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GRI Training Partner GRI 417 · Marketing and Labeling · Disclosure GRI 417-3

Incidents of non-compliance concerning marketing communications

GRI 417-3 · mandatory · metrics + narrative

Disclosure 417-3 requires the organization to report incidents of non-compliance concerning marketing communications in three categories:

Legal status

GRI 417: Marketing and Labeling 2016 remains the applicable published GRI Topic Standard and is effective for reports or other materials published on or after 1 July 2018.

Start preparing ↓ Official Global Reporting Initiative source ↗ Compare 3 real reports

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.

  • Regulatory incidents resulting in a fine or penalty

    Legal / Regulatory Compliance

    Number 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.

  • Regulatory incidents resulting in a warning

    Legal / Regulatory Compliance

    Number 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.

  • Incidents involving voluntary codes

    Marketing Compliance / Legal

    Number 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.

  • Not-at-fault exclusions

    Legal / Compliance

    Candidate 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.

  • Prior-period event identification

    Legal / Compliance / Sustainability Reporting

    Whether 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.

  • Zero-incidents statement — where applicable

    Legal / Marketing Compliance

    Confirmation 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?
＋ Show GRI 417-3 sub-elements (LRA working checklist)

How to prepare it

Identify complaints, regulator cases, self-regulatory findings, campaign-review issues and other candidate matters concerning marketing communications.
Apply the GRI definition of marketing communication, including advertising, personal selling, promotion, public relations, social media and sponsorship.
Separate product information and labeling matters for assessment under GRI 417-2.
Determine which candidate matters became incidents of non-compliance with a regulation or voluntary code.
Exclude cases where the organization was determined not to be at fault and retain supporting evidence.
Classify each remaining regulatory incident according to whether it resulted in a fine or penalty or in a warning.
Classify incidents involving voluntary codes separately.
Determine the reporting-period population using a documented determination, resolution and cut-off methodology.
Flag reported incidents connected with prior-period events.
Reconcile the three required category-level numbers to the case register.
If all three categories are zero, prepare a brief statement covering both regulations and voluntary codes.
Verify the disclosure against Requirements 417-3(a)–(b) and compilation requirements 2.2.1–2.2.2.

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.

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

  • 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 example 1

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 example 2

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 example 3

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 example 4

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.

Real published reports

Zydus Lifesciences Limited

Pharmaceuticals / Biotech / Life Sciences · India · 2025

Review finding

Zydus Lifesciences Limited provides a clear zero-incidents figure for GRI 417-3.

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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

Professional Services · India · 2025

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

Building Products · United States · 2024

Review finding

Owens Corning’s 2024 Sustainability Report provides a relevant but qualified zero-incidents statement on page 184.

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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.

Full evidence map with quotes and page numbers →

✓ Knowledge Hub AI Assistant · Human-in-the-loop
Dr Ross Kurinko

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Framework references

Relevant GRI requirements and related disclosures

GRI

GRI 417-3

within GRI 417: Marketing and Labeling

Open official source →

Related & explore

Requirements for product and service information and labeling → CardIncidents of non-compliance concerning product and service information and labeling → CardBrowse all disclosures →

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How this library is built 1,211 published reports indexed 315,012 pages with page-level citations 272 published cards in the active catalogue
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