Plan your stakeholder engagement
Design an engagement that is representative enough for an auditor and light enough for your stakeholders.
Introduction
Stakeholder engagement is the bottom-up half of your DMA. It turns the AI's analysis into a materiality decision backed by the people your company affects and the people who affect your company. It is also the part of the DMA that takes the most calendar time, because it depends on other people's agendas.
Half an hour of planning here saves weeks later. Use the AI results to decide where to spend your stakeholders' time, and decide the numbers you need before you send the first survey.
Steps
Step 1: Decide where to focus
Open your AI results and sort your subtopics in three groups:
- Clearly material: high AI scores on both views, strong drivers in your documents. Ask a few confirming questions.
- Clearly not material: low scores everywhere and no driver. Document the conclusion and ask few or no questions.
- Grey zone: scores around the threshold, or subtopics that moved a lot between the AI pre-assessment and the AI IRO scoring. This is where your stakeholders add the most. Ask more questions here.
A materiality matrix with the grey zone around the threshold highlighted and a note "focus your questions here".
Step 2: List your stakeholder groups
EFRAG expects a broad range: people affected by your impacts and people with a financial interest in your company. Typical groups:
| Internal | External |
|---|---|
| Board or executive committee | Customers |
| Management team | Suppliers and subcontractors |
| Employees, or a representative such as a works council | Investors, banks, shareholders |
| Sustainability, risk, finance, HR, operations teams | Local communities and affected people |
| NGOs and civil society | |
| Regulators and public authorities |
Split a group when its members will give different answers, know different things or should weigh differently. Employees, management and board as three groups lets you compare their views. Customers per region tells you whether your European and American customers see the same things. Combine groups that share the same perspective and expertise.
Write down why you include each group and why you leave others out. It belongs in your DMA report.
Step 3: Create the groups in the platform
Each group you engage is a stakeholder group in the Stakeholder engagement step. Your assessment starts with a set of default groups that you can rename, delete or complete. Click Add stakeholder group, or open an existing group through its menu. Everything about a group lives in its settings: general settings, impact questions, financial questions and data collection methods.
| Setting | What to choose |
|---|---|
| Name | A name your colleagues recognise, for example "Customers EU" or "Works council". |
| Type | Internal or external. Informative, used in the report. |
| Materiality assessment | Impact materiality, financial materiality or both. Choose both for groups that can judge both, for example management. Choose impact only for affected stakeholders and financial only for investors or your finance team. |
| Population size | The total number of people in this group, for example your number of employees. Informative, used in the report to put your response numbers in perspective. You can update it any time. |
A group that assesses both impact and financial materiality appears in both lists on the engagement page and receives two separate survey links, one per materiality type. The settings are shared; it is one group.
The stakeholder engagement page with the list of stakeholder groups and the "Add stakeholder group" button.
Step 4: Choose a method per group
| Method | Best for | Weight in the results |
|---|---|---|
| Survey | Large groups, external stakeholders, quick answers | 1 |
| Interview | Experts, managers, anyone whose reasoning you want to capture | 3 |
| Focus group | A group that needs to reach consensus, for example the executive team or a works council | 6 |
The weight reflects the quality of the data each method produces. It only plays a role when one group is engaged through more than one method. See How results are calculated.
A mix of surveys for broad groups and interviews or one focus group for your key decision makers is the most common setup.
Step 5: Set your target numbers
There is no legal minimum. What matters is that an auditor can call each group representative. One answer per group is not. Targets we see work:
- Surveys: aim for 10 or more answers per external group and 20 or more for employees. We have seen clients collect 3 and clients collect 150; it depends on how you frame the request.
- Interviews: 3 to 5 per group.
- Focus group: one session of 5 to 10 people per group.
Decide the numbers now and write them in your plan. You will compare against them while collecting.
Step 6: Plan the calendar
- Reserve four to six weeks for data collection. Avoid holiday periods and your stakeholders' busy seasons.
- Send a personal introduction before the survey link. A short video of your CEO in the survey raises response rates noticeably.
- Plan one reminder after two weeks.
- Book the interviews and the focus group in the first week, not the last.
Step 7: Confirm the IRO list is closed
Stakeholder engagement starts from a finished IRO list. Before you build a single survey, confirm that the selection, the wording and the translations are done and that the colleagues who had to review them have. Changes after the first survey goes out cannot be applied cleanly to respondents who already answered.
Step 8: Check with your auditor
If your DMA will be audited, share your IRO short list, your stakeholder groups and your methods with the auditor now. A thirty-minute conversation at this point avoids surprises after the data is collected: anything they disagree with can still be fixed, which stops being true once collection closes. Karomia joins that conversation on request to explain the methodology. See How to prepare for the audit.
Governance
Decide who signs off the final results. For a compliant DMA this is the body responsible for sustainability, often the board or an ESG steering committee. Plan their session at the end of the calendar and keep the pre-read and the minutes.
Starting from a previous Karomia DMA
If you chose to carry over your stakeholder setup, your groups are already here with their settings, logo and welcome message. Check that they still match your organisation, and re-enable the data collection methods you want to use this cycle.
Output
- A written engagement plan: the groups you engage, why you include each one and why you leave others out, the method per group and the number of answers you are aiming for. It goes into your DMA report.
- Your stakeholder groups created in the platform, with their type, materiality focus and population size.
Next: Assign questions and weights.