Implementing double materiality in practice: evidence from Italian early adopters of the CSRD

Purpose: This paper investigates how organisations translate double materiality into workable assessment practices, focusing on the sensemaking processes through which conceptual and regulatory ambiguity is made actionable. The study draws on a sensemaking-informed thematic analysis of 13 interviews with sustainability report preparers from six large Italian organisations subject to the CSRD. Findings: Three interrelated dynamics shape double materiality implementation: the redistribution of interpretive responsibility from sustainability departments to cross-functional actors; the embedding of novel evaluative categories in pre-existing organisational devices such as ERM systems and strategic plans; and the management of interpretive fragmentation through sensegiving and the selective structuring of stakeholder engagement. Managerial implications: Investing in internal interpretive capacity – shared language, clear role allocation, and cross-functional dialogue – is as important as developing technical tools. Regulators should complement principle-based guidance with more operational indications regarding governance design and coordination. Research limitations: The study focuses on large Italian organisations in the early stages of CSRD implementation, limiting generalisation. Originality: The paper shifts attention from implementation challenges to the sensemaking practices through which organisations address the conceptual and regulatory ambiguity characterising double materiality implementation.