Barbara Strozzilaan 336

1083 HN Amsterdam
The Netherlands
info@globalreporting.org

GRI Universal Standards 2021

Frequently Asked Questions (FAQs)
December 2022

© GRI 2022
Contents

New system of GRI Standards ................................................................................................................ 5

1. How was the system of GRI Standards updated? ................................................................... 5
2. How do I use the updated system of GRI Standards? ............................................................ 5
3. What is the difference between the Topic Standards in the previous set and the adapted
Topic Standards? ............................................................................................................................. 6
4. How do I use the Sector Standards? ....................................................................................... 6
GRI Universal Standards 2021 ............................................................................................................... 7
5. Why were the Universal Standards revised?........................................................................... 7
6. What was the process to revise the Universal Standards? ..................................................... 7
7. What has changed in the revised Universal Standards? ......................................................... 7
8. Are the GRI Universal Standards available in other languages? ............................................ 8
Transition from 2016 to 2021 version of Universal Standards ................................................................ 8
9. When will the Universal Standards 2021 come into effect? .................................................... 8
10. What does it mean for my reporting that the Universal Standards 2021 become effective on
1 January 2023? .............................................................................................................................. 8
11. What should I do if the translation into X, Y or Z is not yet available? .................................... 9
12. How can I access the previous set of GRI Standards? ........................................................... 9
13. What are the consequences if I have to use the previous set for my new report?.................. 9
14. What should I do if I cannot report in accordance with the Universal Standards 2021? ......... 9
Human rights ........................................................................................................................................... 9
15. What revisions have been made to the Universal Standards regarding human rights? ......... 9
16. Are the revised Universal Standards aligned with Shift and Mazars’ UN Guiding Principles
Reporting Framework and the Corporate Human Rights Benchmark? ......................................... 10
17. Why has the definition of material topics been changed to include human rights?............... 10
18. Does the inclusion of human rights disclosures imply that ‘human rights’ is always a material
topic for all organizations? ............................................................................................................. 10
19. Is the concept of ‘salient human rights issues’ included in the revised Universal Standards?
11
20. Will GRI update the human rights Topic Standards? ............................................................ 11
21. Are the human rights disclosures aligned with relevant legislation (e.g., UK Modern Slavery
Act, France’s Corporate Duty of Vigilance Law)? .......................................................................... 11
GRI 1: Foundation 2021 ........................................................................................................................ 12
Stakeholder ....................................................................................................................................... 12
22. Has the definition of ‘stakeholder’ changed? ......................................................................... 12
Sustainability context ......................................................................................................................... 12
23. Has the Sustainability context principle been removed? ....................................................... 12
Reporting in accordance with the GRI Standards ............................................................................. 12
24. How do I report in accordance with the GRI Standards? ...................................................... 12

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 25. Can I still report with reference to the GRI Standards? ......................................................... 13
26. Is there a minimum number of disclosures to report from the GRI Topic Standards to comply
with the new in accordance requirements? ................................................................................... 13
27. Is it required to explain why a disclosure from the GRI Topic Standards is not relevant? .... 14
28. Can I still use reasons for omissions if I cannot comply with a disclosure or with a
requirement in a disclosure? .......................................................................................................... 14
29. Is it required to use the GRI Sector Standards to comply with the new in accordance
requirements? ................................................................................................................................ 14
30. Is it possible to only use the GRI Sector Standards, without applying the GRI Topic
Standards, to report in accordance with the GRI Standards? ....................................................... 15
31. Is external assurance a requirement to report in accordance with the GRI Standards? ....... 15
GRI content index .............................................................................................................................. 15
32. Can I change the format for the GRI content index provided in the Appendices of GRI 1:
Foundation 2021? .......................................................................................................................... 15
GRI 2: General Disclosures 2021 ......................................................................................................... 15
33. Is it required to have policies on responsible business conduct to comply with the new in
accordance requirements? ............................................................................................................ 15
34. Does Disclosure 2-27 replace the GRI 307 and GRI 419 Standards? .................................. 16
35. Was there an issue with the tables in GRI 2: General Disclosures 2021 at the time of the
release of the Standard? ............................................................................................................... 16
GRI 3: Material Topics 2021 ................................................................................................................. 16
Materiality .......................................................................................................................................... 16
36. How has the definition of ‘material topics’ changed? ............................................................ 16
37. Do organizations need to redo their materiality assessment? .............................................. 17
38. Do the revised GRI Universal Standards incorporate the double materiality approach? ...... 17
39. How can an organization identify its impacts?....................................................................... 18
40. How often does an organization need to conduct a materiality assessment? ...................... 18
41. Is there a new materiality matrix for use with the revised Universal Standards? .................. 19
Topic Boundary ................................................................................................................................. 19
42. Has the concept of topic Boundary changed? ....................................................................... 19
Management approach...................................................................................................................... 19
43. Have the management approach disclosures changed? ...................................................... 19
Sector Standards .................................................................................................................................. 20
44. How do I determine which Sector Standard(s) apply to my organization? ............................ 20
45. When will the applicable Sector Standard for my organization be available? ....................... 20
46. Does an organization need to report on all topics listed in the applicable Sector Standard(s)?
20
47. Can I just report the topics included in the applicable Sector Standard? .............................. 21
48. If there is no Sector Standard available for my Sector, is my organization required to use the
applicable G4 Sector Disclosure? .................................................................................................. 21
49. If my organization is still using the G4 Sector Disclosures, is it required to list them in the
GRI content index? ........................................................................................................................ 21

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50. Is the additional sector reporting listed in Sector Standards required to be reported? ......... 21

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New system of GRI Standards
1. How was the system of GRI Standards updated?
The updated system of GRI Standards consists of three series of Standards: Universal Standards,
Sector Standards, and Topic Standards.
The revised Universal Standards are identified by a green cover with numbers 1, 2, or 3:

• GRI 1: Foundation 2021;

• GRI 2: General Disclosures 2021;

• GRI 3: Material Topics 2021.
The new Sector Standards now form part of the set. They are identifiable by a brown cover and a
double-digit code number. The first Sector Standard, GRI 11: Oil and Gas Sector 2021, will be made
available at the launch in October 2021.
There are now 31 Topic Standards after the withdrawal of three Standards. The reason for withdrawal
was that either their content was discontinued or incorporated in the revised Universal Standards. All
Topic Standards have a purple cover page and a three-digit code number. The Topic Standards are
adapted to make reporting using the revised Universal Standards and the Sector Standards possible,
but the disclosures in the Topic Standards have not changed. As such, the numbering and release
year of the Topic Standards remains the same as before the update (e.g., GRI 306: Waste 2020).
Until the effective date of 1 January 2023, organizations can continue using the previous set of GRI
Standards. The GRI Standards in the 2021 update are provided free of charge from the GRI website
after registration. They are available as separate files, a complete set in one PDF, or packaged
individually in a zip file. A separate GRI Standards Glossary is also available to download.

2. How do I use the updated system of GRI Standards?

The GRI Standards remain a modular system of interconnected standards. They allow organizations
to publicly report the impacts of their activities in a structured way that is transparent to stakeholders
and other interested parties. With the addition of the Sector Standards, the GRI Standards now
comprise three series: the GRI Universal Standards, the GRI Sector Standards, and the GRI Topic
Standards.
The Universal Standards apply to all organizations and comprise three Standards: GRI 1: Foundation
2021, GRI 2: General Disclosures 2021, and GRI 3: Material Topics 2021. The Universal Standards
guide reporters on how to report with the Standards, and they contain requirements and reporting
principles that all organizations must comply with to report in accordance with the GRI Standards.
The Sector Standards intend to increase the quality, completeness, and consistency of reporting by
organizations. They provide information for organizations about their likely material topics based on
their sector's most significant impacts on the economy, environment, and people, including impacts on
human rights. An organization uses the Sector Standards that apply to its sectors when determining
and reporting on their material topics. The Sector Standards point to the relevant disclosures in the
Topic Standards for the organization to report. A Sector Standard may also list additional disclosures
that are not in a Topic Standard, for example, where the disclosures from the Topic Standard do not
provide sufficient information about the organization's impacts concerning the topic.

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The Topic Standards contain disclosures for organizations to report information about its impacts
relating to certain topics. An organization selects the Topic Standards according to the list of material
topics it has determined using GRI 3 and applicable Sector Standards.
You can find more information on the updated system of GRI Standards in A Short Introduction to the
GRI Standards.

3. What is the difference between the Topic Standards in the

previous set and the adapted Topic Standards?
All GRI Topic Standards are adapted to ensure consistency with the revised Universal Standards. The
adaptations include:
• Updating the Introduction, Glossary, and Bibliography to align with the changes made to
these sections in the Universal Standards.

• Updating revised terminology. For instance, ‘reporting requirements’ are now called
‘requirements’ and ‘Topic-specific disclosures’ are now ‘topic disclosures’.
• Removing references to concepts that no longer exist (such as 'topic Boundary').
• Updating references to the Universal Standards (titles, disclosures, and clauses).
• Applying the new GRI Standards template.
Changes to the Topic Standards focus only on those that are necessary to ensure there are no
contradictions with the revised Universal Standards. The information to be reported remains the
same. The Topic Standards are no longer organized into the 200 (Economic topics), 300
(Environmental topics), and 400 (Social topics) series.

4. How do I use the Sector Standards?

When an applicable Sector Standard is available, an organization reporting in accordance with the
GRI Standards is required to use it.
The organization uses the Sector Standard first when determining its material topics and again when
determining what information to report for the material topics.
The organization needs to use the Sector Standard when determining its material topics, however
Sector Standards are not intended to be a substitute for an organization’s own process of determining
material topics. The organization is still required to determine material topics according to its own
specific circumstances. GRI 3: Material Topics 2021 provides step-by-step guidance on how to
determine material topics.
Once the organization has determined a topic included in the Sector Standard is material for them,
the Standard also helps the organization identify disclosures to report information about that topic.
Sector Standards point to the disclosures from the Topic Standards for the organization to report. A
Sector Standard may also list additional disclosures that are not in a Topic Standard, for example,
where the disclosures from the Topic Standard do not provide sufficient information about the
organization’s impacts. Where the disclosures listed in the Sector Standard do not provide sufficient
information about the organization’s impacts, additional disclosures to report on a topic may also be
used and listed.
If the organization has determined any of the topics included in the Sector Standard as not material,
the organization is required to list them in the GRI content index and explain why they are not
material.

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See the Sector Standards FAQ section to learn more about the GRI Sector Standards.

GRI Universal Standards 2021

5. Why were the Universal Standards revised?
The revision of the Universal Standards was initiated following the recommendations from the GRI
Technical Committee on Human Rights Disclosure. The project also drew on feedback received from
the Global Sustainability Standards Board (GSSB) during the transition from the G4 Guidelines to the
GRI Standards, feedback received from reporting organizations and other stakeholders, and
information gathered from the review of sustainability reports using the GRI Standards. Overall, this
revision aimed to:
• embed mandatory human rights-related disclosures for all reporting organizations;
• integrate reporting on due diligence into the GRI Standards;
• provide greater clarity on key concepts, reporting principles and disclosures in the GRI
Standards, and ensure they align with recent developments around responsible business
conduct;

• drive consistent application;

• encourage more relevant and comprehensive reporting; and
• improve the overall usability of the GRI Standards.

6. What was the process to revise the Universal Standards?

The review of the Universal Standards was informed by the recommendations of the GRI Technical
Committee on Human Rights Disclosure, a stakeholder group on labor-related disclosures, and public
consultation.
Revisions to the Universal Standards were developed according to a formally defined Due Process
Protocol that provides a set of mandatory requirements for developing a standard. This process is
overseen by the Due Process Oversight Committee and ensures that updates are developed
following a transparent and multi-stakeholder process.
The final GRI Universal Standards were approved in July 2021 by the GSSB Due Process Oversight
Committee.

7. What has changed in the revised Universal Standards?

Key revisions to the Universal Standards include:

• The Universal Standards now reflect expectations for responsible business conduct in
authoritative intergovernmental instruments such as the United Nations (UN) Guiding
Principles on Business and Human Rights, the Organisation for Economic Co-operation and
Development (OECD) Guidelines for Multinational Enterprises, the OECD Due Diligence
Guidance for Responsible Business Conduct, the International Labour Standards, and the
International Corporate Governance Network (ICGN) Global Governance Principles.

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 • A revised approach to reporting in accordance with the GRI Standards, there is now only one
way, replacing the previous Core and Comprehensive options. An organization can still report
with reference to the GRI Standards.
• Key concepts that are introduced to lay out the foundation of sustainability reporting. They
comprise impact, material topics, due diligence, and stakeholder.

• Revised reporting principles that focused on the quality and presentation of information.
• New disclosures on policy commitments for responsible business conduct, including respect
for human rights and due diligence, and how these commitments are embedded in the
organization have been introduced.

• Revised disclosures for organizations to provide information about their reporting practices;
activities and workers; governance; strategy, policies, and practices; and stakeholder
engagement.
• A revised approach to materiality, with new guidance to determine material topics that
incorporate the concept of due diligence and revised disclosures for reporting the process by
which an organization has determined its material topics, its list of material topics, and how it
manages each material topic.

• The structure and language of the updated Universal Standards set out requirements more
clearly and group the contents more coherently.

• The updated system of the GRI Standards now including the GRI Sector Standards.

• New templates for the GRI Standards to improve the clarity of information and usability.
Information in the GRI Standards is now structured and presented differently; the naming
convention for all Standards has been updated.

8. Are the GRI Universal Standards available in other languages?

The authoritative text of the GRI Standards is English. Authorized translations of the Universal
Standards in key languages will be made available between 2022 and 2023. Please consult the GRI
Translations page or contact translations@globalreporting.org for more information on the upcoming
translation schedule.

Transition from 2016 to 2021 version

of Universal Standards
9. When will the Universal Standards 2021 come into effect?
On 1 January 2023.

10. What does it mean for my reporting that the Universal

Standards 2021 become effective on 1 January 2023?
Using the Universal Standards 2021 is a requirement for all reporting published on 1 January 2023 or
later.

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11. What should I do if the translation into X, Y or Z is not yet
available?
You should use the English version (of GRI 1: Foundation 2021, GRI 2: General Disclosures 2021,
GRI 3: Material Topics 2021, GRI 11: Oil and Gas Sector 2021 and the adapted Topic Standards) for
reporting until translations become available.

12. How can I access the previous set of GRI Standards?

The previous set of GRI Standards is no longer available.

13. What are the consequences if I have to use the previous set for
my new report?
Your reporting will not comply with the GRI Standards.

14. What should I do if I cannot report in accordance with the

Universal Standards 2021?
An organization that cannot meet the requirements for reporting in accordance with the Universal
Standards 2021 is encouraged to report with reference to the Universal Standards 2021 and to
comply with all in accordance requirements over time.
Many of the disclosures in the Universal Standards 2016 are included in the Universal Standards
2021 and the disclosures in the Topic Standards remain unchanged. You can consult this mapping
document which shows the changes between the 2016 and the 2021 version of the Universal
Standards.
See question 25 for more information.

Human rights
15. What revisions have been made to the Universal Standards
regarding human rights?
The Universal Standards have been revised to align with the UN Guiding Principles on Business and
Human Rights, the Organisation for Economic Co-operation and Development (OECD) Guidelines for
Multinational Enterprises, and the OECD Due Diligence Guidance for Responsible Business Conduct.
Key concepts in the GRI Standards are revised to be in line with these instruments. These include the
concepts of ‘material topics’ and ‘stakeholder’.
GRI 2: General Disclosures 2021 and GRI 3: Material Topics 2021 are also revised to align with these
instruments and enable organizations to report on their due diligence for human rights impacts and
other impacts on the economy, environment, and people. As a result, the revised Universal Standards
introduce minimum reporting requirements for all organizations using the GRI Standards, including,
but not limited to, information on:

• the organization’s policy commitments for responsible business conduct, including the policy
commitment to respect human rights, and how the commitments are embedded throughout
the organization’s activities and business relationships;

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 • the grievance mechanisms and other remediation processes in place;
• the engagement with (affected and potentially affected) stakeholders;
• the due diligence processes for identifying actual and potential negative impacts on the
economy, environment, and people, including impacts on their human rights, across the
organization’s activities and business relationships;

• the prioritization of impacts based on their significance, or severity in the case of negative
human rights impacts, to determine material topics for reporting;

• the management of material topics, including information on specific policies, goals and
targets, actions to prevent, mitigate, and remediate negative impacts, and the effectiveness of
actions taken.
These revisions have been developed by a multi-stakeholder Technical Committee of experts, which
included the participation of the United Nations Office of the High Commissioner for Human Rights
(OHCHR) and the OECD. The full list of experts who participated in the Technical Committee can be
found here.

16. Are the revised Universal Standards aligned with Shift and
Mazars’ UN Guiding Principles Reporting Framework and the
Corporate Human Rights Benchmark?
These reporting frameworks align by virtue of all three being developed in line with the expectations in
the UN Guiding Principles.
A representative from Shift and an expert involved in the development of the Corporate Human Rights
Benchmark participated in the GRI Technical Committee on Human Rights Disclosure, which
contributed to developing the revised Universal Standards.

17. Why has the definition of material topics been changed to

include human rights?
Human rights are the most fundamental level of protection provided to people in authoritative
intergovernmental instruments.
The most acute impacts an organization can have on people are those that negatively affect their
human rights. Human rights impacts cross a threshold as compared to other types of impacts, in that
they affect basic human dignity and equality. Human rights impacts by businesses are also prevalent
to date and will likely continue to be in the future. As a result, this makes human rights impacts one of
the most vital types of impacts for the GRI Standards to address.
The UN Guiding Principles on Business and Human Rights establish that all businesses, everywhere,
have a responsibility to respect human rights. At the same time, human rights impacts are often
underreported by organizations. By highlighting human rights impacts in the definition of material
topics ensures that they are not overlooked, and it better supports organizations to report on how they
meet their responsibility to respect human rights.

18. Does the inclusion of human rights disclosures imply that

‘human rights’ is always a material topic for all organizations?
‘Human rights’ is a subject area, like the environment, and it covers more than 30 specific subjects, as
established by authoritative intergovernmental instruments. Examples of human rights-related topics

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are: non-discrimination, the right to freedom of association and collective bargaining, forced labor, or
the right to privacy. GRI 2: General Disclosures 2021 requires all organizations to report basic
information on how they meet their responsibility to respect human rights. However, organizations will
still need to determine which specific human rights topics are material for them, as in the existing GRI
Standards.

19. Is the concept of ‘salient human rights issues’ included in the

revised Universal Standards?
The concept of ‘salient human rights’ is used in the UN Guiding Principles Reporting Framework from
Shift and Mazars to refer to those human rights that stand out because they are at risk of the most
severe negative impact through the company’s activities or business relationships.
The UN Guiding Principles on Business and Human Rights themselves do not include the term
‘salient human rights’ – therefore, the revised Universal Standards do not include the term ‘salient’.
The UN Guiding Principles introduce a prioritization approach for negative human rights impacts
based on severity. This approach is included in the revised Universal Standards. So, the revised
Universal Standards are aligned with the UN Guiding Principles.
The ‘salient human rights’ reported with the UN Guiding Principles Reporting Framework represent a
company’s most severe negative human rights impacts and should therefore be material to report with
the revised Universal Standards.

20. Will GRI update the human rights Topic Standards?

With the release of the GRI Universal Standards 2021, the Topic Standard GRI 412: Human Rights
Assessment 2016 will be withdrawn since its contents have been revised and incorporated into the
revised Universal Standards.
The GSSB will also look at revising the human rights Topic Standards (e.g., GRI 408: Child Labor
2016, GRI 409: Forced or Compulsory Labor 2016) to ensure they reflect best practice and build upon
the contents in the revised Universal Standards. The GSSB may also develop new human rights
Topic Standards or disclosures as needed. A scoping survey was conducted in March 2021 to help
identify the priority human rights issues for revising the Topic Standards.
While the specific timeline for these revisions is still to be determined by the GSSB, further updates
can be found on the GSSB website.

21. Are the human rights disclosures aligned with relevant

legislation (e.g., UK Modern Slavery Act, France’s Corporate
Duty of Vigilance Law)?
As we create global Standards, our primary references are authoritative intergovernmental
instruments, particularly the UN Guiding Principles on Business and Human Rights, the OECD
Guidelines for Multinational Enterprises, the OECD Due Diligence Guidance for Responsible
Business Conduct, and core ILO instruments. The UN Guiding Principles establish that business
enterprises are responsible for respecting human rights, which exists over and above compliance with
national laws and regulations protecting human rights.
The GRI Standards can be used to report against human rights-specific legislation developed in line
with the UN Guiding Principles on Business and Human Rights.

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GRI 1: Foundation 2021
Stakeholder
22. Has the definition of ‘stakeholder’ changed?
Yes, in the revised Universal Standards, a ‘stakeholder’ is defined as an individual or group that has
an interest that is affected or could be affected by the organization’s activities.
The definition of ‘stakeholder’ aligns with the OECD Due Diligence Guidance for Responsible
Business Conduct.
The revised definition does not include the second part of the previous definition (‘entity or individual
whose actions can reasonably be expected to affect the ability of the organization to successfully
implement its strategies and achieve its objectives’). This change was made to be consistent with the
GRI Standards’ focus on an organization’s most significant impacts on the economy, environment,
and people, including impacts on their human rights.

Sustainability context
23. Has the Sustainability context principle been removed?
No, the Sustainability context principle remains in the GRI Standards and has been revised for clarity.
Please see section 4 of GRI 1: Foundation 2021.
In addition to GRI 1, guidance on sustainability context is covered across the Universal Standards,
Sector Standards, and Topic Standards:
• GRI 3: Material Topics 2021 includes guidance on assessing the organization’s context when
determining its material topics and on reporting goals and targets.

• Each Sector Standard will have a section explaining the sustainability context for the sector.
• Some of the Topic Standards have disclosures that help to report information in context, such
as the disclosures about water stress in GRI 303: Water and Effluents 2018.

Reporting in accordance with the GRI Standards

24. How do I report in accordance with the GRI Standards?
There is now only one way to report in accordance with the GRI Standards. The Core and
Comprehensive options for reporting in accordance with the GRI Standards, as used in the Universal
Standards 2016, no longer exist in GRI 1: Foundation 2021.
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 and how it manages these impacts. This allows information users to make
informed assessments and decisions about the organization’s impacts and contribution to sustainable
development.
To report in accordance with the GRI Standards, an organization must comply with all nine
requirements set out in section 3 of GRI 1:

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 • Requirement 1: Apply the reporting principles
• Requirement 2: Report the disclosures in GRI 2: General Disclosures 2021
• Requirement 3: Determine material topics

• Requirement 4: Report the disclosures in GRI 3: Material Topics 2021

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

• Requirement 6: Provide reasons for omission for disclosures and requirements that the
organization cannot comply with
• Requirement 7: Publish a GRI content index

• Requirement 8: Provide a statement of use

• Requirement 9: Notify GRI

25. Can I still report with reference to the GRI Standards?

Yes, if an organization cannot comply with all the requirements for reporting in accordance with the
GRI Standards, it cannot claim to have prepared the reported information in accordance with the GRI
Standards. Instead, it can claim that it has prepared the reported information with reference to the
GRI Standards, provided that it complies with the requirements specified in ‘Reporting with reference
to the GRI Standards’ at the end of section 3 in GRI 1. In this case, the organization must comply with
these specific requirements:

• Publish a GRI content index

• Provide a statement of use
• Notify GRI
An 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 reporting regulation on climate change. In this case, the organization
must also comply with all three requirements for reporting with reference to the GRI Standards.

26. Is there a minimum number of disclosures to report from the

GRI Topic Standards to comply with the new in accordance
requirements?
There is no requirement to report a minimum number of disclosures from the GRI Topic Standards to
report in accordance with the GRI Standards. The number of disclosures that the organization reports
is based on its assessment of which disclosures are relevant to its impacts in relation to a material
topic.
For each material topic, the organization needs to identify disclosures from the Topic Standards to
report. When the material topic is covered in the applicable GRI Sector Standards, the organization is
required to use the Sector Standards to identify disclosures to report. The organization is required to
report only those disclosures relevant to its impacts in relation to a material topic. The organization is
not required to report disclosures that are not relevant. If the disclosures from the Topic Standards do
not provide sufficient information about its impacts, then the organization should report additional
disclosures, such as the additional sector disclosures recommended in the GRI Sector Standards,
disclosures from other sources, or disclosures developed by the organization.
See Requirement 5 in GRI 1: Foundation 2021.

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27. Is it required to explain why a disclosure from the GRI Topic
Standards is not relevant?
An organization does not need to report the disclosures from the GRI Topic Standards that are not
relevant to its impacts in relation to a material topic. Therefore, there is no requirement for including
these disclosures in the GRI content index, and an organization does not need to provide a reason for
omission for not reporting those disclosures or an explanation for why they are not relevant.

28. Can I still use reasons for omissions if I cannot comply with a
disclosure or with a requirement in a disclosure?
Yes, an organization can use reasons for omission if it cannot comply with a disclosure or with a
requirement in a disclosure for which reasons for omission are permitted.
Reasons for omission are permitted for all disclosures from the GRI Standards except for five
disclosures from GRI 2: General Disclosures 2021 and two disclosures from GRI 3: Material Topics
2021. An organization cannot use reasons for omission for these seven disclosures, which means it
must disclose the information required in these disclosures to report in accordance with the GRI
Standards:

• Disclosure 2-1 Organizational details

• Disclosure 2-2 Entities included in the organization’s sustainability reporting

• Disclosure 2-3 Reporting period, frequency, and contact point

• Disclosure 2-4 Restatements of information

• Disclosure 2-5 External assurance

• Disclosure 3-1 Process to determine material topics

• Disclosure 3-2 List of material topics
There are four reasons for omission an organization is permitted to use:

• Not applicable
• Legal prohibitions

• Confidentiality constraints
• Information unavailable/incomplete
An organization still reports in accordance with the GRI Standards as long as it complies with the
requirements for the reasons for omission specified in Requirement 6 in GRI 1: Foundation 2021.
See Requirement 6 in section 3 of GRI 1 for more information on applying the reasons for omission.

29. Is it required to use the GRI Sector Standards to comply with

the new in accordance requirements?
Yes, to report in accordance with the GRI Standards, an organization is required to use the applicable
GRI Sector Standards when determining its material topics and when determining what information to
report for the material topics. An organization must comply with this requirement only if Sector
Standards that apply to its sectors are available.
See Requirement 3-b and corresponding guidance in GRI 1: Foundation 2021.

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30. Is it possible to only use the GRI Sector Standards, without
applying the GRI Topic Standards, to report in accordance with
the GRI Standards?
The GRI Sector Standards are not designed to be standalone Standards but intended to be used with
the GRI Universal Standards and the GRI Topic Standards. A Sector Standard identifies likely
material topics for organizations in a given sector, and for each likely material topic, lists disclosures
to report.

31. Is external assurance a requirement to report in accordance

with the GRI Standards?
The approach to external assurance has not changed in the revised Universal Standards; rather, it is
now more prominently featured. Therefore, it is recommended, as in the Universal Standards 2016,
for an organization to seek external assurance for its sustainability reporting, in addition to the use of
internal controls.
The use of external assurance for sustainability reporting is still not required to prepare information in
accordance with, or with reference to, the GRI Standards.
See section 5.2 of GRI 1: Foundation 2021. This section describes various ways an organization can
use to enhance the credibility of its sustainability reporting. The section does not introduce new
content but incorporates the previous guidance from Disclosure 102-56 in GRI 102: General
Disclosures 2016 on the use of external assurance, internal controls, and stakeholder or expert
panels.

GRI content index

32. Can I change the format for the GRI content index provided in
the Appendices of GRI 1: Foundation 2021?
Yes, the GRI content index in Appendix 1 and Appendix 2 of GRI 1 provides an example of how to
prepare the GRI content index when reporting in accordance with or with reference to the GRI
Standards. The organization can use these appendices to prepare its content index. However, the
organization can use a different format for the content index, as long as it complies with the
requirements for the content index specified in section 3 of GRI 1. For instance, if there is no
applicable GRI Sector Standard that the organization can use, the column ‘GRI Sector Standard Ref.
No.’ can be removed.

GRI 2: General Disclosures 2021

33. Is it required to have policies on responsible business conduct
to comply with the new in accordance requirements?
No, an organization is not required to have policies on responsible business conduct. Disclosure 2-23
in GRI 2: General Disclosures 2021 requires an organization to describe its policy commitments for
responsible business conduct. This disclosure does not require an organization to have policies on
responsible business conduct; it requires an organization to report on them. If such policies do not

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exist, an organization can comply with this disclosure by reporting that it does not have policies on
responsible business conduct.
If an organization cannot report the required information about an item specified in a disclosure
because the item (e.g., committee, policy, practice, process) does not exist, it can comply with the
requirement by reporting this to be the case. An organization can explain the reasons for not having
this item or describe any plans to develop it. The disclosures in the GRI Standards do not require an
organization to implement the item (e.g., developing a policy), but to report that the item does not
exist. See the Introductions in GRI 2: General Disclosures 2021 and GRI 3: Material Topics 2021.

34. Does Disclosure 2-27 replace the GRI 307 and GRI 419
Standards?
Yes, the content of GRI 307: Environmental Compliance 2016 and GRI 419: Socioeconomic
Compliance 2016 has been moved and expanded under Disclosure 2-27 Compliance with laws and
regulations in GRI 2: General Disclosures 2021. With the release of the Universal Standards 2021,
GRI 307 and GRI 419 will be withdrawn.

35. Was there an issue with the tables in GRI 2: General

Disclosures 2021 at the time of the release of the Standard?
Yes, there was an issue at the time of release with the tables on page 17 of the Standard referred to
in the guidance sections for requirements 2-7-a and 2-7-b. During the production of the PDF file, the
contents of the example template for tables 1. and 2. were mixed up.

This error only affected downloads of the Standard and the Consolidated Set between 5 and 12
October 2021.

The tables were corrected, with a message sent to those who had downloaded the Standard between
5 and 12 October. The message went out only to those who had indicated during registration that they
wished to receive updates about the GRI Standards. In addition, an erratum note was posted on the
flyout popups of GRI 2 and the Consolidated Set on the GRI website.

If you downloaded the Standard between 5 and 12 October, please download GRI 2 with the
corrected tables here. If the link does not work, please copy this link to your
browser: https://www.globalreporting.org/pdf.ashx?id=12358.

GRI 3: Material Topics 2021

Materiality
36. How has the definition of ‘material topics’ changed?
In the GRI Universal Standards 2016, material topics are topics that reflect at least one of the
following dimensions:
• the organization’s significant economic, environmental, and social impacts

• their substantive influence on the assessments and decisions of stakeholders

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Feedback indicated that this approach and the use of the materiality matrix, provided in the guidance
to the Materiality principle in GRI 101: Foundation 2016, often led to biases and incorrect
interpretations of these dimensions.
Separating impact assessment from identifying stakeholder views left materiality assessments
particularly vulnerable to biases based on stakeholder selection, given that this approach led
organizations to prioritize impacts only if the consulted stakeholders highlighted them.
Impacts would often be assessed based on their significance to the organization and influence on
stakeholders. As a result, organizations would consider the impacts on themselves instead of how
they impact the economy, the environment, and society.
The GRI Universal Standards 2021 addresses those issues and focuses on organizations' impacts on
the economy, environment, and people. In the revised Standards, ‘material topics’ are defined as
topics that represent an organization’s most significant impacts on the economy, environment, and
people, including impacts on their human rights.
The ‘influence on the assessments and decisions of stakeholders’ is no longer a standalone factor
that determines whether a topic is material.
While the definition of ‘material topic’ has been revised to focus on impact, engagement with relevant
stakeholders forms part of identifying and assessing an organization’s impacts and informs the
process for determining material topics.

37. Do organizations need to redo their materiality assessment?

The concept of ‘material topics’ in the revised Universal Standards still uses the criterion of
significance of the impacts as outlined in GRI 101: Foundation 2016. Therefore, an organization that
has determined its material topics based on the significance of its economic, environmental, and
social impacts, as required by GRI 101, is well prepared to comply with the requirements in GRI 1:
Foundation 2021.
If a Sector Standard is available that applies to the organization, the organization is required to review
each topic described in the applicable Sector Standards and determine whether it is a material topic
for the organization. If the organization has determined any of the topics included in the applicable
Sector Standards as not material, the organization is required to list them in the GRI content index
and explain why they are not material.

38. Do the revised GRI Universal Standards incorporate the double

materiality approach?
The GRI Standards enable organizations to report information about the most significant impacts of
their activities and business relationships on the economy, environment, and people, including
impacts on people’s human rights. Such impacts are of primary importance to sustainable
development and to organizations’ stakeholders, and they are the focus of sustainability reporting.
The impacts of an organization’s activities and business relationships on the economy, environment,
and people can have negative and positive consequences for the organization itself. These
consequences can be operational or reputational, and therefore in many cases, financial. For
example, an organization’s high use of non-renewable energy contributes to climate change and
could, at the same time, result in increased operating costs for the organization due to legislation that
seeks to shift energy use toward renewable sources.
Even if not financially material at the time of reporting, most, if not all, of the impacts of an
organization’s activities and business relationships on the economy, environment, and people will
eventually become financially material issues. The impacts are also important for those interested in

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the organization's financial performance and long-term success. Therefore, understanding these
impacts is a necessary first step in determining related financially material issues for the organization.
Sustainability reporting is therefore crucial for financial and value creation reporting. Information made
available through sustainability reporting provides input for identifying financial risks and opportunities
related to the organization’s impacts and for financial valuation. This, in turn, helps to make financial
materiality judgments about what to recognize in financial statements.
While the impacts of the organization’s activities and business relationships on the economy,
environment, and people may become financially material, sustainability reporting is also highly
relevant in its own right as a public interest activity. Sustainability reporting is independent of the
consideration of financial implications. Therefore, it is important for the organization to report on all the
material topics it has determined using the GRI Standards. These material topics cannot be
deprioritized on the basis of not being considered financially material by the organization.

39. How can an organization identify its impacts?

As explained under Step 2 of the process for determining material topics in GRI 3: Material Topics
2021, to identify its impacts, the organization can use information from:

• its own or third-party assessments of impacts on the economy, environment, and people,
including impacts on their human rights;
• legal reviews, anti-corruption compliance management systems, financial audits, occupational
health and safety inspections, and shareholder filings;
• any other relevant assessments of business relationships carried out by the organization or
by industry or multi-stakeholder initiatives;
• grievance mechanisms that the organization has established itself or that have been
established by other organizations;
• broader enterprise risk management systems, provided that these systems identify the
organization’s impacts on the economy, the environment, and people, in addition to identifying
risks for the organization itself; and
• external sources, such as news organizations and civil society organizations.

In addition, the organization should seek to understand the concerns of its stakeholders and consult
internal and external experts, such as civil society organizations or academics.
The GRI Standards are not an impact identification and assessment tool. The GRI Standards do not
recommend a specific impact identification and assessment standard, tool, or methodology. It is up to
the organization to identify which one to use.

40. How often does an organization need to conduct a materiality

assessment?
Impacts may change over time as the organization’s activities, business relationships, and context
evolve. New activities, new business relationships, and major changes in operations or the operating
context (e.g., new market entry, product launch, policy change, wider changes to the organization)
could lead to changes in the organization’s impacts. For this reason, the organization should assess
its context and identify its impacts on an ongoing basis.
In each reporting period, the organization should review its material topics from the previous reporting
period to account for changes in the impacts. Changes in impacts can result from changes in the
organization’s activities and business relationships. This review helps ensure the material topics
represent the organization’s most significant impacts in each new reporting period.

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41. Is there a new materiality matrix for use with the revised
Universal Standards?
The materiality matrix in GRI 101: Foundation 2016 is not included in GRI 1: Foundation 2021. The
revisions to the concept of ‘material topic’ eliminate the need for a matrix as the concept no longer
encompasses two independent criteria.
When using the revised Universal Standards, an organization can provide a visual representation of
the prioritization of material topics that shows the initial list of topics the organization has identified
and the threshold set for reporting.

Topic Boundary
42. Has the concept of topic Boundary changed?
The term ‘topic Boundary’ has been revised to address challenges in understanding and applying this
concept.
GRI 3: Material Topics 2021 now clarifies that an organization should consider actual and potential
negative impacts that it causes or contributes to through its activities, as well as those directly linked
to its operations, products, or services by its business relationships. The concepts of ‘cause’,
‘contribute to’, and ‘directly linked to’ have been further explained. They are used only in the context
of negative impacts (not positive impacts), in line with the expectations set out in key instruments
such as the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for
Multinational Enterprises, and the OECD Due Diligence Guidance for Responsible Business Conduct.
The requirement to report the topic Boundary for each material topic – now within Disclosure 3-3 in
GRI 3 – has also been revised. It requires an organization to report, for each material topic, whether it
is involved with the negative impacts through its activities or as a result of its business relationships,
and to describe the activities or business relationships (see 3-3-b in GRI 3 and corresponding
guidance).
This will enable organizations to explain whether a material topic is considered a group-wide issue or
a focalized issue (e.g., in certain countries, sites, business relationships).

Management approach
43. Have the management approach disclosures changed?
Disclosures 103-1, 103-2, and 103-3 from GRI 103: Management Approach 2016 have been
combined into one disclosure and revised to bring the requirements in line with the expectation of due
diligence contained in key instruments. See Disclosure 3-3 in GRI 3: Material Topics 2021.

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Sector Standards
44. How do I determine which Sector Standard(s) apply to my
organization?
Each Sector Standard includes a section titled ‘Sector this Standard applies to’ (usually found on
page 5). In this section, you can find a description of the sector defined for the Standard. To further
support identifying if the Standard applies to your organization, a table that lists relevant industry
groupings from a number of sector classification systems is also included.
It is important to note that the organization must use all applicable Sector Standards for the sectors in
which it has substantial activities. This means that more than one Sector Standard may be applicable.

45. When will the applicable Sector Standard for my organization

be available?
The GRI Sector Program will develop standards for 40 sectors. The full list of these can be found
here.
The primary criterion for prioritizing sectors is their sustainability impacts. This takes into account the
significance of the sector’s impacts, the size of the sector, the sector’s distribution around the world,
and the number of organizations from that sector that are in a position to use the GRI Standards.
Other criteria for prioritizing a sector include utilizing learnings and synergies from other recently
developed Sector Standards.
Following on from oil and gas, for which a Standard was recently published, coal, mining, agriculture,
aquaculture, and fishing, have Standards under development. The next sectors to be prioritized are:

• Food and beverage

• Textiles and apparel
• Banking
• Insurance
• Asset management
• Utilities
• Renewable energy
• Forestry
• Metal processing
The commencement of projects for these sectors has yet to be confirmed. Updated timelines can be
found on the GRI website in the Schedule of Standards projects webpage.

46. Does an organization need to report on all topics listed in the

applicable Sector Standard(s)?
A Sector Standard describes topics identified as likely material for organizations in a given sector.
However, circumstances for each organization vary, which means that not all topics listed in a Sector
Standard may be material for all organizations in that sector. Each organization needs to determine its
material topics according to its specific circumstances, such as its business model; geographic,
cultural, and legal operating context; ownership structure; and the nature of its impacts.

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The organization only needs to report on the topics it has determined as material. However, any
topics in the applicable Sector Standard(s) the organization determined as not material are required to
be listed in the GRI content index, along with a short explanation of why they are not material.
It is important to note that additional topics not included in the applicable Sector Standard(s) may also
be material for an organization due to its circumstances.

47. Can I just report the topics included in the applicable Sector
Standard?
A Sector Standard describes topics identified as likely material for most organizations in a given
sector. It explains why the topic might be material for the organization by outlining significant impacts
and how they occur in the sector by drawing on authoritative international instruments and other
supporting references.
Using Sector Standards is not a substitute for an organization’s own process for identifying material
topics. Not all topics listed in a Sector Standard may be material for all organizations in a given sector.
Similarly, topics that are material for an organization might not be represented in a Sector Standard
due to the organization’s specific circumstances (e.g., the organization’s geographic location).
Therefore, the organization is still required to identify its own material topics according to its specific
circumstances.

48. If there is no Sector Standard available for my Sector, is my

organization required to use the applicable G4 Sector
Disclosure?
While the Sector Standards are under development, the G4 Sector Disclosures (developed for the
GRI G4 Guidelines) can provide additional sector disclosures and guidance. G4 Sector Disclosures
were not updated as part of the transition from the GRI G4 Guidelines to the GRI Standards, and their
use is not required for preparing a report in accordance with the GRI Standards in the case of the
Universal Standards 2016 or the Universal Standards 2021.

49. If my organization is still using the G4 Sector Disclosures, is it

required to list them in the GRI content index?
An organization reporting in accordance with the GRI Standards is required to list in the GRI content
index all the disclosures it has reported. This includes disclosures from sources other than the GRI
Standards and applies to disclosure drawn from G4 Sector Disclosures.
An organization reporting with reference to the GRI Standards is required to list only those disclosures
it has reported from the GRI Standards. As such, it is not required to list disclosures from G4 Sector
Disclosures but can list them if it wants to.
Further guidance on how to prepare a GRI content index can be found in Appendix 1 and Appendix 2
in GRI 1: Foundation 2021.

50. Is the additional sector reporting listed in Sector Standards

required to be reported?
The topics and associated reporting have been identified based on available evidence and
authoritative international instruments, as well as the recommendations of a multi-stakeholder working
group.

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Additional sector disclosures and recommendations for the organization to report are included in
cases where the GRI Topic Standards do not provide disclosures or the disclosures from the Topic
Standards do not provide sufficient information about the impacts of an organization from the given
sector relating to a topic.
Reporting on these additional sector disclosures and recommendations is encouraged; however, it is
not a requirement.

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