are affected by corporate activities reciprocally. EU’s Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS) are also intending to contribute to this policy goal, i.e., the sustainable development of the community. Under the limitations of limited resources and community capabilities, CSRD and ESRS introduced the concept of double materiality assessment. This materiality assessment evaluates the relationship between companies and communities in terms of impact materiality and financial materiality. Once the undertaking concludes that a sustainability matter is material as a result of its materiality assessment, it shall be reported according to a standard form as mandated by the relevant topical or sector-specific ESRS. As such, mandatory disclosure items are differentiated to (1) mandatory disclosure under the law (2) mandatory disclosure as prescribed by ESRS regardless of the materiality assessment, and (3) disclosure through the undertaking’s materiality assessment reflecting the entity-specific circumstances. The double materiality assessment is a useful tool to capture the relationship between an enterprise and the community in both directions of inside-out impact and outside-in impact surrounding the undertaking. In conjunction with the dynamic materiality that has recently been noted, it is necessary to widely understand, publicize, and train the materiality assessment methodology by industry sectors and by enterprises. Sustainability matters, which have been evaluated as material for corporate management through the materiality assessment processes, can be used meaningfully by stakeholders only when they are disclosed while possessing the qualitative characteristics of relevancy, faithful representation, comparability, verifiability, and understandability. The disclosure of non-financial ESG-related information through materiality assessment may also raise controversy and disagreement, including greenwashing, based on different perception of above qualitative characteristics of disclosed information. In the process of designing the system, in-depth discussions and social agreements will be required for each area, such as the establishment of categories and topics for detailed disclosure items, the process for determining whether to disclose, and the determination of disclosure methodologies.