Disclosure focus
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.
Prepare
What to collect before drafting
Tick each field as the evidence lands. Owners are the teams that usually hold the source files.
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Entities included in sustainability reporting
Group reporting / FinanceA complete and accurate list of every entity included in the organisation’s sustainability reporting.
Evidence Legal entity register, current sustainability reporting entity list, consolidation schedule and reporting pack.
Watch for The published list is incomplete, or sites and business units are presented instead of the entities included in sustainability reporting.
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Differences from financial reporting entities
Group reporting / FinanceWhere applicable, specify every difference between the entities included in audited consolidated financial statements or financial information filed on public record and those included in sustainability reporting. A reason for each difference is useful additional context, not a separate GRI requirement.
Evidence Audited consolidated financial statements or financial information filed on public record, entity reconciliation and approved sustainability reporting entity list.
Watch for The two entity lists differ but the report does not identify the differences precisely.
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Treatment of minority interests
Group reporting / FinanceFor an organisation consisting of multiple entities, explain whether and how the consolidation approach adjusts information for minority interests.
Evidence Consolidation policy, group reporting instructions, consolidation workbook, ownership schedule.
Watch for Adjustments for minority interests are applied but not described, or the term is confused with associates, joint ventures or other ownership arrangements.
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Treatment of mergers, acquisitions and disposals
Group reporting / FinanceExplain how the consolidation approach takes account of mergers, acquisitions and disposals of entities or parts of entities.
Evidence Merger and acquisition records, disposal papers, consolidation entries and entity change log.
Watch for Acquisitions and disposals are not reflected on the correct cut-off date, so the reporting boundary is wrong for part of the period.
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Differences in consolidation approach
Sustainability reporting / Group reportingExplain whether and how the consolidation approach differs across the disclosures in GRI 2 and across material topics. This is one GRI requirement, not two separate datapoints.
Evidence Disclosure and material-topic mapping, consolidation methodology and reporting controls matrix.
Watch for Different consolidation approaches are used across GRI 2 disclosures or material topics without being identified and explained.
Before you start
- Do you have a complete, current list of every entity included in sustainability reporting?
- If applicable, have you reconciled that list to the entities in audited consolidated financial statements or financial information filed on public record?
- For a multi-entity organisation, have you documented whether and how the consolidation approach adjusts information for minority interests?
- Have you documented how mergers, acquisitions and disposals of entities or parts of entities are taken into account?
- Have you identified whether and how the consolidation approach differs across GRI 2 disclosures and material topics?
How to prepare it
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.
Formal email template
Subject: Request for GRI 2-2 entity list and consolidation notes Hi [Name], We are preparing the sustainability report and need the current entity information for [period]. Please send: - the complete list of entities included in sustainability reporting - where applicable, every difference from the entities in the audited consolidated financial statements or financial information filed on public record - whether and how the consolidation approach adjusts information for minority interests - how mergers, acquisitions and disposals of entities or parts of entities were taken into account - whether and how the consolidation approach differs across GRI 2 disclosures and material topics Please return this in your usual format if easier, or use the table below. [deadline] [contact for questions] Thanks, [preparer name]
Short Teams / Slack version
Hi [Name] — could you share the complete sustainability reporting entity list for [period], the applicable published financial reporting entity list and their reconciliation, plus the consolidation note covering minority interests, mergers, acquisitions, disposals and any differences across GRI 2 disclosures or material topics? Thanks.
Industry examples
Manufacturing
Context. A multi-site group with several operating subsidiaries and one recently acquired plant.
Adapted request. Please share the complete sustainability reporting entity list for [period], the entity list in the audited consolidated financial statements or financial information filed on public record, their reconciliation, and the treatment of the acquisition, disposal and minority interests.
Example response. Attached are the two entity lists and reconciliation for [period]. The sustainability list includes 14 entities; the audited consolidated financial statements include those 14 plus one dormant holding company. The disclosure specifies this difference. The acquired entity is included from completion and the disposed entity until disposal. No adjustment for minority interests is made in the sustainability consolidation approach.
Retail
Context. A retailer with a parent company, trading subsidiaries, and a small joint venture.
Adapted request. Please provide the complete sustainability reporting entity list for [period], the entity list in the applicable public financial information, and a reconciliation identifying the joint venture and every other difference. Also explain the treatment of minority interests and disposals.
Example response. The sustainability report lists the parent and nine subsidiaries. The publicly filed financial information also includes one joint venture; the reconciliation specifies that difference. The consolidation approach does not adjust sustainability information for minority interests and includes disposed entities until the disposal date.
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]Download Centre
Preparation tools & forms
Download preparation tools for GRI 2-2 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
The sustainability reporting entity list reconciles to the underlying legal entity records.
Risk An entity is missing, duplicated or named inconsistently, or a site or business unit is substituted for a legal entity.
Evidence to check Entity register reconciled to the sustainability reporting entity list
The comparison with financial reporting uses the applicable published entity list.
Risk The comparison uses management accounts or another document that is not an audited consolidated financial statement or financial information filed on public record.
Evidence to check Reconciliation workbook and the applicable audited consolidated financial statements or publicly filed financial information
The consolidation approach addresses minority interests, mergers, acquisitions and disposals.
Risk Ownership adjustments or structural changes are reflected in the data but not explained in the disclosure.
Evidence to check Consolidation methodology, ownership schedule and records of mergers, acquisitions and disposals
All entities included in the organisation’s sustainability reporting are listed completely and accurately.
Risk An entity is omitted because it is considered small, confidential or below an internal threshold, even though reasons for omission are not permitted.
Evidence to check Approved entity register, reconciliation workbook and documented review record
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.
Where drafts go wrong
Mistakes to avoid and where judgement is needed
The left column is what preparers get wrong while collecting; the right column is where you will have to make and explain a judgement.
Mistakes to avoid
- Wrong ownerThe 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 onlyPeople 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 vagueNo one verifies the complete list of entities included in sustainability reporting before collection starts, so different teams build inconsistent lists.
- Wrong period basisThe 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 basisHeadcount, revenue, and entity coverage are gathered on different bases and then merged without a clear bridge, which makes the population inconsistent.
- Source labels lostThe 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 earlyEntities that should stay separate for finance and sustainability are combined into one working list before the differences are checked.
- Missing evidence trailThe 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 recordThe final entity list is circulated informally without a named reviewer or approval trail, so there is no clear record of who checked it.
Judgement needed
- Account for mergers, acquisitions and disposalsExplain 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 perimeterIf 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 interestsFor an organisation consisting of multiple entities, state whether and how the consolidation approach adjusts information for minority interests.
- Keep entity names traceableReconcile 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 treatmentInvestigate 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 listVerify 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 topicsState 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 informationRounding 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
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
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.
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.
Quality ladder
- Basic
I include 12 entities in my sustainability report.
- Better
I list all 12 entities included in sustainability reporting. Our audited consolidated financial statements include 10 of those entities and two additional entities; the reconciliation identifies all four differences.
- Best
I list all 12 entities included in sustainability reporting for the year ended 31 December 2025 and reconcile them to the entities in our audited consolidated financial statements. I explain whether and how minority interests are adjusted, how mergers, acquisitions and disposals are taken into account, and whether and how the consolidation approach differs across GRI 2 disclosures and material topics.
Check your understanding
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.
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.
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.
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.
Real reports
How 3 companies report it
Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.
Globalvia
Direct
Re Sustainability Limited
Partial
Aditya Birla Fashion and Retail Limited
Partial| Field | Globalvia | Re Sustainability Limited | Aditya Birla Fashion and Retail Limited |
|---|---|---|---|
| Entities included in sustainability reporting | Not found | Partial | Partial |
| Differences from financial reporting entities | Not found | Not found | Partial |
| Treatment of minority interests | Partial | Not found | Not found |
| Treatment of mergers, acquisitions and disposals | Not found | Not found | Not found |
| Differences in consolidation approach | Not found | Not found | Partial |
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Advice, not assurance
Framework references
Relevant GRI requirements and related disclosures
GRI
GRI 2-2
within GRI 2: General Disclosures
Guides that settle this question
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FAQ
Questions this page answers
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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