Short answer
The answer, before the reasoning
GRI 101: Biodiversity 2024 is effective for reports or other materials published on or after 1 January 2026 and replaces GRI 304. Its eight disclosures form a connected system: policies, impact management and access-and-benefit-sharing are linked to the method for selecting priority sites and supply-chain products or services, location data, direct drivers, changes in ecosystem condition and affected ecosystem services and beneficiaries.
The core preparation task is a defensible location and supply-chain evidence register, not a generic biodiversity narrative.
GRI 101 is a connected, impact-reporting system organised around priority locations.
At a glance
Why GRI 101 is a major change
GRI 101 replaces GRI 304 and expands biodiversity reporting from a relatively narrow focus on operations in or near protected areas to a connected impact-reporting system. It asks the organisation to identify where the most significant actual and potential impacts occur across its sites and supply chain, then connect those locations to direct drivers, changes in ecosystem condition, affected ecosystem services, beneficiaries and management actions.
The result is not simply a longer biodiversity chapter. It requires a location register, geospatial and ecological evidence, supply-chain screening, transparent methods and limitations, and a clear link between pressures, state of nature, people and actions. Organisations that begin with a generic policy narrative or a list of protected sites will struggle to complete the later disclosures consistently.
Effective date and replacement
GRI 101 is effective for reports or other materials published on or after 1 January 2026, with earlier adoption encouraged. It updates, expands and replaces GRI 304: Biodiversity 2016. The transition should therefore be controlled at the publication level: the content index, reporting basis, evidence register and linked Sector Standards should all use the current standard set.
The eight disclosures as one connected system
LRA evidence-chain visual. Location-specific reporting should connect pressure, condition, people and management action.
Start with 101-4, not with a list of protected areas
Disclosure 101-4 is the organising decision. The organisation explains how it determined which sites and which products and services in its supply chain have the most significant actual and potential biodiversity impacts. The supply-chain scope includes suppliers beyond the first tier. The organisation sets and explains its threshold, methods, assumptions, evidence, stakeholder input, limitations and exclusions.
This selection is impact-led. A headquarters near a protected park may be less significant than an agricultural commodity sourced from a rapidly declining ecosystem. Conversely, a site outside a formally protected area can still have significant impacts because of water stress, high ecosystem integrity, rapid decline, key species or ecosystem services important to communities.
What the location register needs to connect
Direct drivers: report what is relevant at each location
GRI 101 identifies the main direct drivers of biodiversity loss: land and sea use change, exploitation of natural resources, climate change, pollution and the introduction of invasive alien species. Disclosure 101-6 translates those drivers into location-specific information. The organisation reports only the drivers relevant to each selected site and priority supply-chain product or service. It should not populate every category mechanically.
Land and sea use change: natural ecosystem conversion and changes between intensively used or modified ecosystems, with dates, areas and ecosystem types.
Exploitation of natural resources: wild species harvested, extinction risk, water withdrawal and water consumption where relevant.
Pollution: quantities and types of relevant pollutants generated.
Invasive alien species: how activities introduce or may introduce them.
Supply chain: the relevant driver information broken down by country or jurisdiction for priority products and services.
Context: standards, methodologies, assumptions and data limitations needed to understand how the information was compiled.
State of biodiversity is not the same as an activity metric
Restored hectares, trees planted or money spent are activity or output indicators. Disclosure 101-7 focuses on the state of affected or potentially affected ecosystems: ecosystem type, size and condition for a base year and the current reporting period. The organisation should explain whether the evidence is primary, secondary or modelled and disclose methodological limitations. Where ecological monitoring follows a different cycle from annual reporting, the most recent available information can be used with clear dating and context.
Ecosystem services require beneficiaries
Disclosure 101-8 is not satisfied by listing “water regulation, pollination and recreation”. The organisation identifies the ecosystem services affected or potentially affected at each priority site and the beneficiaries - such as Indigenous Peoples, local communities, farmers, other organisations or the reporting organisation itself - then explains how the service and beneficiaries are or could be affected. This connects biodiversity reporting to people and prevents nature impacts from being described as purely ecological abstractions.
A practical 2026 reporting workflow
Hypothetical example: food and ingredients group
Weak versus stronger biodiversity disclosure
Common mistakes
Myth versus reality
Readiness checklist
☐ The GRI 101 effective-date decision and replacement of GRI 304 are documented.
☐ Priority sites and supply-chain products/services are selected through a defensible 101-4 method.
☐ The location register links geography, sensitivity, activities, pressures, condition, people and actions.
☐ Relevant direct drivers are reported by location or jurisdiction with methods and assumptions.
☐ Ecosystem type, size and condition have a clear base year and current-period evidence.
☐ Ecosystem services are connected to identified beneficiaries and stakeholder evidence.
☐ Restoration, rehabilitation, offsets and compensation are not conflated.
☐ Primary, secondary and modelled data are distinguished and limitations are explicit.
☐ Content-index locations and any omissions have been technically reviewed.
Official sources and technical status
1. GRI 101: Biodiversity 2024. Open official source - Effective for reports or other materials published on or after 1 January 2026.
2. GRI 101: Biodiversity 2024 - Frequently Asked Questions. Open official source - Effective date, transition and application guidance.
3. GRI 1: Foundation 2021. Open official source - Reporting routes, omissions, content index, statements of use and notification.
Quick orientation
Quick orientation
- Applies to
- Organisations reporting biodiversity as a material topic in publications issued from 1 January 2026.
- Primary decision
- How to replace the old site-list approach with a location-specific, value-chain and evidence-led reporting system.
- Key source
- GRI 101: Biodiversity 2024 and the official GRI FAQ.
- Common confusion
- GRI 101 does not require every site to receive identical disclosure depth; the selection starts from the most significant impacts.
Rule
REPORTING ROUTE REMINDER
If biodiversity is a material topic, an in-accordance reporter applies GRI 3-3 and reports the GRI 101 disclosures relevant to its impacts. The organisation is not automatically required to report every GRI 101 disclosure regardless of relevance, but applicable Sector Standard links and any permitted omissions must be handled under GRI 1.
In practice
Disclosure
| Disclosure | Focus | Professional question |
|---|---|---|
| 101-1 | Policies to halt and reverse biodiversity loss | What commitments, scope, targets and business relationships are covered? |
| 101-2 | Management of biodiversity impacts | How are significant impacts managed through the mitigation hierarchy, and how are trade-offs and synergies addressed? |
| 101-3 | Access and benefit-sharing | Where genetic resources or associated traditional knowledge are used, how are requirements and benefit-sharing arrangements addressed? |
| 101-4 | Identification of biodiversity impacts | How were priority sites and supply-chain products or services selected, using what methods, evidence, thresholds and limitations? |
| 101-5 | Locations with biodiversity impacts | Where are the priority sites, what is their size and sensitivity, what activities occur, and where are priority supply-chain impacts located? |
| 101-6 | Direct drivers of biodiversity loss | Which location-specific pressures are relevant, and what quantitative or descriptive information supports them? |
| 101-7 | Changes to the state of biodiversity | What ecosystem types, sizes and condition data show change from the base year to the current period? |
| 101-8 | Ecosystem services | Which services and beneficiaries are affected or potentially affected, and how? |
In practice
Evidence field
| Evidence field | Minimum purpose | Typical source |
|---|---|---|
| Location and size | Identify the priority site or supply-chain jurisdiction and the area affected. | Asset register, coordinates or polygons, supplier origin data. |
| Ecological sensitivity | Explain whether the site is in or near areas of importance, integrity, decline, water risk or stakeholder service value. | Protected-area layers, Key Biodiversity Areas, water-risk tools, local ecological studies. |
| Activities and pressures | Link operations or sourcing to land/sea-use change, resource exploitation, pollution, invasive species and climate pressures. | Operational data, land-use records, water data, pollutant inventories, commodity traceability. |
| Ecosystem condition | Provide base-year ecosystem type, size and condition and current condition. | Field surveys, eDNA, remote sensing, secondary or modelled datasets. |
| Ecosystem services and people | Identify services and affected or potentially affected beneficiaries. | Stakeholder engagement, Indigenous Peoples and community evidence, ecosystem-service assessment. |
| Action and monitoring | Show mitigation hierarchy, targets, restoration/rehabilitation, monitoring, limitations and effectiveness. | Management plans, permits, budgets, monitoring reports, governance minutes. |
Caution
AVOID UNSUPPORTED CAUSALITY
A change in ecosystem condition may reflect cumulative influences from the organisation and other actors. Report what the evidence shows, distinguish contribution from attribution, and avoid claiming that an intervention caused improvement unless the monitoring design supports that conclusion.
In practice
1
| 1 | Confirm materiality and route. Document why biodiversity is material, which repo |
|---|---|
| 2 | Build the impact universe. List sites, announced operations, inactive sites, supply-chain products and services, and key downstream activities where relevant. |
| 3 | Screen and prioritise. Use location sensitivity, activity pressures, scale, severity, likelihood and evidence to identify the most significant actual and potential impacts. |
| 4 | Lock the location register. Assign stable IDs, coordinates or jurisdictions, area, activities, data owners and evidence sources. |
| 5 | Map direct drivers. Determine which pressures are relevant at each location and obtain comparable activity data. |
| 6 | Establish state evidence. Select ecosystem type, size and condition methods, base year, current data and uncertainty disclosures. |
| 7 | Identify services and beneficiaries. Combine ecological assessment with stakeholder and rights-holder evidence. |
| 8 | Connect management actions. Apply the mitigation hierarchy, set monitoring and effectiveness indicators, and document restoration or compensation separately. |
| 9 | Prepare limitations and omissions. Report available information, distinguish missing data from non-applicability and set an improvement time frame. |
| 10 | Reconcile the content index. Link GRI 3-3 and relevant GRI 101 disclosures to exact report locations and evidence owners. |
Hypothetical scenario
ILLUSTRATIVE SCENARIO - NOT COMPANY DATA
A food group owns three processing sites and sources cocoa, soy and fruit from several countries. Its previous report listed nearby protected areas and a tree-planting programme. Under GRI 101, it screens all sites and major commodities, identifies one water-stressed processing site and cocoa sourced from two high-risk jurisdictions as priority impact locations, and explains the threshold. The group maps water withdrawal, land conversion and pesticide pollution, establishes an ecosystem-condition baseline at the site, records supply-chain data limitations, identifies farmers and local communities as ecosystem-service beneficiaries, and links management actions to the mitigation hierarchy. It does not claim biodiversity improvement solely because hectares were planted.
Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.
In practice
Weak pattern
| Weak pattern | Why it is weak | Stronger pattern |
|---|---|---|
| “We operate near three protected areas.” | No explanation of impact significance, distance, activities, pressures or condition. | Identify priority sites through 101-4; report location, sensitivity, activities, relevant drivers and ecosystem evidence. |
| “We restored 250 hectares.” | Output measure without ecosystem type, baseline, condition, permanence or affected people. | Report the action under management, then explain condition evidence and limitations separately. |
| “Our suppliers are covered by a sustainable sourcing policy.” | No product, jurisdiction, tier, impact or traceability information. | Identify priority supply-chain products/services and countries, relevant pressures, data coverage and corrective actions. |
In practice
Mistake
| Mistake | Correction |
|---|---|
| Selecting all sites rather than impact-priority locations | Explain the 101-4 selection method and focus the detailed disclosures on the sites and supply-chain products/services with the most significant impacts. |
| Using protected-area proximity as the only screening criterion | Add ecosystem integrity/decline, water risk, key species, services, activities and supply-chain pressures. |
| Reporting only climate emissions under direct drivers | Report the biodiversity pressure relevant to each location and cross-reference detailed climate data where appropriate. |
| Equating restoration activity with improved ecosystem state | Use condition evidence, monitoring period, reference condition and uncertainty; avoid unsupported outcome claims. |
| Describing ecosystem services without beneficiaries | Identify who relies on the service and how they are or could be affected. |
| Hiding modelled-data limitations | Name datasets and assumptions, distinguish primary/secondary/modelled evidence and explain the improvement plan. |
In practice
Myth
| Myth | Reality |
|---|---|
| “GRI 101 is mainly a protected-sites inventory.” | It is an impact-reporting system spanning policies, management, priority sites, supply-chain products/services, drivers, ecosystem condition and ecosystem services. |
| “Only direct operations matter.” | The Standard explicitly includes supply-chain products and services, including suppliers beyond tier one; downstream information is also relevant in the guidance. |
| “No primary ecological data means we cannot report.” | Secondary and modelled data can be used with transparent datasets, methods, limitations and an improvement plan. |
Technical status
LEGAL AND TECHNICAL NOTE
This article explains the structure and implementation implications of GRI 101. It does not make ecological, legal or assurance conclusions for a specific site or supply chain. Biodiversity values, ecosystem condition, Indigenous Peoples’ rights, access and benefit-sharing and causal outcome claims may require specialist and legal input.
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