Disclosure focus
Disclosure 2-2 requires an organisation to list all entities included in its sustainability reporting. Sites and business units can support data collection, but they do not replace the entity list required by 2-2-a.
If the organisation has audited consolidated financial statements or financial information filed on public record, it must specify any differences between the entities included in that financial reporting and those included in sustainability reporting. Specifying the differences is required; explaining why the lists differ is useful additional LRA guidance.
If the organisation consists of multiple entities, it must explain how the information is consolidated: whether adjustments are made for minority interests, how mergers, acquisitions and disposals of entities or parts of entities are taken into account, and whether and how the approach differs across the disclosures in GRI 2 and across material topics. In the GRI guidance, a minority interest means an ownership interest in an entity that is not controlled by its parent entity.
Important GRI guidance: use the same group of entities as in financial reporting where possible. If the lists are identical, a concise statement and reference to the published list can be sufficient; list any additional sustainability-only entities separately. These entities form the basis for the disclosures in GRI 2 and for determining material topics, while impacts connected with additional entities in business relationships still need to be considered when determining material topics.
Reasons for omission are not permitted for Disclosure 2-2. Confidentiality, unavailable information or another reason for omission cannot be used to leave out a required entity or consolidation explanation when reporting in accordance with the GRI Standards.
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.
Preparation
Key datapoints to prepare
＋ Show GRI 2-2 sub-elements (LRA working checklist)
List all entities included in the organisation’s sustainability reporting.
If the organisation has audited consolidated financial statements or financial information filed on public record, specify the differences between the entities included there and those included in sustainability reporting.
For an organisation consisting of multiple entities, explain whether and how minority interests are taken into account in the consolidation approach.
Explain how mergers, acquisitions and disposals of entities or parts of entities are taken into account in the consolidation approach.
Explain whether and how the consolidation approach differs across the disclosures in GRI 2 and across material topics.
How to prepare it
1Build and verify a complete register of every entity included in the sustainability report. Keep sites and business units as supporting collection units only; they do not replace the entity list.
2If audited consolidated financial statements or financial information filed on public record exist, reconcile their entity list to the sustainability reporting entity list and specify every difference.
3If the organisation consists of multiple entities, document the consolidation approach and whether and how it adjusts information for minority interests.
4Explain how the consolidation approach takes account of mergers, acquisitions and disposals of entities or parts of entities. If this causes a restatement of previously reported information, also apply Disclosure 2-4 and explain the reason for and effect of the restatement.
5Explain whether and how the consolidation approach differs across the disclosures in GRI 2 and across material topics. Do not describe these differences as unexplained scope exceptions.
6Before finalising, verify that all required information is complete and that no entity or explanation has been omitted for confidentiality, unavailable information or another reason for omission.
Request the data
Request the group entity scope and consolidation notes
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Which entities are included in sustainability reporting, how does that list compare with the applicable financial reporting entity list, and how is the information consolidated?
Use your organisation’s own perimeter, consolidation and entity-list terms first, then map them to the sustainability report wording. If your team talks about the group structure, reporting perimeter, legal entities, or consolidation pack, use those terms in the request and in the response.
Weak request
Please provide the entities included in sustainability reporting and explain the consolidation approach.
Why it fails: This uses framework-style language only and does not tell the owner what practical records to pull. It is too vague on the source list, the comparison point, the period, and the change events that affect the answer.
Better request
Please send the complete sustainability reporting entity list for [period], the matching list from the audited consolidated financial statements or financial information filed on public record, and a reconciliation showing every difference. Also provide the consolidation approach for minority interests, mergers, acquisitions and disposals, and any differences across GRI 2 disclosures or material topics.
Industry examples
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
Explain which entities are included in the sustainability reporting boundary, how that boundary was built from the group structure, and whether the same approach was used for all disclosures and material topics.
Context note
Clarify what the reported figures represent by linking them to the entities covered, noting any differences from the financial reporting population and any adjustments needed to combine data across the group.
Fluctuation statement
Explain how the consolidation approach takes account of mergers, acquisitions and disposals. If these changes result in restatements of previously reported information, also apply Disclosure 2-4 and explain the reason for and effect of the restatement.
Content index entry
GRI 2-2 Entities included in the organization’s sustainability reporting — [location / page] / [notes]
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Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
The report describes sites, stores, regions or business units but does not provide the complete list of entities included in sustainability reporting.Differences from audited consolidated financial statements or financial information filed on public record are not specified entity by entity where 2-2-b applies.The consolidation approach does not say whether and how minority interests are taken into account.The report does not explain how mergers, acquisitions and disposals of entities or parts of entities are reflected in the consolidation approach.Differences in the consolidation approach across GRI 2 disclosures and material topics are missing or described as unexplained scope exceptions.An entity or required explanation is omitted because it is considered immaterial, confidential or below an internal threshold, even though reasons for omission are not permitted.If structural changes caused previously reported information to be restated, the report does not also provide the reason for and effect of the restatement under Disclosure 2-4.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
The team asks the reporting lead instead of the business unit that actually keeps the entity register, so the source list comes from the wrong place.
Framework language only
People ask for the answer in reporting-framework terms rather than the organisation’s own entity names, which makes the source data hard to map back to operations.
Scope left vague
No one verifies the complete list of entities included in sustainability reporting before collection starts, so different teams build inconsistent lists.
Wrong period basis
The list is pulled using a different cut-off date from the one used for the reporting period, so the entity set does not match the rest of the data pack.
Mixed counting basis
Headcount, revenue, and entity coverage are gathered on different bases and then merged without a clear bridge, which makes the population inconsistent.
Source labels lost
The original file names, system codes, or register labels are stripped out during consolidation, so nobody can trace each entity back to its source record.
Populations merged too early
Entities that should stay separate for finance and sustainability are combined into one working list before the differences are checked.
Missing evidence trail
The collector saves the numbers but not the supporting metadata, such as source date, owner, and version, so the evidence cannot be reconstructed later.
No sign-off record
The final entity list is circulated informally without a named reviewer or approval trail, so there is no clear record of who checked it.
Where judgement is often needed
Account for mergers, acquisitions and disposals
Explain how the consolidation approach takes account of mergers, acquisitions and disposals of entities or parts of entities, including the timing applied to information for the reporting period.
Explain any gap between the finance perimeter and the sustainability perimeter
If audited consolidated financial statements or financial information filed on public record exist and the two lists differ, specify every difference. Explaining why they differ is useful additional LRA guidance.
Explain the treatment of minority interests
For an organisation consisting of multiple entities, state whether and how the consolidation approach adjusts information for minority interests.
Keep entity names traceable
Reconcile local entity names and codes to the legal entity register so every entity included in sustainability reporting can be identified accurately.
Resolve differences in entity treatment
Investigate entities whose treatment in sustainability reporting differs from their treatment in financial reporting. GRI 2-2 does not establish a size or materiality threshold for listing entities included in sustainability reporting.
Use direct records for the entity list
Verify entities against legal registers, corporate records and financial reporting documents. Estimates and proxies may be relevant to individual ESG metrics, but they are not an appropriate basis for establishing whether an entity exists or belongs on the entity list.
Explain consolidation differences across disclosures and topics
State whether and how the consolidation approach differs across the disclosures in GRI 2 and across material topics, and link each difference to the relevant disclosure or topic.
Do not use confidentiality to hide required information
Rounding or aggregation of numerical metrics cannot replace the required entity list or consolidation explanation. Reasons for omission are not permitted for Disclosure 2-2.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — consumer goods manufacturing
Northbridge Consumer Group includes six entities in sustainability reporting: the parent, three wholly owned operating subsidiaries, one joint venture and one dormant holding entity. Its audited consolidated financial statements also include six entities. The two lists differ in two respects: the joint venture is included only in sustainability reporting, while a special-purpose financing entity is included only in financial reporting.
• For economic data affected by intra-group transactions, Northbridge combines the controlled entities line by line and eliminates relevant intra-group balances and transactions. For emissions, water, waste, workforce and health and safety data, it applies the aggregation rule stated with each metric rather than treating accounting consolidation as a universal ESG method.
• The consolidation note states whether and how figures are adjusted for minority interests.
• Mergers, acquisitions and disposals are reflected from the date control begins or ends.
• The approach is consistent across GRI 2 disclosures. Differences for individual material topics are identified with the relevant topic methodology.
Illustrative only: the two entity lists each contain six entities and the two differences are stated separately. The example also distinguishes financial eliminations from metric-specific ESG aggregation.
Illustrative (synthetic) example — infrastructure services
Meridian Infrastructure Group lists eight entities included in sustainability reporting: the parent, four operating subsidiaries, two project companies and one service entity. Its audited consolidated financial statements include seven of these entities; the report identifies the additional sustainability-only project company and explains the difference as useful context.
• Meridian explains whether and how its consolidation approach adjusts information for minority interests.
• Acquired entities are included from the date control begins and disposed entities until the date control ends.
• One approach is used across the disclosures in GRI 2. Where a material-topic assessment also considers impacts connected with contractors or other entities in business relationships, those entities are identified as part of the business relationship and are not presented as entities listed under 2-2-a.
Illustrative only: distinguishes entities included under 2-2-a from additional entities in business relationships whose impacts are considered when determining material topics.
How companies report GRI 2-2 in practice
Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.
Globalvia
Ground Transportation — Highways and Railtracks · Spain · 2025
Globalvia provides a named entity list and states that its sustainability scope corresponds to its accounting consolidation scope (p.11). It then explains a narrower population for environmental quantitative information and how ceased or disposed concession companies are treated, including first-quarter data for two entities that exited in March 2025 (p.12). The treatment of minority interests is not stated clearly. Stakeholder engagement, labour relations and community engagement are not evidence for GRI 2-2.
Re Sustainability Limited
Solid Waste Management Utilities · India · 2025
Re Sustainability’s GRI Content Index directs GRI 2-2 to the Report Overview (p.4). That page describes India coverage, selected environmental and social information for the Middle East and Singapore, and coverage representing more than 90% of revenue. It does not provide a complete entity list, a reconciliation to financial reporting entities or the consolidation explanations required by 2-2-c. This is partial and insufficient reporting practice; internal financial controls and the auditor’s report are not evidence for GRI 2-2.
Aditya Birla Fashion and Retail Limited
Retailing · India · 2025
ABFRL’s Reporting Scope and Boundary describes consolidated financial reporting and names businesses and subsidiaries included in Indian non-financial reporting (pp.3–4), with a subsidiary list in the BRSR (pp.281–282). The BRSR also says its disclosures are prepared on a standalone basis and cover significant operations, creating a boundary inconsistency that is not fully reconciled. Clear treatment of minority interests and mergers, acquisitions and disposals was not found. Local-community disclosures are not evidence for GRI 2-2.
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Scenarios to work through
A group has a parent company, two wholly owned subsidiaries, and one joint venture that is not fully controlled. The finance team’s year-end pack includes all four entities, but the sustainability team has only drafted content for the parent and the two subsidiaries.
QShould the reporting pack name every entity covered by the sustainability report, and if the sustainability scope differs from the finance scope, what extra explanation is needed?
Reveal model answer →Hide answer ↑Yes. The report must list every entity included in sustainability reporting. If 2-2-b applies and the sustainability entity list differs from the entities in the audited consolidated financial statements or financial information filed on public record, the report must specify the differences. Explaining why the lists differ is useful additional context.
Why this matters · Readers need to see which parts of the group sit inside the sustainability boundary, and any mismatch with the finance boundary should be made clear.
A group bought a business in October and sold another in March. The sustainability data team has used the full-year figures from the acquired business but has left out the sold business entirely because it was not owned at year end.
QHow should the consolidation approach deal with the purchase and sale so the reporting boundary is understandable?
Reveal model answer →Hide answer ↑The explanation should describe how changes in the group during the year are handled when combining the information. That means the preparer should say how newly acquired parts and disposed parts are treated, rather than leaving the reader to guess from the numbers alone.
Why this matters · The consolidation method should show how changes in ownership during the period are reflected in the reported information.
A group has a 70% owned operating company and a 30% owned associate. The sustainability team has included 100% of the operating company’s emissions and 30% of the associate’s, but no one has written down whether the minority share was adjusted in the process.
QWhat should the preparer explain about the way the figures were combined?
Reveal model answer →Hide answer ↑The report should explain the consolidation approach and whether and how the information is adjusted for minority interests, so readers can understand the basis on which the totals were prepared.
Why this matters · Where ownership is shared, the report should make clear whether and how minority interests affect the combined figures.
A group reports on climate, workforce, and community topics. For climate, it uses one consolidation method across all entities; for workforce data, it uses a different method because one acquired business has incomplete legacy records; and for community spend, it uses a third approach for a joint operation.
QWhat level of explanation is needed when the consolidation method is not the same for every topic or every disclosure?
Reveal model answer →Hide answer ↑The preparer should explain whether and how the consolidation approach differs across the disclosures in GRI 2 and across material topics, linking each different treatment to the relevant disclosure or topic.
Why this matters · If the consolidation approach is not uniform, the differences should be described clearly and linked to the relevant disclosures or topics.
Framework references
Relevant GRI requirements and related disclosures
Available framework references and nearby disclosures relevant to preparing this requirement.
Primary
Related & explore
FAQ
Questions this page answers
For GRI 2-2, what data do I need to gather before I start drafting the disclosure?+−
Prepare five things: the complete sustainability reporting entity list; any differences from the entities in audited consolidated financial statements or financial information filed on public record; the treatment of minority interests; the treatment of mergers, acquisitions and disposals; and any differences in the consolidation approach across GRI 2 disclosures and material topics.
How do I use the step-by-step preparation section for GRI 2-2 in practice?+−
Use it as a working sequence to move from scoping and ownership through to evidence and draft output. The page is designed to help you prepare the disclosure, not just describe it.
What should I include in the reporting entity list for GRI 2-2?+−
List every entity included in the organisation’s sustainability reporting. Sites, stores and business units can be supporting collection units but do not replace the required entity list. Reasons for omission are not permitted for GRI 2-2.
How should I document boundary differences for GRI 2-2?+−
Where 2-2-b applies, compare the sustainability reporting entity list specifically with the entities in audited consolidated financial statements or financial information filed on public record, and specify every difference. Explaining why the lists differ is useful additional context but is not a separate requirement.
What does the page mean by minority interest treatment for GRI 2-2, and how do I capture it?+−
The page lists minority interest treatment as a datapoint to prepare, so you should document how minority interests are handled in the disclosure and keep that treatment consistent in your working papers. The page does not define the treatment for you.
How do I record transaction boundary changes for GRI 2-2?+−
Explain how the consolidation approach takes account of mergers, acquisitions and disposals of entities or parts of entities. If a structural change leads to restatement of previously reported information, also apply GRI 2-4 and explain the reason for and effect of the restatement.
Who should own the GRI 2-2 disclosure process in my team?+−
The page is set up for practitioners to assign ownership as part of preparation, so the practical approach is to name the data owner, the drafter, and the reviewer early. The page does not prescribe a specific role structure.
What evidence pack do I need to make GRI 2-2 assurance-ready?+−
Keep the legal entity register, applicable published financial entity list, reconciliation, consolidation methodology, ownership schedule, records of mergers/acquisitions/disposals, mapping of consolidation differences and documented review and approval.
What are the four assurance claims I should verify for GRI 2-2?+−
The page says there are four assurance claims to verify, each with a claim, risk and evidence prompt. Use those prompts to check that the disclosure is supported before it goes to review.
What common mistakes does the GRI 2-2 page warn me to avoid?+−
The page lists common reporting gaps and mistakes, so it is worth checking your draft against that list before sign-off. In practice, use it as a final quality-control step to catch missing scope notes, weak methodology or incomplete evidence.
How can I use the synthetic example disclosures for GRI 2-2 without copying them into my report?+−
The examples are synthetic and show how a completed narrative disclosure might be structured. Use them as a drafting reference only; replace every entity, difference and consolidation method with verified information from your own records.
More questions this page can help with
What is the plain-language explanation of GRI 2-2 on this page?How do I turn the GRI 2-2 data points into a first draft?What should go into the GRI 2-2 evidence pack for assurance?How do I use the Prep & Assurance workbook for GRI 2-2?What is in the printable Library Card PDF for GRI 2-2?Where can I find real company report examples for GRI 2-2 on the page?How do I write the narrative starter for a GRI 2-2 draft?What visualisation ideas does the page suggest for GRI 2-2?How do I build the GRI content-index line for GRI 2-2?What methodology notes should I keep for GRI 2-2 boundary changes?How do I check whether my GRI 2-2 draft is assurance-ready?What are the most common GRI 2-2 reporting gaps to check before submission?
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