The company's management is responsible for deciding the materiality of issues and information, including climate-related matters, under the oversight of the certifier/auditor. The information published by listed companies regarding their materiality analysis and results is also within the regulator's supervision scope.

Most companies currently contribute to climate change to varying degrees due to their consumption or production of fossil energy. Additionally, climate change will increasingly affect business activities and their ability to create value, whether due to physical risks induced by climate change or the political and commercial responses to mitigate climate change in line with the Paris Agreement. In this context, few European companies will be able to justify the non-materiality of climate issues given their contribution to climate change relative to European objectives (-55% by 2030 compared to 1990, carbon neutrality by 2050) and their exposure to physical and transition climate risks within the EU and beyond.

To justify that the consequences of climate change on the company are not material, it is necessary to conduct a physical and transition risk analysis to demonstrate that the company's assets, products, and services will not be significantly exposed in a high-emission scenario and in a scenario limiting global warming to 1.5°C.

To justify that the company's contribution to climate change is not material, it must be shown that the magnitude of its GHG emissions is negligible. An approximate inventory across all three scopes is necessary. This inventory should then be compared with relevant magnitudes, which depend on the company's activities and specifics. Here are some benchmarks that can be used to understand these magnitudes: emissions of countries, sectors, different types of installations, or per person, or relative to revenue.