Disclaimer: New EUDR developments - December 2025
In November 2025, the European Parliament and Council backed key changes to the EU Deforestation Regulation (EUDR), including a 12‑month enforcement delay and simplified obligations based on company size and supply chain role.
Key changes proposed:
These updates are not yet legally binding. A final text will be confirmed through trilogue negotiations and formal publication in the EU’s Official Journal. Until then, the current EUDR regulation and deadlines remain in force.
We continue to monitor developments and will update all guidance as the final law is adopted.
If your business is planning to report on the Corporate Sustainability Reporting Directive (CSRD), you've almost certainly come across the concept of a Double Materiality Assessment (DMA). One crucial component of this assessment is the identification and evaluation of Impacts, Risks, and Opportunities (IROs).
This guide explains what IROs are in the context of CSRD and how to approach them in your double materiality assessment.
Under ESRS 1, companies are required to identify and assess their sustainability-related IROs as part of their double materiality assessment:
IROs are the building blocks of your DMA. The process of identifying and assessing them determines which ESRS topics are material for your company — and therefore which disclosures you must make.
Under the amended ESRS following the Omnibus I Directive, the requirements around IRO identification have been clarified and simplified, but the core process remains. You need to be able to demonstrate that your assessment of material topics is grounded in a systematic review of your actual and potential impacts, risks, and opportunities.
Consider your own operations and your upstream and downstream value chain. ESRS requires companies to look beyond their direct operations to understand how their supply chain and the use of their products create impacts, risks, or opportunities.
Work through each ESRS topic (E1–E5, S1–S4, G1) and identify the specific impacts your operations have on that topic, the financial risks arising from that topic, and any financial opportunities it presents.
For each identified IRO, assess its significance:
Determine which IROs are material based on their assessed significance. A topic is material under CSRD if it is material on either the impact dimension or the financial dimension.
The most important thing is documentation. Your auditor will want to understand not just your conclusions but your process and rationale. Every materiality decision should be traceable to evidence and stakeholder input.
Coolset's DMA workflow provides a structured framework for identifying and assessing IROs across all ESRS topics. It includes scoring guidance, documentation templates, and a direct connection from the DMA output to your ESRS reporting scope. Book a demo to learn more.
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