Key Takeaways for Sustainability Controllers & ESG Auditors
- Two Distinct Compliance Pathways: Under
GRI 1: Foundation 2021, organizations can no longer claim “Core” or “Comprehensive” status. They must choose between reporting “In accordance with the GRI Standards” (full accountability across all 9 requirements) or “With reference to the GRI Standards” (partial, entry-level disclosure). - Strict Omission Governance: Reporting “In accordance” permits omitting specific Topic or General disclosures only under four validated Reasons for Omission—and seven foundational disclosures (
GRI 2-1through2-5,GRI 3-1, andGRI 3-2) can never be omitted. - Mandatory Statement of Use Phrasing: Every report must publish a verbatim legal Statement of Use inside its GRI Content Index declaring which pathway and reporting dates apply.
- Assurance & Rating Agency Impact: Institutional investors, global supply-chain buyers, and third-party assurance providers operating under
ISAE 3000 (Revised)andISSA 5000strongly favor “In accordance” reports because they prevent cherry-picking of sustainability metrics.
When evaluating the Gri In Accordance Vs With Reference To framework, when evaluating the Gri In Accordance Vs With Reference To framework, when evaluating the Gri In Accordance Vs With Reference To framework, when evaluating the Gri In Accordance Vs With Reference To framework, one of the most consequential boardroom decisions when preparing an annual sustainability or integrated report is selecting the legal compliance claim under the GRI reporting standards. Prior to 2023, thousands of corporations defaulted to the legacy 2016 “GRI Core” option—a low-threshold tier that allowed companies to claim full GRI alignment while reporting just a single quantitative metric per material topic.
When the Global Sustainability Standards Board (GSSB) implemented the GRI Universal Standards 2021 architecture, it abolished the “Core” and “Comprehensive” labels entirely. In their place, GRI 1: Foundation 2021 established two sharply differentiated reporting pathways: reporting “In accordance with the GRI Standards” and reporting “With reference to the GRI Standards.”
Choosing the wrong claim—or claiming “In accordance” without satisfying all nine mandatory requirements of GRI 1—is one of the fastest ways to trigger a qualified audit opinion during external ESG assurance. In this technical guide, part of our Complete GRI Certification & Reporting Master Guide, we dissect both options, compare their legal requirements side-by-side, and provide the exact templates for Reasons for Omission and Statements of Use.
Table of Contents
1. GRI In Accordance vs With Reference To: Core Definition & Differences
Under the old 2016 framework, the “Core” option created a structural loophole. A chemical manufacturer or mining company could identify Effluents and Waste or Occupational Health and Safety as material topics, disclose a single favorable data point, ignore the remaining topic disclosures, and still badge its annual report as “In accordance with GRI Standards: Core Option.”
To eliminate selective disclosure and align with regulatory frameworks such as the European Union’s Corporate Sustainability Reporting Directive (CSRD) and SEBI’s BRSR Core mandate in India, GRI 1: Foundation 2021 restructured the system around a clear principle:
- “In accordance with the GRI Standards” is the comprehensive benchmark for organizations committed to presenting a complete, balanced picture of their most significant impacts on the economy, environment, and people, along with how those impacts are governed and managed.
- “With reference to the GRI Standards” is designed exclusively for first-time reporters, small and medium-sized enterprises (SMEs), or organizations publishing targeted thematic reports (e.g., a standalone climate or workforce diversity briefing) that draw on specific GRI disclosures without completing a full materiality and governance compliance cycle.
2. Side-by-Side Comparison: “In Accordance” vs. “With Reference To”
Section 3 of GRI 1: Foundation 2021 codifies the exact rules for both approaches. While an “In accordance” report must fulfill all 9 mandatory requirements, a “With reference to” report is only bound by 3 core requirements (Requirements 7, 8, and 9, with recommended application of Requirement 1).
| Compliance Requirement (GRI 1: Foundation 2021) | Reporting “In Accordance With” the GRI Standards | Reporting “With Reference To” the GRI Standards |
|---|---|---|
| Requirement 1: Apply the 8 Reporting Principles (Accuracy, Balance, Clarity, Comparability, Completeness, Sustainability Context, Timeliness, Verifiability) | Mandatory. All 8 principles must be demonstrably applied across data collection and presentation. | Recommended / Best Practice. Strongly encouraged to ensure information quality, though not strictly audited for completeness. |
| Requirement 2: Report GRI 2 General Disclosures (Disclosures GRI 2-1 through GRI 2-30) | Mandatory. All 30 disclosures must be reported (2-1 to 2-5 cannot be omitted; 2-6 to 2-30 allow valid omissions). | Optional. Organization selects only the specific GRI 2 disclosures it chooses to report. |
| Requirement 3: Determine Material Topics (Follow the 4-step impact materiality methodology) | Mandatory. Must identify and assess actual and potential negative/positive impacts across activities and business relationships. | Not Required. Organization may report on chosen topics without executing a formal GRI 3 materiality assessment. |
| Requirement 4: Report GRI 3 Material Topics Disclosures ( GRI 3-1, GRI 3-2, and GRI 3-3) | Mandatory. GRI 3-1 and 3-2 cannot be omitted. GRI 3-3 (Management of material topics) must be reported for every material topic. | Optional. However, for any Topic Standard reported, disclosing GRI 3-3 is strongly recommended. |
| Requirement 5: Report Disclosures from GRI Topic & Sector Standards | Mandatory. Must consult applicable Sector Standards (GRI 11–14+) and report all applicable Topic Standard disclosures for each material topic. | Optional / Selective. Organization reports only the individual Topic or Sector disclosures it selects. |
| Requirement 6: Provide Reasons for Omission | Mandatory. Any required disclosure or sub-requirement not reported must be justified using one of the 4 permitted Reasons for Omission. | Not Required for Unselected Standards. However, if a selected disclosure is only partially reported, the omitted sub-requirements must be noted in the Content Index. |
| Requirement 7: Publish a GRI Content Index | Mandatory. Must list all Universal, Sector, and material Topic disclosures, page/URL locations, and exact omission explanations. | Mandatory. Must list every specific GRI disclosure (and partial disclosure) that the organization has chosen to report, with page/URL links. |
| Requirement 8: Provide a Statement of Use | Mandatory. Must use the exact “In accordance” legal phrasing in the GRI Content Index. | Mandatory. Must use the exact “With reference to” legal phrasing in the GRI Content Index. |
| Requirement 9: Notify GRI | Mandatory. Submit notification via the official GRI online registration portal upon publication. | Mandatory. Submit notification via the official GRI online registration portal upon publication. |
3. The 4 Valid “Reasons for Omission” Under GRI 1 (Requirement 6)
In real-world corporate reporting, even mature enterprises occasionally encounter a disclosure requirement under GRI 2 or a Topic Standard (e.g., GRI 305-3 Scope 3 emissions or GRI 405-2 gender remuneration ratios across foreign subsidiaries) where complete data is not yet available or legally restricted.
Under the “In accordance” pathway, you do not lose compliance simply because a data point is missing—provided the disclosure is eligible for omission and you properly document one of the four valid Reasons for Omission inside your GRI Content Index.
First Rule: The 7 Non-Omissible Disclosures
Before applying any omission reason, ESG controllers must remember that seven foundational disclosures can NEVER be omitted when reporting “In accordance with the GRI Standards”:
GRI 2-1: Organizational detailsGRI 2-2: Entities included in the organization’s sustainability reportingGRI 2-3: Reporting period, frequency and contact pointGRI 2-4: Restatements of informationGRI 2-5: External assuranceGRI 3-1: Process to determine material topicsGRI 3-2: List of material topics
Second Rule: The 4 Permitted Reasons & Required Explanations
For all other disclosures (GRI 2-6 to GRI 2-30, GRI 3-3, and Topic Standard disclosures), if you cannot report a full disclosure or a specific sub-requirement (e.g., GRI 303-3-b), you must state the exact omitted requirement, select one of the four official reasons below, and provide the mandatory secondary explanation:
| Permitted Reason for Omission | When It Can Be Used | Mandatory Explanation Required in Content Index |
|---|---|---|
| 1. Not applicable | The specific phenomenon, activity, or structure covered by the disclosure does not exist within the organization’s operations or value chain. | Explain why the disclosure or requirement is not applicable to the organization (e.g., “The organization operates zero nuclear or hydropower assets”). |
| 2. Legal prohibitions | Disclosing the specific information would violate a national law, statutory regulation, or binding judicial order. | Cite the specific statute, regulation, or legal ruling that prohibits the disclosure in the relevant jurisdiction. |
| 3. Confidentiality constraints | The information is subject to specific commercial, contractual, or competitive confidentiality restrictions (e.g., proprietary chemical formulas or NDA-bound client contracts). | Describe the specific nature of the confidentiality constraint preventing public disclosure. |
| 4. Information unavailable / incomplete | Data collection systems do not yet cover the metric, or data from newly acquired subsidiaries/suppliers is incomplete or fails internal quality thresholds. | Specify which information is unavailable/incomplete, explain why it could not be obtained, and describe the concrete steps and timeline (e.g., “Target: FY 2027-28”) being taken to obtain the data. |
How Auditors Test Omissions During Assurance: One of the most common audit findings we encounter when reviewing draft corporate sustainability reports is the blanket use of “Confidentiality constraints” to hide unfavorable executive pay ratios (GRI 2-21) or workplace injury rates (GRI 403-9). External assurance practitioners trained under GRI Standards will immediately reject vague omission notes. Furthermore, if an organization omits a vast majority of disclosures for a material topic using “Information unavailable,” auditors will challenge whether the report violates the Completeness principle in GRI 1.
4. Mandatory Legal Phrasing: The Official “Statement of Use”
Under Requirement 8 of GRI 1: Foundation 2021, every reporting organization must include a verbatim Statement of Use inside its GRI Content Index. You may not paraphrase, alter, or blend the wording of these two statements:
Template A: For Organizations Reporting “In Accordance”
“[Name of organization] has reported in accordance with the GRI Standards for the period [reporting period start and end dates].”
Example: "Apex Manufacturing India Ltd. has reported in accordance with the GRI Standards for the period 1 April 2025 to 31 March 2026."
Template B: For Organizations Reporting “With Reference To”
“[Name of organization] has reported the information cited in this GRI content index for the period [reporting period start and end dates] with reference to the GRI Standards.”
Example: "Horizon Tech Solutions Pvt. Ltd. has reported the information cited in this GRI content index for the period 1 April 2025 to 31 March 2026 with reference to the GRI Standards."
Master GRI Compliance, Omission Rules & Assurance Audits
Learn how to structure audit-ready GRI “In Accordance” reports, conduct GRI 3 materiality assessments, and align disclosures with SEBI BRSR Core in MCMCER’s live executive cohort.
5. Why Investors and Assurance Providers Demand “In Accordance” Reports
When advising CFOs and Company Secretaries on whether to adopt the “With reference to” pathway or commit to full “In accordance” reporting, three strategic capital-market factors must be weighed:
- Third-Party Assurance Defensibility (
ISAE 3000&ISSA 5000): When an independent assurance provider (such as a Big 4 accounting firm or accredited verification body) is engaged to provide limited or reasonable assurance over a sustainability report, they evaluate the report against “Suitable Criteria.” Because “With reference to” allows an organization to omitGRI 3materiality and cherry-pick indicators without justification, assurance providers can only verify the isolated numbers presented—they cannot assure that the report represents a complete and balanced account of the company’s material impacts. - Global ESG Rating Agency Scoring (MSCI, Sustainalytics, S&P Global CSA, CRISIL): Institutional ESG rating methodologies penalize selective disclosure. Governance disclosures in
GRI 2-9throughGRI 2-28(mandatory under “In accordance”) directly feed the corporate governance and business ethics pillars of S&P DJSI and MSCI ESG ratings. - Seamless Interoperability with SEBI BRSR & EU CSRD: For Indian listed companies subject to SEBI’s Business Responsibility and Sustainability Reporting (BRSR) mandate—or exporters supplying European clients under the EU CSRD—over 80% of the data required for a full “In accordance” GRI report is already collected for statutory compliance. Stopping at “With reference to” leaves significant institutional credibility on the table.
6. Decision Checklist: Which Pathway Should Your Organization Choose?
Use this executive decision framework to determine the right reporting claim for your upcoming cycle:
- Choose “With Reference To” ONLY IF: You are an SME or private enterprise publishing your very first inaugural sustainability report, you have not yet completed a formal
GRI 3impact materiality assessment, and you want a 1-year transitional runway to build internal data controls before committing to full compliance. - Choose “In Accordance” IF: You are a listed company (e.g., NSE Top 1,000), a multinational subsidiary, a Tier-1 export supplier, or an organization seeking third-party ESG assurance, green financing, or institutional investor credibility. Remember: if a few specific metrics are still in development, you can legitimately use the “Information unavailable/incomplete” reason for omission while maintaining full “In accordance” status.
To explore how to format your disclosures and omission statements into an audit-proof index, read our next technical walkthrough or review our Master Guide to GRI Certification and GRI Certified Training Program.
Frequently Asked Questions: “In Accordance” vs. “With Reference To”
Reporting “In accordance with the GRI Standards” requires an organization to fulfill all 9 requirements in GRI 1, including reporting all 30 disclosures in GRI 2, conducting a formal impact materiality assessment under GRI 3, consulting applicable Sector Standards, and reporting all disclosures for each material topic (or providing permitted reasons for omission). Reporting “With reference to the GRI Standards” allows an organization to report selected GRI disclosures without completing full materiality or governance compliance, requiring only a GRI Content Index, a Statement of Use, and GRI notification.
The four valid reasons for omission permitted under Requirement 6 of GRI 1: Foundation 2021 are: (1) Not applicable, (2) Legal prohibitions, (3) Confidentiality constraints, and (4) Information unavailable/incomplete. Each omission must be logged in the GRI Content Index along with the mandatory required explanation.
Yes. Provided the missing metric is not one of the 7 non-omissible disclosures (GRI 2-1 to 2-5, GRI 3-1, and GRI 3-2), the organization can still report “In accordance with the GRI Standards” by citing “Information unavailable/incomplete” in its GRI Content Index, specifying which data is missing, explaining why, and outlining the concrete steps and timeline to collect it in future cycles.
Under Requirement 8 of GRI 1, the official Statement of Use—along with the title of the applicable GRI Universal Standard (“GRI 1: Foundation 2021”) and titles of any applicable Sector Standards—must be placed directly within the organization’s GRI Content Index.
Notifying GRI under Requirement 9 is a mandatory administrative registration step and does not constitute third-party verification of report quality. To obtain independent assurance, organizations engage external auditors (under ISAE 3000 or ISSA 5000) and train internal sustainability leads through the MCMCER GRI Certification Program.
Official Reference: GRI 1: Foundation 2021 (Global Reporting Initiative).
