Disclosure focus
regulatory non-compliance resulting in a fine or penalty;
regulatory non-compliance resulting in a warning; and
non-compliance with voluntary codes.
If the organization has identified no non-compliance with regulations or voluntary codes, a brief statement of that fact is sufficient.
When compiling the disclosure, exclude incidents where the organization was determined not to be at fault. Where applicable, identify reported incidents that relate to events in periods before the reporting period.
Complaints, allegations, open investigations, internal deviations and labeling corrections are not automatically reportable incidents. They must be assessed to determine whether they constitute non-compliance with a regulation or voluntary code.
Incidents concerning advertising, promotion or sponsorship belong under GRI 417-3 rather than GRI 417-2.
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.
-
Regulatory incidents resulting in a fine or penalty
Legal / Regulatory ComplianceNumber of incidents concerning product and service information and labeling that resulted in a fine or penalty.
Evidence Final regulator decisions, legal notices, penalty records and incident files.
Watch for The published response for regulatory incidents resulting in a fine or penalty is incomplete or does not match the supporting records.
-
Regulatory incidents resulting in a warning
Legal / Regulatory ComplianceNumber of incidents concerning product and service information and labeling that resulted in a warning.
Evidence Regulatory warnings, inspection findings, formal notices and incident files.
Watch for The published response for regulatory incidents resulting in a warning is incomplete or does not match the supporting records.
-
Incidents involving voluntary codes
Compliance / Product StewardshipNumber of incidents of non-compliance with applicable voluntary codes concerning product and service information and labeling.
Evidence Code owner decisions, industry-body findings, internal determinations and incident files.
Watch for The published response for incidents involving voluntary codes is incomplete or does not match the supporting records.
-
Not-at-fault exclusions
Legal / ComplianceCandidate incidents excluded because the organization was determined not to be at fault.
Evidence Final investigation or authority conclusion supporting the exclusion.
Watch for The published response for not-at-fault exclusions is incomplete or does not match the supporting records.
-
Prior-period event identification
Legal / Compliance / Sustainability ReportingFor each reported incident, whether the underlying event occurred before the reporting period.
Evidence Event date, resolution date, case chronology and reporting-period assessment.
Watch for The published response for prior-period event identification is incomplete or does not match the supporting records.
-
Zero-incidents statement — where applicable
Legal / ComplianceConfirmation that no non-compliance with regulations or voluntary codes was identified.
Evidence Complete register reconciliation and documented confirmations from responsible owners.
Watch for The published response for zero-incidents statement — where applicable is incomplete or does not match the supporting records.
Before you start
- Have all candidate incidents concerning product and service information and labeling been identified?
- Has each complaint, deviation or allegation been assessed to determine whether it became an incident of non-compliance?
- Does each confirmed incident concern a regulation or a voluntary code?
- For regulatory incidents, did the outcome involve a fine or penalty, or a warning?
- Have incidents concerning advertising, promotion or sponsorship been separated for GRI 417-3?
- Have incidents where the organization was determined not to be at fault been excluded?
- Does each exclusion have supporting evidence?
- Have incidents related to events in earlier reporting periods been identified?
- Does the reporting-period population reflect the applicable resolution and cut-off methodology?
- Can the three required category counts be reconciled to the incident register?
- If no incidents were identified, does the zero statement cover both regulations and voluntary codes?
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.
Please provide the product and service information and labeling incident register for [reporting period]. For each candidate matter, include: incident reference; affected product or service; description of the information or labeling issue; applicable regulation or voluntary code; whether non-compliance was established; whether the organization was determined to be at fault; regulatory outcome: fine or penalty, warning, or neither; voluntary-code non-compliance status; date of the underlying event; date identified; date formally resolved; whether the event occurred in a prior reporting period; supporting decision or investigation file; and disclosure classification. Please also provide the total number of incidents in each GRI 417-2 category and confirm explicitly if no incidents were identified.
Use the organisation's own role and document names, but preserve the defined GRI terms and the scope described above.
Better request
Please provide the product and service information and labeling incident register for [reporting period]. For each candidate matter, include: incident reference; affected product or service; description of the information or labeling issue; applicable regulation or voluntary code; whether non-compliance was established; whether the organization was determined to be at fault; regulatory outcome: fine or penalty, warning, or neither; voluntary-code non-compliance status; date of the underlying event; date identified; date formally resolved; whether the event occurred in a prior reporting period; supporting decision or investigation file; and disclosure classification. Please also provide the total number of incidents in each GRI 417-2 category and confirm explicitly if no incidents were identified.
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 how candidate cases were assessed, how the three incident categories were applied, how not-at-fault exclusions were determined and how incidents linked to prior-period events were identified.
Context note
Keep mandatory GRI Requirements, GRI recommendations and additional LRA preparation controls clearly distinguished. Apply a GRI 1 reason for omission where required information cannot be reported.
Download Centre
Preparation tools & forms
Download preparation tools for GRI 417-2 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We reported the number of regulatory incidents concerning product and service information and labeling that resulted in a fine or penalty.
Risk Regulatory penalties might be omitted, combined with warnings or mixed with health and safety or marketing-communications incidents.
Evidence to check Final regulator decisions, penalty notices, legal register, incident files and reconciliation to the published figure.
We reported the number of regulatory incidents concerning product and service information and labeling that resulted in a warning.
Risk Formal warnings might be omitted because they did not result in a monetary fine.
Evidence to check Regulatory warning notices, inspection outcomes, legal register and category reconciliation.
We reported the number of incidents involving non-compliance with voluntary codes concerning product and service information and labeling.
Risk Voluntary-code incidents might be omitted or mixed with internal procedural deviations that are not code violations.
Evidence to check Applicable code, final finding, industry-body or internal determination and incident classification.
We excluded only incidents in which the organization was determined not to be at fault.
Risk Open, inconclusive or inconvenient cases might be removed without a documented not-at-fault determination.
Evidence to check Investigation conclusions, regulator decisions, legal assessments and exclusion log.
We identified reported incidents relating to events in periods before the reporting period.
Risk The reporting-period count might be correct, but prior-period event information required by the compilation requirements could be omitted.
Evidence to check Event dates, resolution dates, case chronology and prior-period flag.
Where all three categories were zero, our statement that no non-compliance was identified covered both regulations and voluntary codes.
Risk The statement might be based only on regulator records and omit voluntary-code findings.
Evidence to check Complete source-register reconciliation, confirmations from responsible owners and final sign-off.
Evidence pack to prepare
Common reporting gaps
- Only one combined incident total is reported.
- Fines or penalties, warnings and voluntary-code incidents are not presented separately.
- The disclosure reports “no material incidents” rather than confirming that no incidents were identified.
- Customer complaints are counted as incidents without a non-compliance determination.
- Open investigations are counted before resolution.
- Internal deviations are treated as voluntary-code incidents without identifying the code violated.
- Regulatory warnings are omitted because no monetary penalty was imposed.
- Incidents involving advertising or promotion are incorrectly included under GRI 417-2.
- Product health and safety incidents under GRI 416-2 are mixed with labeling incidents.
- Incidents where the organization was determined not to be at fault are included.
- Incidents are excluded as “not at fault” without supporting evidence.
- Reported incidents connected with prior-period events are not identified.
- Prior-period complaints are automatically carried forward even though no non-compliance was established.
- The year of first identification is used as the sole timing rule without considering formal resolution.
- An overall total cannot be reconciled to the three required categories.
- The report provides policies or controls but no incident counts.
- A general “no legal cases” statement does not address voluntary codes.
- A reason for omission is not provided where required information cannot be reported.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative synthetic example — Consumer goods manufacturing
Incident category
Number
Regulatory incidents resulting in a fine or penalty
1
Regulatory incidents resulting in a warning
1
Incidents of non-compliance with voluntary codes
0
Both incidents were formally resolved during the reporting period. One regulatory incident related to a labeling event that occurred in the prior reporting period. No incident was excluded on the basis that the organization was not at fault.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative synthetic example — Online retail and distribution
The organization identified no non-compliance with regulations or voluntary codes concerning product and service information and labeling during the reporting period.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative synthetic example — Multiple outcomes
The organization reported:
two regulatory incidents resulting in penalties;
one regulatory incident resulting in a warning; and
one voluntary-code incident.
An additional complaint was excluded because the final investigation determined that the organization was not at fault.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
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.
Zydus Lifesciences Limited
Review finding
Zydus Lifesciences Limited provides a sufficient zero-incidents statement for GRI 417-2.
View full reviewHide full review
Assessment
The report states that no non-compliance with regulations or voluntary codes concerning product and service information and labeling was identified in FY 2024–25. It also presents a zero value for the disclosure in its Ethical Marketing Performance table.
Disclosure gap
Because Disclosure 417-2(b) permits a brief statement where no non-compliance has been identified, the report does not need additional incident narratives or category-level counts when the result is zero.
LRA review note
The current card should:
- use the zero statement and the table as the principal evidence
- remove materiality and risk-management information from page 148
- remove the suggestion that unspecified “other aspects” are missing
- note that the same sentence also addresses marketing communications, but the GRI 417-2 element is still identifiable
- classify the disclosure as substantially aligned with the zero-incidents reporting route
Bottom line
Zydus’s report expressly states that there were no incidents concerning product and service information and labeling during FY 2024–25.
Owens Corning
Review finding
Owens Corning’s 2024 Sustainability Report should be assessed using the Product Transparency section on page 184 and the GRI content index.
View full reviewHide full review
Assessment
The report states that Owens Corning had no material incidents of non-compliance with regulations or voluntary codes concerning labeling, marketing or advertising.
Disclosure gap
This statement has two limitations for GRI 417-2:
- it combines labeling with marketing and advertising, which spans both GRI 417-2 and GRI 417-3
- it is restricted to “material” incidents, while GRI 417-2 requires incidents of non-compliance without a materiality threshold
LRA review note
The current card should:
- remove parental-leave, insider-trading, occupational-disease and governance references
- use page 184 and the GRI index as the only relevant evidence
- note that the GRI index maps the zero-incidents route to page 184
- classify the disclosure as partial because of the “material” qualifier and the combined labeling/marketing scope
- avoid claiming compliance based on unrelated general legal-compliance disclosures
Bottom line
The report’s actual wording is a combined statement about labeling, marketing or advertising and is qualified by “material incidents”.
Thai Beverage Public Company Limited
Review finding
Thai Beverage’s current card does not provide evidence relevant to GRI 417-2.
View full reviewHide full review
Disclosure gap
The report’s GRI content index maps GRI 417-2 to page 92. However, that location discusses consumer health, nutrition and product development and does not provide the three incident-category counts or a clear zero statement concerning product and service information and labeling.
Assessment
The report separately states that there were zero incidents concerning product health and safety. That information relates to GRI 416-2 and must not be treated as GRI 417-2 evidence.
LRA review note
The current card should:
- remove child labor, forced labor and occupational health and safety information
- remove the product health and safety zero figure as evidence for GRI 417-2
- identify the mismatch between the GRI index and the cited substantive page
- search for another substantive disclosure location
- mark the example as requiring re-review or remove it until valid evidence is found
Bottom line
ThaiBev’s index identifies GRI 417-2 and points to page 92, but the current card cites unrelated labor and health-and-safety content.
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 417-2
within GRI 417: Marketing and Labeling
Related & explore
More in GRI 417 →Browse full catalogue →Search all disclosures →