Disclosure focus
The organization must report whether the process for determining remuneration is overseen by independent members of the highest governance body or by an independent remuneration committee. The term “Board” should be used only where the Board is the organization’s highest governance body. Non-executive status should not be treated automatically as evidence of independence.
The organization must describe how the views of stakeholders, including shareholders, regarding remuneration are sought and taken into consideration. The disclosure should identify the relevant stakeholder groups and engagement channels and explain how the views are reviewed or otherwise considered in the remuneration process. Stakeholder views do not have to result in a policy change, but the consideration process should be described.
The organization must report whether remuneration consultants are involved in determining remuneration. If consultants are involved, it must report whether they are independent of the organization, its highest governance body and its senior executives. External or legally separate status does not automatically demonstrate independence.
The organization must also report the results of stakeholder votes, including shareholder votes, on remuneration policies and proposals where such votes are applicable. The result should identify the proposal and the outcome. The organization can additionally explain whether the vote was binding or advisory and provide votes for, against, abstained or withheld where this is necessary for clarity.
Where no applicable vote took place, the organization can report this directly. Similarly, where stakeholder views are not sought, no remuneration consultant is used, or no independent oversight exists, the organization should report the actual arrangement rather than omit the element or imply that a process exists.
Remuneration policies generally help recruit, motivate and retain highest governance body members, senior executives and other employees. They can also support the organization’s strategy and contribution to sustainable development and align remuneration arrangements with stakeholder interests.
Disclosure 2-20 addresses the process for designing remuneration policies and determining remuneration. The content of the remuneration policies is reported under Disclosure 2-19, while annual total compensation ratios are reported under Disclosure 2-21.
Reasons for omission are permitted for Disclosure 2-20 where required information cannot be reported. However, the absence of a committee, stakeholder-consultation process, consultant or applicable vote should normally be reported directly as a factual response rather than treated as an omission.
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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Policy-design and remuneration-determination processes
People / Remuneration / FinanceDescribe the processes separately where they involve different bodies or approval routes.
Evidence Dated source records, governance papers and approval evidence supporting policy-design and remuneration-determination processes.
Watch for The published response for policy-design and remuneration-determination processes is incomplete or does not match the supporting records.
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Independent oversight
People / Remuneration / FinanceState whether independent members of the highest governance body or an independent remuneration committee oversee determination.
Evidence Dated source records, governance papers and approval evidence supporting independent oversight.
Watch for The published response for independent oversight is incomplete or does not match the supporting records.
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Stakeholder views
People / Remuneration / FinanceDescribe how stakeholder views, including shareholder views, are sought and taken into consideration.
Evidence Dated source records, governance papers and approval evidence supporting stakeholder views.
Watch for The published response for stakeholder views is incomplete or does not match the supporting records.
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Consultants and applicable voting results
People / Remuneration / FinanceState consultant involvement and independence from the three specified parties, and report applicable vote results.
Evidence Dated source records, governance papers and approval evidence supporting consultants and applicable voting results.
Watch for The published response for consultants and applicable voting results is incomplete or does not match the supporting records.
Before you start
- Describe the actual processes for the reporting organisation and relevant remuneration populations; do not create a site-level scope.
- Report directly where independent oversight, stakeholder consultation, a consultant or an applicable vote does not exist.
- Have the supporting records and the final response been reconciled?
How to prepare it
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 policy-design and remuneration-determination processes, independent oversight, stakeholder-view process, consultant involvement and independence, and results of applicable votes.
Use the organisation's own role and document names, but preserve the defined GRI terms and the scope described above.
Better request
Provide policy-design and remuneration-determination processes, independent oversight, stakeholder-view process, consultant involvement and independence, and results of applicable votes.
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
Do not treat non-executive status as independence or external status as proof of consultant independence.
Context note
Explain how stakeholder views were considered; GRI 2-20 does not require every view to change the policy.
Download Centre
Preparation tools & forms
Download preparation tools for GRI 2-20 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
Policy-design and remuneration-determination processes is reported accurately and completely.
Risk The response omits, misclassifies or overstates policy-design and remuneration-determination processes.
Evidence to check Dated source records, governance papers and approval evidence supporting policy-design and remuneration-determination processes.
Independent oversight is reported accurately and completely.
Risk The response omits, misclassifies or overstates independent oversight.
Evidence to check Dated source records, governance papers and approval evidence supporting independent oversight.
Stakeholder views is reported accurately and completely.
Risk The response omits, misclassifies or overstates stakeholder views.
Evidence to check Dated source records, governance papers and approval evidence supporting stakeholder views.
Consultants and applicable voting results is reported accurately and completely.
Risk The response omits, misclassifies or overstates consultants and applicable voting results.
Evidence to check Dated source records, governance papers and approval evidence supporting consultants and applicable voting results.
Evidence pack to prepare
Common reporting gaps
- Using Board where it is not the highest governance body.
- Combining policy design and remuneration determination into one vague process.
- Treating non-executive members as automatically independent.
- Reporting only shareholder votes as the stakeholder-view process.
- Testing consultant independence only from the organisation.
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Peer comparison uses examples on this card, not prevalence in the report corpus.
Advice, not assurance
Framework references
Relevant GRI requirements and related disclosures
GRI
GRI 2-20
within GRI 2: General Disclosures
Guides that settle this question
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