Barbara Strozzilaan 336
1083 HN Amsterdam
The Netherlands
gssbsecretariat@globalreporting.org

Item 06 – GRI Universal Standards
Project – Revised GRI 101: Section 4.
Reporting principles
For GSSB discussion
Date

8 February 2021

Meeting

25 February 2021

Project

GRI Universal Standards Project

Description

This document presents the revised draft of Section 4. Reporting principles in GRI
101: Using the GRI Standards following the public comment feedback. Keychanges are highlighted in comment boxes within the document. Minor editorialchanges have not been highlighted, but a draft tracking all changes to the text has
been included in the Annex.
Item 07 – GRI Universal Standards Project – Public comment feedback onreporting principles includes the public comments received on the reporting
principles section.

This document has been prepared by the GRI Standards Division and is made available to observers
at meetings of the Global Sustainability Standards Board (GSSB). It does not represent an official
position of the GSSB. Board positions are set out in the GRI Sustainability Reporting Standards. The
GSSB is the independent standard setting body of GRI. For more information visit
www.globalreporting.org.

© GRI 2021

1

Contents

2

Explanatory note .................................................................................................................................... 3

3

Revised section 4. Reporting principles .................................................................................................. 3

4

Annex. Revisions with track changes ..................................................................................................... 9Page 2 of 14

5

Explanatory note

6

The following significant revisions have been made in response to public comment feedback:

7
8
9
10
11
12
13
14

•
•
•

Revised the formulation of the Accuracy reporting principle following a contradiction with thetext of the guidance that was identified, see lines 37-38.
Revised the guidance to the Accuracy reporting principle following the view that anorganization should maintain high levels of accuracy regardless of the needs of the users, seelines 44-45.
Revised the guidance to the Sustainability context reporting principle following views to retain
explicit reference to thresholds- and norms-based authoritative instruments, see lines 141171.

15
16

Other editorial revisions have been made to the text to improve clarity and consistency with the GRI
Style Guide and are explained in comment boxes.

17

Revised section 4. Reporting

18

principles

19
20
21

The reporting principles are fundamental to achieving high-quality sustainability reporting. The
organization is required to apply the reporting principles to be able to claim that it has prepared
information in accordance with the GRI Standards (see Section 3.1 of this Standard).

22
23
24

The reporting principles guide organizations in ensuring the quality and proper presentation of thereported information. Quality information enables information users to make sound assessments of
the organization’s impacts and aids in decision-making.

25

Each reporting principle consists of a requirement and guidance on how to apply it.

26

Overview of principles

27•

Accuracy

28•

Balance

29•

Clarity

30•

Comparability

31•

Completeness32•

Sustainability context

33•

Timeliness

34•

Verifiability

35

Accuracy

36

Requirement

37
38

a. The organization shall report information that is correct and sufficiently detailed to enable
the assessment of the organization’s impacts.

Commented [SD1]: Type of change: revision following
public comment feedback.
Original wording: “that is factually correct”.
Changed to avoid contradiction given that some
reported information will include estimations.

Page 3 of 14

39

Guidance

40
41
42
43
44
45

The characteristics that define accuracy vary depending on the nature of the information (qualitativeor quantitative) and the intended use of the information. The accuracy of quantitative information candepend on the specific methods used to gather, compile, and analyze data. The accuracy ofqualitative information can depend on its level of detail and consistency with available evidence.
Information users require sufficient detail in order to make assessments about the organization’s
impacts.

46

To apply the Accuracy principle, the organization should:

Commented [SD2]: Type of change: revision following
public comment feedback.

47
48

•

report qualitative information that is consistent with available evidence and other reported
information;

Original wording: “Certain information users require
higher levels of accuracy than others.”

49•

indicate which data has been measured;

50
51

•

adequately describe data measurements and bases for calculations, and ensure it is possible
to replicate measurements and calculations with similar results;

Changed to emphasize that an organization should
maintain high levels of accuracy regardless of theneeds of the users, however the detail of reported
information might vary subject to the needs of the users.

52
53

•

ensure that the margin of error for data measurements does not inappropriately influence theconclusions or assessments of information users;

54
55

•

indicate which data has been estimated, and explain the underlying assumptions andtechniques used for the estimation as well as any limitations.

56

Balance

57

Requirement

58
59

a. The organization shall report information in an unbiased way and provide a fair
representation of the organization’s negative and positive impacts.

60

Guidance

61

To apply the Balance principle, the organization should:

62•

not omit relevant information concerning its negative impacts;63•

not overemphasize positive news or impacts;

64
65

•

present information in a way that allows information users to see negative and positive yearon-year trends in impacts;

66•

distinguish clearly between facts and the organization’s interpretation of the facts;

67
68

•

avoid presenting information in a way that is likely to inappropriately influence the conclusions
or assessments of information users.

69

Clarity70

Requirement

71
72

a. The organization shall present information in a way that is accessible, understandable,
and usable.

73

Guidance

74

To apply the Clarity principle, the organization should:

75
76

•

take into account specific accessibility needs of information users, associated with abilities,
language, and technology;

Page 4 of 14

77
78

•

present information in a way that users are able to find the information they want without
unreasonable effort, for example, through a table of contents, maps, or links;

79
80

•

present information in a way that it can be understood by users who have reasonableknowledge of the organization and its activities;

81
82

•

avoid abbreviations, technical terms, or other jargon likely to be unfamiliar to users or, if these
are used, include relevant explanations in the appropriate sections or in a glossary;

83
84

•

report information in a concise way and aggregate information where useful without omitting
necessary details;

85
86

•

use graphics and consolidated data tables to make information accessible andunderstandable.

Commented [SD3]: Type of change: editorial revision.
Removed wording “(i.e., provide the level of detailrequired by users)” due to repetition with the wording of
the Accuracy principle.

87

Comparability

88

Requirement

89
90
91

a. The organization shall select, compile, and report information in a consistent manner, toenable an analysis of changes in the organization’s impacts over time and an analysis ofthese impacts relative to those of other organizations.

92

Guidance93
94
95

Comparability allows an organization to assess its progress. It is also necessary for external parties toassess and benchmark the organization’s progress as part of rating activities, investment decisions,and advocacy programs.

96
97
98
99

To facilitate comparability, it is important for the organization to maintain consistency in the methods
used to calculate data, in the report layout, and in explanations of methods and assumptions used toprepare the reported information. This allows for evaluating an organization’s current impacts against
its past impacts and its goals and targets, and against the impacts of other organizations.

100

To apply the Comparability principle, the organization should:

101
102

•

present information for the current reporting period and at least two previous periods, as wellas any goals and targets that have been set;

103
104

•

use generally accepted international metrics (e.g., kilograms or liters), and standard
conversion factors and protocols, where applicable, for compiling and reporting information;

105
106

•

maintain consistency in the methods used to measure and calculate data and in how thesemethods are described;

107
108

•

maintain consistency in the the manner of presenting information, and explain the methods
and assumptions used to prepare the information;

109
110
111

•

report total numbers or absolute data (e.g., metric tons of CO2 equivalent) as well as ratios ornormalized data (e.g., CO2 emissions per unit produced) to enable comparisons, and provide
explanatory notes when using ratios;

112
113
114

•

provide contextual information (e.g., organization’s size, geographic location) that helps
information users understand the factors that contribute to differences between theorganization’s impacts and the impacts of other organizations;

115
116
117
118
119
120

•

if there are changes in the information reported by the organization for its identified material
topics, in the length of the reporting period, or in other elements of reporting, such as thedefinitions used, present the current disclosures alongside restatements of historic data toenable comparisons. The organization is required to explain any restatements of informationfrom previous reporting periods and their effect and report the reasons for such restatements
under Disclosure REP-4 in GRI 102: About the Organization;

Page 5 of 14

Commented [SD4]: Type of change: edtitorial revision(overall clarifications).

Commented [SD5]: Type of change: editorial revision(change in location).

•

121
122

if restatements of historic data are not provided, explain the changes to provide contextual
information for interpreting the current disclosures.

123

Completeness

124

Requirement

125
126

a. The organization shall provide sufficient information to enable an assessment of theorganization’s impacts during the reporting period.

127

Guidance

128

To apply the Completeness principle, the organization should:

129•

not omit information that is necessary for understanding the organization’s impacts;

130
131
132
133

•

present activities, events, and impacts for the reporting period in which they occur. This
includes reporting on activities that have a minimal impact in the short-term, but a reasonably
foreseeable cumulative impact that can become unavoidable or irreversible in the long-term(e.g., activities that generate bio-accumulative or persistent pollutants).

134
135
136

If the organization consists of multiple entities (i.e., a parent entity and its subordinate entities), theorganization is required to explain the approach used for consolidating the information under REP-2-c
in GRI 102: About the Organization.

137
138
139
140

If gaps are identified in collecting information (e.g., when information is not available for all relevant
activities or entities, or is incomplete), the organization is required to identify and explain these gaps
when reporting in accordance with the GRI Standards. See Requirement A-5-b in Section 3.1 of thisStandard.

141

Sustainability context

142

Requirement

143
144

a. The organization shall report information on its impacts in the wider context ofsustainable development.

145

Guidance

146
147
148
149
150

The objective of sustainability reporting is to provide transparency on how an organization contributes
or aims to contribute to sustainable development, which ‘meets the needs of the present withoutcompromising the ability of future generations to meet their own needs’1. For this reason theorganization needs to assess and report information on its impacts in the broader context ofsustainable development.

151

To apply the Sustainability context principle, the organization should:

Commented [SD6]: Type of change: revisions
following public comment feedback.

152
153
154

•

draw on societal expectations as well as objective information and authoritative measures onsustainable development, where available, when reporting on its impacts (e.g., scientificresearch or consensus on ecological limits);

155
156
157

•

report on its impacts in relation to sustainable development goals and conditions (e.g., thelimits and demands placed on environmental resources, and social and economic objectives
and goals);

158
159

•

report information on its impacts, as reflected in recognized sector-specific, local, regional, or
global instruments (e.g., reporting total GHG emissions as well as reductions in GHG

1

World Commission on Environment and Development, Our Common Future, 1987.

Page 6 of 14

Revised the text of the guidance to retain explicit
reference to thresholds- and norms-based authoritative
instruments.

160
161

emissions in relation to the goals set out in the United Nations Framework Convention on
Climate Change [UNFCCC] Paris Agreement);

162
163
164
165

•

report information on its impacts in relation to expectations of responsible business conduct
set out in internationally recognized instruments with which the organization is expected tocomply (e.g., OECD Guidelines for Multinational Enterprises, UN Guiding Principles on
Business and Human Rights);

166
167
168

•

if operating in a range of locations, report information in a way that communicates its impacts
in relation to appropriate local contexts (e.g., reporting total water use as well as water use
relative to the sustainable thresholds and the social context of given catchments).

169
170
171

The sustainability context provides the organization with critical information for identifying andreporting on its material topics and related impacts (see GRI 103: Material Topics). The GRI Sector
Standards describe the sustainability context for organizations in a given sector.

172

Timeliness

173

Requirement

174
175

a. The organization shall report information on a regular schedule and make it available intime for information users to make decisions.

176

Guidance

177
178
179

The usefulness of information is closely tied to whether it is available in time for information users tointegrate it into their decision-making. The Timeliness principle refers to how regularly as well as how
soon after the reporting period the information is published.

180

To apply the Timeliness principle, the organization should:

181
182
183

•

balance the need to make information available in a timely manner with the need to ensurethat the information is of high quality and meets the requirements under the other reporting
principles;184•

ensure consistency in the frequency of reporting and the length of reporting periods;

185•

clearly indicate the time period covered by the reported information;•

indicate when the reported information was last updated and when it will be updated next.

186
187
188

See Section 5.1 of this Standard for information on aligning the reporting periods and publishingschedules of sustainability reporting with other types of reporting.

189

Verifiability

190

Requirement

191
192

a. The organization shall gather, record, compile, and analyze information in a way that the
information can be examined to establish its credibility.

193

Guidance

194
195

It is important that the reported information can be examined to establish its credibility and to
determine the extent to which the reporting principles have been applied.

196

To apply the Verifiability principle, the organization should:

197
198
199

•

Commented [SD7]: Type of change: editorial revision.
Original wording: “balance the need to make information
available in a timely manner with the need to ensurethat the information is reliable”
Changed to consider balance with all reporting
principles.
Commented [SD8]: Type of change: editorial revision.
Original wording: “clearly indicate the time period
covered by the reported information, for example, whenpresenting information for several periods;”

ensure that individuals other than those preparing the reported information (e.g., internal
auditors, external assurance providers) are able to review the supporting internal controls anddocumentation;

Page 7 of 14

Removed “for example, when presenting information forseveral periods” as indication of time periods should be
independent of one-time or recurring reporting practice.

200
201
202

•

document the decision-making processes underlying the organization’s sustainability
reporting in a way that allows for the examination of the key decisions and processes, such as
the identification of material topics;

203
204

•

if the organization designs information systems for its sustainability reporting, design thesesystems in a way that they can be examined as part of an external assurance process;

205
206

•

be able to identify the original sources of the reported information and provide reliable
evidence to support assumptions or calculations;

207
208

•

be able to provide representation from the original sources of the reported information
attesting to the accuracy of the information within acceptable margins of error;

209
210

•

avoid including information that is not substantiated by evidence, unless it is relevant forunderstanding the organization’s impacts;

211
212

•

provide unambiguous explanations of any uncertainties associated with the reported
information.

213
214

See Section 5.2 of this Standard for more information on enhancing the credibility of sustainability
reporting

Page 8 of 14

215

Annex. Revisions with track changes

216
217
218

The reporting principles are fundamental to achieving high-quality sustainability reporting. The
organization is required to apply the reporting principles to be able to claim that it has prepared
information in accordance with the GRI Standards (see Section 3.1 of this Standard).

219
220
221

The reporting principles guide organizations in ensuring the quality and proper presentation of thereported information. Quality information enables information users to make sound assessments of
the organization’s impacts and aids in decision-making.

222

Each reporting principle consists of a requirement and guidance on how to apply it.

223

Overview of principles

224•

Accuracy

225•

Balance

226•

Clarity227•

Comparability

228•

Completeness229•

Sustainability context

230•

Timeliness

231•

Verifiability

232

Accuracy

233

Requirement

234
235

a. The organization shall report information that is factually correct and sufficiently detailed
to enable the assessment of the organization’s impacts.

236

Guidance

237
238
239
240
241
242
243

The characteristics that define accuracy vary depending on the nature of the information (qualitativeor quantitative) and the intended use of the information. The accuracy of qualitative information candepend on its level of clarity and detail. The accuracy of quantitative information can depend on thespecific methods used to gather, compile, and analyze data. The accuracy of qualitative information
can depend on its level of detail and consistency with available evidence. Information users requiresufficient detail in order to make assessments about the organization’s impacts.Certain information
users require higher levels of accuracy than others.

244

To apply the Accuracy principle, the organization should:

245
246

•

report qualitative information that is consistent with available evidence and other reported
information;

247•

indicate which data has been measured;

248
249

•

adequately describe data measurements and bases for calculations, and ensure it is possible
to replicate measurements and calculations with similar results;

250
251

•

ensure that the margin of error for data measurements does not inappropriately influence theconclusions or assessments of information users;

252
253

•

indicate which data has been estimated, and explain the underlying assumptions andtechniques used for the estimation, as well asnd any limitations.

Page 9 of 14

254

Balance

255

Requirement

256
257

a. The organization shall report information in an unbiased way and provide a fair
representation of the organization’s negative and positive impacts.

258

Guidance259

To apply the Balance principle, the organization should:

260•

not omit relevant information concerning its negative impacts;261•

not overemphasize positive news or impacts;

262
263

•

present information in a way that allows information users to see negative and positive yearon-year trends in impacts on a year-to-year basis;

264•

distinguish clearly between facts and the organization’s interpretation of the facts;

265
266

•

avoid presenting information in a way that it is likely to inappropriately influence theconclusions or assessments of information users.

267

Clarity268

Requirement

269
270

a. The organization shall present information in a way that is accessible, understandable,
and usable.

271

Guidance272

To apply the Clarity principle, the organization should:

273
274

•

take into account specific accessibility needs of information users, associated with abilities,
language, and technology;

275
276

•

present information in a way that users are able to find the information they want without
unreasonable effort, for example, through a table of contents, maps, or links;

277
278

•

present information in a way that it can be understood by users who have a reasonableknowledge of the organization and its activities;

279
280
281

•

avoid abbreviations, technical terms, acronyms, or other jargon likely to be unfamiliar tousers, and or, if these are used, include relevant explanations in the appropriate sections or ina glossary;

282
283

•

report information in a concise way and aggregate information where useful, without omitting
necessary details (i.e., provide the level of detail required by users);

284
285

•

use graphics and consolidated data tables to make information accessible andunderstandable.

286

Comparability

287

Requirement

288
289
290

a. The organization shall select, compile, and report information in a consistent manner, toenable the an analysis of changes in the organization’s impacts over time and an theanalysis of these impacts relative to other organizations.

Page 10 of 14291

Guidance292
293

Comparability is necessary for evaluating an organization’s current impacts against its past impacts
and its goals and targets, and against the impacts of other organizations.

294
295
296
297

Consistency Comparability allows an organization to assess its progress. It allows is also necessary
for assessing progress external parties to assess and benchmark the organization’s progress and forbenchmarkingthe by the organization or external parties as part of rating activities, investment
decisions, and advocacy programs, among other activities.

298
299
300
301

To facilitate comparability, it is important for the organization to maintain consistency in the methods
used to calculate data, in the report layout, and in explanations of methods and assumptions used toprepare the information. This allows for evaluating an organization’s current impacts against its past
impacts and its goals and targets, and against the impacts of other organizations.

302

To apply the Comparability principle, the organization should:

303
304

•

present information for the current reporting period and at least two previous periods, as wellas any goals and targets that have been set;

305
306

•

use generally accepted international metrics (e.g., kilograms or liters), and standard
conversion factors and protocols, where applicable, for compiling and reporting information;

307
308

•

maintain consistency in the methods used to measure and calculate data and in how thesemethods are described;

309
310

•

maintain consistency in the the manner of presenting information, , and explain the methods
and assumptions used to prepare the information;

311
312
313

•

use generally accepted international metrics (e.g., kilograms or liters), standard conversion
factors, and protocols, where applicable, for compiling and reporting information, and describe
the bases for measurements and calculations where this is not apparent;

314
315
316

•

report total numbers or absolute data (e.g., metric tons of CO2 equivalent) as well as ratios ornormalized data (e.g., CO2 emissions per unit produced) to enable comparisons, and provide
explanatory notes when using ratios;

317
318
319
320

•

provide contextual information (e.g., organization’s size, geographic location) that helps
information users understand the factors that contribute to differences between theorganization’s impacts and the impacts of other organizations, such as the organization’s sizeand geographic location;

321
322
323
324
325
326

•

if there are changes in the information reported by the organization’s for its identified material
topics, in the length of the reporting period, or in other elements of reporting, such as thedefinitions used, present the current disclosures alongside restatements of historic data toenable comparisons. The organization is required to explain any restatements of informationfrom previous reporting periods and their effect, and report the reasons for such restatements,
under Disclosure REP-4 in GRI 102: About the Organization;

327
328

•

when if restatements of historic data are not provided, explain the changes to provide
contextual information for interpreting the current disclosures.

Page 11 of 14329

Completeness

330

Requirement

331
332

a. The organization shall provide sufficient information to enable anthe assessment of theorganization’s impacts during the reporting period.

333

Guidance334

To apply the Completeness principle, the organization should:

335•

not omit information that is necessary for understanding the organization’s impacts;

336
337
338
339
340

•

present activities, events, and impacts for the reporting period in which they occur. This
includes reporting on activities that have a minimal short-term impact in the short-term, butthat have a reasonably foreseeable cumulative impact that can become unavoidable orirreversible in the long-term (such ase.g., activities that generate bio-accumulative or
persistent pollutants).

341
342
343

If the organization consists of multiple entities that form a consolidated group (i.e., a parent entity andits subordinate entities), the organization is required to explain the approach used for consolidating
the information under . See REP-2-c in GRI 102: About the Organization.

344
345
346
347

If gaps are identified in collecting information (e.g., when information is not available for all relevant
activities or entities, or is incomplete), the organization is required to identify and explain these gaps
when reporting in accordance with the GRI Standards. See Requirement A-5-b in Section 3.1 of thisStandard for more information on reasons for omission.

348

Sustainability context

349

Requirement

350
351

a. The organization shall report information on its impacts in the wider context ofsustainable development.

352

Guidance

353
354
355
356
357

The objective of sustainability reporting is to provide transparency on how an organization contributes,
or aims to contribute to sustainable development, which ‘meets the needs of the present withoutcompromising the ability of future generations to meet their own needs’2. For this reason theorganization needs to assess and report information on its impacts in the broader context ofsustainable development.

358

To apply the Sustainability context principle, the organization should:

359
360
361

•

draw on societal expectations as well as objective information and authoritative measures onsustainable development, where available, when reporting on its impacts (e.g., scientificresearch or consensus on ecological limits, societal expectations);

362
363
364

•

report information on its impacts in relation to with reference to internationally-agreed
sustainable development goals and conditions (e.g., , the limits and demands placed on
environmental resources, and social and economic objectives and goals);

365
366
367
368

•

report information on its impacts , as reflected in recognized sector-specific, local, regional, or
global instruments (e.g., reporting total GHG emissions as well as reductions in GHG
emissions in relation to the goals set with reference to out in the United Nations Framework
Convention on Climate Change [UNFCCC] Paris Agreement);

369
370

•

report information on its impacts with referencein relation to expectations of responsible
business conduct set out in internationally recognized instruments with which the organization

2 World Commission on Environment and Development, Our Common Future, 1987.Brundlandt report

Page 12 of 14

371
372
373
374
375

is expected to comply (e.g., OECD Guidelines for Multinational Enterprises, UN Guiding
Principles on Business and Human Rights);•

if operating in a diverse range of locations, report information in a way that communicates its
impacts in relation to appropriate local contexts (e.g., reporting total water use as well aswater use relative to the sustainable thresholds and the social context of given catchments).

376
377
378

Tthe organization’s sustainability context provides the organization with critical information for
identifying and reporting on its material topics and related impacts (see GRI 103: Material Topics).
The GRI Sector Standards describe the sustainability context for organizations in a given sector.

379

Timeliness

380

Requirement

381
382

a. The organization shall report information on a regular schedule and make it available intime for information users to make decisions.

383

Guidance

384
385
386
387

The usefulness of information is closely tied to whether it is available in time for information users tointegrate it into their decision-making. The Timeliness principle refers to how regularly information isreported, as well as how soon after up to date the information is in relation to the reporting period theinformation is published..

388

To apply the Timeliness principle, the organization should:

389•

make information available in a timely manner;

390
391
392

•

balance the need to make information available in a timely manner with the need to ensurethat the information is rofeliable high quality and meets the requirements under the otherreporting principles;393•

ensure consistency in the frequency of reporting and the length of reporting periods;

394
395

•

clearly indicate the time period covered by the reported information, for example,particularly
when presenting information for several periods;•

indicate when the reported information was last updated and when it will be updated next.

396
397
398

See Section 5.1 of this Standard for information on aligning the reporting periods and the publishingschedules of sustainability reporting with other types of reporting.

399

Verifiability

400

Requirement

401
402

a. The organization shall gather, record, compile, and analyze information in a way that the
information can be examined to establish its credibility.

403

Guidance404
405

It is important that the reported information can be examined to establish its credibility and to
determine the extent to which the reporting principles have been applied.

406

To apply the Verifiability principle, the organization should:

407
408
409

•

ensure that individuals other than those involved in preparing the reported information (e.g.,internal auditors, external assurance providers) are able to review the supporting internal
controls and documentation;

Page 13 of 14

410
411
412

•

document the decision-making processes underlying the organization’s sustainability
reporting in a way that allows for the examination of the key decisions andas well as theprocesses, such as the identification of material topics;

413
414

•

if the organization designs information systems for its sustainability reporting, design thesesystems in a way that they can be examined as part of an external assurance process;

415
416

•

be able to identify the original sources of the reported information and provide reliable
evidence to support assumptions or complex calculations;

417
418
419

•

be able to provide representation from the original information sources, of the reported
information attesting to the accuracy of the reported information within acceptable margins oferror;

420
421•

avoid including information that is not substantiated by evidence, unless it is relevant forunderstanding the organization’s impacts;

422
423

•

provide unambiguous explanations of any uncertainties associated with the reported
information.

424
425

See Section 5.2 of this Standard for more information on enhancing the credibility of sustainability
reporting.

Page 14 of 14