Writing a report in accordance with the Standards
Will you delay the effective dates of the new and revised Topic Standards because of COVID-19?
While sustainable development and transparency remain as important as ever, the Global Sustainability Standards Board (GSSB) recognizes that the COVID-19 pandemic presents unprecedented financial and operational challenges for organizations. This may affect the organization’s access to information and in turn their upcoming sustainability reporting.
The following three GRI Topic Standards: GRI 207: Tax 2019, GRI 303: Water and Effluents 2018, and GRI 403: Occupational Health and Safety 2018, will be effective for reports or other materials published on or after 1 January 2021.
If an organization planned to adopt these Standards for a report that will be published in 2021 because it has identified these topics as material but is finding it difficult to provide complete reporting (for either the Core or Comprehensive option) due to the pandemic, it may use reasons for omission for the disclosures in these Standards. In this case, the organization can explain that the necessary information cannot be obtained or is not of adequate quality to report due to organizational effects related to COVID-19, and provide the expected timeframe for obtaining and reporting this information.
Reasons for omission enable organizations to build up their reporting gradually and respond to all requirements over time. They provide transparency on how the Standards have been applied. Please consult clause 3.2 in GRI 101: Foundation 2016 for more information on reasons for omission.
Further, GRI 207 and GRI 403 contain additional information on other cases where reasons for omission are permitted. Please consult these Standards directly for this additional information.
For organizations who feel that a delay to the effective date may assist them to provide complete reporting, we would like to clarify there is no submission deadline for reports or other materials prepared in accordance with the GRI Standards. However, it is important to note that the usefulness of information is closely tied to whether it is available in time for stakeholders to integrate it into their decision-making. Organizations should consider whether it is of value to them and their stakeholders to delay their sustainability reporting.
The GSSB will continue to monitor the situation and revise this FAQ as needed. For updates on the GRI Standards, please sign up here.
How do I make a claim that a report has been prepared in accordance with the Standards?
An organization preparing a report in accordance with the GRI Standards can choose one of two options (Core or Comprehensive), depending on the degree to which the GRI Standards have been applied. For each option, there is a corresponding claim, or statement of use, that the organization is required to include in the report. These claims have set wording.
The criteria to claim that a report has been prepared in accordance with the GRI Standards (either Core or Comprehensive option) can be found on pages 22-23 of GRI 101: Foundation.
An organization is required to notify GRI when it makes an in accordance claim in any report or published materials (see page 26 in GRI 101).
Disclosure 102-54 in GRI 102: General Disclosures requires reporting the in accordance claim made by the organization.
Can I use reasons for omission for topic-specific management approach disclosures?
Reasons for omission can be used if, in exceptional cases, an organization cannot report a disclosure that is required for reporting in accordance with the GRI Standards. Reasons for omission can only be used for certain disclosures – see Table 1 in GRI 101: Foundation for more detail.
Management approach disclosures in GRI 103: Management Approach
Organizations are required to use GRI 103: Management Approach to report management information about each material topic. Reasons for omission can be used for:
- Disclosure 103-2: The management approach and its components
- Disclosure 103-3: Evaluation of the management approach
Reasons for omission cannot be used for Disclosure 103-1: Explanation of the material topic and its Boundary. This disclosure is required to be reported for each material topic to prepare a report in accordance with the GRI Standards.
Management approach disclosures in topic-specific Standards
Some topic-specific Standards include additional management approach requirements (see for example, clause 1.2 in GRI 305: Emissions). Organizations are required to comply with any additional management approach requirements for the topic-specific Standards used. Reasons for omission are permitted for these requirements.
See clause 3.2 in GRI 101: Foundation for the requirements to report on the reasons for omission.
Can I use another definition than the one provided in the GRI Standards Glossary?
The GRI Standards are to be used together with the GRI Standards Glossary. This means that an organization is required to apply the definitions provided in the Glossary when using the GRI Standards, and is not permitted to omit or deviate from these definitions.
However, when reporting on a disclosure that permits the use of reasons for omission, an organization may deviate from the definition in the Glossary when information is not available for all elements covered in the definition. See Table 1 in GRI 101: Foundation for the disclosures that permit reasons for omissions and see clause 3.2 in GRI 101 for how to report reasons for omission.
For example, if an organization reports on Disclosure 403-1-b (Percentage of workers whose work, or workplace, is controlled by the organization, that are represented by formal joint management-worker health and safety committees), it is required to apply the definition of ‘worker’ provided in the Glossary. However, if the organization only has the required information available for its employees, which is a subset of workers, the organization may deviate from this definition as long as it provides a reason for omission stating that this information is not available for workers who are not employees.
The Notes accompanying the definitions include additional information, explanations and examples to help organizations better understand the definitions. An organization is not required to comply with the Notes.
Where a term is not defined in the Glossary, definitions that are commonly used and understood apply – this means definitions that are available in a dictionary. When a term is not defined in a dictionary, it is up to the reporting organization to define the term. The organization is expected to state the definition that it has used for that term in the report or published material.
Terms defined in the GRI Standards Glossary are underlined in the text of the GRI Standards.
How can I report information if it varies between reporting periods due to changes in the organization, such as mergers or acquisitions?
Disclosure 102-10 in GRI 102: General Disclosures requires an organization to report any significant changes to the organization’s size, structure, ownership, or supply chain during the reporting period. The list of entities included in the organization’s financial statements or equivalent documents that are covered in the report is reported with Disclosure 102-45 in GRI 102.
GRI 101: Foundation recommends that organizations ‘present information for the current reporting period and at least two previous periods’ (clause 2.7.1), although this is not a requirement to prepare a report in accordance with the GRI Standards.
If an organization does provide information for previous periods, and if the size, structure or ownership of the organization has changed so that the information can no longer be compared, it can re-calculate the information for previous periods to account for changes in the organization.
If the organization has re-calculated the information for previous periods, Disclosure 102-48 in GRI 102 requires an organization to report restatements of information.
Is external assurance or certification required to use and reference the GRI Standards?
The GSSB is an independent operating entity under the auspices of GRI, with the sole responsibility for setting globally accepted standards for sustainability reporting. It does not judge the outcome or quality of an organization’s report or whether a report is in accordance with the GRI Standards, as impartiality is important for maintaining credibility of a standard-setter.
The use of external assurance for sustainability reports is advised, but it is not required in order to make a claim that a report has been prepared in accordance with the GRI Standards. An organization is required to report its approach to external assurance with Disclosure 102-56. For more information, see pages 41-42 in GRI 102: General Disclosures.
The GRI Standards are not subject to certification. There is no cost associated with using the GRI Standards for sustainability reporting, or with notifying GRI of the use of the Standards.
GRI offers a range of paid services which can help reporters ensure that they have prepared their reports in line with the expectations set out in the GRI Standards. For more information, please visit our Services page.
Can the range of entities reported on vary between disclosures?
Overview of entities covered by the report
Disclosure 102-45 in GRI 102: General Disclosures requires organizations to report a list of all entities included in the organization’s consolidated financial statements or equivalent documents, and whether any entity included in the organization’s consolidated financial statements or equivalent documents is not covered by the report.
An organization can report Disclosure 102-45 by referencing the information in publicly available consolidated financial statements or equivalent documents. See clause 2.6 and related guidance in GRI 101: Foundation.
If an organization covers any additional entities in its report, which are not included in its consolidated financial statements or equivalent documents, it is expected to clearly indicate this in response to Disclosure 102-45.
Organizations are expected to report the disclosures from GRI 102: General Disclosures consistently for all entities covered by the report, as disclosed under Disclosure 102-45. If information for a general disclosure is not available for all entities covered by the report, as disclosed under Disclosure 102-45, and the general disclosure permits the use of reasons for omission, the organization is required to provide a reason for omission and to explain which entities have been excluded from that disclosure. See Table 1 in GRI 101, which shows for which disclosures reasons for omission are permitted, and see clause 3.2 in GRI 101 for more information about reasons for omission.
For example, an organization prepares a report for its entities A, B, and C but does not have information available for Disclosure 102-17 for entity C. Table 1 in GRI 101 shows that a reason for omission is permitted for Disclosure 102-17. In this case, the organization reports the information for entities A and B and provides a reason for omission explaining that information for Disclosure 102-17 is not available for entity C.
Management approach and topic-specific disclosures
Organizations are also expected to report the management approach and topic-specific disclosures consistently for the same entities covered by the report, as disclosed under Disclosure 102-45, although the entities to be reported may vary depending on where impacts occur for the material topic (see Disclosure 103-1-b-i where an organization describes where the impacts for a material impact occur). If not all entities disclosed under Disclosure 102-45 are relevant for reporting on a material topic, organizations are expected to clearly indicate which entities each disclosure covers.
For example, an organization prepares a report for its entities in country X and has identified ‘energy’ as a material topic. Only those entities in regions Y and Z (within country X) have significant impacts related to energy consumption. The organization can report the energy consumption for entities in regions Y and Z only, and clearly indicate this within the report.