Double Materiality as a Discourse : Transparency, Legitimacy, and Strategic Framing under the Corporate Sustainability Reporting Directive

The implementation of the Corporate Sustainability Reporting Directive (CSRD) introduces a new regulatory landscape for corporate transparency in the European Union, requiring companies to assess both financial and impact materiality. However, the directive leaves room for interpretive discretion, raising questions about how companies construct and communicate their double materiality assessments in practice. This thesis addresses that gap by examining how seven major Danish and Swedish construction and real estate companies articulate materiality, stakeholder engagement, and sustainability responsibilities in their 2023/2024 sustainability reports. The aim of this study is to explore how double materiality is discursively constructed, visualized, and strategically framed under the CSRD, and to what extent this fosters substantive transparency or symbolic compliance. Through a critical discourse analysis inspired by Fairclough, the study analyzes sustainability reports from Denmark and Sweden. The analysis is guided by discourse theory, institutional theory, stakeholder theory, and legitimacy theory. The findings reveal that while all companies formally adopt the CSRD’s double materiality language, their interpretations are shaped by institutional pressures and communicative choices. Materiality matrices often function as tools of narrative control, prioritizing regulatory-visible topics like climate and governance, while reframing or omitting systemic concerns such as biodiversity or affected communities. Stakeholder engagement is referenced vaguely and rarely demonstrates dialogical influence. These patterns suggest that transparency under the CSRD is not merely a technical outcome, but a negotiated, discursive process. The study contributes to sustainability reporting scholarship by showing how regulation is translated into organizational language, reinforcing legitimacy while leaving room for discretion.