Disclosure focus
First, the organization must report the ratio of the annual total compensation of its highest-paid individual to the median annual total compensation of all employees, excluding the highest-paid individual where that individual is part of the employee population.
Second, the organization must report the ratio of the percentage increase in annual total compensation of the highest-paid individual to the median percentage increase in annual total compensation of all employees, excluding the highest-paid individual where applicable. This second ratio is a mandatory element of Disclosure 2-21 and should not be treated as optional.
The highest-paid individual is not necessarily an employee. The numerator should include the individual who received the highest annual total compensation from the organization during the reporting period. The denominator covers all employees reported under Disclosure 2-7 for the entities included in the organization’s sustainability reporting under Disclosure 2-2. Workers who are not employees are not included in the denominator.
Annual total compensation includes salary, bonus, stock awards, option awards, non-equity incentive plan compensation, changes in pension value and nonqualified deferred compensation earnings provided during the year. Depending on the organization’s remuneration policies and data availability, the calculation should consider base salary, total cash compensation and direct compensation, including the fair value of annual long-term incentives.
The organization should use a consistent compensation definition and valuation basis for the highest-paid individual and the employee population. It should explain the treatment of equity awards, deferred remuneration, pension-value changes, benefits, part-time employees, part-year employees and currency translation.
For the second ratio, the organization should distinguish the median of employee-level percentage increases from the percentage change in the median compensation amount. The calculation methodology and treatment of employees without comparable prior-period data should be documented and explained.
The contextual information should state:
1. whether any employees reported under Disclosure 2-7 were excluded;2. whether full-time-equivalent pay rates were used for part-time employees;3. the types of compensation included;4. the title of the highest-paid individual.
Additional context can explain the effects of organizational size, sector, employment strategy, outsourced or part-time work, automation, workforce mix, one-off remuneration, currency volatility, methodology changes and improvements in data collection.
Where the highest-paid individual changes between periods, the organization should not combine the compensation of different role-holders. It should identify the individual with the highest annual total compensation in the current reporting period and explain how the percentage-increase calculation was handled where comparable prior-period compensation was unavailable.
Where the median percentage increase is zero, the second ratio is mathematically undefined. Where percentage changes are negative, the organization should report the underlying changes and explain how the resulting ratio should be interpreted.
The two results should be presented as ratios, for example 20:1 and 2.5:1, rather than as percentages unless a percentage is being shown as an underlying calculation input.
Reasons for omission are permitted for Disclosure 2-21. Where required data are unavailable or incomplete, the organization must identify the affected requirement, specify the missing employee populations or entities, explain why the information is unavailable, and describe the steps and expected time frame for obtaining it in its GRI content index.
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.
-
Annual total compensation ratio
People / Remuneration / FinanceCalculate the highest-paid individual's annual total compensation divided by the median for all employees reported under GRI 2-7, excluding that individual only where applicable.
Evidence Dated source records, governance papers and approval evidence supporting annual total compensation ratio.
Watch for The published response for annual total compensation ratio is incomplete or does not match the supporting records.
-
Percentage-increase ratio
People / Remuneration / FinanceCalculate the highest-paid individual's percentage increase divided by the median of employee-level percentage increases.
Evidence Dated source records, governance papers and approval evidence supporting percentage-increase ratio.
Watch for The published response for percentage-increase ratio is incomplete or does not match the supporting records.
-
Method and contextual information
People / Remuneration / FinanceReport exclusions, FTE treatment, compensation types, title of the highest-paid individual and other context needed to understand the ratios.
Evidence Dated source records, governance papers and approval evidence supporting method and contextual information.
Watch for The published response for method and contextual information is incomplete or does not match the supporting records.
Before you start
- Use all employees reported under GRI 2-7 for the entities in GRI 2-2; workers who are not employees are not in the denominator.
- The highest-paid individual is not necessarily an employee; exclude that individual from the employee denominator only if included in the GRI 2-7 population.
- 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 employee-level current and prior-period annual total compensation, the highest-paid individual's data and title, population reconciliation, compensation components, FTE and currency treatment, and methodology for both ratios.
Use the organisation's own role and document names, but preserve the defined GRI terms and the scope described above.
Better request
Provide employee-level current and prior-period annual total compensation, the highest-paid individual's data and title, population reconciliation, compensation components, FTE and currency treatment, and methodology for both ratios.
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
Use a consistent compensation definition and distinguish the median of employee-level percentage increases from the percentage change in median compensation.
Context note
Explain exclusions, zero or negative median increases, changes in the highest-paid individual, methodology changes and material data limitations.
Fluctuation statement
Explain significant changes in either ratio, including compensation, population, policy, methodology, inclusion, currency and data-collection effects.
Download Centre
Preparation tools & forms
Download preparation tools for GRI 2-21 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
Annual total compensation ratio is reported accurately and completely.
Risk The response omits, misclassifies or overstates annual total compensation ratio.
Evidence to check Dated source records, governance papers and approval evidence supporting annual total compensation ratio.
Percentage-increase ratio is reported accurately and completely.
Risk The response omits, misclassifies or overstates percentage-increase ratio.
Evidence to check Dated source records, governance papers and approval evidence supporting percentage-increase ratio.
Method and contextual information is reported accurately and completely.
Risk The response omits, misclassifies or overstates method and contextual information.
Evidence to check Dated source records, governance papers and approval evidence supporting method and contextual information.
Evidence pack to prepare
Common reporting gaps
- Using highest-paid employee or top earner instead of highest-paid individual.
- Using a wider workforce denominator instead of all employees reported under GRI 2-7.
- Treating the second ratio as optional.
- Using change in median compensation instead of the median of employee-level percentage increases.
- Omitting FTE treatment, compensation types or the title of the highest-paid individual.
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.
Cogna Educação S.A.
PartialChina Steel Corporation
PartialCAE Inc.
Partial| Field | Cogna Educação S.A. | China Steel Corporation | CAE Inc. |
|---|---|---|---|
| Annual total compensation ratio | Not found | Not found | Not found |
| Percentage-increase ratio | Not found | Not found | Not found |
| Method and contextual information | Not found | Partial | Partial |
Ask the Knowledge Hub AI Assistant about this disclosure
Get practical answers for your reporting context.
Check your text
Paste one or two paragraphs. The fragment is used for this check only and is not stored in your conversation.
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 2-21
within GRI 2: General Disclosures
Guides that settle this question
Related & explore
More in GRI 2 →Browse full catalogue →Search all disclosures →