Guide for hotels

What a double materiality assessment means for a hotel

Tour operators, banks and large corporate clients are asking hotels more questions about sustainability. This guide explains double materiality in plain language, what the EU's voluntary standard for small and medium-sized companies (VSME) actually asks for, and how a hotel can get it done without a consultant.

Updated September 2026

Double materiality in one paragraph

Double materiality means looking at sustainability in two directions. Impact materiality asks how your hotel affects people and the environment: energy, water, waste, food, your staff and the local community. Financial materiality asks how sustainability issues affect your business: energy prices, water shortages, heatwaves, changing guest expectations and access to finance. A topic is material if it matters in either direction.

Does a hotel have to do one?

Usually not by law. After the EU's Omnibus simplification, mandatory sustainability reporting under the CSRD applies only to the largest companies, with more than 1,000 employees. Most hotels are well below that.

For everyone else there is the VSME, a voluntary standard published by EFRAG in December 2024 and recommended by the European Commission on 30 July 2025 (Recommendation (EU) 2025/1710). The VSME itself does not require a formal double materiality assessment.

So why do one? Because the questions still arrive: supplier questionnaires from tour operators, green loan applications, public tenders and corporate travel buyers. A double materiality assessment shows, in a structured way, how you decided which topics matter and why. It turns a pile of questionnaires into one clear answer.

What the VSME asks for

The VSME has two levels. The Basic Module has 11 disclosures, covering how the report was prepared, your sustainability practices, energy use and greenhouse gas emissions, pollution, biodiversity, water, resource use and waste, your workforce, health and safety, pay and training, and corruption or bribery convictions. The Comprehensive Module adds 9 disclosures for companies that want to go further or are asked for more by banks and clients.

Typical material topics for a hotel

Every property is different, but these topics come up again and again in hospitality:

Five practical steps

1. Map your activities. Rooms, food and drink, laundry, spa, gardens, events, and your main suppliers.
2. List your impacts. For each activity, note the positive and negative effects on people and the environment, and how severe and likely they are.
3. List risks and opportunities. Note how each topic could affect costs, revenue or access to finance, and how much.
4. Ask your stakeholders. Short surveys for staff, guests, suppliers and the local community show what they think matters.
5. Build the matrix and act. Plot impact against financial importance, choose your priorities, and collect the VSME data points for them.

How long does it take?

With a structured tool, the self-assessment takes about 20 minutes. Stakeholder surveys then run in the background, and most businesses go from registration to certificate in about three weeks.

Quick answers

Is the VSME mandatory for hotels?

No. It is a voluntary standard. The European Commission recommends it for small and medium-sized companies that want to answer sustainability questions from clients, banks and partners in one consistent format.

Does the VSME require a double materiality assessment?

No. A double materiality assessment is optional under the VSME, but it is the clearest way to show how you chose the topics you report on.

Can a large client ask me for more than the VSME?

Under the EU's Omnibus simplification, companies that must report cannot require smaller partners to provide more information than the voluntary standard. Many will still ask, and the VSME gives you a fair, standard answer.

Sources: EFRAG, Voluntary Sustainability Reporting Standard for non-listed SMEs (VSME), December 2024. European Commission Recommendation (EU) 2025/1710 of 30 July 2025. EFRAG