Understanding the Interplay of GRI Standards and ESRS

In the dynamic world of sustainability reporting, the Global Reporting Initiative (GRI) Standards remain the widely recognised global framework — used by thousands of organisations worldwide. With the European Sustainability Reporting Standards (ESRS), companies operating in the EU have found themselves at the intersection of GRI and ESRS.

In November 2023, GRI and EFRAG signed a cooperation agreement to harmonise sustainability reporting standards. In November 2024, that joint work produced the GRI-ESRS Interoperability Index and the GRI-ESRS Standards Data Point Mapping, which compare the two frameworks DR-by-DR.

Two years on, the policy context has changed. Directive (EU) 2026/470 (Omnibus I, in force 18 March 2026) directs the European Commission, when revising the ESRS, to take account "to the greatest extent possible" of interoperability with global sustainability reporting standards (recital 18(vi)). That is a policy direction to the Commission for the upcoming revised delegated act — not, in itself, a recognition that a GRI report counts as an ESRS report. The November 2025 EFRAG draft of ESRS 1 (AR 5) goes one step further by permitting undertakings to "use" GRI Standards as one source for entity-specific disclosures — i.e. the gap-filling disclosures added when an ESRS Disclosure Requirement does not cover a material topic with sufficient granularity. Together, these strengthen — but do not establish — the GRI-ESRS bridge.

Omnibus I also reshapes who is in mandatory ESRS scope. From FY 2027 onwards, only undertakings exceeding EUR 450 million in net turnover AND more than 1,000 employees are in mandatory scope. Wave 2 and Wave 3 categories are deleted. For most former CSRD-bound companies, this means GRI is back to being the primary reporting framework rather than "preparation for ESRS."

GRI Standards: A Solid Foundation

GRI provides guidelines and standards for companies worldwide to report sustainability-related information in a standardised and transparent manner.

The GRI standards consist of reporting guidelines and indicators for environmental, social and governance (ESG) performance and impacts.

It helps organizations identify

• (1) material issues relevant to their operations and stakeholder concerns,
• (2) set targets and objectives, and
• (3) measure progress over time.

Companies worldwide have embraced GRI as a global gold standard, incorporating its approach into their reporting practices. GRI Standards consider the multifaceted aspects of sustainability and offer a framework that resonates globally — including for the many companies that, under Omnibus I, are now out of mandatory ESRS scope.

What Omnibus I Means for GRI-ESRS Interoperability

The relationship between GRI and ESRS shifted in early 2026 — though not as dramatically as headlines sometimes suggest. Three threads matter for the practical picture:

1) Recital 18(vi) — a mandate on the Commission for the revision

Directive (EU) 2026/470 instructs the Commission, within six months of entry into force, to adopt a delegated act revising the ESRS — and item (vi) of recital 18 says the revision must take account, "to the greatest extent possible," of interoperability with global sustainability reporting standards. Two things are worth being precise about: (a) this is a mandate on the Commission for the upcoming revision, not an obligation on undertakings today; and (b) the recital uses generic language ("global sustainability reporting standards") rather than naming GRI specifically — although in practice GRI is the most widely adopted global standard the Commission has to align with. The exact operative wording will land in the revised delegated act, expected H2 2026.

2) ESRS 1 AR 5 — GRI as a permitted source for entity-specific disclosures

The November 2025 EFRAG draft of ESRS 1 (Application Requirement 5) says undertakings "may use" available best practices, frameworks or reporting standards — including GRI Standards (topic and sector standards) and IFRS industry-based guidance — for entity-specific disclosures. These are the disclosures undertakings add when an ESRS Disclosure Requirement does not cover a material topic with sufficient granularity. AR 5 is permissive, not mandatory, and scoped to entity-specific disclosures — it doesn't make a full GRI report equivalent to an ESRS report. What it does is give Wave 1 reporters an explicit textual hook to reuse GRI work inside their ESRS sustainability statements where ESRS leaves gaps.

3) Scope contraction — GRI is back to being primary for many companies

This is the practical change with the biggest reach. Many companies that were preparing for CSRD under the original 2023 regime — listed SMEs, mid-sized non-PIE companies, third-country undertakings under the old EUR 150M threshold — are no longer in mandatory ESRS scope under Omnibus I. For these companies, GRI is once again the primary reporting framework, not "preparation for ESRS."

In short: the GRI-ESRS bridge is stronger than it was in 2024 — explicit textual hooks now exist in the EFRAG draft, and the Commission has a forward-looking obligation to keep building it. But "interoperable" still doesn't mean "identical." Differences in materiality, format and scope remain (see the next section).

Mapping GRI and ESRS Reporting Requirements

Addressing the practical concerns of sustainability professionals, GRI and EFRAG provide detailed technical guidance on mapping GRI Standards to ESRS requirements.

On 22 November 2024 — one year after the cooperation agreement — the GRI-ESRS Interoperability Index was published. It is a mapping tool that maps the ESRS Standards to the appropriate GRI Standards to provide clarity for reporting organisations. GRI and EFRAG have also published a GRI-ESRS Standards Data Point Mapping that maps the GRI Standards to the respective ESRS Standards.

Both tools set aim to:

• illustrate the interrelation between disclosure requirements and data points in each set of standards
• empower you to incorporate GRI standards as a reference in your ESRS reporting
• assist you in utilizing your ongoing reporting endeavors to craft your ESRS sustainability report
• establish robust groundwork for a mutual digital taxonomy

The mapping highlights the substantial commonality that has been already established between the two standards. Their interoperability eliminates the necessity for dual reporting, creating a user-friendly reporting system without unnecessary complexity. 

Entities reporting under ESRS can be considered as reporting "with reference" to the GRI standards, allowing you to use ongoing GRI reporting efforts for crafting your ESRS sustainability report.

Note: The GRI-ESRS Standards Data Point Mapping was originally published as a "Prefinal Draft" awaiting EFRAG SRB approval. Editors should check globalreporting.org for the current approved version before publishing.

ESRS vs. GRI: Novelties and Differences

The ESRS have been legally binding for Wave 1 companies for financial years 2024, 2025 and 2026 — a milestone for data availability and comparability in the EU. The GRI Standards remain a voluntary global framework. From FY 2027, only a much smaller population of large undertakings is in mandatory ESRS scope; for everyone else, GRI is again the primary framework.

While EFRAG aligns with the GRI Standards wherever possible, differences between the two frameworks exist. These can relate to granularity and data type, scope of application or definitions. The explicit differences (and similarities) are visible in the published GRI-ESRS Interoperability Index and the GRI-ESRS Standards Data Point Mapping.

Some examples of differences:

ESRS 1 General Requirements vs. GRI 1 Foundation

• ESRS sustainability reporting is somewhat more prescriptive than GRI regarding the format of disclosures — though this gap has narrowed under Omnibus I, which mandates removing least-important datapoints and tightening the materiality filter.
• ESRS requires a double materiality assessment, including both impact and financial perspectives. GRI focuses on impact materiality.
• ESRS requires materiality at the topic level. ESRS 1 AR 14 in the November 2025 EFRAG draft confirms that undertakings need not analyse every characteristic of severity or every time horizon, and AR 12 confirms qualitative analysis can be sufficient. The earlier framing that ESRS requires materiality at "sub-sub-topic" granularity is no longer accurate.

ESRS E1 Climate Change vs. GRI 302 Energy

The differences between ESRS E1-5 and GRI 302-1 — both dealing with energy consumption data — lie mainly in how energy consumption data is aggregated and disaggregated. (Worth verifying against current ESRS Set 1 wording post-Omnibus simplification.)

ESRS E1 Climate Change vs. GRI 305 Emissions

ESRS E1-6 requires the intensity ratio for total GHG emissions (Scopes 1, 2 and 3). GRI 305-4 requires the intensity ratio for Scope 1 and Scope 2 GHG emissions separately from Scope 3. (Worth verifying against current ESRS Set 1 wording post-Omnibus simplification.)

ESRS S1 Own Workforce vs. GRI 403 Occupational Health and Safety

GRI 403-1a requires reporting on the legal requirements and management system standards on which the system relies; ESRS does not require this, as the regulatory context is taken as given for EU reporters.

ESRS S3 Affected Communities vs. GRI 411 Rights of Indigenous Peoples

GRI 411-1 requires quantitative data on the number of incidents. ESRS S3 requires narrative disclosures.

ESRS G1 Business Conduct vs. GRI 414 Supplier Social Assessment

GRI 414-1 requires quantitative data on new supplier screening based on social criteria; ESRS G1-2 requires a disclosure in narrative format.

Navigating Materiality Across Standards

Material topics, as defined by GRI, transcend the conventional financial materiality applied to businesses. GRI focuses on impact materiality — material topics are those representing the organisation's most significant impacts on the environment and people, including their human rights. This impact perspective views materiality as the organisation's outward effects on the socioeconomic systems it engages with.

GRI Sector Standards, when available, serve as a valuable reference for material topics pertinent to specific sectors. Each organisation, guided by its unique context, refines its material topics through iterative collaboration with relevant stakeholders.

Impact materiality according to ESRS distinguishes between negative and positive impacts. Aligning with GRI guidance, it describes actual and potential negative impacts, emphasising severity determined by scale, scope and irremediable character. In November 2024, EFRAG adopted the GRI definition of impact materiality.

In addition, the ESRS involve the financial perspective of materiality, applying the IFRS Sustainability Disclosure Standards lens that is tailored to the needs of investors and capital markets. This encompasses the assessment of how the financial effects of sustainability topics shape your organisation.

Both perspectives combined — impact and financial materiality — are referred to as double materiality in the context of CSRD.

The November 2025 EFRAG draft makes the materiality filter explicit in ESRS 1 §24: "the undertaking is not required to disclose information prescribed by an ESRS Disclosure Requirement if that information is not material." And §27 permits a top-down materiality approach — anchoring materiality in strategy and business model rather than starting from a bottom-up review of every IRO.

The ESRS also introduced a due diligence process informing the materiality assessment of impacts, risks and opportunities. It references two international instruments: the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. This due diligence process adds a layer of robustness to the materiality assessment within the ESRS framework, aligning with globally recognised principles and guidelines.

Harmonisation of the XBRL Taxonomy for ESRS and GRI

The XBRL taxonomy is a standardised digital format developed to record, transmit and analyse reporting data in a structured manner. It helps companies make sustainability and financial reports more transparent and efficient, significantly increasing comparability and usability for stakeholders.

To advance digital sustainability reporting, GRI and EFRAG have been working on a standardised XBRL taxonomy. This harmonisation will facilitate the transition from traditional reporting formats to digital platforms, improving the accuracy and accessibility of data for all stakeholders.

Important context as of May 2026: Directive (EU) 2026/470 amends CSRD Article 29d to suspend mandatory XBRL tagging of sustainability reports until the European Single Electronic Format (ESEF) rules are updated. The harmonisation work between GRI and EFRAG continues, but mandatory tagging is on hold. See our companion article on the ESRS XBRL Taxonomy for the full picture.

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