How CSOs must lead strategic materiality assessment
The CSO's evolving role in ESG materiality
As ESG reporting frameworks continue to proliferate and regulatory requirements tighten globally, Chief Sustainability Officers find themselves at the center of an increasingly complex challenge. While materiality assessments have traditionally been viewed through the lens of disclosure compliance, forward-thinking CSOs are recognising that their role extends far beyond simply meeting reporting requirements. The real strategic value lies in understanding and addressing the full spectrum of material issues – both those that must be disclosed and those that remain hidden but equally critical to long-term business resilience.
Why compliance isn’t enough
Most organisations approach materiality assessments as a checkbox exercise for ESG reporting. They conduct stakeholder surveys, map issues against reporting standards like GRI, SASB or the emerging ISSB framework and produce neat matrices that satisfy auditors and rating agencies. This disclosure-focused approach, while necessary, captures only a fraction of the sustainability challenges that truly matter to business strategy.
The problem with this narrow view is that disclosure materiality is inherently backward-looking and constrained by what stakeholders currently understand and what reporting frameworks currently measure. It focuses on issues that are already visible, quantifiable and broadly recognised as material by the market. But the most significant sustainability risks and opportunities often exist in the spaces between established frameworks – in emerging issues, interconnected systems and non-linear impacts that don't yet have standardised metrics.
Leading beyond reporting
CSOs must position themselves as strategic leaders who use materiality assessment as a tool for comprehensive risk identification and opportunity mapping, not just disclosure compliance. This means developing a dual-track approach that addresses both regulatory requirements and strategic foresight.
The disclosure track ensures the organisation meets its reporting obligations across relevant frameworks, satisfies stakeholder expectations and maintains access to capital markets increasingly focused on ESG performance. This is table stakes – essential but not differentiating.
The strategic track, however, is where CSOs can demonstrate real leadership value. This involves identifying material issues that may not yet be required for disclosure but could fundamentally impact the business model, competitive position or operational resilience in the coming years. These might include emerging regulatory trends, shifts in consumer behavior, supply chain vulnerabilities or ecosystem dependencies that aren't captured in current reporting frameworks.
Uncovering non-discloseable but critical issues
The most sophisticated CSOs are developing methodologies to identify and assess issues that fall outside traditional disclosure requirements but remain highly material to business success. These often include:
Systemic dependencies
Understanding how the business relies on natural systems, social structures or economic conditions that may be invisible in financial statements but critical to operations. A food company's dependence on pollinator health, for instance, may not be immediately quantifiable but could be existential.
Regulatory horizon scanning
Anticipating how evolving policy landscapes will create new compliance requirements, market opportunities or competitive disadvantages. The CSO who identifies emerging carbon border adjustment mechanisms before they become mandatory creates strategic advantage.
Stakeholder evolution
Recognising how stakeholder expectations and power dynamics are shifting in ways that will eventually impact the business, even if they're not yet reflected in formal engagement processes or materiality surveys.
Interconnected risks
Mapping how apparently separate sustainability issues interact to create compound risks or cascading impacts that may not be visible when examining issues in isolation.
Building dual-track materiality processes
Leading CSOs are developing sophisticated processes that serve both disclosure and strategic purposes simultaneously. This requires building assessment methodologies that can satisfy reporting requirements while also providing insights for strategic planning and risk management.
The key is expanding beyond traditional stakeholder engagement to include expert consultation, scenario planning and systems thinking approaches. This might involve engaging with scientists, policy researchers and industry futurists alongside traditional stakeholders. It means conducting deep-dive analyses of specific risk areas rather than relying solely on broad-based surveys.
Successful dual-track approaches also integrate materiality assessment into broader business planning cycles, ensuring that insights inform capital allocation, product development and market strategy decisions – not just sustainability reporting.
The competitive advantage of strategic materiality
Organisations that approach materiality assessment strategically rather than as a compliance exercise gain significant competitive advantages. They identify emerging risks before they become widespread concerns, allowing for proactive adaptation rather than reactive response. They spot new market opportunities in sustainability solutions before competitors recognise the demand. They build more resilient business models by understanding and addressing systemic dependencies.
Perhaps most importantly, they position sustainability as a strategic function rather than a compliance cost center, elevating the CSO's role in organisational decision-making and resource allocation.
Conclusion: From compliance to strategy
The regulatory environment will continue to expand disclosure requirements, making the compliance track of materiality assessment increasingly complex and time-consuming. But CSOs who limit themselves to meeting these requirements will find their function marginalised as a necessary but non-strategic cost center.
The opportunity lies in using materiality assessment as a strategic intelligence tool that informs business strategy, identifies emerging risks and opportunities and builds organisational resilience for long-term success. This requires moving beyond the comfortable boundaries of established reporting frameworks to explore the messy, uncertain, but critically important issues that will define competitive advantage in a rapidly changing world.
The CSOs who master this dual-track approach – satisfying disclosure requirements while providing strategic insight on non-disclosable but material issues – will establish themselves as indispensable strategic leaders. They will transform materiality assessment from a reporting exercise into a competitive intelligence capability that drives real business value.
In an era where sustainability challenges are becoming business-critical challenges, this strategic approach to materiality isn't just an opportunity – it's becoming an essential capability for organisational survival and success.
