Disclosure focus
regulatory incidents resulting in a fine or penalty;
regulatory incidents resulting in a warning; and
incidents involving non-compliance with voluntary codes.
Marketing communications include activities used to promote the organization, its reputation, brands, products or services. Examples include advertising, personal selling, promotion, public relations, social media and sponsorship.
If no non-compliance with regulations or voluntary codes was identified, a brief statement is sufficient.
When compiling the disclosure, exclude incidents where the organization was determined not to be at fault. Where applicable, identify reported incidents connected with events in periods before the reporting period.
Complaints, allegations, campaign corrections and open investigations are not automatically reportable incidents. They must be assessed to determine whether non-compliance with a regulation or voluntary code was established.
Product and service information and labeling incidents belong under GRI 417-2. Policies, controls, corrective actions and broader topic management belong primarily under Disclosure 3-3 where marketing and labeling is a material topic.
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.
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Regulatory incidents resulting in a fine or penalty
Legal / Regulatory ComplianceNumber of marketing-communications incidents resulting in a regulatory fine or penalty.
Evidence Final regulator or court decisions, penalty notices, legal records and case files.
Watch for The published response for regulatory incidents resulting in a fine or penalty is incomplete or does not match the supporting records.
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Regulatory incidents resulting in a warning
Legal / Regulatory ComplianceNumber of marketing-communications incidents resulting in a regulatory warning.
Evidence Formal warnings, inspection or regulator findings and case files.
Watch for The published response for regulatory incidents resulting in a warning is incomplete or does not match the supporting records.
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Incidents involving voluntary codes
Marketing Compliance / LegalNumber of marketing-communications incidents involving non-compliance with an applicable voluntary code.
Evidence Self-regulatory rulings, industry-code findings, documented internal determinations and case records.
Watch for The published response for incidents involving voluntary codes is incomplete or does not match the supporting records.
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Not-at-fault exclusions
Legal / ComplianceCandidate incidents excluded because the organization was determined not to be at fault.
Evidence Final investigation, regulator, court or self-regulatory conclusion.
Watch for The published response for not-at-fault exclusions is incomplete or does not match the supporting records.
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Prior-period event identification
Legal / Compliance / Sustainability ReportingWhether each reported incident relates to a marketing communication or event occurring before the reporting period.
Evidence Communication date, determination date, resolution date and case chronology.
Watch for The published response for prior-period event identification is incomplete or does not match the supporting records.
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Zero-incidents statement — where applicable
Legal / Marketing ComplianceConfirmation that no non-compliance with regulations or voluntary codes was identified.
Evidence Complete register reconciliation and 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 matters concerning marketing communications been identified?
- Does the candidate population cover advertising, personal selling, promotion, public relations, social media and sponsorship where applicable?
- Has each complaint, allegation or internal issue been assessed to determine whether non-compliance was established?
- Does every reportable incident concern an applicable regulation or voluntary code?
- For regulatory incidents, did the outcome involve a fine or penalty, or a warning?
- Have product-information and labeling incidents been separated for GRI 417-2?
- Have product health and safety incidents been separated for GRI 416-2?
- Have incidents where the organization was determined not to be at fault been excluded?
- Does each exclusion have supporting evidence?
- Have reported incidents connected with prior-period events been identified?
- Does the reporting-period population follow a documented determination, resolution and cut-off basis?
- Can the three category-level numbers be reconciled to the source 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 marketing-communications compliance register for [reporting period]. Include candidate matters concerning advertising, personal selling, promotion, public relations, social media, sponsorship and other communications meeting the GRI definition. For each matter, provide: case reference; communication, campaign or activity; communication type; 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 communication or event; determination date; formal resolution date; whether the event occurred in a prior reporting period; supporting decision or investigation file; and proposed GRI 417-3 classification. Please also provide the total number of incidents in each required category and confirm explicitly if all three categories are zero.
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 marketing-communications compliance register for [reporting period]. Include candidate matters concerning advertising, personal selling, promotion, public relations, social media, sponsorship and other communications meeting the GRI definition. For each matter, provide: case reference; communication, campaign or activity; communication type; 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 communication or event; determination date; formal resolution date; whether the event occurred in a prior reporting period; supporting decision or investigation file; and proposed GRI 417-3 classification. Please also provide the total number of incidents in each required category and confirm explicitly if all three categories are zero.
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 marketing-communications matters were assessed, how the three incident categories were applied, how not-at-fault exclusions were determined and how incidents connected with 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 417-3 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 marketing-communications incidents that resulted in a fine or penalty.
Risk Penalties might be omitted, combined with warnings or mixed with product-labeling or product-safety incidents.
Evidence to check Final regulator or court decisions, penalty notices, legal register, incident files and reconciliation to the published number.
We reported the number of regulatory marketing-communications incidents that resulted in a warning.
Risk Formal warnings might be omitted because no monetary penalty was imposed.
Evidence to check Warning notices, regulator findings, legal register and category reconciliation.
We reported the number of marketing-communications incidents involving non-compliance with voluntary codes.
Risk Voluntary-code incidents might be omitted or mixed with ordinary internal procedural deviations.
Evidence to check Applicable code, final self-regulatory or documented 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 matters might be removed without a supported not-at-fault determination.
Evidence to check Regulator, court, self-regulatory or investigation conclusions and the exclusion log.
We identified reported incidents connected with events in periods before the reporting period.
Risk The category numbers might be correct, but required prior-period-event identification could be omitted.
Evidence to check Communication dates, determination and resolution dates, case chronology and prior-period flag.
Where all three categories were zero, our statement covered both regulations and voluntary codes.
Risk The zero statement might be based only on regulator records and omit voluntary-code or self-regulatory findings.
Evidence to check Complete source-register reconciliation, responsible-owner confirmations and final sign-off.
Evidence pack to prepare
Common reporting gaps
- Only one combined marketing-incident total is reported.
- Fines or penalties, warnings and voluntary-code incidents are not presented separately.
- The report states that there were “no material incidents” rather than confirming whether any incidents were identified.
- The incident population is limited to paid advertising and omits other marketing communications.
- Complaints are counted without a non-compliance determination.
- Open investigations are counted as established incidents.
- Pre-publication corrections are counted as incidents without identifying a violated regulation or voluntary code.
- Regulatory warnings are omitted because no monetary penalty was imposed.
- Internal commitments are treated as voluntary codes without identifying the code.
- Product-information and labeling matters under GRI 417-2 are mixed with marketing-communications incidents.
- Product health and safety incidents under GRI 416-2 are mixed with marketing 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.
- The date first logged is used as the sole timing rule.
- An incidence rate is disclosed without the required absolute category-level numbers.
- The overall total cannot be reconciled to the three prescribed categories.
- The report provides policies or campaign-control descriptions but no incident numbers.
- A general “no legal cases” statement does not address voluntary codes.
- Required information is omitted without applying the GRI 1 reason-for-omission requirements.
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
Incident category
Number
Regulatory incidents resulting in a fine or penalty
1
Regulatory incidents resulting in a warning
0
Incidents involving non-compliance with voluntary codes
1
Both incidents were included in the reporting-period population. One voluntary-code incident related to a promotional campaign published in the prior reporting period. No candidate incident was excluded as not at fault.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative synthetic example — Healthcare services
The organization identified no non-compliance with regulations or voluntary codes concerning marketing communications during the reporting period.
Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.
Illustrative synthetic example — Materiality qualifier
The organization identified one regulatory warning concerning a social-media advertisement. The incident is reported even though the organization did not classify it as material.
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.
A separate complaint was excluded because the final determination found 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 clear zero-incidents figure for GRI 417-3.
View full reviewHide full review
Assessment
The Ethical Marketing Performance table on page 135 reports zero incidents of non-compliance concerning marketing communications for FY 2024–25 and each of the three preceding periods.
Assessment
Because GRI 417-3 permits a brief statement where no non-compliance with regulations or voluntary codes has been identified, the zero figure can satisfy the disclosure if it covers both sources of non-compliance.
LRA review note
The current card should:
- cite the marketing-communications row on page 135 rather than the separate product-information and labeling row
- remove materiality and risk-management information from page 148
- remove the suggestion that unspecified narrative elements are missing
- verify whether the zero figure covers regulations and voluntary codes
- classify the disclosure as substantially aligned with the zero-incidents route
Bottom line
The current card cites the wrong row, although the same report separately provides a zero figure specifically for marketing communications.
Firstsource Solutions Limited
Review finding
Firstsource Solutions Limited’s GRI Content Index provides a zero-incidents statement for GRI 417-3.
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Assessment
The index states that no incidents of non-compliance with marketing-communication regulations or voluntary codes were reported during the reporting period.
Disclosure gap
It also describes the disclosure as “not applicable” because Firstsource operates business-to-business and follows ethical communication guidelines. That rationale should be treated cautiously: a business-to-business model does not by itself make marketing communications or GRI 417-3 inapplicable.
LRA review note
The current card should:
- remove all references to forced or compulsory labor and GRI 409-1
- remove occupational health and safety data
- cite the GRI Content Index location containing the zero statement
- recognise that the statement expressly covers regulations and voluntary codes
- note that “not applicable” is not supported solely by the business-to-business nature of the company
- classify the zero statement as relevant GRI 417-3 evidence
Bottom line
Firstsource’s report expressly maps GRI 417-3 and states that no non-compliance with marketing-communication regulations or voluntary codes was reported.
Owens Corning
Review finding
Owens Corning’s 2024 Sustainability Report provides a relevant but qualified zero-incidents statement on page 184.
View full reviewHide full review
Assessment
The Product Transparency section states that the company had no material incidents of non-compliance with regulations or voluntary codes concerning labeling, marketing or advertising of its products and material services.
Disclosure gap
The statement has two limitations for GRI 417-3:
- it combines labeling with marketing and advertising, spanning both GRI 417-2 and GRI 417-3
- it is restricted to “material” incidents, while GRI 417-3 does not prescribe a materiality threshold
LRA review note
The current card should:
- remove parental-leave data
- remove employee health-screening information
- remove assurance-provider independence information
- use page 184 as the principal evidence
- identify the combined labeling/marketing scope
- identify the unsupported materiality qualifier
- classify the disclosure as partial rather than complete
Bottom line
Owens Corning’s actual relevant disclosure appears on page 184 and combines labeling, marketing and advertising under a “no material incidents” statement.
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Framework references
Relevant GRI requirements and related disclosures
GRI
GRI 417-3
within GRI 417: Marketing and Labeling
Related & explore
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