Skip to the disclosure focus
Courses

GRI Training Partner GRI 2 · General Disclosures · Disclosure GRI 2-27

Compliance with laws and regulations

GRI 2-27 · mandatory · metrics + narrative

Disclosure 2-27 requires an organization to report the total number of significant instances of non-compliance with laws and regulations during the reporting period. This total must be broken down into instances for which fines were incurred and instances for which non-monetary sanctions were incurred.

Start preparing ↓ Official GRI source ↗

Disclosure focus

The organization must also report the total number and monetary value of fines paid during the reporting period. These fines must be broken down between fines relating to instances of non-compliance that occurred in the current reporting period and fines relating to instances that occurred in previous reporting periods.

The term “significant instances of non-compliance” should be used consistently. Internal terms such as serious, major or material breaches can be mapped to the GRI terminology, but they should not replace it in the published disclosure or methodology.

The unit counted under GRI 2-27-a is a distinct instance of non-compliance. The unit counted under GRI 2-27-b is a distinct fine paid, not a legal case, regulatory letter, payment instalment or accounting entry. One significant instance can result in more than one fine and can result in both a fine and a non-monetary sanction. The sanction-category counts should therefore be reconciled to the total and should not be assumed to be mutually exclusive.

Fines incurred should be distinguished from fines paid. A fine can be incurred or imposed during one period, appealed, and paid during a later period. Provisions or reserves can support identification of incurred or appealed fines but do not constitute fines paid unless an actual payment has occurred.

The scope of laws and regulations can include international declarations, conventions and treaties, national and subnational laws and regulations, and specified binding or voluntary agreements that have regulatory applicability to the organization.

The reporting scope is based on the entities included in sustainability reporting under Disclosure 2-2. The organization should not create an arbitrary site- or activity-level boundary for Disclosure 2-27. Non-compliance by a supplier, contractor, agent or joint venture should not be included automatically unless the reporting organization or an included entity itself failed to comply with an applicable law or regulation or incurred the relevant sanction.

When determining significance, the organization should consider the severity of the impact resulting from the instance and relevant external sector benchmarks. Severity can be assessed through the scale, scope and irremediable character of the impact. Financial size, legal exposure, operational disruption, licence implications or reputational risk can be used as additional internal considerations but should not replace impact severity and external benchmarks.

Significant instances resulting in administrative or judicial sanctions and fines that are being appealed during the reporting period should be included. The organization should report the appeal status without implying that a final legal determination has been made where proceedings are ongoing.

Non-monetary sanctions can include restrictions or withdrawal of licences and directives to cease or remediate unlawful activity. Warning letters, information requests and investigation notices should not automatically be treated as sanctions unless they have the relevant formal legal or regulatory effect.

For fines paid, the classification between current and previous reporting periods should be based on when the underlying instance of non-compliance occurred, rather than the fine-payment date, regulator-decision date or investigation-opening date. The organization should document a consistent approach for continuing or recurring instances.

For each significant instance, the organization should provide sufficient information to understand its type and context. This can include the geographic location, legal or regulatory matter, authority involved, period of occurrence, sanction, appeal status and whether the issue was repeated, recurring or continuing. Sensitive or legally privileged information can be protected through appropriate aggregation, but the description should not be reduced to generic boilerplate.

Settlements, damages, compensation, remediation expenditure, legal fees, tax assessments and provisions should not be included automatically in fines paid unless they are legally classified as fines.

If no significant instances occurred, the organization should state this directly. If no fines were paid, it should also state this separately. The absence of fines paid does not necessarily mean that no significant instances or non-monetary sanctions occurred.

Reasons for omission are permitted for Disclosure 2-27 where required information cannot be reported. In that case, the affected requirement, applicable reason and required explanation must be provided in the 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.

  • Total significant instances of non-compliance

    Legal / Compliance

    Report the total number of distinct significant instances of non-compliance with laws and regulations.

    Evidence Dated source records, governance papers and approval evidence supporting total significant instances of non-compliance.

    Watch for The published response for total significant instances of non-compliance is incomplete or does not match the supporting records.

  • Significant instances with fines incurred

    Legal / Compliance

    Report the number of significant instances for which fines were incurred.

    Evidence Dated source records, governance papers and approval evidence supporting significant instances with fines incurred.

    Watch for The published response for significant instances with fines incurred is incomplete or does not match the supporting records.

  • Significant instances with non-monetary sanctions

    Legal / Compliance

    Report the number of significant instances for which non-monetary sanctions were incurred.

    Evidence Dated source records, governance papers and approval evidence supporting significant instances with non-monetary sanctions.

    Watch for The published response for significant instances with non-monetary sanctions is incomplete or does not match the supporting records.

  • Total number of fines paid

    Legal / Compliance

    Report the total number of distinct fines actually paid during the reporting period.

    Evidence Dated source records, governance papers and approval evidence supporting total number of fines paid.

    Watch for The published response for total number of fines paid is incomplete or does not match the supporting records.

  • Total monetary value of fines paid

    Legal / Compliance

    Report the total monetary value of fines actually paid during the reporting period.

    Evidence Dated source records, governance papers and approval evidence supporting total monetary value of fines paid.

    Watch for The published response for total monetary value of fines paid is incomplete or does not match the supporting records.

  • Current-period fines paid — number

    Legal / Compliance

    Report the number of fines paid for instances occurring in the current reporting period.

    Evidence Dated source records, governance papers and approval evidence supporting current-period fines paid — number.

    Watch for The published response for current-period fines paid — number is incomplete or does not match the supporting records.

  • Current-period fines paid — value

    Legal / Compliance

    Report the monetary value of fines paid for instances occurring in the current reporting period.

    Evidence Dated source records, governance papers and approval evidence supporting current-period fines paid — value.

    Watch for The published response for current-period fines paid — value is incomplete or does not match the supporting records.

  • Previous-period fines paid — number

    Legal / Compliance

    Report the number of fines paid for instances occurring in previous reporting periods.

    Evidence Dated source records, governance papers and approval evidence supporting previous-period fines paid — number.

    Watch for The published response for previous-period fines paid — number is incomplete or does not match the supporting records.

  • Previous-period fines paid — value

    Legal / Compliance

    Report the monetary value of fines paid for instances occurring in previous reporting periods.

    Evidence Dated source records, governance papers and approval evidence supporting previous-period fines paid — value.

    Watch for The published response for previous-period fines paid — value is incomplete or does not match the supporting records.

  • Description of significant instances

    Legal / Compliance

    Describe the type and context of the significant instances of non-compliance.

    Evidence Dated source records, governance papers and approval evidence supporting description of significant instances.

    Watch for The published response for description of significant instances is incomplete or does not match the supporting records.

  • Method used to determine significance

    Legal / Compliance

    Describe how significant instances of non-compliance were determined.

    Evidence Dated source records, governance papers and approval evidence supporting method used to determine significance.

    Watch for The published response for method used to determine significance is incomplete or does not match the supporting records.

Before you start

  • Use entities reported under GRI 2-2 and count distinct instances and distinct fines; do not attribute supplier or contractor breaches automatically to the reporting organisation.
  • State separately where no significant instances occurred and where no fines were paid; the absence of fines does not prove the absence of instances or non-monetary sanctions.
  • Have the supporting records and the final response been reconciled?
＋ Show GRI 2-27 sub-elements (LRA working checklist)

How to prepare it

Use entities reported under GRI 2-2 and count distinct instances and distinct fines; do not attribute supplier or contractor breaches automatically to the reporting organisation.
Collect and reconcile the records for: Total significant instances of non-compliance; Significant instances with fines incurred; Significant instances with non-monetary sanctions; Total number of fines paid; Total monetary value of fines paid; Current-period fines paid — number; Current-period fines paid — value; Previous-period fines paid — number; Previous-period fines paid — value; Description of significant instances; Method used to determine significance.
State separately where no significant instances occurred and where no fines were paid; the absence of fines does not prove the absence of instances or non-monetary sanctions.
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 legal and regulatory matter register, sanction and appeal records, fine-level payment ledger, entity-scope reconciliation, case descriptions and approved significance methodology.

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

Better request

Provide the legal and regulatory matter register, sanction and appeal records, fine-level payment ledger, entity-scope reconciliation, case descriptions and approved significance methodology.

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

Distinguish fines incurred from fines paid and classify paid fines by the period of the underlying instance; determine significance using impact severity and external sector benchmarks.

Context note

Describe appeal status, recurring or continuing instances and sensitive matters through appropriate aggregation without reducing the disclosure to generic boilerplate.

Fluctuation statement

Explain material changes in significant instances, sanctions and fines paid while preserving the required current- and previous-period classifications.

Download Centre

Preparation tools & forms

Download preparation tools for GRI 2-27 with free verified email access for 24 hours. Source-report links remain public.

Free · Email access
01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Check

For each claim, check the evidence

  • Total significant instances of non-compliance is reported accurately and completely.

    Risk The response omits, misclassifies or overstates total significant instances of non-compliance.

    Evidence to check Dated source records, governance papers and approval evidence supporting total significant instances of non-compliance.

  • Significant instances with fines incurred is reported accurately and completely.

    Risk The response omits, misclassifies or overstates significant instances with fines incurred.

    Evidence to check Dated source records, governance papers and approval evidence supporting significant instances with fines incurred.

  • Significant instances with non-monetary sanctions is reported accurately and completely.

    Risk The response omits, misclassifies or overstates significant instances with non-monetary sanctions.

    Evidence to check Dated source records, governance papers and approval evidence supporting significant instances with non-monetary sanctions.

  • Total number of fines paid is reported accurately and completely.

    Risk The response omits, misclassifies or overstates total number of fines paid.

    Evidence to check Dated source records, governance papers and approval evidence supporting total number of fines paid.

  • Total monetary value of fines paid is reported accurately and completely.

    Risk The response omits, misclassifies or overstates total monetary value of fines paid.

    Evidence to check Dated source records, governance papers and approval evidence supporting total monetary value of fines paid.

  • Current-period fines paid — number is reported accurately and completely.

    Risk The response omits, misclassifies or overstates current-period fines paid — number.

    Evidence to check Dated source records, governance papers and approval evidence supporting current-period fines paid — number.

  • Current-period fines paid — value is reported accurately and completely.

    Risk The response omits, misclassifies or overstates current-period fines paid — value.

    Evidence to check Dated source records, governance papers and approval evidence supporting current-period fines paid — value.

  • Previous-period fines paid — number is reported accurately and completely.

    Risk The response omits, misclassifies or overstates previous-period fines paid — number.

    Evidence to check Dated source records, governance papers and approval evidence supporting previous-period fines paid — number.

  • Previous-period fines paid — value is reported accurately and completely.

    Risk The response omits, misclassifies or overstates previous-period fines paid — value.

    Evidence to check Dated source records, governance papers and approval evidence supporting previous-period fines paid — value.

  • Description of significant instances is reported accurately and completely.

    Risk The response omits, misclassifies or overstates description of significant instances.

    Evidence to check Dated source records, governance papers and approval evidence supporting description of significant instances.

  • Method used to determine significance is reported accurately and completely.

    Risk The response omits, misclassifies or overstates method used to determine significance.

    Evidence to check Dated source records, governance papers and approval evidence supporting method used to determine significance.

Evidence pack to prepare

Common reporting gaps

  • Replacing significant instances of non-compliance with serious or material breaches.
  • Using non-cash sanctions instead of non-monetary sanctions.
  • Counting communications, instalments or accounting entries instead of distinct instances and fines.
  • Including provisions, settlements or remediation costs automatically in fines paid.
  • Using internal financial thresholds instead of impact severity and external benchmarks.
✓ Knowledge Hub AI Assistant · Human-in-the-loop
Dr Ross Kurinko

Ask the Knowledge Hub AI Assistant about this disclosure

Get practical answers for your reporting context.

Try How do I prepare GRI 2-27? What data do I need to collect? What mistakes should I avoid?

Framework references

Relevant GRI requirements and related disclosures

GRI

GRI 2-27

within GRI 2: General Disclosures

Open official source →

Guides that settle this question

GRI 2-5 External Assurance Explained: assurance policy, scope, level, provider independence, limitations and disclosure checklist →GRI 2: General Disclosures 2021 — Complete Guide and Common Reporting Errors →GRI Sector Standards for Diversified Groups: When More Than One Standard Applies →

Related & explore

Organizational details → CardNomination and selection of the highest governance body → CardChair of the highest governance body → CardRole of the highest governance body in overseeing the management of impacts → CardDelegation of responsibility for managing impacts → CardBrowse all disclosures →

More in GRI 2 →Browse full catalogue →Search all disclosures →

How this library is built 1,211 published reports indexed 315,012 pages with page-level citations 272 published cards in the active catalogue
/en/knowledge-hub/disclosure-cards/gri-2-27/