Impact lens
GRI’s test: the organisation’s most significant impacts.
GRI 3Materiality · the impact test
GRI materiality: material topics are the most significant impacts
GRI materiality means an organisation reports the topics that represent its most significant impacts on the economy, environment and people, including impacts on their human rights.
GRI 3: Material Topics 2021 sets four steps to find them, and the significance of an impact is the only criterion.
That is the impact half of what the EU calls double materiality, and nothing in the GRI test asks how a topic affects the organisation’s finances.
The definition
What GRI means by a material topic
GRI 1 §2.2 says an organisation prioritises reporting on the topics that represent its most significant impacts on the economy, environment and people, including impacts on their human rights.
“In the GRI Standards, these are the organization’s material topics.”
Read the definition in GRI 3
GRI 3 opens with the same sentence: “Material topics are topics that represent an organization’s most significant impacts on the economy, environment, and people, including impacts on their human rights.”
The Standard is issued by the Global Sustainability Standards Board, and it is effective for reports or other materials published on or after 1 January 2023.
It also explains how the GRI Sector Standards are used in the process, and it contains the three disclosures an organisation reports about its material topics.
The family of standards around it is set out on the GRI Standards page; this page covers the materiality test only.
One test, three subjectsExplore
GRI 3, Section 1
Four steps to GRI 3 material topics
GRI 3 sets out four steps, and the first three are about impacts before any topic is chosen.
The fourth step is where the organisation prioritises and sets its threshold.
- Step 101
Understand the organisation’s context
An overview of its activities and business relationships, their sustainability context, and its stakeholders. - Step 202
Identify actual and potential impacts
Actual and potential, negative and positive impacts on the economy, environment and people, across activities and business relationships. - Step 303
Assess the significance of the impacts
Severity for negative impacts, plus likelihood for potential ones; scale and scope for positive impacts. - Step 404
Prioritise the most significant impacts for reporting
Rank, set a cut-off or threshold, document it, and group impacts into topics. - Then05
Report Disclosures 3-1, 3-2 and 3-3
The process, the list of material topics, and how each is managed.
Read the disclosures in GRI 3
| Disclosure | What it reports |
|---|---|
| 3-1 Process to determine material topics | How the organisation determined its material topics. |
| 3-2 List of material topics | The material topics themselves. |
| 3-3 Management of material topics | How each material topic is managed; reasons for omission are permitted only for this disclosure. |
Step 3
How GRI judges the significance of an impact
GRI 3 says the significance of an actual negative impact is determined by its severity, and of a potential negative impact by its severity and likelihood.
Severity has three characteristics: scale, how grave the impact is; scope, how widespread it is; and irremediable character, how hard it is to counteract or make good the harm.
Read the severity rules
“Any of the three characteristics (scale, scope, and irremediable character) can make an impact severe.”
So a scoring method that averages the three would contradict the Standard: one grave characteristic is enough.
“In the case of potential negative human rights impacts, the severity of the impact takes precedence over its likelihood.”
Positive impacts are judged on scale and scope, and on likelihood as well when they are potential.
The revised ESRS 1 uses the same architecture at ¶40 and AR 22, which is why the same evidence can serve both; impact materiality sets the ESRS rules out in full.
Four kinds of impactExplore
Module 02 / 04
Potential negative
Severity and likelihood; for human rights, severity takes precedence.
Step 4
The GRI materiality threshold is the organisation’s own
GRI 3 says the organisation should arrange its impacts from most to least significant and define a cut-off point or threshold to decide which it will report.
“Where to set the threshold is up to the organization.”
Read the threshold wording
“The organization should document this threshold.”
GRI 3 adds that the organisation “can provide a visual representation of the prioritization”, which is the closest any of these standards comes to a matrix, and it is optional.
“The significance of an impact is the sole criterion to determine whether a topic is material for reporting.”
That sentence is the line between GRI and the other frameworks: an impact cannot be dropped because it is not financially material.
How other frameworks treat thresholds, and why no standard sets a number, is set out under materiality thresholds.
- 1
Rank
Arrange impacts from most to least significant.
- 2
Group
Group impacts into topics to help prioritise.
- 3
Cut off
Define a cut-off point or threshold.
- 4
Document
Record the threshold; a visual of the prioritisation is optional.
The question most people ask
Does GRI use double materiality? It is the impact half
GRI does not run a double materiality test of its own.
Its policy guide says “The European Union dubbed this concept ‘Double Materiality’” and that GRI’s standards represent “the impact side of double materiality”.
Read GRI’s own wording
The same guide says GRI supports the concept of double materiality.
GRI’s answer on its revised Universal Standards is that material topics cannot be deprioritised because the organisation does not consider them financially material.
The phrase “impact materiality” does not appear in the GRI Standards themselves, which say material topics and most significant impacts.
GRI the organisation does use the phrase: its news release on the ESRS says it “called on EFRAG to enhance impact materiality” and asked EFRAG to align the definition of impact materiality with GRI’s.
So the accurate sentence is that GRI applies impact materiality, and the EU’s ESRS apply both lenses, either one being enough.
Two lenses
Financial lens
Not part of the GRI test; it belongs to the ISSB, UK SRS and the financial half of the ESRS.
IFRS S1, UK SRS S1 ¶18GRI and the ESRS
The same impact definition, written into the ESRS
EFRAG and GRI said in their 2023 joint statement that “the ESRS have adopted the same definition for impact materiality as GRI”.
Entities reporting under the ESRS “are considered as reporting with reference to the GRI Standards”.
Read the joint statement and the index
The GRI–ESRS Interoperability Index, V1 of 22 November 2024, maps GRI disclosures to ESRS disclosure requirements to support reporting “with reference” to GRI.
An ESRS reporter that wants to report “in accordance” with GRI has to report the additional applicable GRI requirements that the ESRS do not cover.
The index’s disclaimer is plain: it “does not imply that an entity can comply with the ESRS by reporting ‘in accordance’ with the GRI Standards.”
Both documents describe the 2023 ESRS in Delegated Regulation (EU) 2023/2772, and no updated index had been located as at 10 September 2026.
The revised ESRS keep the link in their own text: ESRS 1 AR 21 says the term “most significant impacts” is used in some frameworks for impacts the ESRS call material impacts.
EFRAG’s non-authoritative IG 1 said a GRI impact assessment “constitutes a good basis for the assessment of impacts under the ESRS”.
The ESRS then add financial materiality, which is how a group moves from a GRI assessment to a double materiality assessment.
GRI and ESRSExplore
Module 01 / 04
Same definition
The ESRS adopted the same definition of impact materiality as GRI (joint statement, 2023).
Module 02 / 04
“With reference to”
An ESRS report counts as reporting with reference to GRI.
Module 03 / 04
“In accordance”
Needs the additional GRI requirements the ESRS do not cover.
Module 04 / 04
Revised ESRS
AR 21: “most significant impacts” in other frameworks are “material impacts” in the ESRS.
GRI and the ISSB
Different questions, one operative link
The GRI and IFRS Foundation joint statement of 26 May 2026 sets the two purposes side by side.
GRI reporting gives “a range of stakeholders, including investors, material information about their most significant impacts on the economy, environment and people”.
Read what links the two families
ISSB reporting gives “investors with material information about sustainability-related risks and opportunities that could reasonably be expected to affect an entity’s prospects”.
The statement says the ISSB and the GSSB “make decisions separately in accordance with their established standard-setting due processes”.
The one operative mechanism is greenhouse gas figures: GRI’s statement of 26 June 2025 lets organisations reporting under both use the IFRS S2 Scope 1, 2 and 3 disclosures to meet GRI 102, measured under the GHG Protocol Corporate Standard (2004) and cross-referenced in the GRI content index.
That applies from GRI 102’s effective date of 1 January 2027, or on early adoption.
No disclosure-level mapping between the two families had been located as at 10 September 2026.
The ISSB’s own test is financial materiality, and the ISSB and GRI comparison sets out the rest.
GRI and ISSBExplore
Module 01 / 04
GRI purpose
Material information about the most significant impacts, for a range of stakeholders.
Module 02 / 04
ISSB purpose
Material information for investors about risks and opportunities affecting prospects.
Module 03 / 04
GHG equivalence
IFRS S2 Scope 1, 2 and 3 figures can meet GRI 102, on conditions, from 1 January 2027.
UK reporting
GRI under UK SRS: a source of guidance, not the test
UK SRS S1 ¶C2 lets an entity consider the GRI Standards as a source of guidance when it identifies sustainability-related risks and opportunities.
The UK test stays single (financial) materiality, judged by the decisions of primary users of general purpose financial reports (¶18).
Read the UK detail
¶C3 adds that an entity applying GRI without UK SRS cannot make an explicit and unreserved statement of compliance with UK SRS.
So a GRI impact assessment can feed a UK SRS assessment, but an impact enters the UK report only where it gives rise to a risk or opportunity for the entity.
The UK test, paragraph by paragraph, is on UK SRS materiality.
The UK positionExplore
Module 01 / 04
UK SRS S1 ¶C2
An entity may consider the GRI Standards as a source of guidance.
Module 02 / 04
UK SRS S1 ¶C3
Applying GRI without UK SRS bars an explicit and unreserved statement of compliance.
Module 03 / 04
The UK test
Single (financial) materiality: primary users’ decisions (¶18).
Module 04 / 04
Voluntary GRI
A UK company may still publish a GRI report for its stakeholders.
What you report
The three GRI 3 disclosures behind every material topic
GRI materiality ends in three disclosures, not a picture.
Disclosure 3-1 reports the process, 3-2 the list of material topics, and 3-3 how each topic is managed.
Read the omission rule
GRI 3 says reasons for omission are only permitted for Disclosure 3-3.
So an organisation cannot omit its process or its list; it can explain a gap only in how it manages a topic.
A working register that records each impact, its scores and the threshold applied is what makes Disclosure 3-1 checkable, and the double materiality assessment template sets out the fields.
GRI 3 disclosuresExplore
One assessment, several reports
Using a GRI materiality assessment under the ESRS and UK SRS
A group that already runs a GRI materiality assessment has the impact half of the ESRS work in hand.
What it adds for the ESRS is the financial lens, and what it carries to UK SRS is only the financially material subset.
Read how the work carries over
EFRAG’s IG 1, written for the 2023 ESRS and non-authoritative, called a GRI impact assessment “a good basis” for the ESRS impact assessment.
The revised ESRS 1 then asks the undertaking to assess risks and opportunities on “a combination of the likelihood of occurrence and the potential magnitude of the financial effects” (¶50).
Under UK SRS the impacts enter only as sources of risks and opportunities for the entity, which is the financial materiality test.
The step-by-step EU method is on the double materiality assessment.
Reusing the impact workExplore
Module 01 / 04
GRI impacts
A GRI impact assessment “constitutes a good basis” for the ESRS impact assessment (IG 1, non-authoritative).
Module 02 / 04
Add the financial lens
The ESRS also assess risks and opportunities on likelihood and magnitude (revised ESRS 1 ¶50).
Module 04 / 04
UK SRS report
Uses only what gives rise to risks and opportunities for the entity.
Dates
GRI materiality and the other frameworks, by date
The dates show how the GRI impact test came to sit inside the ESRS and beside the ISSB.
Dated items are as at 11 October 2026.
- 1 January 202301
GRI 3 takes effect
For reports or other materials published on or after this date. - 31 July 202302
- 202303
EFRAG–GRI joint statement
The ESRS adopted GRI’s definition of impact materiality; the statement is undated in its text. - 22 November 202404
- 26 June 202505
- 26 May 202606
- 21 September 202607
Revised ESRS published
Delegated Regulation (EU) 2026/1563 keeps the impact architecture. - 1 January 202708
GRI 102 and the revised ESRS apply
GRI 102’s effective date; the revised ESRS apply to financial years beginning on or after this date.
What goes wrong
Six GRI materiality mistakes
“GRI is a double materiality standard”
GRI applies the impact test; it attributes the term double materiality to the EU.
Dropping an impact because it costs nothing
Significance is the sole criterion; financial effect is not a GRI test.
Averaging severity
Any one of scale, scope or irremediable character can make an impact severe.
Treating likelihood as a filter on human rights
For potential human rights impacts, severity takes precedence.
Saying an ESRS report complies with GRI
It is considered “with reference to” GRI, not “in accordance”.
Requiring a matrix
A visual of the prioritisation is optional; the documented threshold is not.
Where to go next
The full process across frameworks is on running a materiality assessment.
The meaning of material in every framework is on materiality explained.
Frequently asked
Questions people ask
What is GRI materiality?
It is the test GRI uses to decide what an organisation reports.
Under GRI 1 and GRI 3, material topics are topics that represent the organisation’s most significant impacts on the economy, environment and people, including impacts on their human rights.
What are GRI 3 material topics?
They are the topics the organisation identifies by working through GRI 3’s four steps: understand its context, identify actual and potential impacts, assess the significance of those impacts, and prioritise the most significant for reporting.
It then reports the process (Disclosure 3-1), the list (3-2) and how it manages each topic (3-3).
Does GRI use double materiality?
Not as its own test.
GRI’s policy guide says “The European Union dubbed this concept ‘Double Materiality’” and that GRI’s standards represent “the impact side of double materiality”.
The GRI test asks only about impacts; financial effects on the organisation are not a criterion.
Do the GRI Standards use the phrase “impact materiality”?
The Standards themselves say material topics and most significant impacts.
GRI the organisation does use the phrase “impact materiality” in its commentary and submissions, including about its own approach.
How does GRI assess severity?
GRI 3 says the severity of a negative impact is determined by its scale (how grave), scope (how widespread) and irremediable character (how hard to put right), and that any one of the three can make an impact severe.
Likelihood is considered separately for potential impacts.
Does GRI set a materiality threshold?
No number.
GRI 3 tells the organisation to rank its impacts, define a cut-off point or threshold and document it, and says where to set the threshold is up to the organisation.
What about potential human rights impacts?
GRI 3 says that for potential negative human rights impacts, the severity of the impact takes precedence over its likelihood.
The revised ESRS 1 ¶40 says the same.
Can positive impacts be material under GRI?
Yes.
GRI 3 assesses an actual positive impact on its scale and scope, and a potential positive impact on scale, scope and likelihood.
Does an ESRS report count as a GRI report?
An ESRS report is considered to report “with reference to” the GRI Standards, according to the EFRAG–GRI joint statement and the November 2024 interoperability index.
Reporting “in accordance with” GRI needs the additional GRI requirements as well.
Both documents describe the 2023 ESRS.
Is the ESRS impact test the same as GRI’s?
EFRAG and GRI said in 2023 that the ESRS adopted the same definition of impact materiality as GRI.
The revised ESRS keep the same severity architecture, and ESRS 1 AR 21 notes that other frameworks call material impacts “most significant impacts”.
The ESRS then add the financial lens, which GRI does not have.
How do GRI and the ISSB relate on materiality?
They answer different questions.
Their joint statement of 26 May 2026 says GRI reporting gives a range of stakeholders information about the most significant impacts, while ISSB reporting gives investors information about risks and opportunities that could affect the entity’s prospects.
The one operative link is GHG figures: from GRI 102’s effective date of 1 January 2027, IFRS S2 Scope 1, 2 and 3 figures can meet the GRI 102 requirements on the stated conditions.
Can a UK company use GRI under UK SRS?
UK SRS S1 ¶C2 lets an entity consider the GRI Standards as a source of guidance.
The UK test itself stays single (financial) materiality, and ¶C3 says that applying GRI without UK SRS does not give an explicit and unreserved statement of compliance with UK SRS.
Is a materiality matrix required by GRI?
No. GRI 3 says the organisation “can provide a visual representation of the prioritization”, which a matrix can be, but it is optional; what GRI requires is the documented threshold and the disclosures.
When did GRI 3 take effect?
GRI 3: Material Topics 2021 is effective for reports or other materials published on or after 1 January 2023.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 13 sources fromGlobal Reporting InitiativeEFRAG and GRIGRI and EFRAGGRI and IFRS FoundationEUR-LexEFRAG
- Global Reporting InitiativeGRI 3: Material Topics 2021 — Effective Date, Section 1 Steps 1–4, Disclosures 3-1 to 3-3
Effective for reports published on or after 1 January 2023. Severity is scale, scope and irremediable character; the organisation sets and documents its own threshold.
- Global Reporting InitiativeGRI 1: Foundation 2021, §2.2
Material topics are the organisation’s most significant impacts on the economy, environment and people, including on their human rights.
- Global Reporting InitiativeThe GRI Standards
The Universal, Sector and Topic Standards issued by the Global Sustainability Standards Board.
- Global Reporting InitiativeDouble materiality: the guiding principle for sustainability reporting
GRI attributes the term to the EU and describes its standards as the impact side of double materiality.
- Global Reporting InitiativeImpact focus of the ESRS must be strengthened (news release)
GRI, the organisation, uses the phrase “impact materiality” of its own approach.
- EFRAG and GRIEFRAG–GRI Joint Statement of Interoperability (2023)
The ESRS adopted the same definition of impact materiality as GRI; ESRS reporters are considered to report “with reference to” GRI.
- GRI and EFRAGGRI–ESRS Interoperability Index, V1, 22 November 2024
Maps the 2023 ESRS; reporting “in accordance” with GRI needs the additional GRI requirements.
- GRI and IFRS FoundationJoint statement on reporting with both GRI and ISSB Standards, 26 May 2026
Separate purposes; the two boards decide separately.
- Global Reporting InitiativeGRI 102 and IFRS S2: statement on equivalence for GHG emissions, 26 June 2025
The one operative mechanism between the two families: Scope 1, 2 and 3 figures.
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — revised ESRS 1 ¶40, AR 21, AR 22
The ESRS severity rules, and the note that other frameworks call material impacts “most significant impacts”.
- EUR-LexCommission Delegated Regulation (EU) 2023/2772 — the first ESRS
The 2023 standards that the joint statement and the index describe.
- EFRAGIG 1: Materiality Assessment Implementation Guidance (May 2024), key point 11
A GRI impact assessment “constitutes a good basis” for the ESRS impact assessment. Non-authoritative; written for the 2023 ESRS.
- Department for Business and TradeUK SRS S1 — ¶¶C2–C3 and ¶¶17–18
GRI may be considered as a source of guidance; the UK test stays single (financial) materiality.
Continue reading
Read next
The family
The GRI Standards
The Universal, Sector and Topic Standards, and how a GRI report is built.
The ESRS lens
Impact materiality
The ESRS impact rules: severity, likelihood and the four kinds of impact.
The other end
SASB materiality map
The investor-focused industry topics the ISSB points to.
The hub
Materiality, all the tests
What material means in accounts, audit, UK SRS, the ESRS and GRI.