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

Item 01 – GRI Universal Standards
Project – Revised GRI 101: Section 3.
For GSSB discussion
Date

16 March 2021

Meeting

25 March 2021

Project

GRI Universal Standards Project

Description

This document presents the revised draft of Section 3. Reporting in accordancewith the GRI Standards in GRI 101: Using the GRI Standards following the publiccomment feedback.
Key changes are highlighted in comment boxes within the document.
The exposure draft of Section 3 of GRI 101 is included in Annex 1. It can also befound here: https://www.globalreporting.org/standards/media/2605/universalexposure-draft.pdf#page=11.
The public comments to Section 3 of GRI 101 can be found here:
https://www.globalreporting.org/media/3uypwlmr/item-02-public-comments-torevisions-on-the-reporting-model-in-the-universal-standards.pdf

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

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Contents
Explanatory note ..................................................................................................................................... 3
Revised GRI 101: Using the GRI Standards........................................................................................... 4
Section 3. Reporting in accordance with the GRI Standards .................................................................. 4
Annex 1. GRI 101: Using the GRI Standards in the exposure draft ..................................................... 18

Page 2 of 27

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Explanatory note

3

The following significant revisions have been made in response to public comment feedback:4

Section 3. Reporting in accordance with the GRI Standards

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The section now focuses on reporting in accordance with the GRI Standards to communicatethat this is the preferred approach of reporting with the GRI Standards. Therefore, reporting inaccordance with, and with reference to, the GRI Standards are no longer presented side byside as two approaches that can be used to report with the GRI Standards. All information
related to reporting with reference is now included in the sub-section ‘Reporting withreference to the GRI Standards’. Also, a recommendation has been added that organizations
reporting with reference to the GRI Standards when they are unable to comply with all the inaccordance requirements, should transition to reporting in accordance with the GRI
Standards in time. See lines 52-69 and 328-341.
Revised the mechanism to use reasons for omissions. Reasons for omission are permitted fordisclosures in GRI 102 and GRI 103 with the exception of Disclosures REP-1, REP-2, REP-3,
REP-4, REP-5, MT-1 and MT-2. A standalone requirement has been introduced to provide a
reason for omission when the organization cannot comply with a disclosure or a requirement
in a disclosure for which reasons for omission are permitted in the GRI content index. Seelines 204-260.
A reason for omission must now be used when an item required by the disclosure does notexist to ensure consistent and clear reporting about items (e.g., policy, practice, committee, orrole) that do not exist. The organization uses ‘not applicable’ as the reason for omission inthese instances. See lines 223-228.
Revised the concept of ‘appropriate disclosures’, which were defined as disclosures that
adequately capture the impacts related to the organization’s material topics. The disclosuresfrom the GRI Topic Standards that are required to be reported for each material topic are now
defined as those disclosures that are relevant for reporting on its impacts and approach inrelation to a material topic. See lines 136-139.
A new requirement has been included to either report on the disclosures from the GRI Topic
Standards listed for a material topic covered in the applicable Sector Standard, or provide the‘not applicable’ reason for omission and the required explanation in the GRI content index.
Such an explanation helps understand whether the disclosures are indeed not relevant forreporting on the organization’s impacts and approach in relation to a material topic andwhether they have not been reported for the right reasons. An organization is required tocomply with this requirement only if GRI Sector Standards that apply to the organization’s
sectors are available. If there is no applicable Sector Standard available, the organization is
not required to explain why disclosures from the GRI Topic Standards are not relevant forreporting on the its impacts and approach in relation to the material topic. See lines 129-133.
A new requirement has been added to include the disclosure title in the GRI content index inaddition to the disclosure code. This will help information users understand what the reported
disclosures are about. This used to be a recommendation. See lines 270 and 347.
Retained the statement of use, but amended wording to avoid implication of direct legal
responsibility for the statement by the body signing off the statement. The statement is now to
be issued by the organization with acknowledgement of the highest governance body’s orsenior executives’ involvement in reviewing and approving the reported information. See lines
295-299 and 368-372.

47

Additional revisions made in response to public comment feedback are explained in comment boxes.

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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.

Page 3 of 27

50

Revised GRI 101: Using the GRI

51

Standards

52

Section 3. Reporting in accordance

53

with the GRI Standards

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55
56
57
58
59

Reporting in accordance with the GRI Standards enables an organization to provide a comprehensive
picture of its most significant impacts on the economy, environment, and people, including impacts on
their human rights. The organization uses the GRI Standards to report information on all its material
topics and how it manages these topics, and to provide contextual information about itself. This allows
information users to make informed assessments and decisions about the organization’s contribution
to sustainable development.

60
61
62
63

The organization must comply with all nine requirements in this section to report in accordance with
the GRI Standards. For disclosures for which reasons for omission are permitted, the organizationmust either report the required information, or if that is not possible, provide one of the reasons foromission in Table 2. See Requirement 6 for more information.

64

Table 1. Overview of in accordance requirements

Commented [SD1]: Section 3 focuses on reporting inaccordance with the GRI Standards to communicate
this is the preferred approach of reporting with the GRI
Standards. These changes have been made:- Reporting in accordance with, and with reference to,
the GRI Standards are no longer presented side by side
as two approaches that can be used to report with the
GRI Standards.
- Sections 3.1 and 3.2 have been removed. All
information about reporting with reference to the GRI
Standards is included in the sub-section ‘Reporting withreference to the GRI Standards’.
- Approach A and B have been removed.
Commented [SD2]: Type of change: editorial revision.
Original wording: “Sustainability reporting using the GRI
Standards”.
Commented [SD3]: Type of change: editorial revision.
Original wording: “complete and balanced picture”.

Requirement 1: Apply the reporting principles
Requirement 2: Report the disclosures in GRI 102: About the Organization

There was confusion with ‘completeness’ and ‘balance’
being two of the reporting principles.

Requirement 3: Determine material topics

Commented [SD4]: Type of change: editorial revision.

Requirement 4: Report the disclosures in GRI 103: Material Topics

New text added.

Requirement 5: Report disclosures from the GRI Topic Standards for each material topic

Commented [SD5]: Type of change: editorial revision.

Requirement 6: Provide reasons for omission for disclosures and requirements that theorganization cannot comply with

New text added.

Requirement 7: Publish a GRI content index

Commented [SD6]: Type of change: editorial revision.
The requirements for reporting with reference to the
GRI Standards have been moved to Table 3 in the
Section ‘Reporting with reference to the GRI
Standards’.

Requirement 8: Provide a statement of use
Requirement 9: Notify GRI
65
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67
68
69

If the organization does not comply with all in accordance requirements, it cannot claim that it has
prepared the reported information in accordance with the GRI Standards. In this case, theorganization may be able to claim that it has prepared the reported information with reference to the
GRI Standards, provided it complies with the requirements set out in the Section ‘Reporting withreference to the GRI Standards’.

70

Requirement 1: Apply the reporting principles

Commented [SD8]: Type of change: editorial revision.

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72

a. The organization shall apply all the reporting principles set out in Section 4 of GRI 101:
Using the GRI Standards.

Original wording: “Requirement A-1”.

These requirements have ben revised in line with thechanges made to the requirements.
Commented [SD7]: Type of change: editorial revision.
Original wording: “Section 3.2”.

Page 4 of 27

The requirements are numbered differently, asApproach A and B have been removed. This change
applies to all requirements.

74

Requirement 2: Report the disclosures in GRI 102: About theOrganization

75

a. The organization shall report all disclosures in GRI 102.

76

Guidance77

Reasons for omission are permitted for all disclosures in GRI 102 except for:

73

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•

REP-1 Organizational details

79•

REP-2 Organizational entities included in the sustainability reporting80•

REP-3 Reporting period and frequency

81•

REP-4 Restatements of information

82•

REP-5 External assurance

Commented [SD9]: Type of change: revision following
public comment feedback.
Added guidance to explain that reasons for omission
are permitted for most disclosures in GRI 102, and what
the requirements are when using reasons for omission.

83
84
85
86

If the organization cannot comply with a requirement in a disclosure in GRI 102 for which reasons foromission are permitted, the organization is required to specify the requirement it cannot comply with,and provide a reason for omission and an explanation. See Requirement 6 for more information on
how to report reasons for omission.

87

Requirement 3: Determine material topics

88

The organization shall:

89

a. determine its material topics;90

b. use the GRI Sector Standard(s) that apply to its sector(s) and:Commented [SD10]: Type of change: global editorial
revision.
Original wording: ”identify its material topics”.

91
92

i.

determine whether each topic in the applicable GRI Sector Standard(s) is a material
topic for the organization;

93
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95

ii.

list, in the GRI content index, any topics from the applicable GRI Sector Standard(s)that the organization has determined as not material and explain why they are notmaterial.

Commented [SD11]: Type of change: editorial
revision.
Original wording: “use the GRI Sector Standard(s) that
apply to its sector(s), where these are available, whenidentifying its material topics in A-3-a.”Commented [SD12]: Type of change: editorial
revision.

96

Guidance

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Guidance to 3-a

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See Section 2 of GRI 103: Material Topics for guidance on how to determine material topics.

99

Guidance to 3-b

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101
102

The organization is required to comply with 3-b only if GRI Sector Standards that apply to its sectors
are available. The Sector Standards provide information for organizations in a given sector about theirmost likely material topics.

103
104
105

The organization is required to use the applicable Sector Standards when determining its material
topics. Using the Sector Standards helps the organization determine its material topics, but theorganization is still required to determine its material topics based on its specific circumstances.

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108
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110

The organization needs to review each topic described in the applicable Sector Standards anddetermine whether it is a material topic for the organization. If any of the topics that are included in theapplicable Sector Standards have been determined by the organization as not material, theorganization is required to list them in the GRI content index and explain why they are not material.
See Requirement 7 for more information on the content index.

Page 5 of 27

Requirement relocated from Disclosure MT-2.
It has also been clarified that the list of topics that theorganization has determined as not material and the
explanation are required to be reported in the GRI
content index.
Commented [SD13]: Type of change: editorial
revision.
Relevant guidance from ‘Guidance to MT-2-b’ has been
relocated to this section.

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Section 2 of GRI 103 and the GRI Sector Standards provide guidance on how to use the GRI Sector
Standards when determining material topics.
Commented [SD14]: Type of change: editorial
revision.

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Requirement 4: Report the disclosures in GRI 103: Material Topics

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The organization shall:

Revised requirements in line with changes made to thetitles of Disclosures MT-1, MT-2, and MT-3.

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a. report how it has determined its material topics using Disclosure MT-1;

Commented [SD15]: Type of change: revision
following public comment feedback.

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b. report a list of its material topics using Disclosure MT-2;

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c. report how it manages each material topic using Disclosure MT-3, irrespective of whether
the topic is covered by a GRI Topic Standard or not.

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Guidance

Commented [SD16]: Original wording: “reportappropriate disclosures from the GRI Topic Standards
that correspond to the material topic;”

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Reasons for omission are only permitted for Disclosure MT-3 Management of material topics in GRI
103.

Type of change: revision following public comment
feedback.

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If the organization cannot comply with a requirement in Disclosure MT-3, the organization is required
to specify the requirement it cannot comply with, and provide a reason for omission and an
explanation. See Requirement 6 for more information on how to report reasons for omission.

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Requirement 5: Report disclosures from the GRI Topic Standards
for each material topic

The reference to ‘appropriate disclosures’ has been
removed, as the concept of ‘appropriate disclosures’ isrevised. Appropriate disclosures were defined as thosethat adequately capture the impacts related to theorganization’s material topics. It is now required for theorganization to report the disclosures from the Topic
Standards that are relevant for reporting on its impacts
and approach in relation to a material topic.

127

The organization shall:

128

a. report disclosures from the GRI Topic Standards for each material topic;

129

b. when a material topic is covered in the applicable GRI Sector Standard(s), either:

Added guidance to explain that reasons for omission
are permitted for Disclosure MT-3 in GRI 103, and what
the requirements are when using reasons for omission.

Type of change: editorial revision.

130
131

i.

report on the disclosures from the GRI Topic Standards listed for that topic in the
Sector Standard, or;

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133

ii.

provide the ‘not applicable’ reason for omission and the required explanation in the
GRI content index.

134

Guidance

135

Guidance to 5-a

136
137
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139

For each material topic, the organization needs to identify disclosures from the GRI Topic Standards
to report on. The organization is required to report only on those disclosures that are relevant forreporting on its impacts and approach in relation to a material topic; it is not required to report on
disclosures that are not relevant.

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There is no requirement for the organization to report on a minimum number of disclosures from theTopic Standards. The number of disclosures that the organization reports on is based on theorganization’s own assessment of how many disclosures are relevant for reporting on its impacts andapproach in relation to a material topic.

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The organization may need to use more than one Topic Standard to report on a material topic. In
addition, not all disclosures in a Topic Standard may be relevant for the organization to report on. For
example, an organization identifies pay equality as a material topic. The organization needs to report
Disclosure 202-1 Ratios of standard entry level wage by gender compared to local minimum wage
from GRI 202: Market Presence 2016, and Disclosure 405-2 Ratio of basic salary and remunerationof women to men from GRI 405: Diversity and Equal Opportunity 2016. The organization is not
required to report other disclosures from these Standards (such as Disclosure 202-2 Proportion ofPage 6 of 27

The words ‘that correspond to the material topic’ havebeen removed to clarify it is required to report all
disclosures that are relevant for reporting on theimpacts and approach in relation to a material topic,
irrespective of whether they come from a Topic
Standard that corresponds to the material topic or not.
Commented [SD17]: Type of change: revision
following public comment feedback.
Added a new requirement for organizations to either
report on the disclosures from the Topic Standards
listed for a material topic covered in the applicable
Sector Standard, or provide the ‘not applicable’ reason
for omission and the required explanation in the GRI
content index.
Commented [SD18]: Type of change: editiorialchange.
Guidance has been revised in line with the changes
made to Requirement 5-a. For example, the guidance
explaining that the topic names used in the GRI Topic
Standards are intentionally high-level, and what to do if
a material topic does not exactly match the topic names
used in the GRI Standards, has been removed because
the reference to corresponding Topic Standards has
been removed from the requirement.
Commented [SD19]: Type of change: revision
following public comment feedback.
Added guidance to clarify that there is no minimum
number of disclosures to be reported from the GRI
Topic Standards.

151
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senior management hired from the local community), as these disclosures do not address the topic of
pay equality.

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When a material topic is covered in the applicable GRI Sector Standard(s), the organization isrequired to use the Sector Standard(s) to identify disclosures to report on. See Requirement 5-b formore information.

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159

Reasons for omission are permitted for all disclosures from the Topic Standards. If the organization
cannot comply with a requirement in a disclosure from the Topic Standards, the organization isrequired to specify the requirement it cannot comply with, and provide a reason for omission and an
explanation. See Requirement 6 for more information on how to report reasons for omission.

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161
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165

The organization should provide sufficient information about its impacts and approach in relation toeach material topic, so that information users can make informed assessments and decisions about
the organization. If the disclosures from the Topic Standards do not provide sufficient information
about the organization’s impacts and approach, then the organization should report additional
disclosures. These can include additional disclosures recommended in the Sector Standards,
disclosures from other sources, or disclosures developed by the organization itself.

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168

Disclosures that the organization reports from other sources, or that are developed by theorganization itself, should have the same rigor as disclosures from the GRI Standards, and theyshould align with expectations set out in authoritative intergovernmental instruments.

169

Reporting on material topics not covered by the GRI Topic Standards

170
171
172
173

When a material topic is not covered by the disclosures in the GRI Topic Standards, the organization
should report other disclosures for that topic. These can include additional disclosures recommended
in the GRI Sector Standards, disclosures from other sources, or disclosures developed by theorganization itself.

174
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176

If the organization’s material topic is not covered by the disclosures in the Topic Standards, theorganization is still required to report how it manages the material topic, using Disclosure MT-3 in GRI
103: Material Topics. See Requirement 4-c for more information.

New text added.

177
178
179
180

For example, an organization identifies freedom of speech as a material topic. As there is no Topic
Standard that covers this topic, the organization should report disclosures from other sources ordevelop its own disclosures to report on the topic. The organization is still required to report how it
manages the topic of freedom of speech, using Disclosure MT-3 in GRI 103: Material Topics.

New text added.

181

Guidance to 5-b

182
183
184

The organization is required to comply with 5-b only if GRI Sector Standards that apply to its sectors
are available. The Sector Standards provide information for organizations in a given sector about theirmost likely material topics.

Commented [SD26]: Type of change: revision
following public comment feedback.

185
186

The organization needs to review each topic described in the applicable Sector Standards anddetermine whether it is a material topic for the organization.

Added guidance to explain how to report on material
topics that are not covered by the GRI Topic Standards.

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188
189
190
191
192
193
194
195
196

If the organization determines a topic in an applicable Sector Standard to be material, theorganization is also required to use the Sector Standard to identify disclosures to report on its impacts
and approach in relation to that topic. For each likely material topic, the Sector Standards list
disclosures from the Topic Standards for organizations to report on. If any of the disclosures listed in
the Sector Standards are not relevant for reporting on the organization’s impacts and approach, theorganization is not required to report these. However, the organization is required to identify these
disclosures in the GRI content index and provide ‘not applicable’ as the reason for omission for notreporting on the disclosures. The organization is also required to explain in brief why the disclosures
are not relevant for reporting on its impacts and approach in relation to the material topic. See
Requirement 6 for more information on how to report reasons for omission.

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199

Note that the organization can still use any of the four reasons for omission included in Table 2 if itcannot comply with a requirement in a disclosure from the GRI Topic Standards listed for a material
topic covered in the Sector Standards that the organization reports on.

200
201

In addition to disclosures from the Topic Standards, the Sector Standards may list additional
disclosures for organizations to report on. Reporting on these additional disclosures is not a

Commented [SD20]: Type of change: editorial
revision.
The example has been updated to illustrate that anorganization may need to use more than one GRI Topic
Standard to report on a material topic and that not all
disclosures in a Topic Standard may be relevant for theorganization to report on. In addition, GRI 302: Energy
2016 and GRI 305: Emissions 2016 may change when
updating the climate-related GRI Standards.
Commented [SD21]: Type of change: editorial
revision.
Original wording: “If the organization identifies a topic asmaterial and that topic is included in the applicable GRISector Standard, this Sector Standard can also assist
the organization in determining appropriate disclosures
to report on that topic.”
Commented [SD22]: Type of change: editorial
revision.
Added guidance to clarify that reasons for omission are
permitted for all disclosures from the GRI Topic
Standards.
Commented [SD23]: Type of change: editorial
revision.

Commented [SD24]: Type of change: editorial
revision.

Commented [SD25]: Type of change: editorial
revision.
New text added.

Page 7 of 27

Commented [SD27]: Type of change: editorial
revision.
The example has been updated.
Commented [SD28]: Type of guidance: editorial
revision.
Added guidance for the new Requirement 5-b.

202
203

requirement. The organization is also not required to explain why the additional disclosures are not
relevant for reporting on its impacts and approach.

204
205

Requirement 6: Provide reasons for omission for disclosures andrequirements that the organization cannot comply with

206
207
208

a. If the organization cannot comply with a disclosure or a requirement in a disclosure forwhich reasons for omission are permitted, the organization shall, in the GRI content
index:

209i.

specify the disclosure or requirement it cannot comply with;

210
211

ii.

provide one of the four reasons for omission included in Table 2 and the required
explanation for that reason.

212

Table 2. Permitted reasons for omission and required explanations
Reason for omission

Required explanation

Not applicable

Explain why the disclosure or requirement is considered not
applicable.

Legal prohibitions

Describe the specific legal prohibitions.

Confidentiality constraints

Describe the specific confidentiality constraints.

Information unavailable /incomplete

Specify whether all or part of the information is unavailable.
When part of the information is unavailable, specify whichpart (e.g., list the entities for which the information isunavailable).

Commented [SD29]: Type of change: revision
following public comment feedback.
Added this new requirement, because the use ofreasons for omission has been extended to mostdisclosures in GRI 102 and Disclosure MT-3 in GRI
103. It includes Requirement A-5-b and theaccompanying guidance from the exposure draft.
Commented [SD30]: Type of change: editorial
revision.
Original wording: “if it cannot comply with a requirement
within an appropriate disclosure from a GRI Topic
Standard identified in A-5-a:”Reasons for omission could only be used forrequirements in appropriate disclosures. Now they canbe used for requirements in most disclosures in GRI
102 and Disclosure MT-3 in GRI 103. In addition, the‘not applicable’ reason for omission can be used fordisclosures from a GRI Topic Standard that are listed ina GRI Sector Standard (see Requirement 5-b-ii). It has
also been clarified that it is required to provide thisinformation in the GRI content index.
Commented [SD31]: Type of change: editorial
revision.
Original wording: “requirement that it has omitted”.
Commented [SD32]: Type of change: editorialchange.
Original wording: “Reasons for omission”.

Explain why the required information is unavailable.

Commented [SD33]: Type of change: revision
following public comment feedback.

Describe the steps being taken, and the expected time frame,
to obtain the unavailable information.

Original wording: “Not appropriate”.
Commented [SD34]: Type of change: revision
following public comment feedback.

213

Guidance214

Reasons for omission are permitted for all disclosures from the GRI Standards except for:215•

REP-1 Organizational details

216•

REP-2 Organizational entities included in the sustainability reporting217•

REP-3 Reporting period and frequency

218•

REP-4 Restatements of information

219•

REP-5 External assurance

220•

MT-1 Process to determine material topics

221•

MT-2 List of material topics

Original wording: “Describe why the requirement does
not contribute toward explaining the impacts related tothe organization’s material topic.”
Commented [SD35]: Type of change: revision
following public comment.
Requirement added to specify whether all or part of theinformation is unavailable, and which part.
Commented [SD36]: Type of change: editorial
revision.
Original wording: “If the required information cannot be
obtained, or it is not of adequate quality to report (asmight be the case when the information is collectedfrom another organization, e.g., a supplier), explain thissituation.”
Commented [SD37]: Type of change: revision
following public comment feedback.
Added this guidance to explain for which disclosuresreasons for omission are permitted.

Page 8 of 27

222
223
224

The organization is only permitted to use one of the four reasons for omission included in Table 2:•

Not applicable – The organization can use ‘not applicable’ as the reason for omission in thefollowing situations:

225
226
227
228

-

When the item required by the disclosure (e.g., a committee, policy, practice, or process)does not exist – In these cases, the organization is required to state that the item, such as
the committee, policy, practice, or process, does not exist. Additionally, the organization
can explain the reason for not having the item or describe any plans to develop it.

229
230
231
232
233

-

When a disclosure from the GRI Topic Standards that is listed in the applicable GRISector Standard is not relevant for reporting on the organization’s impacts and approachin relation to the material topic – In these cases, the organization is required to explain
why the disclosure is not relevant for reporting on the organization’s impacts andapproach in relation to the material topic.

234
235

•

Legal prohibitions – The organization can use ‘legal prohibitions’ as the reason for omission
when the law forbids collecting the required information or reporting it publicly.

236
237
238
239

•

Confidentiality constraints – There may be cases where the law does not forbid collecting
or reporting the required information, but the organization considers the information
confidential and cannot report it publicly. In this case, the organization can use ‘confidentiality
constraints’ as the reason for omission.

240
241
242

•

Information unavailable / incomplete – The organization can use ‘information unavailable /incomplete’ as the reason for omission when it cannot report all or part of the required
information.

243
244
245
246
247
248

When the organization cannot report part of the required information it means the information
is incomplete, i.e., it does not cover the complete scope of information required under thedisclosure. For example, when the organization does not have information for certain entities,
sites, or geographic locations, the organization is required to use ‘information unavailable /incomplete’ as the reason for omission, and to specify the entities, sites, or geographic
locations for which the required information is unavailable and cannot be reported.

249
250
251

The required information, or part of the required information, can be unavailable when, forexample, it cannot be obtained or is not of adequate quality to report (this could be the casewhen the information is collected from another organization, e.g., a supplier).

252
253
254
255
256
257

‘Confidentiality constraints’ and ‘information unavailable / incomplete’ should only be used in
exceptional cases. Using ‘confidentiality constraints’ and ‘information unavailable / incomplete’frequently as reasons for omitting information reduces the credibility and usefulness of anorganization’s sustainability reporting. It does not align with the aim of reporting in accordance with
the GRI Standards, which is to provide a comprehensive picture of the organization’s most significant
impacts.

258

The organization is not allowed to use other reasons for omission than those included in Table 2.

259
260

The reasons for omission are required to be reported in the GRI content index. See Requirement 7 formore information on the content index.

Commented [SD38]: Type of change: editorial
revision.
Guidance has been added to clarify when each reason
for omission can be used.

Commented [SD39]: Type of change: editorial
revision.
Added a new requirement for organizations to use ‘notapplicable’ as reason for omission when the item
required by the disclosure does not exist.
Commented [SD40]: Type of change: editorial
revision.
Added a new requirement for the organization to use‘not applicable’ as reason for omission when adisclosure from the GRI Topic Standards that is listed in
the applicable GRI Sector Standard is not relevant forreporting on its impacts and approach in relation to thematerial topic (see Requirement 5-b-ii).

Commented [SD41]: Type of change: revision
following public comment feedback.
Added guidance for the new required explanation to
specify what information is unavailable.
Commented [SD42]: Type of change: editorial
revision.
Guidance relocated from ‘information incomplete orunavailable’ reason for omission in Table 2.
Commented [SD43]: Type of change: revision
following public comment feedback.
Original wording: “Reasons for omission should only be
used in exceptional cases when the organization isunable to comply with a requirement. Using reasons foromission frequently or for critical requirements reduces
the credibility and usefulness of the reported
information.”
Commented [SD44]: Type of change: revision
following public comment feedback.
Original wording: “Additionally, it does not align with
reporting in accordance with the GRI Standards”.
Commented [SD45]: Type of change: editorial
revision (new text added).

Page 9 of 27

261

Requirement 7: Publish a GRI content index

262

The organization shall:

263

a. publish a GRI content index that includes:

Commented [SD46]: Type of change: editorial
revision.
Requirements relocated from Appendix 1, where they
were included in the guidance section.
Commented [SD47]: Type of change: editorial
revision.

264

i.

the title: GRI content index;

265

ii.

the statement of use;

266

iii.

the titles of the Sector Standard(s) that apply to the organization’s sector(s);

267

iv.

the organization’s material topics;

268
269

v.

a list of the topics in the Sector Standards determined as not material and an
explanation for why they are not material;

270

vi.

a list of the reported disclosures (including the disclosure code and title);

271
272
273

vii.

a list of the Topic Standards disclosures from the Sector Standards that theorganization does not report on for a material topic, and the required reason foromission;

274
275

viii.

the titles of the GRI Standards or other sources that the reported disclosures come
from;

276

ix.

the location where the information reported under each disclosure can be found;

277

x.

any reasons for omission used;

278

xi.

the Sector Standard reference numbers;

Added new requirement for the organization to list its
material topics in the GRI content index.
Commented [SD48]: Type of change: editorial
revision.
Added new requirement to include a list of the topics in
the Sector Standards determined as not material and an
explanation for why they are not material in the GRI
content index (see Requirement 3-b-ii).
Commented [SD49]: Type of change: revision
following public comment feedback.
Added new requirement to report the disclosure title in
the GRI content index.
Commented [SD50]: Type of change: editorial
revision.
Added new requirement to list the Topic Standards
disclosures from the Sector Standards that theorganization does not report on for a material topic, andthe required reason for omission in the GRI content
index (see Requirement 5-b-ii).

279

b. present the complete GRI content index in a publicly and easily accessible location;

280
281

c. if it publishes a standalone sustainability report and the GRI content index is not provided
in the report itself, include a link or reference to the GRI content index in the report.

282

Guidance

Original wording: “The GRI Universal Standards andTopic Standards it has used”.

283
284
285
286
287

The information reported using the GRI Standards can be published or made available across one ormore locations (e.g., standalone sustainability report, webpages, annual report). The GRI content
index provides an overview of the organization’s reported information, shows where the reported
information can be found, and helps information users access this information. The content index also
shows which GRI Standards and disclosures the organization has used.

Commented [SD52]: Type of change: editorial
revision.

288
289
290
291

Appendix 1 provides guidance on how to prepare the GRI content index. It includes an example tablethat the organization can use to prepare the content index. The organization can use a different
format for the content index than the one provided in Appendix 1 as long as it complies with therequirements for the content index.

292
293

The organization is required to include the full title of the GRI Standard, which includes the number,
name, and publication year, for each Standard it has used (e.g., GRI 303: Water and Effluents 2018).

Commented [SD51]: Type of change: editorial
revision.

Added new requirement to report the Sector Standard
reference numbers. These refer to the unique identifier
for each disclosure identified in a Sector Standard.
Commented [SD53]: Type of change: editorial
revision.
Added a new requirement to include a link or reference
to the GRI content index in the report, if the organization
publishes a standalone sustainability report and the GRI
content index is not provided in the report itself.
Commented [SD54]: Type of change: editorial
revision.
Guidance revised to reflect that the GRI content index is
not only a navigation tool anymore.
Commented [SD55]: Type of change: editorial
revision.
Guidance added to clarify that it is not required to use
the content index table in Appendix 1.
Commented [SD56]: Type of guidance: editorial
revision (new text added).

Page 10 of 27

294

Requirement 8: Provide a statement of use

295

a. The organization shall include the following statement in its GRI content index:

296
297
298
299

[Title of the highest governance body, senior executive, or group of senior executivesof the organization] has reviewed and approved the reported information. The
information reported by [name of organization] for the [reporting period] has been
prepared in accordance with the GRI Standards.

300

Guidance

301
302
303

The organization is required to insert the title of its highest governance body, senior executive orgroup of senior executives, the name of the organization, and the reporting period in the statement.
For example:

304
305
306

‘The Board of Directors has reviewed and approved the reported information. The information
reported by ABC Limited for the year ending 31 December 2020 has been prepared inaccordance with the GRI Standards.’

307
308
309
310
311

The term ‘GRI Standards’ in the statement refers to all Standards (Universal Standards: GRI 101, GRI
102, GRI 103, Sector Standards, and Topic Standards) that are effective at the date when theinformation is published, as well as Standards that are adopted by the organization earlier than theireffective date. The effective date is the date from when it is mandatory for the organization to use aparticular GRI Standard.

312
313
314
315

The organization should consider its legal and operating context when determining whether thehighest governance body, a senior executive, or a group of senior executives should provide thestatement of use. For some organizations this decision will be influenced by applicable legislation or
regulation, depending on:

Commented [SD57]: Type of change: revision
following public comment feedback.
Original wording:“[Title of the highest governance body or most senior
executive of the organization] acknowledges
responsibility for the following statement of use:
The information reported by [name of organization] forthe [reporting period] has been prepared in accordancewith the GRI Standards.”
Commented [SD58]: Type of change: editorial
revision.
Guidance has been updated in line with the changes
made to the statement of use.
Commented [SD59]: Type of change: editorial
revision.
Original wording: “The term ‘GRI Standards’ includes allStandards”.

316•

the country where the organization is incorporated or registered;317•

a stock exchange the organization trades its securities on;

The following sentence has been removed: “Thisstatement applies to all information included in the GRI
content index.”

318
319

•

the nature and type of the organization (e.g., charity, incorporated company, mutualorganization).

Commented [SD60]: Type of change: editorial
revision.
New text added.

320

Requirement 9: Notify GRI

321
322

a. The organization shall notify GRI of the use of the GRI Standards and statement of use
through the GRI Standards Report Registration System.

323

Guidance

324
325
326
327

The GRI Standards Report Registration System can be accessed using the GRI website. The
registration system notifies GRI of the use of the GRI Standards and the corresponding statement of
use reported by the organization. There is no cost associated with notifying GRI of the use of theStandards.

Commented [SD61]: Type of change: editorial
revision.
Original wording: “register its reported information”.

Page 11 of 27

Reporting with reference to the GRI

Commented [SD62]: Type of change: editorial
revision.

329

Standards

Original wording: “3.2 Approach B: Reporting withreference to the GRI Standards”.

330
331
332
333

The organization can report with reference to the GRI Standards if it is unable to comply with all therequirements for reporting in accordance with the GRI Standards. The organization should transition
to reporting in accordance with the GRI Standards in time as it provides a comprehensive picture ofits most significant impacts on the economy, environment, and people.

334
335
336

The organization can also report with reference to the GRI Standards if it uses selected GRI
Standards, or parts of their content, to report information about specific topics for specific purposes,
for example, to comply with a specific reporting regulation on climate change.

337
338
339
340

The organization must comply with all three requirements in this section to report with reference to the
GRI Standards. The organization should also apply the reporting principles from Section 4 of thisStandard, which ensure high-quality reporting. Additionally, the organization should report how it
manages its impacts for the specific topics using Disclosure MT-3 in GRI 103: Material Topics.

341

Table 3. Overview of requirements for reporting with reference to the GRI Standards

328

Commented [SD63]: Type of change: editorial
revision.
The order of the scenarios of reporting with reference to
the GRI Standards has changed. The section now starts
with the scenario in which the organization is unable tocomply with all requirements for reporting in accordancewith the GRI Standards and then presents the scenario
in which the organization uses selected GRI Standards,
or parts of their content, to report information about
specific topics for specific purposes.
Commented [SD64]: Type of change: revision
following public comment feedback.
Added this recommendation.
Commented [SD65]: Type of change: editiorial
revision.

Publish a GRI content index
The overview of requirements relocated from Table 1 in
the introduction to Section 3.

Provide a statement of use

Commented [SD66]: Type of change: editorial
revision.

Notify GRI

342

Publish a GRI content index

343

The organization shall:344

a. publish a GRI content index that includes:

Original wording: “Requirement B-1: Publish a GRI
content index”.
The requirements for reporting with reference to the
GRI Standards are no longer numbered, as Approach B
has been removed. This change applies to all
requirements in this sub-section.
Commented [SD67]: Type of change: editorial
revision.

345

i.

the title: GRI content index;

346

ii.

the statement of use;

347

iii.

a list of the reported disclosures (including the disclosure code and title);

Requirements relocated from Appendix 2, where they
were included in the guidance section.

348
349

iv.

the titles of the GRI Standards or other sources that the reported disclosures comefrom;

Commented [SD68]: Type of change: revision
following public comment feedback.

v.

the location where the information reported under each disclosure can be found;

Added new requirement for the organization to report
the disclosure title in the GRI content index.

350
351

b. present the complete GRI content index in a publicly and easily accessible location;

352
353

c. if it publishes a standalone sustainability report and the GRI content index is not provided
in the report itself, include a link or reference to the GRI content index in the report.

354

Guidance

355
356
357
358
359

The information reported using the GRI Standards can be published or made available across one ormore locations (e.g., standalone sustainability report, webpages, annual report). The GRI content
index provides an overview of the organization’s reported information, shows where the reported
information can be found, and helps information users access this information. The content index also
shows which GRI Standards and disclosures the organization has used.

360
361
362

Appendix 2 provides guidance on how to prepare the GRI content index. It includes an example tablethat the organization can use to prepare the content index. The organization can use a different
format for the content index than the one provided in Appendix 2 as long as it complies with theCommented [SD69]: Type of change: editorial
revision.
Original wording: “The GRI Standards it has used”.

Page 12 of 27

Commented [SD70]: Type of change: editorial
revision.
Added a new requirement to include a link or reference
to the GRI content index in the report, if the organization
publishes a standalone sustainability report and the GRI
content index is not provided in the report itself.
Commented [SD71]: Type of change: editorial
revision.
Guidance revised to reflect that the GRI content index is
not only a navigation tool anymore.

363
364

requirements for the content index. The organization can also use the content index specified forreporting in accordance with the GRI Standards in Appendix 1, if suitable.

365
366

The organization is required to include the full title of the GRI Standard, which includes the number,
name, and publication year, for each Standard it has used (e.g., GRI 303: Water and Effluents 2018).

367

Provide a statement of use

Commented [SD73]: Type of guidance: editorial
revision.

368

a. The organization shall include the following statement in its GRI content index:

New text added.

369
370
371
372

[Title of the highest governance body, senior executive, or group of senior executivesof the organization] has reviewed and approved the reported information. The
information reported by [name of organization] for the [reporting period] has been
prepared with reference to the GRI Standards cited in this content index.

373

Guidance

374
375
376

The organization is required to insert the title of its highest governance body, senior executive orgroup of senior executives, the name of the organization, and the reporting period in the statement.
For example:

377
378
379

‘The Board of Directors has reviewed and approved the reported information. The information
reported by ABC Limited for the year ending 31 December 2020 has been prepared withreference to the GRI Standards cited in this content index.’

380
381
382
383
384

The term ‘GRI Standards’ in the statement refers to all Standards (Universal Standards: GRI 101, GRI
102, GRI 103, Sector Standards, and Topic Standards) that are effective at the date when theinformation is published, as well as Standards that are adopted by the organization earlier than theireffective date. The effective date is the date from when it is mandatory for the organization to use aparticular GRI Standard.

385
386
387
388

The organization should consider its legal and operating context when determining whether thehighest governance body, a senior executive, or a group of senior executives should provide thestatement of use. For some organizations this decision will be influenced by applicable legislation or
regulation, depending on:

Commented [SD72]: Type of change: editorial
revision.
Guidance added to clarify that it is not required to use
the content index table in Appendix 2.

Commented [SD74]: Type of change: revision
following public comment feedback.
Original wording:“[Title of the highest governance body or most senior
executive of the organization] acknowledges
responsibility for the following statement of use:
The information reported by [name of organization] forthe [reporting period] has been prepared with reference
to the GRI Standards cited in this content index.”Commented [SD75]: Type of change: editorial
revision.
Guidance has been updated in line with the changes
made to the statement of use.
Commented [SD76]: Type of change: editorial
revision.
Original wording: “The term ‘GRI Standards’ includes allStandards”.

389•

the country where the organization is incorporated or registered;390•

a stock exchange the organization trades its securities on;

The following sentence has been removed: “Thisstatement applies to all information included in the GRI
content index.”

391
392

•

the nature and type of the organization (e.g., charity, incorporated company, mutualorganization).

Commented [SD77]: Type of change: editorial
revision.
New text added.

393

Notify GRI

394
395

a. The organization shall notify GRI of the use of the GRI Standards and statement of use
through the GRI Standards Report Registration System.

396

Guidance

397
398
399
400

The GRI Standards Report Registration System can be accessed using the GRI website. The
registration system notifies GRI of the use of the GRI Standards and the corresponding statement of
use reported by the organization. There is no cost associated with notifying GRI of the use of theStandards.

Commented [SD78]: Type of change: editorial
revision.
Original wording: “register its reported information”.

Page 13 of 27

401

Appendix 1. GRI content index for

402

reporting in accordance with the GRI

403

Standards

404

Commented [SD79]: Type of change: revision
following public comment feedback.
Original wording:“[Title of the highest governance body or most senior
executive of the organization] acknowledges
responsibility for the following statement of use:

GRI content index[Title of the highest governance body, senior executive, or group ofsenior executives of the organization] has reviewed and approved thereported information. The information reported by [name oforganization] for the [reporting period] has been prepared inaccordance with the GRI Standards.

The information reported by [name of organization] forthe [reporting period] has been prepared in accordancewith the GRI Standards.”

GRI 101 used

GRI 101: Using the GRI Standards 2021

Applicable GRISector Standard(s)[Titles of the applicable GRI Sector Standards]

Added a new requirement for the organization to include
GRI 101 in the GRI content index to clarify which
requirements it must comply with.

Statement of use

GRI Standard

Disclosure(GRI Standard title)(Disclosure code andtitle)

Location ofreported
information(including page
numbers, URLs)

Commented [SD82]: Type of change: editorial
revision.

Omission
Requirement(s)omittedReasonExplanation

SectorStandardreference
numberOriginal wording: “[Title of the Sector Standard(s) used
to identify the material topics]”.
Commented [SD81]: Type of change: editorial
revision.
Original wording: “GRI Sector Standard(s)”.

Disclosures about the organization
GRI 102:
About theOrganization
2021

Commented [SD80]: Type of change: editorial
revision.

Commented [SD83]: Type of change: editorial
revision.

Section 2. Organization and its reporting practices
REP-1
Organizational
details

Original wording: “Number, title, and publication year”.
Commented [SD84]: Type of change: revision
following public comment feedback.

REP-2
Organizational
entities includedin thesustainability
reportingOriginal wording: “(Disclosure code)”.
Added new requirement for the organization to report
the disclosure title in the GRI content index in addition
to the disclosure code (see Requirement 7-a-vi).

REP-3 " "Commented [SD85]: Type of change: editorial
revision.

REP-4 " "REP-5 " "Added a new requirement for the organization to report
the Sector Standard reference number (seeRequirement 7-a-xi).

Section 3. Activities and workers
ACT-1 " "Commented [SD86]: Type of change: editorial
revision.

ACT-2 " "ACT-3 " "Section 4. GovernanceOriginal wording: “Requirement omitted”.

GOV-1 " "Commented [SD87]: Type of change: editorial
revision.

GOV-2 " "GOV-3 " "The table has been updated in line with the latest
changes made to GRI 102 and GRI 103 (e.g.,
disclosure codes, titles of sections).

GOV-4 " "Page 14 of 27

GOV-5 " "GOV-6 " "GOV-7 " "GOV-8 " "GOV-9 " "GOV-10 " "GOV-11 " "GOV-12 " "GOV-13 " "GOV-14 " "GOV-15 " "Section 5. Strategy, policies, and practices
SPP-1 " "SPP-2 " "SPP-3 " "SPP-4 " "SPP-5 " "SPP-6 " "SPP-7 " "Section 6. Stakeholder engagementSE-1 " "SE-2 " "Disclosures about process to determine material topics and list of material topics
GRI 103:
Material
Topics 2021

MT-1 " "MT-2 " "Material topics (list all material topics listed in Disclosure MT-2)[Material topic name]
GRI 103:
Material
Topics 2021

MT-3 " "[TopicStandard /SectorStandard /other source][Disclosure codeand title]
Commented [SD88]: Type of change: editorial
revision.

[Material topic name]
GRI 103:
Material
Topics 2021

MT-3 " "[TopicStandard /SectorStandard /other source][Disclosure codeand title]

Added Sector Standard. When the organization reports
an additional disclosure listed in the Sector Standard fora material topic, it is required to include the title of the
Sector Standard where the reported disclosure comesfrom.

Page 15 of 27

Topics in the applicable GRI Sector Standards determined as not material
TopicsExplanation[Topic name][Explanation][Topic name][Explanation]

Commented [SD89]: Type of change: editorial
revision.

A striped cell indicates something that does not apply. This only relates to‘Omissions’ and ‘Sector Standard reference numbers’.
Reasons for omission are not permitted – and hence do not apply – in the case ofDisclosures REP-1, REP-2, REP-3, REP-4, and REP-5 in GRI 102: About theOrganization 2021 and Disclosures MT-1 and MT-2 in GRI 103: Material Topics
2021.

Added this table to include any topics from theapplicable GRI Sector Standard(s) that the organization
has determined as not material and an explanation for
why they are not material (see Requirement 3-b-ii).

The Sector Standard reference numbers do not apply to the disclosures in GRI 102:
About the Organization 2021 and Disclosures MT-1 and MT-2 in GRI 103: Material
Topics 2021.
This information is indicated in the table using the striped cells.

Commented [SD90]: Type of change: editorial
revision.
New text added and updated the disclosures for which
reasons for omission are permitted.

Page 16 of 27

405

Appendix 2. GRI content index for

406

reporting with reference to the GRI

407

Standards

408

GRI content index
Statement of use

GRI 101 used

[Title of the highest governance body, senior executive, or group ofsenior executives of the organization] has reviewed and approved thereported information. The information reported by [name of organization]
for the [reporting period] has been prepared with reference to the GRI
Standards cited in this content index.

Commented [SD91]: Type of change: revision
following public comment feedback.

GRI 101: Using the GRI Standards 2021

GRI Standard

Disclosure(GRI Standard title)(Disclosure code and title)

Location of reported
information(including page numbers, URLs)[GRI Standard][Disclosure code and title][GRI Standard][Disclosure code and title]

Original wording:“[Title of the highest governance body or most senior
executive of the organization] acknowledges
responsibility for the following statement of use:
The information reported by [name of organization] forthe [reporting period] has been prepared with reference
to the GRI Standards cited in this content index.”Commented [SD92]: Type of change: editorial
revision.
Added a new requirement for the organization to include
GRI 101 in the GRI content index to clarify which
requirements it must comply with.
Commented [SD93]: Type of change: editorial
revision.
Original wording: “Number, title, and publication year”.
Commented [SD94]: Type of change: revision
following public comment feedback.
Original wording: “(Disclosure code)”.
Added new requirement for the organization to report
the disclosure title in the GRI content index in addition
to the disclosure code (see a-iii under the requirement
to publish a GRI content index).

Page 17 of 27409

Annex 1. GRI 101: Using the GRI

410

Standards in the exposure draft411

3. Sustainability reporting using the
GRI Standards

412
413

The organization can select between two approaches for using the GRI Standards:

414
415

A. Reporting in accordance with the GRI Standards: The organization uses the set of GRI
Standards to report on its most significant impacts on the economy, environment, and people.

416
417

B. Reporting with reference to the GRI Standards: The organization uses selected GRI
Standards, or parts of their content, to report information about specific topics.

418
419
420

Each approach to reporting with the GRI Standards has a set of requirements and a corresponding
statement of use that the organization is to use once it meets these requirements. These
requirements and statements are set out in Sections 3.1 and 3.2.

421

Table 1. Overview of requirements for Approaches A and B
Approach A: Reporting in accordance with the
GRI Standards

Approach B: Reporting with reference to the GRI
Standards

Requirement A-1: Apply the reporting principles

Requirement B-1: Publish a GRI content index

Requirement A-2: Report the disclosures in GRI 102

Requirement B-2: Provide a statement of use

Requirement A-3: Identify material topics

Requirement B-3: Notify GRI

Requirement A-4: Report the disclosures in GRI 103
Requirement A-5: Report appropriate disclosures foreach identified material topic
Requirement A-6: Publish a GRI content index
Requirement A-7: Provide a statement of use
Requirement A-8: Notify GRI

422

3.1 Approach A: Reporting in

423

accordance with the GRI Standards

424
425
426
427

Reporting in accordance with the GRI Standards provides a complete and balanced picture of anorganization’s material topics and related impacts and how it manages these topics. It also provides
information about the organization’s specific context, which assists in understanding theorganization’s approach towards its material topics.

428
429

To report in accordance with the GRI Standards, the organization must comply with all therequirements in this section. These requirements ensure that the organization:

430•

applies the reporting principles;

Page 18 of 27

431
432
433

•

reports contextual information, including information on its reporting practices, activities,
governance, responsible business conduct policies and practices, and stakeholder
engagement;

434•

identifies its material topics;

435
436

•

reports information on its impacts and how it manages these impacts for each of its material
topics.

437
438
439
440

If the organization does not meet all these requirements, it cannot claim that it has prepared thereported information in accordance with the GRI Standards. In this case, the organization may be able
to claim that it has prepared the reported information with reference to the GRI Standards (ApproachB), provided it meets the requirements as set out in Section 3.2.

441

Requirement A-1: Apply the reporting principles

442
443

a. The organization shall apply all the reporting principles set out in Section 4 of GRI 101:
Using the GRI Standards.

444

Requirement A-2: Report the disclosures in GRI 102

445

a. The organization shall report all disclosures in GRI 102: About the Organization.

446

Requirement A-3: Identify material topics

447

The organization shall:

448

a. identify its material topics;

449
450

b. use the GRI Sector Standard(s) that apply to its sector(s), where these are available, toidentify its material topics in A-3-a.

451

Guidance

452
453
454
455

Section 2 of GRI 103: Material Topics provides guidance on how to identify material topics. The
Sector Standards provide information on the most likely material topics for organizations in a given
sector. Using Sector Standards, however, is not a substitute for the organization’s own process for
identifying material topics.

456

Requirement A-4: Report the disclosures in GRI 103

457

The organization shall:

458
459

a. report how it has identified its material topics using Disclosure MT-1 in GRI 103: Material
Topics;460
461

b. report its material topics and related impacts using Disclosure MT-2 in GRI 103: Material
Topics;

462
463
464

c. for each material topic, whether covered by a GRI Topic Standard or not, report how it
manages the material topic and related impacts, using Disclosure MT-3 in GRI 103:
Material Topics.

Page 19 of 27

466

Requirement A-5: Report appropriate disclosures for eachidentified material topic

467

For each material topic, the organization shall:

468
469

a. report appropriate disclosures from the GRI Topic Standards that correspond to thematerial topic;

470
471

b. if it cannot comply with a requirement within an appropriate disclosure from a GRI Topic
Standard identified in A-5-a:

465

472

i.

specify the requirement that it has omitted;

473
474

ii.

provide one of the following four reasons for omission and the required
explanation for that reason.

475

Table 2. Reasons for omission
Reason for omission

Required explanation

Not appropriate

Describe why the requirement does not contribute toward
explaining the impacts related to the organization’s material
topic.

Confidentiality constraints

Describe the specific confidentiality constraints.

Legal prohibitions

Describe the specific legal prohibitions.

Information incomplete orunavailable

Describe the steps being taken to obtain the missing
information and the expected time frame.
If the required information cannot be obtained, or it is not of
adequate quality to report (as might be the case when theinformation is collected from another organization, e.g., asupplier), explain this situation.

476

Guidance

477

Guidance to A-5-a

478
479

Appropriate disclosures are those that adequately capture the impacts related to the organization’smaterial topics.

480
481

If a material topic is covered by an existing GRI Topic Standard, the organization is required to reportappropriate disclosures from that Standard.

482
483
484
485

The topic names used in the GRI Topic Standards are intentionally high-level, as each topic can covera number of related areas. For example, the Topic Standard GRI 303: Water and Effluents 2018
covers a range of specific areas related to water and effluents, such as water stress, water pollution,
and access to water.

486
487
488
489

In some cases, the organization might identify a material topic that does not exactly match the topic
names used in the GRI Topic Standards. In these cases, if the material topic is similar or relates to
one of the topics covered in the GRI Topic Standards, the organization should use the corresponding
GRI Topic Standard to identify appropriate disclosures to report on its material topic.

490
491

When Topic Standards include disclosures on a range of areas, the organization only needs to report
the appropriate disclosures that relate to the impacts identified by the organization.

492
493

For example, suppose an organization identifies energy and GHG emissions as material topics.
These topics are covered by GRI 302: Energy 2016 and GRI 305: Emissions 2016. However, the only

Page 20 of 27

494
495
496
497
498
499
500

form of energy that the organization consumes is purchased electricity. Neither the organization nor
any of the sources that it owns or controls consume fuel. In this case, the disclosure related to fuelconsumption in GRI 305, i.e., Disclosure 305-1 Direct (Scope 1) GHG emissions, does not adequately
capture the organization’s impacts for the topic of GHG emissions and the organization is not required
to report it. The organization is only required to report the appropriate disclosures from GRI 302 andGRI 305 related to the specific impacts it has identified for the material topics of energy and GHG
emissions.

501
502
503
504
505
506

If the GRI Topic Standards do not provide appropriate disclosures for the organization’s impacts for amaterial topic, or if the organization’s material topic is not covered by the GRI Topic Standards, theorganization should report appropriate disclosures from other sources. For example, suppose anorganization identifies chemicals of concern as a material topic. As there is currently no GRI Topic
Standard that covers this topic, the organization should report appropriate disclosures using otherframeworks or develop its own disclosures to report on this topic.

507
508
509

If the organization identifies a topic as material and that topic is included in the applicable GRI Sector
Standard, this Sector Standard can also assist the organization in determining appropriate disclosures
to report on that topic.

510

Guidance to A-5-b

511
512
513
514

When the organization cannot comply with a requirement within an appropriate disclosure from a GRI
Topic Standard it has identified in A-5-a, it is required to use one of the four reasons for omission.
Reasons for omission are not permitted for the requirements in GRI 102: About the Organization and
GRI 103: Material Topics.

515
516
517
518
519

Reasons for omission should only be used in exceptional cases when the organization is unable tocomply with a requirement. Using reasons for omission frequently or for critical requirements reduces
the credibility and usefulness of the reported information. Additionally, it does not align with reportingin accordance with the GRI Standards, which aims to provide a complete and balanced picture of theorganization’s most significant impacts.

520
521
522
523

In the example above where the organization only consumes purchased electricity and does notconsume fuel, it can use the 'not appropriate’ reason for omission for the requirements in Disclosure302-1 Energy consumption within the organization in GRI 302: Energy 2016 which relate to fuel, e.g.,
302-1-a and 302-1-b.

524
525
526

Note that the organization is not required to provide a reason for omission for disclosures from a GRI
Topic Standard that it has identified as not appropriate; the reasons for omission only apply when theorganization cannot comply with requirements within the appropriate disclosures.

527

Requirement A-6: Publish a GRI content index

528
529

a. The organization shall publish a GRI content index in one location that is publicly andeasily accessible, using the template set out in Appendix 1.

530

Guidance

531
532
533

The GRI content index is a navigation tool that provides information users with a quick overview of theorganization’s reported information and facilitates easy access to this information. The content index
shows which GRI Standards and disclosures the organization has used.

534

Requirement A-7: Provide a statement of use

535

a. The organization shall include the following statement in its GRI content index:

536
537

[Title of the highest governance body or most senior executive of the organization]
acknowledges responsibility for the following statement of use:

Page 21 of 27

538
539

The information reported by [name of organization] for the [reporting period] has been
prepared in accordance with the GRI Standards.

540

Guidance541
542

The organization is required to insert the title of its highest governance body or most senior executive,
the name of the organization, and the reporting period in the statement. For example:

543“The Board of Directors acknowledges responsibility for the following statement of use:

544
545

The information reported by ABC Limited for the year ending 31 December 2020 has been
prepared in accordance with the GRI Standards.”

546
547
548
549

This statement applies to all information included in the GRI content index. The term ‘GRI Standards’
includes all Standards (Universal Standards: GRI 101, GRI 102, GRI 103, Topic Standards, andSector Standards) that are effective at the date when the information is published, as well asStandards that are adopted by the organization earlier than their effective date.

550
551
552

When determining whether the highest governance body or the most senior executive provides thestatement of use, an organization should consider its legal and operating context. For someorganizations this will be influenced by applicable legislation or regulation, which can be related to:553•

the country where the organization is incorporated or registered;554•

a stock exchange the organization trades its securities on;

555
556

•

the nature and type of the organization (e.g., charity, incorporated company, mutualorganization).

557

Requirement A-8: Notify GRI

558
559

a. The organization shall register its reported information and statement of use through the
GRI Standards Report Registration System.

560

Guidance

561
562
563
564

The GRI Standards Report Registration System can be accessed using the GRI website. The
registration system notifies GRI of the use of the GRI Standards and the corresponding statement of
use reported by the organization. There is no cost associated with notifying GRI of the use of theStandards.

Page 22 of 27

565

3.2 Approach B: Reporting with566

reference to the GRI Standards

567
568
569
570
571
572
573
574

This is the other approach of reporting using the GRI Standards. The organization can use selected
GRI Standards, or parts of their content, to report information to meet the needs of specificinformation users for specific purposes. For example, the organization can report with reference to the
GRI Standards to comply with a specific reporting regulation on climate change. The organization canalso report with reference to the GRI Standards if it is unable to meet all the requirements forreporting in accordance with the GRI Standards. However, this approach of using the GRI Standards
does not provide a complete and balanced picture of the organization’s most significant impacts on
the economy, environment, and people.

575
576

To report with reference to the GRI Standards, the organization must comply with all the requirementsin this section.

577
578
579
580

In addition to the meeting these requirements, the organization should apply the reporting principles
from Section 4 of this Standard. These principles ensure high-quality sustainability reporting and areimportant for any information reported using the GRI Standards. The organization should also report
how it manages its impacts using Disclosure MT-3 in GRI 103: Material Topics for any topics reported.

581

Requirement B-1: Publish a GRI content index

582
583

a. The organization shall publish a GRI content index in one location that is publicly andeasily accessible, using the template set out in Appendix 2.

584

Guidance

585
586
587

The GRI content index is a navigation tool that provides information users with a quick overview of theorganization’s reported information and facilitates easy access to this information. The content index
shows which GRI Standards and disclosures the organization has used.

588

Requirement B-2: Provide a statement of use

589

a. The organization shall include the following statement in its GRI content index:

590
591

[Title of the highest governance body or most senior executive of the organization]
acknowledges responsibility for the following statement of use:

592
593

The information reported by [name of organization] for the [reporting period] has been
prepared with reference to the GRI Standards cited in this content index.

594

Guidance595
596

The organization is required to insert the title of its highest governance body or most senior executive,
the name of the organization, and the reporting period in the statement. For example:

597“The Board of Directors acknowledges responsibility for the following statement of use:

598
599

The information reported by ABC Limited for the year ending 31 December 2020 has been
prepared with reference to the GRI Standards cited in this content index.”

600
601
602
603

This statement applies to all information included in the GRI content index. The term ‘GRI Standards’
includes all Standards (Universal Standards: GRI 101, GRI 102, GRI 103, Topic Standards, andSector Standards) that are effective at the date when the information is published, as well asStandards that are adopted by the organization earlier than their effective date.

Page 23 of 27

604
605
606

When determining whether the highest governance body or the most senior executive provides thestatement of use, the organization should consider its legal and operating context. For someorganizations this will be influenced by applicable legislation or regulation, which can be related to:607•

the country where the organization is incorporated or registered;608•

a stock exchange the organization trades its securities on;

609
610

•

the nature and type of the organization (e.g., charity, incorporated company, mutualorganization).

611

Requirement B-3: Notify GRI

612
613

a. The organization shall register its reported information and statement of use through the
GRI Standards Report Registration System.

614

Guidance

615
616
617
618

The GRI Standards Report Registration System can be accessed using the GRI website. The
registration system notifies GRI of the use of the GRI Standards and the corresponding statement of
use reported by the organization. There is no cost associated with notifying GRI of the use of theStandards.

Page 24 of 27

619

Appendix 1. GRI content index for

620

reporting in accordance with the GRI

621

Standards

622

GRI content index
Statement of use[Title of the highest governance body or most senior executive of theorganization] acknowledges responsibility for the following statement ofuse:
The information reported by [name of organization] for the [reporting
period] has been prepared in accordance with the GRI Standards.

GRI Sector
Standard(s)[Title of the Sector Standard(s) used to identify the material topics]

GRI Standard

Disclosure(Number, title, and publication
year)(Disclosure code)

Location ofreported
information(including page
numbers, URLs)

Omission
Requirement
omittedReasonExplanation

Disclosures about the organization
GRI 102: About theOrganization

Organizational details and reporting practices
REP-1
REP-2
REP-3
REP-4
REP-5
Organizational activities
ACT-1
ACT-2
Governance
GOV-1
GOV-2
GOV-3
GOV-4
GOV-5
GOV-6
GOV-7

Page 25 of 27

GOV-8GOV-9
GOV-10
GOV-11
GOV-12
GOV-13
GOV-14
GOV-15
Responsible business conduct
RBC-1
RBC-2
RBC-3
RBC-4
RBC-5
RBC-6
RBC-7
Stakeholder engagement
SE-1
SE-2
Material topics (list all material topics identified in MT-2-a)Disclosures about identification of material topics
GRI 103: Material
TopicsMT-1
MT-2-a[Material topic name]
GRI 103: Material
TopicsMT-2-b[Topic Standard /other source][Disclosure
code]

MT-3

[Material topic name]
GRI 103: Material
TopicsMT-2-b[Topic Standard /other source][Disclosure
code]

MT-3

Reasons for omission are not permitted for the requirements in GRI 102:
About the Organization and GRI 103: Material Topics

Page 26 of 27

623

Appendix 2. GRI content index for

624

reporting with reference to the GRI

625

Standards

626

GRI content index
Statement of use[Title of the highest governance body or most senior executive of theorganization] acknowledges responsibility for the following statement ofuse:
The information reported by [name of organization] for the [reporting
period] has been prepared with reference to the GRI Standards cited inthis content index.

GRI Standard

Disclosure(Number, title, and publication year)(Disclosure code)

Location of reported
information(including page numbers, URLs)[GRI Standard][Disclosure code][GRI Standard][Disclosure code]

Page 27 of 27