UK law
No UK instrument requires GRI.
SECR, CFD and UK SRS do not name it.The standards
Does it apply to you
Reporting under it
Start here
Dates and penalties
Doing it
What you must file
Doing it
Start here
Setting targets
Who and where
The UK duty
Doing it
The baseline
Europe
Reporting more widely
Carbon markets and trade
Packaging and net zero
Carbon accounting
Choosing
Carbon
Compliance and offsets
Software
Templates
Careers
GRI · voluntary in UK law
No UK law requires a company to report under the GRI Standards.
The requirements start when a company says it uses them: nine for a report “in accordance with” the GRI Standards, three for one “with reference to” them.
Groups with an EU subsidiary meet GRI through the ESRS, and listed companies meet a different test under UK SRS.
Status
No. GRI binds the company that claims it, and the law never names it.
GRI is a private standard-setter, and its Standards carry no UK legal hook.
The closest UK law comes is permission: UK SRS S1 lets a company consider GRI as a source of guidance (UK SRS S1, Appendix C).
What the Standards contain is explained on the GRI Standards.
The UK duties that are law are on ESG reporting requirements in the UK.
No UK instrument requires GRI.
SECR, CFD and UK SRS do not name it.“In accordance with” or “with reference to” the Standards.
GRI 1 sets the requirements for each.An EU subsidiary’s ESRS report, or a buyer’s questionnaire.
Each brings its own question.Two claims
Nine requirements for “in accordance with”, three for “with reference to”, and no certification for either.
| Requirement in GRI 1 | In accordance with | With reference to |
|---|---|---|
| Apply the eight reporting principles | Required | Recommended |
| Report all 30 disclosures in GRI 2 | Required | Only those chosen |
| Determine material topics (GRI 3) | Required | Recommended |
| Report GRI 3’s disclosures | Required | Recommended |
| Report Topic Standard disclosures for each material topic | Required | Only those chosen |
| Give a permitted reason for any omission | Required | — |
| Publish a GRI content index | Required: twelve items | Required: six items |
| Provide a statement of use | Required | Required |
| Notify GRI by email (free) | Required | Required |
“If the organization does not comply with all nine requirements, it cannot claim that it has prepared the reported information in accordance with the GRI Standards” (GRI 1 §3).
A report that says it is “in line with GRI” but has no content index and no statement of use meets neither claim.
One group
A UK aquaculture and food group claiming “in accordance with” takes on nine requirements and the GRI 13 Sector Standard.
It is an illustration, not a real company: unlisted, with an EU subsidiary in CSRD scope and a supermarket customer that uses a sustainability rating.
Its own claim does all the work; nothing in UK law adds a GRI duty.
Had it written “with reference to”, GRI 13 would be a recommendation and the content index would need six items, not twelve.
“In accordance with the GRI Standards”, so all nine GRI 1 requirements apply (GRI 1 §3).
Yes: its fish farms put it under GRI 13, so it reviews every GRI 13 topic and explains those it judges not material.
Reports published from 1 January 2027 use GRI 102 for climate and GRI 103 for energy (GRI).
Its ESRS report counts as “with reference to” GRI, not “in accordance” (EFRAG–GRI statement).
It is not listed, so UK SRS is voluntary for it, and no UK instrument requires GRI.
The content index
Twelve items for “in accordance with”, six for “with reference to”, and only four reasons to leave anything out.
Disclosures 2-1 to 2-5 and 3-1 and 3-2 admit no reason for omission at all (GRI 1, Requirements 2 and 4).
Where a policy or committee does not exist, saying so complies; it is not an omission.
The index can take any format, as long as it holds the required items.
The content index
The content index
The content index
The content index
Sector Standards
Four are in use, three more apply from 2029, and GRI aims at 40 sectors.
A Sector Standard binds only an “in accordance” reporter, and only if one exists for its sector (GRI 1, Requirements 3-b and 5-b).
Outside these sectors, material topics come from the GRI 3 process alone (GRI 3).
New labour Standards, GRI 104 to 107, were approved in June and July 2026, but their effective dates had not been set on 15 October 2026 (GSSB).
Your position
Pick the claim, the sector and where you sit: the requirements, the Sector Standard and the EU and UK notes follow.
The check reads GRI 1 and the Sector Program as published on 15 October 2026.
The claim decides almost everything, so settle that before planning the report.
GRI · do you need it, and how much?
Pick the claim first: it decides almost everything else.
Rules: GRI 1 Section 3 and Requirements 3-b and 5-b; GRI Sector Program; GRI–ESRS Interoperability Index V1; UK SRS S1 ¶C2; FCA PS26/19.
A provisional reading, not advice. Nothing you enter leaves your browser.
EU exposure
Its ESRS report counts as “with reference to” GRI, and the mapping between them has not caught up with the revised ESRS.
To claim “in accordance” as well, the group reports the GRI requirements the ESRS do not cover (GRI–ESRS index).
Do not cite the 2024 index’s ESRS paragraph numbers against the revised ESRS.
Whether the EU entity reports at all is on CSRD reporting requirements for UK companies.
GRI and the ESRS
GRI and the ESRS
GRI and the ESRS
GRI and the ESRS
UK SRS and ISSB
They answer different questions: GRI asks about impacts, UK SRS about what investors need.
For listed companies in UKLR 6, 14, 15, 16 and 22, UK SRS applies on comply or explain for periods from 1 January 2027 (FCA PS26/19).
GRI and the ISSB signed a memorandum in March 2022 to “seek to coordinate” (IFRS Foundation), and the one operative equivalence covers greenhouse gas emissions: IFRS S2 figures can meet GRI 102 from 2027 (GRI).
GRI itself says its Standards represent the impact side of double materiality (GRI).
The comparison in depth is on ISSB vs GRI, and GRI’s own test on GRI materiality.
Material topics are the organisation’s most significant impacts on the economy, environment and people.
GRI 1 §2.2 and GRI 3.Information that could reasonably be expected to influence the decisions of investors and lenders.
UK SRS S1 ¶¶17–18.Customers and tenders
No UK procurement rule we hold names GRI; ratings map to it, which is a different thing.
| Who asks | What they actually ask | Source |
|---|---|---|
| A UK public buyer | No UK procurement rule we hold names GRI | — |
| A rating such as EcoVadis | Its 21 criteria are mapped to ISO 26000, GRI and the SDGs; it does not ask for a GRI report | EcoVadis methodology 2026 |
| A CDP request | CDP’s own questionnaire, partly aligned with GRI 101, GRI 102, GRI 103 and GRI 303 | CDP reporting |
| A contract or customer code | Whatever the contract says; read the clause | — |
Answering a questionnaire with GRI disclosures does not make a GRI claim; the claim needs a content index and a statement of use.
Order of work
Decide the claim, then the sector, then build the index the claim needs.
Most of the effort is the GRI 3 process, because it decides which Topic Standards apply.
Software that holds the content index and the omission reasons is compared on GRI reporting software.
“In accordance with”, “with reference to”, or none.
GRI 11 to 14 now; 16 to 18 from 2029.
Context, impacts, significance, then a documented threshold.
Reports published from 1 January 2027.
Statement of use, locations, omissions, then an email.
GRI is optional in the UK, but the claim on the cover of a report is a promise, and GRI 1 says exactly what it costs.
Climate and energy in 2027, financial services in 2029, labour Standards with dates still to come.
None of the 2016 labour Standards had been withdrawn on 15 October 2026.
Date any reference to GRI 101, 102 or 103: before 2024 those numbers meant the Foundation, General Disclosures and Management Approach standards.
What is coming
What is coming
What is coming
What is coming
Advisers and software vendors; GRI itself certifies neither the report nor the adviser.
| Ask a provider | Why it matters |
|---|---|
| Which claim will the report make, and why? | It sets nine requirements or three (GRI 1 §3). |
| How will the GRI 3 threshold be set and documented? | GRI 3 Step 4 leaves the threshold to the organisation and asks it to document it. |
| Which Sector Standard applies, and in which version? | The V1.1 versions apply to climate and energy after 31 December 2026. |
| Is the work assured, by whom and to what standard? | GRI requires no assurance; a reader may still want it. |
This site names no adviser as its own and has no clients; how to choose one is on ESG reporting consultants.
Frequently asked
No. No UK instrument requires a company to report under the GRI Standards.
The duties that are law, such as SECR, climate-related financial disclosure and, for listed companies, UK SRS on comply or explain, do not name GRI.
GRI becomes binding only on a company that claims to use it.
They depend on the claim.
To report “in accordance with” the GRI Standards, an organisation must meet all nine requirements in GRI 1, including reporting all of GRI 2, determining material topics under GRI 3, publishing a content index and notifying GRI.
To report “with reference to” the Standards, it must meet three: publish a content index, provide a statement of use and notify GRI.
“In accordance with” is the full claim: nine requirements, the eight reporting principles and every applicable Sector Standard.
“With reference to” lets an organisation report selected disclosures, and its statement of use says it reported only the information cited in its content index.
No. GRI says it is not an auditor, assessor, certifier or verifier of sustainability reports.
Notifying GRI is an email to reportregistration@globalreporting.org and costs nothing.
No GRI requirement involves assurance.
For an “in accordance” claim, twelve items, including the statement of use, the applicable Sector Standards, the sector topics judged not material with the reason, every reported disclosure with its location, and any reasons for omission.
For “with reference to”, six items.
Only for one of four reasons: not applicable, legal prohibitions, confidentiality constraints, or information unavailable or incomplete, each explained.
Disclosures 2-1 to 2-5, 3-1 and 3-2 cannot be omitted at all.
Four are in use: GRI 11 for oil and gas, GRI 12 for coal, GRI 13 for agriculture, aquaculture and fishing, and GRI 14 for mining.
GRI 16, 17 and 18 for banking, capital markets and insurance were approved in September and October 2026 and apply to reports published from 1 January 2029.
Partly.
GRI and EFRAG say an organisation reporting under the ESRS is considered to report “with reference to” the GRI Standards, not “in accordance”.
The GRI–ESRS index is V1 of November 2024, mapped to the 2023 ESRS, and had not been updated for the revised ESRS on 15 October 2026.
No. GRI asks about an organisation’s most significant impacts on the economy, environment and people.
UK SRS and the ISSB standards ask what information could reasonably influence investors’ decisions.
UK SRS S1 lets a company consider GRI as a source of guidance without adopting GRI’s test.
No UK procurement rule we hold names GRI.
Ratings that buyers use, such as EcoVadis, say they map their criteria to GRI, which is not the same as asking for a GRI report.
Answer the question the buyer actually asked.
Sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
The nine requirements for “in accordance with”, the three for “with reference to”, the statements of use and Requirement 9, notifying GRI.
The twelve content-index items and the four permitted reasons for omission (Table 1).
The eight reporting principles an “in accordance” reporter must apply.
Thirty disclosures in five sections, effective for reports published from 1 January 2023.
The four steps to material topics; the significance of impacts as the sole criterion.
Universal Standards effective 1 January 2023; GRI 101 in effect from 2026, GRI 102 and 103 from 2027.
GRI 11 to 14 in use, the target of 40 sectors, and the V1.1 alignment.
Approved by the GSSB on 17 September 2026 and the Due Process Oversight Committee on 9 October 2026.
Effective for reports published on or after 1 January 2029.
The labour Standards GRI 106 and 107 approved with effective dates still to be determined.
The V1.1 Sector Standards and the GRI 102 and 103 files.
An ESRS reporter is considered to report “with reference to” the GRI Standards.
Non-authoritative, mapped to the 2023 ESRS.
GRI named as a source an undertaking may use for entity-specific disclosures.
No GRI–ESRS index for the revised ESRS listed as at 15 October 2026.
The two purposes, and that each board decides separately.
IFRS S2 Scope 1, 2 and 3 disclosures can meet the corresponding GRI 102 requirements.
The memorandum of understanding: the boards “will seek to coordinate”.
The financial materiality test, and GRI as a source of guidance an entity may consider.
C2 names the GRI Standards and the ESRS as sources of guidance.
Comply or explain for UKLR 6, 14, 15, 16 and 22, periods from 1 January 2027.
Its 21 criteria are mapped to ISO 26000, GRI and the SDGs.
GRI’s Standards represent the impact side of double materiality.
GRI is not an auditor, assessor, certifier or verifier of sustainability reports.
Continue reading
Universal, Topic and Sector Standards explained.
What a tool must hold to support a GRI claim.
The GRI 3 process, step by step.
Two materiality tests, one GHG equivalence.
GRI beside CDP, SASB and the ISSB standards.
The other request a UK company most often gets.
More on GRI: GRI Standards · GRI reporting software · GRI materiality