Doppelte Wesentlichkeitsanalyse als zentraler Filter für die ESG-Berichterstattung in österreichischen und deutschen Stadtwerken

The 2022 Corporate Sustainability Reporting Directive significantly expands the number of companies required to disclose non-financial information, now including many large municipal utilities (MUs) for the first time. The study focuses on 14 Austrian and German MUs and examines the current state, challenges, and opportunities of a double materiality analysis in line with the European Sustainability Reporting Standards (ESRS). Methodologically, the study is based on a qualitative content analysis of 28 sustainability reports. In addition, five expert interviews were conducted with representatives of large Austrian MUs in February 2025. The findings show that only a few pioneering MUs have embedded their highly material topics in their corporate strategy. In other MUs, structured double materiality analyses have been carried out and can be allotted to the Environmental, Social and Governance (ESG) dimensions required by the CSRD. The identification of narrative and quantitative data points and the embeddedness in the strategy process is not yet completed. The 14 highly prioritized topics of MUs can be divided into three dimensions. The environmental dimension (E) focuses on five key aspects: (1) energy efficiency; (2) (greenhouse gas) emissions; (3) climate protection measures; (4) energy, heating and mobility transition and (5) reliable and high-quality waste disposal. The social dimension (S) also comprises five key topics: (1) health protection; (2) attractiveness as an employer; (3) security of service provision/security of supply; (4) sustainable cities and (5) product responsibility. In the governance dimension (G), four key aspects are very important: (1) compliance and anti-corruption; (2) security and data protection; (3) industry, innovation and sustainable infrastructure; and (4) efficient operations. There is a clear trend that "ESRS E1: Climate Change", "ESRS S1: Own Workforce" and "ESRS G1: Business Conduct" are of utmost importance for all studied MUs. The range of qualitative and quantitative data points is broad in the analysed MUs. This ranges from estimates of around 200 data points based on the European Financial Reporting Advisory Group (EFRAG) guidelines to MUs that have already defined up to 650 qualitative and quantitative data points for their ESG reporting. Key challenges include the complexity of Scope 3 emissions accounting, a meaningful stakeholder engagement, and high consultancy costs. Despite regulatory uncertainty and differing levels of ESG maturity, the double materiality process offers strategic potential like corporate resilience or stakeholder trust improvement. Pioneering MUs can serve as benchmarks, while others should leverage best practices. However, policymakers need to address quite soon the uncertainties of an ESG reporting landscape that has been further fragmented by the EU Omnibus I proposal in February 2026 and should provide regulatory clarity.