GRI reporting checklist

Has the organization determined whether the reported information is prepared in accordance with the GRI Standards or with reference to the GRI Standards, and is it prepared using the Universal Standards 2021, which are required for all reporting published on or after 1 January 2023?

Evidence: Documented decision on the claim, approved before drafting; register of each GRI Standard applied with its issue year; no reliance on the superseded 2016 Universal Standards or the discontinued Core and Comprehensive options

Where the organization cannot comply with all nine requirements of GRI 1 Section 3, or uses selected GRI Standards to report on specific topics for a specific purpose, is the claim restricted to with reference to, and are the three obligations for that claim met: GRI content index, statement of use and notification to GRI?

Evidence: Gap analysis against Requirements 1 to 9; decision record downgrading the claim where any requirement is unmet; draft GRI content index and statement of use for the with reference to claim

Are the reporting principles in GRI 1 Section 4, including accuracy, balance, verifiability and sustainability context, applied across data collection, preparation and review, with performance on each material topic presented against the wider sustainability context, such as local water stress or sector benchmarks?

Evidence: Data quality procedure mapped to the reporting principles; review checklist evidencing each principle; context statements per material topic with sources for thresholds and benchmarks

Does the reported information present negative impacts, incidents and targets not met with the same prominence as positive impacts and achievements, so that it gives an unbiased picture of the organization's impacts?

Evidence: Target register reconciled to the narrative; incident, grievance and sanctions registers reconciled to the reported information; no exclusion of underperforming sites or periods

Can each reported data point be traced to its source records, calculation methodology, assumptions and data owner, to a standard that allows an internal reviewer or assurance provider to re-perform it?

Evidence: Audit trail per indicator: source system, extraction date, calculation workbook, emission and conversion factors with sources, estimation methods, preparer and reviewer sign-off

Is each disclosure in GRI 2: General Disclosures 2021 reported in full, or subject to a permitted reason for omission, noting that reasons for omission are not permitted for Disclosures 2-1 to 2-5?

Evidence: GRI 2 completeness matrix showing, for Disclosures 2-1 to 2-30, the status, data owner, report location and any reason for omission

Were material topics determined through the process in GRI 3, using each applicable GRI Sector Standard, before disclosures were selected, rather than derived from the data already available?

Evidence: Materiality documentation dated before the data collection plan; assessment of each likely material topic in the applicable Sector Standards; approval of the final list

Are Disclosure 3-1 Process to determine material topics and Disclosure 3-2 List of material topics reported, and is Disclosure 3-3 Management of material topics reported for every material topic?

Evidence: Report sections for 3-1 and 3-2; one 3-3 section per material topic, cross-checked to the 3-2 list

For each material topic, has the organization identified and reported the Topic Standard disclosures relevant to its impacts, and reported additional disclosures where the Topic Standards do not provide sufficient information about those impacts?

Evidence: Material topic to disclosure mapping with the relevance rationale for each disclosure; methodology statements for additional disclosures

Is each disclosure or requirement the organization cannot comply with supported by one of the four permitted reasons for omission (not applicable, legal prohibitions, confidentiality constraints, information unavailable or incomplete) with an explanation, and is no reason for omission applied to Disclosures 2-1 to 2-5, 3-1 or 3-2?

Evidence: Omissions register recording the disclosure or requirement, the reason for omission, the explanation and, where information is unavailable or incomplete, the steps being taken to obtain it

Does Disclosure 2-1 report the organization's legal name, nature of ownership and legal form, location of headquarters and countries of operation, consistent with its registration documents?

Evidence: Trade licence or certificate of incorporation; memorandum and articles of association; countries of operation reconciled to the financial statements

Does Disclosure 2-2 list the entities included in sustainability reporting, explain any differences from the entities in the financial statements, and describe the approach to consolidating information across entities?

Evidence: Entity list reconciled to the audited financial statements; consolidation approach (operational control, financial control or equity share); treatment of acquisitions, disposals and minority interests

Does Disclosure 2-3 specify the reporting period and frequency, the publication date and a contact point, and explain any difference between the sustainability and financial reporting periods?

Evidence: Reporting period reconciled to the financial year; publication date; monitored contact point

Are restatements of information made from previous reporting periods disclosed under 2-4, with the reason for each restatement and its effect?

Evidence: Restatement register; recalculated base years; methodology change notes; prior period report reconciled to the current comparatives

Does Disclosure 2-5 describe the organization's policy and practice for seeking external assurance, including whether and how the highest governance body and senior executives are involved?

Evidence: Highest governance body or audit committee minutes on assurance; assurance policy or procurement record; draft 2-5 disclosure

Where the sustainability reporting has been externally assured, does 2-5 provide or reference the assurance report, and state the assurance provider, the assurance standard applied, the level of assurance, the disclosures in scope and the relationship between the organization and the provider?

Evidence: Signed assurance report; engagement letter; assured disclosures reconciled to the GRI content index

Does Disclosure 2-6 describe the sectors in which the organization is active, its products and services, its upstream and downstream value chain, its other relevant business relationships and significant changes compared with the previous reporting period?

Evidence: Business description reconciled to the annual report; value chain map; supplier and customer profile; record of acquisitions, disposals and market entries

Are employees reported under 2-7 by gender and region, and by permanent, temporary, non-guaranteed hours, full-time and part-time contract, with the methodology stated (head count or full-time equivalent, end of period or average), and are workers who are not employees described under 2-8?

Evidence: HR system extract on the stated basis; data definitions; contractor and agency worker records from procurement and site systems

Do Disclosures 2-9 to 2-11 describe the governance structure and committees, the composition of the highest governance body, the nomination and selection processes and criteria, and whether the chair is also a senior executive?

Evidence: Board charter; committee terms of reference; composition matrix; nomination policy; chair appointment record

Do Disclosures 2-12 to 2-14 describe the highest governance body's role in overseeing due diligence and the management of impacts on the economy, environment and people, the delegation of that responsibility, and whether the body reviews and approves the reported information, including the material topics?

Evidence: Highest governance body and committee minutes; delegation of authority matrix; approval of the material topics and of the final report

Do Disclosures 2-15 and 2-16 describe the processes to prevent and mitigate conflicts of interest in the highest governance body, how critical concerns are communicated to it, and the total number and nature of critical concerns communicated in the reporting period?

Evidence: Conflicts of interest policy and declarations register; related party disclosures; escalation and whistleblowing reports to the highest governance body

Do Disclosures 2-17 and 2-18 describe the measures taken to advance the collective knowledge of the highest governance body on sustainable development, and the processes for evaluating its performance in overseeing the management of impacts?

Evidence: Board development records; skills matrix; board evaluation report and resulting actions

Do Disclosures 2-19 to 2-21 describe the remuneration policies for members of the highest governance body and senior executives, including any link to objectives for the management of impacts, the process to determine remuneration, and the annual total compensation ratio?

Evidence: Remuneration policy; remuneration committee minutes; payroll data and the compensation ratio calculation; reason for omission recorded where confidentiality constraints apply

Is a statement from the highest governance body or the most senior executive provided under 2-22 on the relevance of sustainable development to the organization and its strategy for contributing to it?

Evidence: Signed statement from the chair or chief executive; consistency with the strategy disclosed in the annual report

Does Disclosure 2-23 describe the policy commitments for responsible business conduct, including the commitment to respect human rights, the authoritative intergovernmental instruments referenced, the level at which each commitment was approved and where it is publicly available, and state where a policy commitment does not exist?

Evidence: Code of conduct; human rights, environmental and supplier policies with approval records; public links to each policy

Does Disclosure 2-24 describe how each policy commitment is embedded across the organization's activities and business relationships, including allocation of responsibility, integration into processes and the training provided?

Evidence: Responsibility matrix; supplier code of conduct and contract terms; training records; procedures referencing the policy commitments

Do Disclosures 2-25 and 2-26 describe the processes to provide for or cooperate in the remediation of negative impacts, the grievance mechanisms available to stakeholders, the mechanisms for seeking advice and raising concerns, and how the effectiveness of these mechanisms is tracked?

Evidence: Grievance mechanism procedure; whistleblowing channel and case log; remediation records; stakeholder feedback on the mechanisms

Does Disclosure 2-27 report significant instances of non-compliance with laws and regulations, the fines paid and non-monetary sanctions, and how significant instances are determined? (2-27 replaces the withdrawn GRI 307 and GRI 419.)

Evidence: Legal and regulatory register; regulator correspondence; fines and penalties ledger reconciled to the general ledger; approved significance criteria

Does Disclosure 2-28 report the industry associations, other membership associations and advocacy organizations in which the organization participates in a significant role?

Evidence: Membership register with fees and positions held; governance or committee seats in associations

Does Disclosure 2-29 describe the approach to engaging with stakeholders, including the categories of stakeholders engaged and how they are identified, the purpose of the engagement and how the organization seeks to ensure meaningful engagement?

Evidence: Stakeholder mapping; engagement plan; records of meetings, surveys and consultations held in the reporting period

Does Disclosure 2-30 report the percentage of total employees covered by collective bargaining agreements and, for employees not covered, how their working conditions and terms of employment are determined?

Evidence: Collective agreements by country; employment contracts or works council arrangements; legal position in jurisdictions where collective bargaining is restricted

Did the process to determine material topics start from the organization's context and identify actual and potential, negative and positive impacts on the economy, environment and people, including impacts on their human rights, across its activities and business relationships, drawing on stakeholders and experts consulted for that purpose?

Evidence: Context analysis; impact register covering own operations and business relationships upstream and downstream; inputs such as risk registers, grievance mechanisms, audits and external sources; interview and survey records showing how stakeholder and expert input was used

Was the significance of each impact assessed, with negative impacts assessed on severity and likelihood, and severity taking precedence over likelihood for potential negative human rights impacts?

Evidence: Assessment methodology and scales; scored impact register; record of assessors and resolution of differences

Was a threshold set to prioritise the most significant impacts for reporting, and were the resulting material topics reviewed and approved by the highest governance body or senior executives, as reported under 2-14?

Evidence: Threshold rationale; prioritised impact list; approval minutes

Where the organization also assesses financial materiality (for example for ESRS or IFRS S1 and IFRS S2), are the material topics reported under the GRI Standards determined on the basis of impact, with no material topic deprioritised because it is not considered financially material?

Evidence: Separate impact and financial assessments; reconciliation showing every impact-based material topic retained in the GRI reporting

Does Disclosure 3-2 list the material topics and report changes to the list compared with the previous reporting period?

Evidence: Current and prior period lists; rationale for topics added, merged or removed; evidence of review in the reporting period

For each material topic, does Disclosure 3-3 describe the actual and potential, negative and positive impacts on the economy, environment and people, and whether the organization is involved with the negative impacts through its activities or as a result of its business relationships?

Evidence: 3-3 sections per material topic; corresponding impact register entries; value chain map locating the impacts

For each material topic, does Disclosure 3-3 describe the policies and commitments, and the actions taken to prevent or mitigate potential negative impacts, to address actual negative impacts including remediation, and to manage positive impacts?

Evidence: Policies; action plans with owners and deadlines; remediation records

For each material topic, does Disclosure 3-3 describe how the effectiveness of actions is tracked, including goals, targets and indicators with progress against them, lessons learned, and how stakeholder engagement has informed the actions taken?

Evidence: Target register with base years and progress; management review minutes; internal audit or monitoring results

Has the organization identified each published Sector Standard applicable to the sectors in which it has substantial activities, recognising that more than one may apply? Published Sector Standards: GRI 11 Oil and Gas (in effect for reporting from January 2023), GRI 12 Coal and GRI 13 Agriculture, Aquaculture and Fishing (January 2024) and GRI 14 Mining (January 2026).

Evidence: Revenue and activity analysis by sector; comparison with the sector description in each Sector Standard; documented applicability decision

Has each likely material topic in the applicable Sector Standards been assessed for materiality, and is each topic determined as not material listed in the GRI content index with an explanation of why it is not material?

Evidence: Materiality documentation with a line for every Sector Standard topic; explanation for each topic determined as not material

For Sector Standard topics determined as material, are the disclosures listed in the Sector Standard reported and identified in the GRI content index by their Sector Standard reference numbers?

Evidence: Mapping of Sector Standard reference numbers to report locations; omissions register for listed disclosures not reported

Are the V1.1 versions of GRI 11 to GRI 14, aligned with GRI 101, GRI 102 and GRI 103, applied? The earlier versions may be used for reporting on climate change and energy only until 31 December 2026.

Evidence: Sector Standard version recorded in the GRI content index; transition plan for reporting published in 2027

For banks, insurers and capital markets firms, has the organization planned for the GRI Sector Standards for Banking, Capital Markets and Insurance, approved by GRI for launch in 2027?

Evidence: Reporting plan entry; gap analysis against the Sector Standards once published

Is each Topic Standard applied cited in the GRI content index at its current edition, for example GRI 303: Water and Effluents 2018, GRI 306: Waste 2020 and GRI 403: Occupational Health and Safety 2018?

Evidence: GRI content index entries reconciled to the current list of GRI Standards on globalreporting.org

Where biodiversity is a material topic, is it reported using GRI 101: Biodiversity 2024, which replaces GRI 304 and is required for reporting on biodiversity published on or after 1 January 2026?

Evidence: Biodiversity disclosures referenced to GRI 101; site locations and their proximity to areas important for biodiversity; supply chain sourcing data where relevant

Is the organization prepared for GRI 102: Climate Change 2025, required for reporting on climate change published on or after 1 January 2027, which replaces Disclosures 305-1 to 305-5 and 201-2 and introduces disclosures on the transition plan and just transition? Earlier adoption is encouraged.

Evidence: Gap analysis from GRI 305 and Disclosure 201-2 to GRI 102; transition plan for climate change mitigation; just transition data on affected workers and local communities

Is energy reporting transitioning to GRI 103: Energy 2025, which replaces GRI 302: Energy 2016 for reporting on energy published on or after 1 January 2027?

Evidence: Energy data by source and site; gap analysis from GRI 302 to GRI 103

Are Scope 1, 2 and 3 GHG emissions measured in accordance with the GHG Protocol and, where equivalent IFRS S2 disclosures are used to meet the corresponding requirements of GRI 102, is their location referenced in the GRI content index?

Evidence: GHG inventory and organisational boundary; emission factor sources; IFRS S2 cross-references in the GRI content index

Where workforce topics are material, are the GRI 401, GRI 403, GRI 404 and GRI 405 disclosures compiled on the definitions and calculation bases each Topic Standard specifies, and consistent with the employee data reported under 2-7?

Evidence: HR and occupational health and safety system extracts; hours worked; work-related injury and ill health records; reconciliation to 2-7

Where supply chain impacts are material, are the supplier environmental assessment (GRI 308), supplier social assessment (GRI 414) and procurement practices (GRI 204) disclosures supported by records?

Evidence: Supplier screening criteria; assessment and audit results; spend analysis by local and other suppliers

Is a GRI content index published with the reported information, or at a stated location, listing each disclosure reported and its location (page number or URL)? For a claim of in accordance with the GRI Standards, does it also list disclosures reported from sources other than the GRI Standards?

Evidence: GRI content index with locations verified against the final layout and web links

Does the GRI content index include a statement of use consistent with the claim (in accordance with, or with reference to, the GRI Standards), the organization's name and the reporting period reported under 2-3?

Evidence: Statement of use; reporting period reconciled to 2-3; claim reconciled to the gap analysis under 1.0

Does the GRI content index state GRI 1: Foundation 2021 as the GRI 1 used, identify each applicable Sector Standard and give the Sector Standard reference numbers?

Evidence: GRI content index header and columns; Sector Standard versions reconciled to test 4.4

Are omitted disclosures and requirements shown in the GRI content index with the reason for omission and explanation, and are the Sector Standard topics determined as not material listed with an explanation?

Evidence: Omission entries reconciled to the omissions register; not material topics reconciled to test 4.2

Where disclosures are located in other published documents, such as the annual report, corporate governance report or IFRS S2 report, does each GRI content index reference identify the specific section, and are those documents publicly available at the time of publication?

Evidence: Hyperlinks tested on the publication date; page references verified against the final version of each document

Has the highest governance body, or the committee or executive to which it has delegated the task, reviewed and approved the reported information, the GRI content index and the statement of use before publication, as reported under 2-14?

Evidence: Approval minutes or written resolution dated before publication

After publication, has GRI been notified of the use of the GRI Standards and of the statement of use through the GRI Standards Report Registration System? Notification is mandatory for both claims; where the report is not made public, the report and the Requirement 9 information are sent to GRI directly.

Evidence: Registration confirmation from the GRI system; record of the person registering and the date

Is the reported information, and any summary, press release or web content, free of any statement that GRI has certified, approved or verified it? GRI does not verify or assess the quality of registered reports.

Evidence: Press release and web content reviewed against the statement of use

Where external assurance has been obtained, does the scope stated in the assurance report match the claims made in the reported information and the GRI content index? External assurance is recommended but is not required for either claim.

Evidence: Assurance report; assured disclosures identified in the GRI content index; management representation letter