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GRI 201: Economic Performance · 2016

Disclosure GRI 201-3

Defined benefit plan obligations and other retirement plans

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official GRI source.

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Reviewed by Dr Ross Kurinko · GRI Certified Trainer LRA educational guidance · Not issued or endorsed by GRI

To prepare this disclosure

9datapoints↓ 6claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to explain its retirement plan obligations in a way that shows the real financial commitment behind them. In practice, that means describing the main defined benefit and other retirement arrangements it supports, and setting out the obligations, assets and any funding position that are relevant to understanding the scale of those commitments at the reporting date.

The practical focus is on completeness and consistency across the organisation, not just on a single flagship plan or one location. Report the arrangements that matter to the business as a whole, and make clear whether the figures cover all operations, only certain countries or entities, or only specific plans, so readers can see how broad the coverage is and how representative the numbers are.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

First, have you decided which retirement arrangements sit in scope here — the employer-backed pension promise, any separate pot set aside for it, and any other retirement arrangements you plan to mention? For the funding position, have you fixed the basis used to estimate how much of the pension promise is covered, and can you say when that estimate was made? If the pension promise is not fully covered by the set-aside assets, have you agreed the recovery approach and the timeframe you will describe? Can you trace each figure back to a source you can evidence — for example, the liability estimate, the employee and employer contribution rates, and the participation level? Have you checked which definitions and measurement basis your team will use so the numbers are comparable and read the same way across the disclosure?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Liability value if unfunded Capture the estimated amount that would need to be met from the organisation’s own resources if the plan’s obligations were not covered by a separate fund. Actuarial valuation, pension trustee report, finance note, or scheme funding papers showing the estimate and the date used. Finance / Pensions

Separate pension fund exists Confirm whether the plan has its own ring-fenced fund used to meet pension obligations, rather than relying only on the employer’s general resources. Scheme rules, trust deed, pension plan documentation, or trustee confirmation. Pensions / Legal

Funding coverage estimate Capture the estimated share of the plan’s obligations that is covered by the assets set aside for them. Actuarial funding statement, trustee valuation, or funding report showing the coverage estimate. Finance / Pensions

Coverage estimate basis Record the method, assumptions, and source data used to produce the coverage estimate. Actuarial methodology note, valuation assumptions paper, or trustee report explaining how the estimate was derived. Pensions / Actuarial

Coverage estimate date Capture the date on which the funding coverage estimate was prepared. Valuation report date, trustee paper date, or actuarial certificate date. Pensions / Actuarial

Recovery plan and timing If the fund is not fully covered, capture the employer’s explanation of the approach being used to move toward full coverage and the expected timeframe for reaching it. Recovery plan, employer funding statement, trustee agreement, or board-approved pension strategy paper. Finance / Pensions

Employee contribution rate Capture the employee’s contribution rate as a percentage of salary for the plan being reported. Payroll rules, benefits schedule, or plan terms showing the employee rate. Payroll / Benefits

Employer contribution rate Capture the employer’s contribution rate as a percentage of salary for the plan being reported. Finance contribution schedule, pension agreement, or payroll/benefits configuration showing the employer rate. Finance / Payroll

Retirement plan participation Describe how many eligible people take part in retirement plans, and the level or pattern of participation across the workforce. Benefits enrolment report, HRIS participation extract, or pension provider summary by eligible population. HR / Benefits

＋ Show GRI 201-3 sub-elements (LRA working checklist)

How to prepare it

1Map the retirement arrangements in scope and decide which ones you will report on, so you can separate plans backed from the organisation’s own resources from those supported by a dedicated pot of assets.

2Set the reporting boundary and define the figures and narrative you will treat as reportable: the estimated liability amount, whether a separate funding vehicle exists, the share of liabilities covered by set-aside assets, the method used to make that estimate, the date it was calculated, any recovery plan if coverage is incomplete, the employee and employer contribution rates, and the level of participation.

3Gather the source records that support each item, such as actuarial or trustee papers, funding statements, payroll records, scheme documents, and internal approvals, so every reported point can be traced back to evidence.

4Prepare the disclosure content in the required form: use a clear text explanation for the liability estimate and funding position, provide the two contribution percentages, and describe participation in retirement arrangements in a way that is consistent with the underlying records.

5Record any exclusions, assumptions, estimation basis, calculation date, or changes in method or scope, and explain them plainly so readers can understand how the numbers and narrative were produced.

6Check the draft against the official source and the underlying evidence to confirm nothing required is missing, the wording matches the facts, and the reported amounts, dates, and percentages are internally consistent.

Request the data

Request the pension plan evidence pack

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

What do we need to report about our retirement arrangements, funding position, and employee/employer contribution rates for the reporting period?

Use your organisation’s own names for the pension scheme, retirement arrangement, funding vehicle, and employee groups first; then map those terms to the reporting fields. Keep the ask in the language the finance or pensions team already uses, rather than framework wording.

Weak request

Please provide the GRI 201-3 data for the pension disclosure, including the defined benefit obligation, funding status, contribution rates, and participation information.

Why it fails: This uses framework language that may not match how the business stores the information, and it does not tell the owner which internal reports, dates, entities, or source files to pull. It is also too broad to return a clean evidence pack.

Better request

Please send the latest finance or trustee pack for [plan name(s)] covering [reporting period] and [entity/boundary], including the liability estimate, whether a separate fund exists, the latest coverage view with method and date, any recovery plan and timeframe if the fund is not fully covered, employee and employer contribution rates, and participation levels. Attach the source documents and note the assumptions used.

Formal email template

Subject: Request for pension and retirement plan data for [reporting period]

Hi [name/team],

We are preparing the sustainability reporting pack and need the latest information on our pension and retirement arrangements for [reporting period]. Please send the figures and supporting documents for [plan name(s)] covering [entity/boundary].

Please include:
- the estimated liability amount if the obligation were met from the organisation’s general resources;
- whether there is a separate fund or similar vehicle set aside for the pension obligation;
- the latest view of how far the set-aside assets cover the obligation, including the method used and the date of the estimate;
- any plan or recovery approach in place if the fund is not fully covered, including the expected timeframe;
- employee and employer contribution rates as a share of salary;
- the current level of participation in the retirement arrangements.

Please attach the source documents and note any assumptions, definitions, or exclusions used. If any figures are not available, please explain why and identify the closest internal source.

Please adapt this to your organisation’s own terminology and check the official source before sign-off.

Thanks,
[preparer name]

Short Teams / Slack version

Hi [name] — could you share the latest pension / retirement plan pack for [reporting period] for [plan name(s)]? We need the liability estimate, whether there’s a separate fund, the latest coverage view and method/date, any recovery plan if it’s not fully covered, employee/employer contribution rates, and participation levels. Please include the source docs and any assumptions. Please use your team’s usual terms and we’ll map them for reporting. Thanks.

Industry examples

Manufacturing

Context. A UK manufacturer with a legacy final-salary scheme and a newer workplace pension for current staff.

Adapted request. Please share the latest scheme valuation pack for the legacy pension arrangement and the current workplace pension summary for [reporting period]. We need the liability estimate, whether the legacy scheme has a separate funding vehicle, the latest coverage view and date, any recovery plan and timetable, the employee and employer contribution rates for the workplace plan, and participation levels across eligible staff.

Example response. Legacy scheme liability estimate: GBP 42.8m; separate fund exists: Yes; coverage estimate: 86%; basis: trustee funding valuation; estimate date: 30 September 2025; recovery plan: additional employer cash payments over 6 years; employee contribution rate: 5%; employer contribution rate: 7%; participation: 91% of eligible employees enrolled.

Professional services

Context. A services firm with only a defined contribution workplace pension and no legacy defined benefit arrangement.

Adapted request. Please confirm whether any legacy pension obligation exists for [reporting period]. If not, provide the workplace pension summary showing employee and employer contribution rates and the level of participation among eligible colleagues, together with the source payroll or benefits report.

Example response. Legacy pension obligation: None identified; separate fund: Not applicable; employee contribution rate: 4%; employer contribution rate: 6%; participation: 97% of eligible employees enrolled; source: benefits administration report dated 31 December 2025.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

State how the funding coverage figure was calculated, including the basis used for the estimate and the date it was prepared, so readers can understand what the numbers are built on.

Context note

Explain what the figures mean in practice by linking the liability estimate, any dedicated fund, the level of asset cover, contribution rates and participation levels to the plan’s overall funding position.

Fluctuation statement

If the coverage position, contribution rates or participation levels have changed, briefly explain the main drivers and whether any recovery actions or revised timing assumptions were put in place.

Content index entry

GRI 201-3 Defined benefit plan obligations and other retirement plans — [location / page] / [notes]

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Preparation tools & forms

Professional preparation tools for GRI 201-3 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

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01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check

I used the latest actuarial or scheme figures available at the reporting date to estimate the amount that would be needed if the obligation were met from the organisation’s own resources.Assurer checks whether the amount is based on current, supportable inputs rather than an outdated or selectively chosen estimate, and whether the reporter has blurred a liability estimate with a funding position.Actuarial report or scheme valuation, calculation workbook, date of the estimate, assumptions used, sign-off from finance or pensions lead, and any reconciliation to the reported figure.

I stated clearly whether the arrangement has a ring-fenced pot or other dedicated assets set aside for the obligation.Assurer probes whether the reporter has correctly identified the existence of a separate funding arrangement and has not overstated segregation where assets are only notionally earmarked.Trust deed, plan rules, funding agreement, trustee or administrator confirmation, and internal note explaining how the arrangement was classified for reporting.

I reported the coverage level by comparing the obligation estimate with the assets earmarked for it, using the same measurement basis for both sides of the comparison.Assurer checks whether the coverage percentage is mathematically correct, whether the asset and liability measures are comparable, and whether any exclusions or adjustments are explained.Coverage calculation, source data for assets and obligation estimate, methodology note, reconciliation to underlying records, and review evidence showing the arithmetic was checked before publication.

I explained the method used to derive the coverage estimate, including the main assumptions, valuation approach, and any judgement calls that affect the result.Assurer probes whether the basis is transparent enough to understand how the figure was produced and whether the method is consistent with the underlying records and assumptions.Valuation methodology paper, actuarial assumptions, model or spreadsheet logic, management review notes, and evidence of consistency with prior periods or approved policy where relevant.

I identified the date on which the coverage assessment was prepared, so readers can see how current the information is.Assurer checks whether the timing is accurate and whether the disclosed date matches the source valuation or calculation date used in the report.Valuation date, calculation timestamp, draft and final report versions, approval trail, and any note explaining if the estimate was prepared before the reporting period end.

Where the dedicated pot was not fully sufficient, I described the plan to move towards full funding and the expected timeframe for doing so.Assurer probes whether the narrative is specific, internally consistent, and supported by an actual recovery or funding plan rather than a vague aspiration.Recovery plan, trustee or employer funding agreement, board papers, timetable, contribution schedule, and correspondence showing the plan and timescale were agreed.

Evidence pack to prepare

The governing policy or written commitment behind this disclosureA methodology / definition note setting out how the disclosure was scoped and preparedSource-system exports the figures or facts were drawn fromThe internal approval / sign-off record for the disclosure before publicationMinutes or records evidencing the relevant engagement or consultation

Common reporting gaps

A percentage is stated without the underlying counts (numerator and denominator).The denominator — what the figure is a share of — is not explained.Partial scope is reported as if it were complete coverage.One-off activities are counted as if they were ongoing programmes.Boundary or period changes that move the figure are not flagged.Exclusions from the reported scope are not listed or explained.

Common gaps

Mistakes to avoid when collecting the data

Wrong owner, wrong desk

The request goes to payroll or finance in framework language, so the team that actually holds pension files, trustee updates, or scheme notes is never asked.

Scope left vague

The collector does not pin down which plans, employee groups, or locations are in scope, so separate arrangements get blended into one file.

No boundary check

Data is pulled without confirming whether the plan sits on the organisation’s own books or is backed by assets set aside for it, which changes what needs to be captured.

Mixed measurement basis

One source gives a year-end balance while another uses an actuarial or management estimate, and the two are merged as if they were the same basis.

Timing not fixed

The team records figures from different dates, so the liability estimate, funding position, and contribution rates do not line up to the same reporting cut-off.

Source labels stripped out

When figures are copied into a tracker, the original file names, table headings, and note references are lost, making it hard to trace each number back to its source.

Separate populations merged

Employee and employer contribution rates, or different retirement arrangements, are combined into one total even though they should stay distinct.

Evidence trail missing

The pack contains numbers but no supporting note, calculation basis, or reviewer sign-off, so nobody can show how the data was checked before drafting.

Coverage status not tested

The collector records whether a fund exists but forgets to capture how far the assets go toward meeting the liabilities, so the funding picture is incomplete.

Action plan not captured

Where the fund is short, the team omits the employer’s plan and target timing for moving toward full coverage, leaving the follow-up story blank.

Where judgement is often needed

Set the reporting boundary after a deal closes

If a pension arrangement comes in or leaves through an acquisition, disposal or similar change, explain whether you have included it for the full year, from the change date, or excluded it, and keep the approach consistent with the rest of the report.

Translate local pension labels into one group view

Where countries use different pension labels or legal setups, decide which schemes sit in scope for this disclosure and describe the mapping you used so readers can see how local plans were grouped.

Decide how to treat people near the edge of the scheme

For workers whose status is unclear, such as recent joiners, leavers, secondees or part-time staff, state the rule used to include or exclude them and note any material population left out.

Choose the measurement date for the funding view

If the funding position is taken from a point in time other than the reporting date, say when the estimate was made and explain why that date was used.

Explain whether the funding figure is modelled or directly observed

If the liability or cover level is based on an estimate rather than a full measurement, say what method or source underpins it and make clear that it is an estimate.

State the basis used for the cover percentage

When showing how far the set-aside assets go toward meeting the obligations, explain the calculation basis, including whether you used gross or net amounts, and keep the same basis across periods unless you explain a change.

Describe any rounding used in contribution rates

If employee or employer contribution rates are rounded, say the rounding convention and make sure the published percentages still reflect the underlying payroll basis.

Aggregate sensitive plan data before publication

If scheme-level detail could identify individuals or small groups, combine the figures to a level that protects privacy and say that the published view has been grouped for confidentiality.

Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Utilities

We report a synthetic pension snapshot for illustration only. Our scheme has a separate fund, and at the date shown the assets set aside were estimated to cover 82% of the liabilities; the estimate was based on an actuarial valuation completed in March 2026. The plan liabilities were estimated at £500 million, with £410 million held in the fund and £90 million expected to be met from our general resources; employees contribute 5% of salary, we contribute 10%, and 1,200 of our 1,500 eligible staff take part. Because the fund is not yet fully covered, we are working to close the gap through higher employer payments and investment returns, with full coverage targeted by 2031.

Synthetic illustration only. Shows how to combine funding status, valuation basis and date, contribution rates, participation, and the recovery approach in one concise disclosure.

Illustrative pension plan funding and participation snapshot (£m / people)

Plan liabilities (£m)41090

Assets set aside (£m)4100

Eligible staff (people)1200300

Participants (people)12000

Illustrative (synthetic) example — Food manufacturing

This is a synthetic example for training purposes. We have a separate retirement fund, and our latest estimate, made in September 2025 using the trustee valuation, put coverage at 67%: liabilities were £300 million, assets held for the plan were £201 million, and £99 million would fall to our general resources if needed. Staff pay 4% of salary, we pay 8%, and 540 of 600 eligible colleagues are enrolled; to move towards full cover, we plan to raise employer contributions and review the investment mix, aiming for full funding by 2030.

Synthetic illustration only. Demonstrates a second plausible reporting pattern with different figures, while keeping the same required content and internal arithmetic consistent.

Illustrative pension plan funding and participation snapshot (£m / people)

Plan liabilities (£m)20199

Assets set aside (£m)2010

Eligible staff (people)54060

Participants (people)5400

Company reports

How companies report GRI 201-3

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

Aditya Birla Fashion and Retail Limited

Retailing · India · 2025

Open report →

Aditya Birla Fashion and Retail Limited’s Integrated Annual Report 2024-25 provides reported values related to interest income on plan assets and actuarial gains or losses recognised in OCI, with figures noted on pages 222 and 294. The report also includes information on the estimated useful lives of assets, reflecting a fair approximation of their usage period, as detailed on page 195. However, several narrative items and percentage values relevant to the disclosure are not found or remain unclear in the report.

Zydus Wellness Limited

Food Production — Agricultural · India · 2025

Open report →

Zydus Wellness Limited’s Integrated Annual Report 2024-25 provides some coverage of financial data related to foreign currency transactions on page 224 and details about insurance plan assets as a percentage of total plan assets on page 246. Additionally, there is evidence of examination of company records on page 78. However, several narrative items, including parts (b-ii), (b-iii), (c), and (e), as well as specific percentage values, are not found or unclear in the report.

China Airlines, Ltd.

Air Transportation — Airlines · Taiwan · 2024

Open report →

China Airlines' Sustainability Report 2024 provides detailed coverage of water resource management, including interactions with water as a shared resource, water withdrawal, discharge, and consumption, as outlined on page 36. The report also includes financial data related to employee benefits and pension reserves on page 130, and asset values on page 171. Additionally, it reports a 100% risk assessment ratio for tier-1 suppliers on page 72 and work-related fatality rates on page 182. However, the report lacks information on certain narrative items such as item (b-iii) and item (e), and no percentage values were found for some disclosures.

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Check your understanding

Scenarios to work through

A preparer is drafting the pensions note for a group with one closed final-salary arrangement. The scheme is not fully funded, and the latest trustee valuation was completed nine months ago.

QWhat should be checked before the note is signed off about the funding position and the date used for that estimate?

Reveal model answer →

A preparer has a figure for the amount the company would need to pay if it had to meet the retirement promises from its own general resources. The number came from finance, but no supporting note has been attached.

QWhat needs to be confirmed before using that amount in the disclosure?

Reveal model answer →

An employer contributes 6% of salary to a retirement arrangement, while employees contribute 4%. The plan is open to most staff, but the HR team has not described how many people actually take part.

QWhat else should the preparer include about the arrangement beyond the contribution rates?

Reveal model answer →

A company has a pension fund that is only partly covered by assets. Management wants to say simply that it is “working on it” and leave out the timeline because the target date is still being discussed.

QHow should the preparer handle the recovery narrative?

Reveal model answer →

Framework references