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GRI Training Partner GRI 101 · Biodiversity · Disclosure GRI 101-4

In effect 2026

Effective for reporting periods beginning on or after 1 January 2026. Replaces GRI 304.

Identification of biodiversity impacts

GRI 101-4 · mandatory · narrative disclosure

Disclosure 101-4 requires an organization to explain how it determined which of its sites and which products and services in its supply chain have the most significant actual and potential impacts on biodiversity. The disclosure focuses on the determination process. Detailed information on the resulting sites, products and services and their biodiversity impacts is reported under Disclosures 101-5 to 101-8.

Legal status

GRI 101: Biodiversity 2024 is effective for reports or other materials published on or after 1 January 2026 and replaces GRI 304: Biodiversity 2016.

Disclosure focus

Sites include locations owned, leased or managed by the organization and other locations where it conducts activities. They also include sites where future operations have been announced but have not yet started, inactive sites, and relevant subsurface infrastructure such as underground tunnels, cables and pipelines.

The supply-chain assessment covers products and services from suppliers throughout the upstream supply chain, including suppliers beyond the first tier. The organization can additionally report information for entities downstream in its value chain where such information is available.

The organization should describe the methods and assumptions used, the threshold applied, any limitations or exclusions, and the sources and evidence used. It should also explain whether and how stakeholders were engaged to identify biodiversity impacts.

The organization should distinguish between primary, secondary and modeled data. When secondary or modeled data are used, it should identify the datasets, explain their limitations and state whether and how it plans to improve data accuracy.

To assess the significance of impacts, the organization should consider the severity of actual impacts and the severity and likelihood of potential impacts. Severity is assessed through scale, scope and irremediable character. Relevant supporting factors can include direct drivers of biodiversity loss, proximity to ecologically sensitive areas, threatened species, ecosystem condition and changes in ecosystem services.

Where it is not feasible to conduct a detailed assessment across all sites and all supply-chain products and services, the organization can first conduct a documented scoping exercise to identify where impacts are most likely to be present and significant. It should explain the scope, criteria, assumptions, limitations and exclusions of that exercise.

Reasons for omission are permitted in accordance with GRI 1 where the organization cannot comply with the disclosure or a specific requirement.

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

Prepare

What to collect before drafting

Tick each field as the evidence lands. Owners are the teams that usually hold the source files.

  • Site determination process

    Sustainability reporting / Biodiversity

    Explain how sites with the most significant actual and potential biodiversity impacts were determined.

    Evidence Complete site universe, impact screening, detailed assessments and approved resulting list.

    Watch for The published response for site determination process is incomplete or does not match the supporting records.

  • Supply-chain determination process

    Procurement / Supply Chain / Sustainability reporting

    Explain how products and services in the upstream supply chain with the most significant biodiversity impacts were determined, including beyond the first tier.

    Evidence Product and service universe, supplier and country mapping, screening, assessments and approved resulting list.

    Watch for The published response for supply-chain determination process is incomplete or does not match the supporting records.

  • Methods and assumptions

    Sustainability reporting / Biodiversity

    Describe the methods and assumptions used in the determination process.

    Evidence Methodology, model documentation, assumptions register and expert review.

    Watch for The published response for methods and assumptions is incomplete or does not match the supporting records.

  • Threshold

    Sustainability reporting / Biodiversity

    Describe the threshold used to determine the most significant impacts.

    Evidence Significance criteria, severity and likelihood assessment, threshold paper and approval.

    Watch for The published response for threshold is incomplete or does not match the supporting records.

  • Limitations and exclusions

    Sustainability reporting / Biodiversity

    Explain limitations and exclusions in site and supply-chain coverage.

    Evidence Coverage reconciliation, limitation register, exclusion rationale and improvement plan.

    Watch for The published response for limitations and exclusions is incomplete or does not match the supporting records.

  • Sources, evidence and data type

    Sustainability reporting / Biodiversity

    Identify the primary, secondary and modeled data, datasets and evidence used and explain their limitations.

    Evidence Data inventory, dataset licences and versions, model outputs, site evidence and data-quality assessment.

    Watch for The published response for sources, evidence and data type is incomplete or does not match the supporting records.

  • Stakeholder engagement

    Stakeholder Engagement / Biodiversity

    Explain whether and how stakeholders were engaged to identify biodiversity impacts.

    Evidence Engagement plan, affected-stakeholder mapping, feedback and decision trail.

    Watch for The published response for stakeholder engagement is incomplete or does not match the supporting records.

  • Impact-significance assessment

    Sustainability reporting / Biodiversity

    Explain how severity of actual impacts and severity and likelihood of potential impacts were assessed.

    Evidence Scale, scope and irremediable-character criteria, likelihood method and impact assessment.

    Watch for The published response for impact-significance assessment is incomplete or does not match the supporting records.

  • Initial scoping exercise

    Sustainability reporting / Biodiversity

    Where detailed assessment of every site or supply-chain item was not feasible, describe the documented scoping exercise used to identify likely significant impacts.

    Evidence Scoping universe, criteria, assumptions, limitations, exclusions and progression plan.

    Watch for The published response for initial scoping exercise is incomplete or does not match the supporting records.

Before you start

  • Cover owned, leased, managed and other activity sites, announced future operations, inactive sites and relevant subsurface infrastructure, plus products and services from suppliers throughout the upstream supply chain.
  • Use a documented scoping exercise only as an initial step where full detailed assessment is not feasible; do not convert it into a permanent first-tier or control boundary.
  • Have the supporting records and the final response been reconciled?
+ Show GRI 101-4 sub-elements (LRA working checklist)

How to prepare it

Cover owned, leased, managed and other activity sites, announced future operations, inactive sites and relevant subsurface infrastructure, plus products and services from suppliers throughout the upstream supply chain.
Collect and reconcile the records for: Site determination process; Supply-chain determination process; Methods and assumptions; Threshold; Limitations and exclusions; Sources, evidence and data type; Stakeholder engagement; Impact-significance assessment; Initial scoping exercise.
Use a documented scoping exercise only as an initial step where full detailed assessment is not feasible; do not convert it into a permanent first-tier or control boundary.
Draft the response using the defined terms shown in the disclosure focus; do not substitute broader internal labels.
Review the final wording against every requirement and the supporting governance or data records before sign-off.

Request the data

Request the disclosure evidence

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

Provide the complete site and upstream product/service universes, screening and detailed impact assessments, significance criteria and threshold, methods, assumptions, data and source register, stakeholder input, limitations and approved resulting lists.

Use the organisation's own role and document names, but preserve the defined GRI terms and the scope described above.

Better request

Provide the complete site and upstream product/service universes, screening and detailed impact assessments, significance criteria and threshold, methods, assumptions, data and source register, stakeholder input, limitations and approved resulting lists.

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

Assess actual impacts by severity and potential impacts by severity and likelihood. Use direct drivers, sensitive-area proximity, threatened species, ecosystem condition and ecosystem services as supporting factors rather than substitutes for significance.

Context note

GRI 101-4 reports the determination process. Report the resulting site, product, service and impact details under GRI 101-5 to GRI 101-8.

Download Centre

Preparation tools & forms

Download preparation tools for GRI 101-4 with free verified email access for 24 hours. Source-report links remain public.

Free · Email access

Check

For each claim, check the evidence

  • Site determination process is reported accurately and completely.

    Risk The response omits, misclassifies or overstates site determination process.

    Evidence to check Complete site universe, impact screening, detailed assessments and approved resulting list.

  • Supply-chain determination process is reported accurately and completely.

    Risk The response omits, misclassifies or overstates supply-chain determination process.

    Evidence to check Product and service universe, supplier and country mapping, screening, assessments and approved resulting list.

  • Methods and assumptions is reported accurately and completely.

    Risk The response omits, misclassifies or overstates methods and assumptions.

    Evidence to check Methodology, model documentation, assumptions register and expert review.

  • Threshold is reported accurately and completely.

    Risk The response omits, misclassifies or overstates threshold.

    Evidence to check Significance criteria, severity and likelihood assessment, threshold paper and approval.

  • Limitations and exclusions is reported accurately and completely.

    Risk The response omits, misclassifies or overstates limitations and exclusions.

    Evidence to check Coverage reconciliation, limitation register, exclusion rationale and improvement plan.

  • Sources, evidence and data type is reported accurately and completely.

    Risk The response omits, misclassifies or overstates sources, evidence and data type.

    Evidence to check Data inventory, dataset licences and versions, model outputs, site evidence and data-quality assessment.

  • Stakeholder engagement is reported accurately and completely.

    Risk The response omits, misclassifies or overstates stakeholder engagement.

    Evidence to check Engagement plan, affected-stakeholder mapping, feedback and decision trail.

  • Impact-significance assessment is reported accurately and completely.

    Risk The response omits, misclassifies or overstates impact-significance assessment.

    Evidence to check Scale, scope and irremediable-character criteria, likelihood method and impact assessment.

  • Initial scoping exercise is reported accurately and completely.

    Risk The response omits, misclassifies or overstates initial scoping exercise.

    Evidence to check Scoping universe, criteria, assumptions, limitations, exclusions and progression plan.

Evidence pack to prepare

Common reporting gaps

  • Presenting the resulting list as the core requirement instead of the determination process.
  • Limiting sites to owned or active operational locations.
  • Limiting supply-chain assessment to direct suppliers.
  • Mixing biodiversity impacts with dependencies or financial risks.
  • Using exposure screening alone as the final impact-significance assessment.
  • Failing to distinguish primary, secondary and modeled data.
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Dr Ross Kurinko

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Framework references

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